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National Spectrum Managers Association Unlicensed Devices May 16, 2006 Mitchell Lazarus 703-812-0440 lazarusfhh - PowerPoint PPT Presentation


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National Spectrum Managers Association Unlicensed Devices May 16, 2006 Mitchell Lazarus | 703-812-0440 | [email protected] Topics. TV “white space” legislation Proposed service changes in the 902-928 MHz band 5 GHz U-NII band expansion. TV “White Space” Legislation. Background.

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National Spectrum Managers AssociationUnlicensed DevicesMay 16, 2006Mitchell Lazarus | 703-812-0440 | [email protected]


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Topics

  • TV “white space” legislation

  • Proposed service changes in the 902-928 MHz band

  • 5 GHz U-NII band expansion.



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Background

  • Many TV channels in every market are vacant:

    • co-channel, adjacent channel separations

    • “UHF taboos” (needed for early receivers)

      • broadcasting on one UHF channel limits 16 others

  • Proposal: unlicensed operation on unused TV channels

  • Need mechanism to protect TV receivers:

    • unlicensed device can move from place to place

    • TV channel assignments change over time

  • TV channels also used for land mobile, wireless microphones, medical telemetry, radio astronomy.


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FCC Proceeding

  • May 2004: NPRM on unlicensed use of vacant channels

    • fixed: 4 watts EIRP

    • portable: 0.4 watts EIRP

  • To protect TV operations, unlicensed device –

    • looks for “control signal” identifying locally vacant channels, or

    • uses “detect-and-avoid” (DAA) technology, or

    • has built-in GPS and channel database

  • Strong and specific opposition; lukewarm support

  • Mid-2005: FCC seemed ready to abandon the proposal.



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Problems (2): DAA in Shadow

TV Tower

Figure 2: Unlicensed DAA device in shadow can cause interference

Unlicensed Device in Shadow

TV Receiver

Building / Terrain


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Problems (3): DAA at Distance

Figure 3: Unlicensed transmitter can fail to detect distant signal

TV Tower

Outdoor TV Antenna

Unlicensed Device Misses Weak Signal

Great Distance


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Problems (4): GPS with Database

  • GPS works poorly indoors

  • Problem of keeping millions of databases current as TV channels move and change

  • Problem of occasional malfunctioning unlicensed device.


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Senate Action

  • February 2006: Senate introduced legislation requiring FCC to allow unlicensed operation in TV bands

  • Current version of bill* instructs FCC to:

    • have rules take effect within 270 days of passage

    • protect licensees from harmful interference

    • require devices to have FCC certification

    • require a mechanism for disabling devices remotely

    • address interference complaints “immediately.”

* “Communications, Consumer’s Choice, and Broadband Deployment Act of 2006,” S. 2686, Sec. 602 (May 1, 2006).


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Opposition

  • Broadcast industry vigorously opposes Senate bill

    • concerned about interference to TV reception

    • seeks delay at least until end of digital TV transition

  • Other parties concerned about precedent

    • Congress created the FCC to make technical decisions

      • Congress is not well equipped to decide on feasibility of new wireless services

    • first time in recent memory that Congress would have dictated a specific outcome on a technical issue

    • message to public: if the FCC does not accept your technical arguments, try Congress instead.


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IEEE 802.22 Proposal

  • Fixed devices only

    • base station must be professionally installed

      • programmed for available TV channels

    • remote can be installed by consumer

      • but needs enabling signal from base to operate

      • remote frequencies under control of base station

  • All devices on network monitor for TV signals

    • remotes report unexpected TV signal to base station

    • base station takes remotes off that frequency.



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Present Uses of 902-928 MHz

  • ISM devices (industrial, scientific, and medical) – unlimited power

  • Location and Monitoring Service (LMS) – 49 watts

  • Federal radar – unknown power

  • Federal fixed and mobile – unknown power (secondary)

  • Amateur radio – 1,500 watts (secondary)

  • Unlicensed devices – 0.001-4 watts.

    • RFID, home security, industrial remote controls, medical devices, home audio and video, more.

      (Power ratings are not directly comparable.)


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Multilateration LMS (M-LMS)

  • Triangulates from differences in arrival times

  • Authorized at 904-909.75, 919.75-928 MHz

    • rules restrict type of service, telephone interconnection

    • effectively limits numbers of units in use

  • 1999, 2001: M-LMS licenses auctioned for $4.4 million

  • 2000: U.S. Gov’t turned off “dither” in GPS

    • greatly improved accuracy; and prices dropped sharply

  • M-LMS never constructed

  • 2002: Progeny asked for “flexibility to offer whatever services the market can support and demand.”


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FCC NPRM -- 1

  • Drop restriction on type of service

    • no limitation; allow telephone interconnection, or

    • add flexibility to location services

  • Technical proposals:

    • reduce power to 10 watts EIRP

    • adopt Part-15-type digital modulation rules

    • limit number of units operating simultaneously

    • limit duty cycle


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FCC NPRM -- 2

  • Eliminate spectrum aggregation limits

  • Retain current Part 15 protections:

    • M-LMS licensees must prove lack of interference to Part 15 by field testing. 47 C.F.R. § 90.353(d)

    • Part 15 devices that meet “safe harbor” conditions are deemed not to cause harmful interference to M-LMS. 47 C.F.R. § 90.361.


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Possible Opposition

  • Part 15 interests

    • likely concerns: power, density, duty cycle

    • likely to favor retaining existing protections

  • Wireless companies may allege unfair competition

    • LMS auctions: $311 thousand/MHz

    • PCS auction 58: $17 million/MHz (for partial licenses)

  • Amateur radio

  • Federal users (but may have approved NPRM).


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Other Proceedings at 902-928 MHz

  • Amateur spread spectrum, RM-11325

    • present rules:

      • spread spectrum to 100 watts

      • over 1 watt requires automatic power control

    • request: drop requirement for automatic power control

  • Cellnet proposal, ex parte in ET Docket No. 03-201

    • full power only for 10% duty cycle or less

    • power limit drops as duty cycle exceeds 10%.



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FCC Rulemaking

  • November 2003: FCC Report and Order (R&O) added 255 MHz to the 5.8 GHz U-NII band

    • expanded band covers 5.470–5.825 GHz

  • New requirements across entire band (to protect radars):

    • dynamic frequency selection (DFS)

    • transmit power control (TPC)

  • But compliance test procedure was difficult to specify

    • implementation dates repeatedly postponed.


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2006 Action

  • March 30: NTIA filed 47-page compliance test procedure

    • agreed to by FCC, NTIA, industry panel

  • April 26: FCC seeks to refresh the record on three requests to clarify original R&O

  • Comments May 15, replies May 18

  • Under current schedule, DFS and TPC rules take effect for:

    • certification applications filed on or after July 20, 2006

    • devices imported or marketed on or after July 20, 2007.


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Thank you!

Mitchell Lazarus | 703-812-0440 | [email protected]


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