Methods and devices configured to apply a power back-off (PBO) to limit a radio frequency (RF) transmitter power up to a first limit, where the first limit is below a pre-defined RF power limit; accumulate a difference between RF transmission power spent transmitting data and the pre-defined RF power limit over a duration to produce an accumulated energy budget; and once the accumulated energy budget reaches a pre-defined energy credit value, remove the PBO and allow RF transmitter power exceeding the pre-defined RF power limit until the accumulated energy budget meets a threshold.