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Testing Newly-Approved Technologies: Challenges and Solutions Mitchell Lazarus 703-812-0440 | lazarus@fhhlaw.com 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

703-812-0440 | lazarus@fhhlaw.com

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  • technology becomes outdated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.
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Questions?

Mitchell Lazarus

703-812-0440 | lazarus@fhhlaw.com