Enhancing Lives: Wireless Tech for Better Hearing

1. Project: IEEE P802.15 Working Group for Wireless Personal Area Networks (WPANs) Submission Title: [Potential Waiver and Rulemaking change to Part 15.247] Date Submitted: [14 May 2008] Source: [Jeff Solum] Company [Starkey Laboratories, Inc] Address [6600 Washington Av S, Eden Prairie, MN, 55344] Voice:[Add telephone number], FAX: [Add FAX number], E-Mail:[Jeff_Solum@starkey.com] Re: [in response to the call for presentations from WNG Chair] Abstract: [Description of wireless hearing aid needs.] Purpose: [Informative document on NPRM to FCC Part 15.247] 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. <Jeff Solum >, <Starkey Laboratories>

2. Potential Waiver and Rulemaking change to Part 15.247 Starkey Laboratories, Inc. Jeff Solum 5/14/2008 <Jeff Solum >, <Starkey Laboratories>

3. Agenda • Introduction of Starkey Laboratories, Inc. • What are we trying to accomplish • Hearing aid styles • Benefits for the hearing disabled • Assistive Listening Devices • Waiver/Rulemaking relative to hearing aids operating within Part 15.247

4. Starkey Laboratories, Inc. • Private company founded in 1967 by William F. Austin • Headquarters in Eden Prairie, MN • With 35 facilities in more than 24 countries around the globe, Starkey is an industry leader in hearing instrument manufacturing. We create top quality diagnostic equipment, hearing protection products, wireless technology and unique hearing solutions for every environment. • Starkey is a world leader in the design, development and distribution of comprehensive hearing solutions. We believe in using superior hearing technology as a means to something even greater—creating meaningful connections between people and their worlds.

5. What we are trying to accomplish • We care about our patients • We care about the real life frustrations today’s hearing disabled patients face on a daily basis. • We are passionate about the quality of our patient’s life experiences. • We believe that the hearing disabled should be able to enjoy the same quality of life as persons with normal hearing. • We believe that the hearing disabled should be fully connected to the world in which they live through digital wireless technology. • There are over 31 million Americans with hearing problems that can be addressed through wireless technology. • 16 million (and rising) are baby boomers

6. What we are trying to accomplish • Current regulations do not enable us to provide next generation patient benefits for the hearing disabled. • We are seeking a waiver and subsequent rule making change to help facilitate a high quality of life for the hearing disabled.

7. Receiver-In-Canal (RIC) In-The-Ear (ITE) In-The-Canal (ITC) Completely-In-Canal (CIC) Behind The Ear (BTE) On The Ear (OTE) The receiver-in-the-canal device is small, discreet, and incredibly quick to fit; perfect for many first-time wearers. Smaller, in-the-ear instruments house their technology components in a custom-formed earmold that fits within the outer portion of the ear. In-the-canal instruments are smaller still, featuring an earmold that fits down into the ear canal and a smaller portion that faces out into the outer ear. These devices fit completely in the canal. Only the head of a tiny plastic line—with which you insert or remove the instrument—shows above the canal. BTE instruments have a plastic casing that rests behind the ear and houses the device's technology. A clear plastic tube then directs amplified sound into an earmold inside the ear canal. With soft, flexible earbuds and an extra-small casing, on-the-ear models are light and comfortable. Hearing Aid Styles

8. Benefits for the hearing disabled available through digital wireless technology • Social • Interaction with others • Social Events • Large gatherings are often avoided by hearing aid wearers. • Many venues do not have ALD systems or require stigmatizing apparatus to be used. • Intimacy • Interpersonal warmth in relationships significantly declines as hearing loss worsens. • It can be exhausting to cope with the needs of a spouse with a hearing disability. • Independence • There is a strong relationship between one’s ability to hear, perceived safety, and independence. • Education • Classroom • Online • Other learning situations http://www.betterhearing.org/hearing_solutions/qualityOfLifeDetail.cfm

9. Benefits for the hearing disabled available through digital wireless technology • Safety • Alarms and announcements • Doorbells • Fire alarms • Emergency announcements • Information • Audible indicators • Public transportation • Buses/Trains • Bus/Train/Airport Terminals • Entertainment • Music • TV • Live Theater http://www.betterhearing.org/hearing_solutions/qualityOfLifeDetail.cfm

10. Benefits for the hearing disabled available through digital wireless technology • Economic • Household income is affected by hearing loss, particularly for moderate to profound loss – $-13,000 per year • Wearing a hearing aid reduces this to $-7000 • Greater connectivity could reduce this even further http://www.betterhearing.org/hearing_solutions/qualityOfLifeDetail.cfm

11. Today’s Patient Limitations • Custom hearing aid wearers are generally unable to take advantage of many Assistive Listening Devices (ALD’s) because direct audio input connectors are not physically available on custom hearing aids. • Speech Understanding in public places • Poor signal to noise ratios make it difficult to understand public announcements such as bus/train arrivals or next stops. • Often, patients must remove their hearing aids in order to use currently available public ALD systems. • Using most widely available ALD systems causes patients to give up their prescribed frequency response. • Range on in-home ALD’s is often limited to line of sight (same-room usage). • Many are not compatible with hearing aids • Dongles, cables, or headsets are required for most current communication interfaces • Almost all current ALD systems highlight a patient’s disability.

12. Current Assistive Listening Devices • Audio Inductive Loop Systems • Require high power magnetic loops • Audio frequencies direct to tele-coil input • Suffer from low range and polarization effects • Not widely installed in the US • Analog FM Systems • 200 and 70 MHz narrow band analog FM • Require external receiver • Require direct audio input connection to HA • Infrared Systems • Some public venues (Museums) • Limited to line of sight • Require direct audio input connection to HA http://www.betterhearing.org/hearing_solutions/listeningDevices.cfm

13. The Future of Personal Assistive Listening Devices Low Power 915 MHZ, One Way Voice Link <Jeff Solum >, <Starkey Laboratories>

14. Assistive listening device in an auditorium setting <Jeff Solum >, <Starkey Laboratories>

15. Assistive listening device in a public transportation setting <Jeff Solum >, <Starkey Laboratories>

16. Starkey’s vision for personal connectivity

17. Tomorrow’s connectivity Change the paradigm of wireless connectivity from a clumsy, costly accessory to a ubiquitous communication feature. • Safety information/alarms can be transmitted directly to a hearing instrument. • Digital audio can be utilized in classrooms or theaters without the need for expensive loop system installation. • Allows connection to the public telephone network. • Extend the range at which ALD’s are able to be effective, including personal microphone systems.

18. Applications envisioned for new hearing instruments • Phase 1 (2008-2009) –possible under part 15.249 • Programming Hearing Instruments • Patient Ear to Ear Communication • Remote control • Patient Data Logging • Phase 2 (2010) – NOT possible under part 15.249 • Digital Streaming Audio • Assistive Listening Device • Phase 3 (2011) – also NOT possible under 15.249 • Bi-Directional Streaming Audio 15.249 NOT 15.249

19. Why we are using 902-928 MHz • Unlicensed band in the US with similar bands available in the EU and many other countries. • 900 MHz is a good place to operate small body worn ultra-low power devices • Antennas are small and efficient for the size available in a hearing aid. • Small, custom hearing aids dominate the US market. • Power consumption is low, with transmit and receive consumption nearly equal at this frequency and antenna efficiency. • Losses due to body absorption are relatively low below 1 GHz.

20. Part 15.249 Technical Limitations • 15.249 RF output level is limited to -1.5 dBm. • Range is limited to < 3m for good quality links given the hearing aid antenna size and limited sensitivity. • This works well for the programming and ear to ear applications for a programmer using adaptive frequency selection and relatively large antennas. • 15.249 will not work well for real time streaming audio applications beyond 2 meters. • Interference will be problematic at this low a power level operating in this “unlicensed band”.

21. What about 15.247? • 15.247(e) For digitally modulated systems, the power spectral density conducted from the intentional radiator to the antenna shall not be greater than 8 dBm in any 3 kHz band during any time interval of continuous transmission. • Allows a power spectral density of 8 dBm/ 3 kHz. • This power level extends the range of communication to 30 m and opens up streaming digital audio and other applications for classrooms, households, and public venues. • 15.247(a)(2) Systems using digital modulation techniques may operate in the 902–928 MHz, 2400–2483.5 MHz, and 5725–5850 MHz bands. The minimum 6 dB bandwidth shall be at least 500 kHz. • Constraint is the specification of a minimum bandwidth of 500 kHz

22. Design Crossroad Reached • Starkey and other hearing aid manufacturers have three design options to use 902-928 MHz • Work within Part 15.249 • Limits the applications • Poor reliability due to limited link margin • Increase occupied bandwidth to meet Part 15.247 • Occupy more bandwidth than necessary for the application (500 kHz) • Power consumption increases (Battery life decreases) • Work within Part 15.247 with requested waiver • Allows operation of all applications without creating unnecessary interference. • Improves reliability • Reduces overall power consumption

23. Waiver Request • A waiver to 15.247 minimum bandwidth requirements to allow the hearing disabled to use the same power spectral density (8 dBm/3 kHz), but with a lower bandwidth minimum (100 kHz vs. 500 kHz) • Waiver is in the public interest • Waiver request does not undermine the purpose of the rule 100 to 300 kHz is sufficient for most digital streaming audio signals

24. Rule Making Change the rules to allow operation under 15.247 at a lower minimum bandwidth (100 kHz) while maintaining the power spectral density requirement of 8 dBm/ 3 kHz. • Public interest • Current rule has potentially unintended consequences. • Promotes inefficient use of the spectrum • A rule change will allow efficient and better utilization of the available bandwidth.