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National Spectrum Managers Association Unlicensed Devices – An Update Mitchell Lazarus May 22, 2007 703-812-0440 | lazar

National Spectrum Managers Association Unlicensed Devices – An Update Mitchell Lazarus May 22, 2007 703-812-0440 | lazarus@fhhlaw.com. A Brief History of Unlicensed Use. Early period: 1936-1985 e.g. , toys, home intercoms, early cordless phones low power, short range, poor performance

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National Spectrum Managers Association Unlicensed Devices – An Update Mitchell Lazarus May 22, 2007 703-812-0440 | lazar

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  1. National Spectrum Managers AssociationUnlicensed Devices– An UpdateMitchell LazarusMay 22, 2007703-812-0440 | lazarus@fhhlaw.com

  2. 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.

  3. 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.

  4. 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.

  5. White Space – History • December 2002: Notice of Inquiry • strong opposition, little support • May 2004: Notice of Proposed Rule Making • suggested three mechanisms: • find device location; consult table of vacant channels • receive “control signal” that identifies vacant channels • 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.

  6. 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.

  7. 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.

  8. 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.

  9. 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.

  10. 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 stand-alone; 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.

  11. 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.

  12. “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.

  13. Other Matters

  14. “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.

  15. OTARD • Over the air receiver device (OTARD) rules prohibit third-party restrictions on an antenna if: • one meter or less in diameter • on property under the exclusive control of the user • used to transmit or receive fixed wireless signals • Applied to video and licensed services (e.g., BRS) • FCC: OTARD also protects Part 15 antennas.

  16. 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).

  17. 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).

  18. 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.

  19. Thank you! Mitchell Lazarus | 703-812-0440 | lazarus@fhhlaw.com

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