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