FCBA CLE 2007 - National Spectrum Management Association
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Transcript FCBA CLE 2007 - National Spectrum Management Association
National Spectrum Managers Association
Unlicensed Devices
– An Update
Mitchell Lazarus
May 22, 2007
703-812-0440 | [email protected]
Slide 0
A Brief History of Unlicensed Use
Early period: 1936-1985
e.g., toys, home intercoms, early cordless phones
low power, short range, poor performance
Middle period: 1985-2006
e.g., Wi-Fi, Bluetooth, ZigBee, many more
spread spectrum, high power, “dedicated” spectrum
good data rate, range, reliability
• but inefficient spectrum use
Late period: 2006- . . .
better data rates, reliability, plus intelligent sharing
“Ninja” devices – slip in and out unnoticed.
Slide 1
Signs of Transition
Wi-Fi a/b/g, Bluetooth: always same power, all directions
even if receiver close by, or nothing to transmit
“selfish” dynamic frequency selection
Expanded U-NII (5 GHz) requires:
“altruistic” dynamic frequency selection
automatic transmit power control
ZigBee: brief transmissions
IEEE 802.11n: MIMO – potential for spatial multiplexing
“White space” (IEEE 802.22): multiple sharing techniques.
Slide 2
White Space Proceeding
Premise: most TV channels in any area are vacant
same-channel and adjacent-channel spacing rules,
“UHF taboos” (analog only), sparse markets
long-standing interest in wireless use
Problem: avoiding interference to TV reception
potential interference on same and adjacent channels
exacerbated by high-gain outdoor TV antennas
TV reception has near-absolute right to protection
• but Congress can change that.
Slide 3
White Space – History
December 2002: Notice of Inquiry
strong opposition, little support
May 2004: Notice of Proposed Rule Making
suggested three mechanisms:
1. find device location; consult table of vacant channels
2. receive “control signal” that identifies vacant channels
3. monitor for TV activity (“detect and avoid”)
Strong opposition from broadcasters
Senate bills (2005-06) requiring FCC to allow WS use
never passed; died when Congress adjourned
but doubtless prompted FCC action.
Slide 4
White Space – FCC “Decision”
Oct. 2006: First Report and Order and Further NPRM
announces intent to allow fixed operation (only) after
2/18/09 –when analog TV ceases
will protect channel 37
Seeks comment on:
portable operation
same three interference protection mechanisms
protection of channels 2-4, 14-20
licensed vs. unlicensed operation
many technical details.
Slide 5
White Space – IEEE 802.22
Provides for fixed operation only
base unit serves multiple remotes
Base unit:
must be professionally installed
programmed for locally vacant channels
Remote unit:
can be installed by the consumer
cannot operate without control signal from base
• signal identifies vacant channels
All units monitor for TV activity, lock out channels in use
Has support of broadcasters.
Slide 6
White Space – Legislation
Several bills pending; details vary
Some would:
require both fixed and portable operation
not protect channel 37
not protect low power TV, TV translators, wireless
microphones
require implementation before DTV transition date
Broadcasters strongly opposed.
Slide 7
IEEE 802.11n
Pending Wi-Fi standard
74-248 Mbps (at 70 meters indoors)
compared to 54 Mbps for 802.11g
Uses MIMO (multiple antennas) for greater speed and range
provides for spatial multiplexing
Complies with present FCC rules
Publication expected September 2008
products available now.
Slide 8
Modular Certification
Permits FCC-certified device in multiple host devices
allowed under public notice since 2000; now in rules
Requires eight additional showings:
own shielding; buffered I/O; own power supply
regulation; “unique” antenna connector; tested as standalone; host device carries FCC ID; complies with same
rules as complete transmitter; RF exposure limits
Allows “split modular” transmitters – separate RF front
end and controlling firmware
Limited approval available for partial compliance
must assure full compliance in final combination.
Slide 9
Software Defined Radios – Changes
FCC policy: manufacturers should not make security
software public
controversial in open-source community
SDR must be certified under SDR rules only if others will
modify its software
Rules exempting most amateur transmitters from
certification still stands, even for transmitters that
incorporate SDR capability.
Slide 10
“Late Period” Proceedings Terminated
Interference temperature proposal:
measure background emissions
add proposed transmission
check whether total is under some predetermined limit
problems: (1) specifying limits; (2) where to measure
emissions
Receiver standards
proposed to promote denser spectrum use
question whether within FCC’s authority
Both proceedings now terminated.
Slide 11
Other Matters
Slide 12
“Progeny” Proceeding
Progeny LMS, LLC: Location and Monitoring Service (LMS)
licensee in the 902-928 MHz band
LMS licenses auctioned in 1999 for $3.5M
never constructed; could not compete with GPS
LMS rules protect Part 15 operation
Progeny seeks:
increase power, provide any service
eliminate Part 15 protections
Progeny claims band is 97.5% free, LMS block is 99.2% free
Part 15 users are opposing.
Slide 13
OTARD
Over the air receiver device (OTARD) rules prohibit thirdparty restrictions on an antenna if:
1. one meter or less in diameter
2. on property under the exclusive control of the user
3. used to transmit or receive fixed wireless signals
Applied to video and licensed services (e.g., BRS)
FCC: OTARD also protects Part 15 antennas.
Slide 14
All Wireless Broadband Deregulated
Unlicensed services have never been regulated (as to rates,
discrimination, etc.)
FCC previously declared three forms of broadband Internet
access also to be unregulated:
cable modem service (2002)
DSL (2005)
broadband over power line (2006)
2007: all wireless forms of broadband Internet access are
unregulated (licensed or not).
Slide 15
Increased Fines for Violations – 1
Some recent fines:
$1,000,000: 50 models of sound equipment (missing
labels and test reports)
$150,000: 17 models of amateur transmitter easily
converted to CB
$75,000: GPS re-radiator (first offense)
$65,000: locator beacon (premature advertising)
$50,000: 2.4 GHz power amplifier for access points
(repeat offense)
$25,000: police radar jammer (multiple repeat
offense).
Slide 16
Increased Fines for Violations – 2
Enforcement Bureau calculations:
large fines for administrative offenses – i.e., no
allegation of non-compliance with technical rules
multiply base fine by number of models, even if similar
raised composite fine from from $28,000 to $75,000
based on activities prior to statute of limitations
raised base fine from $7,000 to $50,000 based on one
previous offense
raised fines based on estimate of economic gain.
Slide 17
Thank you!
Mitchell Lazarus | 703-812-0440 | [email protected]
Slide 18