Project: IEEE P802.15 Working Group for Wireless Personal Area Networks (WPANs) Submission Title: [ Sensus’ Proposal to

1. Project: IEEE P802.15 Working Group for Wireless Personal Area Networks (WPANs) Submission Title: [Sensus’ Proposal to TG4g] Date Submitted: [2 May, 2009] Source: [Britton Sanderford] Company [Sensus] Address [Covington, Louisiana] Voice:[985-773-1232], E-Mail:[Britton.Sanderford@sensus.com] Re: [Response to CFP issued January 22nd 2009, document 15-09-077-00-004g] Abstract: [Proposal for optional licensed band operation.] Purpose: [Proposal for consideration of inclusion into draft amendment] Notice: This document has been prepared to assist the IEEE P802.15. 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 P802.15. <Britton Sanderford>, <Sensus>

2. Sensus’ Proposal to TG4g Sensus submits its proposal to TG4g that provides significant benefits towards fulfilling the W-SUN goals such as: Increased available bandwidth Broaden Utility supplier options Enable demanding applications that benefit from additional power output Provide options for Utilities that operate in significant RF interference Proven building penetration, high rise operation, and coverage, for diverse environments such as urban, rural, and mountainous terrain

3. Proposal Benefits <Britton Sanderford>, <Sensus>

4. Proposal benefits • Increase available bandwidth: • There are many MHz of spectrum available in the 450 to 1.4 GHz licensed bands. Further, licensed systems are not required to hop which can waste 25 to 50 X of the band’s capacity in order to resolve co-existence and interference issues (for example the 4/23/09 802.15.4g submittal results in two 400 kHz BW channels from a 26 MHz channel). Removing the Licensed band restriction will increase available data capacity by more then an order of magnitude. • Broaden Utility supplier options, • increases competition to provide users with lower costs and enhanced features <Britton Sanderford>, <Sensus>

5. Proposal benefits • Enable demanding applications that benefit from additional power output • Licensed operation permits greater than 1 Watt operation) thus avoiding the delays and cost of engineered repeater solutions • Provide lower RF interference options for Utilities Unlicensed Band 902-928 theoretical noise floor FlexNet Protected Spectrum 901.125 <Britton Sanderford>, <Sensus>

6. Proposal benefits • Faster response times and lower latency • hop pattern synchronization/ discovery time not required. • Increased options for international operation. • Increased rangeof operation • due to lower noise floor • Simplicity <Britton Sanderford>, <Sensus>

7. Proposal benefits • Availability • no dynamic routing delays, no loss of effective available BW due to other legal non-utility users who share the band. • Frequency bands available • 450-470 MHz, 700 MHz, 896-901 MHz, 901-902 MHz, 928-960 MHz, 1427-1432 MHz, 1605-1625 MHz or any band that the FCC makes available for AMI/ Smart grid use • There are millions of 450-470 MHz and 901-902 MHz licensed band AMR devices operating the field. <Britton Sanderford>, <Sensus>

8. Proposal <Britton Sanderford>, <Sensus>

9. 802.15.4g Specification Modification • 2 FSK and GFSK– Expand to “In addition to this base modulation, manufacturers will be allowed to create vendor specific enhancements including any ‘M’ M-FSK.” For example, 4 FSK is proven in millions of paging devices. Allowing advanced modulations increases innovation, and promotes the stated SUN goal of bandwidth while retaining low cost of phase continuous modulations. • Frequency hop on 25 to 50 channels – Change to “N channels limited by the FCC rules that the system operates under. Licensed band systems may use an ‘N’ of 1, or more if required by utility applications.” • Frequency channel separation 300 to 400kHz – propose “6.25, 12.5, 25, 50, 100, 150, 200, 300, & 400 kHz and as allowed by the FCC.” • Data “Whitening” - make this optional “if required by the RF hardware.” This simplifies implementation of hardware if receiver can tolerate long run lengths or 0’s and 1’s. <Britton Sanderford>, <Sensus>

10. 802.15.4g Specification Modification • Message Leader– “32 bits, or as needed for the receiver’s synchronization hardware” • Baud Rate– “matched to Utility’s application 100 b/s to 300 kb/s.” • Lower Bauds are very advantageous to vault meters, buried FCI or water meters and basement meters (a basement may cause >32 dB of attenuation). Most metering applications are in fact very low baud. For example, an hourly meter read (4 Byte ID + 4 Registers + Status and Misl + CRC32 < 40 Bytes, is less then0.1 Baud; • There is questionable justification for the proposed 1 Mb/s option. At the proposed 300 to 400 kHz BW the high Eb/N0 will reduce link budget driving applications into short ranges already provided by Bluetooth and 802.11. • Protocol – “Modeled from IEEE802.3 OSI Layer 2.” This is well defined, has operated and evolved for 30 years, is the choice for most TCP/IP transport layers, and allows the 1500 Byte goal of SUN. In addition, add the following language to promote vendor innovation “vendors may define additional sync bytes to allow message format optimizations to support diverse applications.” This flexibility will facilitate outage management, Rural operation, security options, and further advance FEC methods and low latency communications. <Britton Sanderford>, <Sensus>

11. 802.15.4g Specification Modification Error Correction FEC – “optional Viterbi ½ and ¾ rate with interleaving.” Large packet failure rate will increase exponentially with lower SNRs and interference. PSR, Packet Success Rate, see below: Lower PSR leads to re-tries and re-routing which exponentially reduce effective BW due to added poll-response and re-routing logic. Retries are more “expensive” then FEC. Assumptions: GMSK Modulation AWGN Channel Eb/No = 14 dB Blue Plot = No Convolutional Code (Assumed BER = 1x10-3) Red Plot = Rate 1/2 Convolutional FEC (K=3) w/ Viterbi Decode (Assumed BER 1.25 x 10-4) <Britton Sanderford>, <Sensus>

12. 802.15.4g Specification Modification • “Allow both Poll-Response & ALOHA” – ALOHA can be more robust then Poll-Respond and can provide greater capacity than poll-response. It is proven in over 20 million AMR/AMI fielded devices operating in ALOHA mode for the last 15 years. Utility applications such as outage management and report-by-exception will benefit from this option. • Power Output – “5mW, 20mW, 50mW, 100mW, 250mW, 1W, 2W, 5W” • Jamming Reporting – “Provide Utility dynamic log of unavailable channels and of resulting effective date rate capacity.” <Britton Sanderford>, <Sensus>

13. Summary <Britton Sanderford>, <Sensus>

14. Summary • Matches Industry Best Practices Design ( Verizon, AT&T, Sprint ) • No Departure from Existing Utility Practices (MAS, Part 90) • Mission Critical Transactional Benefits • Clear Channel Spectrum • Avoid Interference and Obsolescence • Greater RF Penetration Power • Legal Recourse Sensus Verizon <Britton Sanderford>, <Sensus>

15. Background <Britton Sanderford>, <Sensus>

16. Background: Comments on W-SUN 802.15.4g Proposed Modifications It should be noted that there are more FCC licensed band AMI Smart Meters deployed than all other unlicensed bands combined (3M vs. 2M) in 450 customer sites in US and Canada covering over 100,000 square miles. The requirement for common international bands should not be forced upon a utility centric standard.  A electric meter or utility asset is fixed in place.  This is very different from a PC using 802.11 internet connections that may move from San Diego to Florence during a work day.   Further PC connectivity is fungible, whereas AMR/ Smart Grid operation must be matched to widely varying requirements.  The objectives of Enel Power in Italy are different from those of SDG&E in California.  Thus local requirements can be matched to local spectrum availability.  QUALCOMM, Verizon, Sprint and AT&T have managed this process as evidenced by their offerings of international phones operating over multiple frequency bands.  <Britton Sanderford>, <Sensus>

17. Comments on W-SUN 802.15.4g Proposed Modifications (Cont’d) • IEEE doc15-09-0037-00-004g, page 6 specifies use of “License exempt frequency bands. The drafting of this language may satisfy vendors that use unlicensed spectrum but this limitation is contrary to the stated goals of ‘SUN’ (Doc 15-09-0073-01-004g) as noted below: • page 15 states “Capacity will constrain SUN – need to exploit all available frequencies” - there are numerous licensed band available frequencies. • page 13 states “Unlicensed bands impose stricter co-existence requirements” – which is not true compared to licensed bands. It is well established that co-existence of unlicensed AMI systems is at issue (Ref: Itron and Cellnet FCC request for rule change). In the last 20 years, due to industry requests to mitigate jamming and improve co-existence, the FCC has changed the regulations of unlicensed operation 8 times. • Licensed band operation is well established in the Utility industry representing the largest segment of wireless SCADA controls. The FCC has provided licensed spectrum for preferential utility use under Part 90. Many Utilities already own these licenses and Utilities were large winners in the FCC MAS license auctions. • Every shared spectrum mesh system relies upon public RF carrier backhauls from their collectors. All public RF carriers (voice and data) use Licensed spectrum, because it has BW, availability, and reliability. <Britton Sanderford>, <Sensus>

18. Comments on W-SUN 802.15.4g Proposed Modifications (Cont’d) Why single out licensed band operation for non-use? • FCC licensed bands represent a level playing field available to all the public for the public good. The market values licensed spectrum by putting a price on it because it is premium spectrum. This price is inconsequential compared to the project cost of an Smart Meter system. Shared spread spectrum use is free because the FCC cannot realistically sell it • It is only available on a shared secondary use basis with Industrial, Scientific and Medical (i.e. the ISM band). Also, the FCC has notified there may be a required reduction in Spread Spectrum power output to prevent interference to Government/ Military applications, which are primary use in this band. Licensed band operation gives the utility industry an alternative to interference risks • When the FCC has had interference complaints from Spread Spectrum users it has not accommodated those requests, for example: Excerpt from paragraph 30 of November 6, 2006 FCC Ruling: “‘Part 15 specifies power levels, frequency bands, and conditions under which devices may transmit RF signals without requiring a license.’ Says the FCC. And, most importantly here, ‘Part 15 devices do not receive interference protection from other Part 15 devices.’ Because of this, ‘Massport has no right to operate the airport Wi-Fi backbone free from interference from other Part 15 devices, including Continental’s Wi-Fi… The type of traffic carried by the backbone does not change the application of Part 15 of our rules. [emphasis added] Users who believe they must have interference-free communication should pursue the exclusive-use options under our licensed service models instead of relying on Part 15 devices.” Source: Federal Communications Commission FCC 06-157 In the Matter of Continental Airlines Petition for Declaratory Ruling Regarding the Over-the-Air Reception Devices (OTARD) Rules MEMORANDUM OPINION AND ORDER Adopted: October 17, 2006 Released: November 1, 2006 <Britton Sanderford>, <Sensus>

19. Comments on W-SUN 802.15.4g Proposed Modifications (Cont’d) Ref: IEEE P802.15-09-0037-00-004g “Range & density requirements mean that maximum allowable power must be used “ • In fact, Licensed band operation offers more power, 2 to 5 Watts, to penetrate below ground FCI’s, meter vaults, basement meters and urban high rises. Intellectual Property concerns: • There are many (666?) granted and pending MESH Utility-AMI patents which must be considered when designing or deploying these systems <Britton Sanderford>, <Sensus>

20. Comments on W-SUN 802.15.4g Proposed Modifications (Cont’d) The FCC conditions for use of unlicensed spectrum should be included in the 802.15.4g standard:Section 15.5 General conditions of operation. (a) Persons operating intentional or unintentional radiators shall not be deemed to have any vested or recognizable right to continued use of any given frequency by virtue of prior registration or certification of equipment, or, for power line carrier systems, on the basis of prior notification of use pursuant to Section 90.63(g) of this chapter. (b) Operation of an intentional, unintentional, or incidental radiator is subject to the conditions that no harmful interference is caused and that interference must be accepted that may be caused by the operation of an authorized radio station, by another intentional or unintentional radiator, by industrial, scientific and medical (ISM) equipment, or by an incidental radiator. (c) The operator of a radio frequency device shall be required to cease operating the device upon notification by a Commission representative that the device is causing harmful interference. Operation shall not resume until the condition causing the harmful interference has been corrected. Note: Spread spectrum systems are sharing these bands on a noninterference basis with systems supporting critical Government requirements that have been allocated the usage of these bands, secondary only to ISM equipment operated under the provisions of Part 18 of this Chapter. Many of these Government systems are airborne radiolocation systems that emit a high EIRP which can cause interference to other users. Also, investigations of the effect of spread spectrum interference to U.S. Government operations in the 902-928 MHz band may require a future decrease in the power limits allowed for spread spectrum operation. <Britton Sanderford>, <Sensus>

21. Frequency Hopping Proposals <Britton Sanderford>, <Sensus>

22. Frequency Hopping Proposals (cont.) <Britton Sanderford>, <Sensus>