Response: BIS is not adopting this proposal to raise the threshold floor frequency for
Comment: One commenter stated that MMICs and discrete microware transistors with significant military applications operate at frequencies that fall within the gaps between the operating frequency ranges listed in paragraph .c and .d of ECCN 3A611 in the
Response: There are no gaps between the operating frequency ranges in ECCN 3A611.c and .d in this proposed rule.
Comment: One commenter provided extensive comments on the
* Wireless broadband and mobile carriers operate in the 2.5-2.7 GHz segment of the S-band frequency range.
* Descriptions of operating frequency thresholds should be consistent among ECCNs, and recommend the pattern currently in ECCN 3A001 (frequencies exceeding X up to and including Y) as being better than the pattern in the
* A total overlap exists between the frequency ranges for both
* ECCNs 3A611.c and .d--For tiers exceeding 3.2 GHz, proposed ECCN 3A611 would encompass the same frequencies currently covered by ECCN 3A001 (with carve outs in the 31.8 GHz range and for frequencies exceeding 75 GHz). However, by changing the unit of measure for the wattage cut-off points from average power to peak power, the power thresholds would become more restrictive.
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