Testing Newly-Approved Technologies: Challenges and Solutions
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Testing Newly-Approved Technologies: Challenges and Solutions Mitchell Lazarus 703-812-0440 | [email protected] April 10, 2014. Innovator’s Tasks. Invent device Obtain FCC waiver or rule change can entail substantial delay: technical waiver takes about 2 years

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Testing Newly-Approved Technologies: Challenges and Solutions Mitchell Lazarus

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Testing newly approved technologies challenges and solutions mitchell lazarus

Testing Newly-Approved Technologies: Challenges and Solutions

Mitchell Lazarus

703-812-0440 | [email protected]

April 10, 2014


Innovator s tasks

Innovator’s Tasks

  • Invent device

  • Obtain FCC waiver or rule change

    • can entail substantial delay:

      • technical waiver takes about 2 years

      • technical rulemaking takes 2-5 years

  • Obtain FCC certification

    • can take several more months.


Delays due to testing

Delays Due to Testing

  • New technologies may require new compliance test procedures

  • Even after FCC settles on procedures:

    • FCC may want to try out procedures

    • labs and TCBs will consult with FCC on how procedures work

    • client may have last-minute design issues, e.g.:

      • needed test modes missing from device software

      • problems with out-of-band emissions

    • commercial labs may have to acquire equipment, train personnel

    • testing takes longer than for established technologies.


Consequences of delay

Consequences of Delay

  • technology becomes outdated

  • investors pull out

  • customers go elsewhere

  • key employees leave

  • businesses fail

  • people die.


Rulemakings for new technologies

Rulemakings for New Technologies

  • Outcomes apply to everyone

  • Legal processes are uniform

    • set by Administrative Procedure Act

    • public comment (nearly) always required

  • Test procedures usually considered along with technical rules

    • often topic of public comment

    • sometimes topic of vigorous dispute

  • Rulemaking examples …


Level probing radars 1

Level Probing Radars – 1

  • Measure quantity of materials, liquid depth outdoors

    • wideband operation

    • traditional rules set limit on transmitted (downward) emissions

    • interference arises from scattered (horizontal) emissions

      • difficult to measure reliably.


Level probing radars 2

Level Probing Radars – 2

  • New rules require boresight measurement

    • seeking max. horizontal emissions of –41.3 dBm

    • boresight emissions limits exceed that level by 22–38 dB, depending on band

  • allows for losses due to scattering, etc.

  • Authorized in three bands: 5.925–7.25, 24.05–29,75–85 GHz

  • Rules took effect April 7

    • FCC lab issued detailed draft KDB.


  • Broadband over power line 1

    Broadband over Power Line – 1

    • Communications over power distribution lines at 1.7-80 MHz

      • regulated devices: couplers take signal off line, feed to premises

      • typically one coupler per 3-8 houses

      • only one coupler per several blocks works at one time

    • Compliance testing inherently difficult

      • FCC requires testing in situ: low signal, high noise

    • Detailed testing guidance in Report & Order

      • FCC engineers worked at manufacturers’ prototype houses.


    Broadband over power line 2

    Broadband over Power Line – 2

    • Amateur radio licensees and ARRL filed 6,000+ oppositions:

      • claimed power lines act as city-sized antennas

    • BPL providers argued that couplers act as isolated point sources

      • agreed to rules that turn down or turn off couplers that cause interference

    • Timetable:

      • 2003-04-28 Notice of Inquiry

      • 2004-02-23 NPRM

      • 2004-10-28 Report and Order (18 months after NOI)

      • 2006-08-07 Order on Reconsideration

      • 2006-08-28 first certification (22 months after R&O).


    Broadband over power line 3

    Broadband over Power Line – 3

    • Dispute throughout proceeding over extrapolation factor:

    • Amateur radio interests favored 20 dB/decade at all frequencies

      • challenged 40 dB/decade in U.S. Court of Appeals

      • court sent back to FCC for second look

      • FCC reaffirmed.


    Ultra wideband

    Ultra-Wideband

    • Authorized low-emission signals over very wide bandwidth

      • eight types of devices; each has different rules

      • max emissions for any device in any band: –41.3 dBm/MHz

        • lower in some bands

    • Testing challenges

      • Class B digital emissions can exceed intentional emissions

        • FCC specified procedures to isolate digital emissions

      • GPS band emissions as low as –85.3 dBm

    • Timetable:

      • 1998-09-01 Notice of Inquiry

      • 2000-05-11 Notice of Proposed Rulemaking

      • 2002-04-22 First Report and Order (44 months after NOI)

      • 2002-09-12 first certification (5 months after R&O).


    Tv band white space devices

    TV Band (“White Space”) Devices

    • Downside risk: interference to broadcast TV, other services

    • FCC proceeded with great caution:

      • multiple successive rule modifications

      • live field tests in multiple kinds of environments

      • highly detailed test procedures

      • initial roll-outs limited to small areas

      • live, public testing of candidate database managers

    • Timetable:

      • Dec. 2002: proceeding began

      • Dec. 2012: first large-scale roll-out (after 10 years)

        • so far only fixed devices have been certified.


    Waivers for new technologies

    Waivers for New Technologies

    • Process driven by waiver proponent

      • no required procedure; can vary

        • FCC usually seeks public comment

      • waiver initially applies only to company that asked for it

      • central issue is usually technical rules

      • FCC may not look at compliance testing until prompted by client (or TCB)

    • Examples …


    Surveillance robot 1

    Surveillance Robot – 1

    • Police surveillance robot

      • steered by remote control

      • transmits analog video back to controller

      • manufacturer sought 430-448 MHz (federal radar & amateur)

      • dozens of police departments wrote to the FCC in support

      • amateursstrongly opposed

      • FCC authorized.


    Surveillance robot 2

    Surveillance Robot – 2

    • Timetable:

      • 2008-01-11 waiver requested

      • 2010-02-23 waiver granted (25 months after request)

      • 2010-04-22 certification granted (two months after waiver)

      • 2012-02-06 first licenses granted (21 months after certification)

    • Licensing delay due in part to challenges to certification …


    Surveillance robot 3

    Surveillance Robot – 3

    • First model had B/W video, no sound

      • measured bandwidth per required procedure: 100 kHz

    • Opponents: analog video is “inevitably on the order of 5.75 MHz”

      • demanded that certification be set aside

    • FCC retained certification, granted licenses (after delay).


    Airport body scanners 1

    Airport Body Scanners – 1

    • Uses fast sweep 24.25–30 GHz

      • sweep takes 5.2 microseconds

        • (pauses for 2.6 microseconds)

      • sweep repeats twice for each of 192 antennas on vertical mast

      • mast sequence repeats for each of 210 rotating mast positions

      • complete scan uses 80,640 sweeps

      • takes less than 2 seconds (including mast rotation)

      • software processes reflections into image.


    Airport body scanners 2

    Airport Body Scanners – 2

    • Compliance issues:

      • Sec. 15.31(c) requires measurement with sweep stopped

      • Sec. 15.35(b) sets 20 dB peak-to-average limit

    • FCC waived both rules.

    17


    Airport body scanners 3

    Airport Body Scanners – 3

    • Timetable:

      • 2004-08-18 waiver requested

      • 2006-08-04 waiver granted (24 months after request)

      • 2006-08-22 certification granted (18 days after waiver)

    • FCC allowed certification process to begin while waiver was pending

      • FCC conducted tests at Columbia lab

      • waiver order had detailed guidance on testing.


    Conclusion

    Conclusion

    • Delays are reduced when rulemaking or waiver order has clear guidance on testing

    • How labs and TCBs can help innovators:

      • if asked, become involved early

      • deal with the right person at the client (not the lawyer)

      • the client may not know what services they need; tell them

      • and may not know what information you need; ask them

      • be creative on test procedures

      • if guidance is needed, go to the FCC promptly

        • for novel questions, KDB may not be the best place to start

      • but if rules and procedures are clear, do not ask the FCC

    • Time is always critical.


    Testing newly approved technologies challenges and solutions mitchell lazarus

    • Questions?

    Mitchell Lazarus

    703-812-0440 | [email protected]


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