Transcript Slide 0 - ACBcert.com

Testing Newly-Approved Technologies:
Challenges and Solutions
Mitchell Lazarus
703-812-0440 | [email protected]
April 10, 2014
Innovator’s Tasks
1. Invent device
2. Obtain FCC waiver or rule change
 can entail substantial delay:
 technical waiver takes about 2 years
 technical rulemaking takes 2-5 years
3. Obtain FCC certification
 can take several more months.
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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.
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Consequences of Delay
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technology becomes outdated
investors pull out
customers go elsewhere
key employees leave
businesses fail
people die.
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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 …
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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.
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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.
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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.
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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).
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Broadband over Power Line – 3
 Dispute throughout proceeding over extrapolation factor:
Frequency
< 30 MHz
> 30 MHz
Distance
30 Meters
10 Meters
40 dB/decade
20 dB/decade
Point source
(1/r²)
Line source
(1/r)
Extrapolation
Implication
 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.
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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).
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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.
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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 …
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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
 amateurs strongly opposed
 FCC authorized.
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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 …
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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).
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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.
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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.
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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.
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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 | [email protected]
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