IEEE P802'15 Working Group for Wireless Personal Area Networks

1
Project IEEE 802.15 Working Group for Wireless
Personal Area Networks (WPANs) Submission Title
FCC Waiver Request Overview Date Submitted
14Nov2004 Source John Barr Company
Motorola Address 1303 E. Golf Road,
Schuamburg, IL 60196 Voice1 847 576-8706,
FAX [phone], E-MailJohn.Barr_at_Motorola
.com Re Abstract Overview of the MBOA SIG
Waiver Request and background of FCC waiver
processing. Purpose Provide information about
regulatory approval status of Merger Proposal
1. Notice This document has been prepared to
assist the IEEE 802.15. It is offered as a basis
for discussion and is not binding on the
contributing individual(s) or organization(s).
The material in this document is subject to
change in form and content after further study.
The contributor(s) reserve(s) the right to add,
amend or withdraw material contained
herein. Release The contributor acknowledges and
accepts that this contribution becomes the
property of IEEE and may be made publicly
available by 802.15.
2
MBOA SIG Waiver Request

• Official FCC Record
• http//gullfoss2.fcc.gov/cgi-bin/websql/prod/ecfs/
  comsrch_v2.hts?ws_moderetrieve_listid_proceeding
  04-352
• Timeline
• 26Aug2004 MBOA SIG Leadership files petition to
  FCC requesting a waiver of certain measurement
  procedures and policies for MB-OFDM
  ultra-wideband devices.
• Intel, TI, Staccato, Alereon, and Wisair
• Purpose is to allow MB-OFDM a level playing
  field
• 30Aug2004 FCC Issues DA-04-2793 opening a
  30-day comment window followed by a 15-day reply
  window inviting comments on the waiver request.
• Comments due 29Sept2004, Replies due 14Oct2004

3
Summary of 29Sept Comments

• Against grant of the waiver
• Motorola, Freescale, C-Band Coalition, Satellite
  Industry Association, PulseLINK, Time
  Derivative, decaWave, Cingular
• For grant of the waiver
• WiMedia Alliance, Renesas, Time Domain, Philips,
  Focus, Cetecom, HP, WiLinx, Alereon, and Harris
• Other correspondence
• MBOA meeting (TI, Intel, Staccato) 23Sept2004
• Motorola presentation 28Sept2004

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Issues Raised Against Waiver (1)

• Doesnt meet minimum bandwidth requirement (MOT)
• Not representative of all MBOA SIG members (Time
  Derivative, PulseLINK)
• Current test procedures DO apply to MB-OFDM (PL)
• Creates unfair advantage FOR MB-OFDM devices (PL,
  TD)
• Increases interference (PL, TD, SIA)
• Inconsistent with Telecommunications Act of 1996
  (PL, TD)
• without regard to any specific technology
• Changes the rules for small companies not aligned
  with the MBOA-SIG (PL)
• FCC rules DO apply to MB-OFDM waveform (Cingular,
  TD)
• Develop appropriate test procedures (Cingular,
  TD)
• Burst pulses of MB-OFDM cause large number of
  symbol errors in many systems (SIA, CBC)
• Current rules still to be proven. Accepting a
  waiver has not been adequately analyzed. (FSL,
  MOT)
• Petition does not prove that approval will serve
  the public interest. (Cingular, FSL)

5
Issues Raised Against Waiver (2)

• FCC does not have any evaluation of different
  measurement procedures requested by the petition.
  (Cingular)
• Should be done via rulemaking, not as a waiver.
  (Cingular)
• FCC previously stated that changes should be
  based on commercially available products, which
  have not yet been provided. (MOT)
• Current rules do not prevent deployment of
  devices based on MB-OFDM technology. Current
  measurement procedures can be applied. (MOT)
• Petitioner has not demonstrated lack of
  interference of commercially available products
  with all of the incumbent spectrum users. (MOT)
• Measurement techniques used by the MBOA SIG were
  flawed. (CBC)
• Granting waiver would disadvantage conforming UWB
  devices that also transmit in bursts, but cannot
  average power. (FSL)
• No innovative products or services require the
  waiver. Three of the four technical points
  claimed to improve performance are wrong. The
  fourth claim regarding flexibility in balancing
  performance against implementation complexity is
  not clearly explained. (FSL)

6
Timeline Continued

• MBOA SIG asks for 7 day extension to reply period
  due to complexity of waiver objections
• Reply comments due on October 21
• FCC TAC meeting on October 27 includes discussion
  of UWB applications and options
• 3Nov04 TI, Intel, Staccato, and Philips meet
  with FCC OET
• 5Nov04 Freescale meets with FCC OET

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Summary of October 21 Comments

• Against grant of the waiver
• Freescale, Motorola, decawave
• For grant of the waiver
• MBOA SIG

8
Additional Issues Raised

• Denial of the petition would not disadvantage the
  manufacturers of MB-OFDM devices as they would be
  free to release products under the current rules
• CEO of Staccato Will not impact product plans
  (IEEE 802.15.3a meeting in Berlin)
• Stephen Wood of Intel Will not change product
  plans of MBOA SIG members (answer to question
  posed by Ed Thomas at 27Oct04 FCC TAC meeting)
• Limited support from MBOA SIG members shows lack
  of industry support
• MBOA SIG members objected to the waiver petition
  and only 12 comments supported the waiver.
• Technical support based on APD plots is
  insufficient to characterize the interference
  potential of MB-OFDM devices. (FSL)
• No valid test results using commercially
  available products (MOT)
• Possible threat to 4.9 GHz public safety and DSRC
  services at 5.9 GHz. (FSL)
• Close proximity MB-OFDM systems can operate
  simultaneously on bands not used by other devices
  which raises victim interference. (FSL)

9
MB-OFDM Waiver Request
10
DS-UWB 1-unit
11
Aggregation of MB-OFDM Signals
12
DS-UWB 3 close devices
13
Conclusions

• Under waiver
• Multiple MB-OFDM units together exceed limits by
  5-6 dB
• Grant of the waiver makes it possible regardless
  of whether the MBOA SIG claims their devices will
  not be designed to do this
• The waiver is not justified
• MBOA SIG has failed to carry its burden of proof
  that the waiver is of public interest
• MBOA SIG has not resolved doubts as to increased
  interference
• MBOA SIG has not resolved doubts as to
  performance advantage
• A waiver gives discriminatory preference to
  MB-OFDM
• MBOA SIG told the TAC that denial of the waiver
  will not disrupt their marketing plans
• A waiver effectively raises emissions limits
• This should be done only through a transparent
  rulemaking, if at all
• Existing spectrum licensed users do not support
  the waiver
• Even if the waiver is granted, it will be a
  footnote to the current rules that can be removed
  after further review. Not good for long term
  business plans.

14
IEEE 802.15.3a Impact

• Products using DS-UWB technology have already
  been approved by the FCC.
• Products using MB-OFDM technology (when
  available) can be approved by the FCC using
  current rules
• MBOA SIG waiver petition admits that the current
  rules do not allow testing with frequency hopping
  on
• Must turn frequency hopping off
• Reduces power level by 5.9 dB
• Performance of FCC compliant MB-OFDM devices will
  not meet IEEE 802.15.3a technical requirements
  (A bit rate of at least 110 Mb/s at 10 meters is
  required at the PHY-SAP. 03030r0P802-15_TG3a-Tech
  nical-Requirements.doc)
• Regulatory approval required (The alt-PHY
  standard will comply with necessary geopolitical
  or regional regulations. 03030r0P802-15_TG3a-Tech
  nical-Requirements.doc)

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Two Futures

• Waiver Granted
• Incumbent spectrum users file complaints with FCC
  due to extra interference
• No guarantee that the waiver will remain in force
  after additional review
• Further review under NPRM
• Business plans subject to uncertain regulatory
  approval
• Non-US regulatory bodies avoid FCC rules
• Merger 1 and 2 proposals meet 802.15.3a
  requirements
• Fewer UWB devices may get deployed in the market
  due to regulatory uncertainty

• Waiver Denied
• MBOA SIG members go forward with product plans
• Merger 1 proposal does not meet 802.15.3a
  requirements
• Merger 2 proposal does meet 802.15.3a
  requirements
• No regulatory uncertainty
• Lots of UWB devices get deployed in the market