Project: IEEE 802.15 Working Group for Wireless Personal Area Networks (WPANs)

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] Voice:[+1 847 576-8706], FAX: [+1 847 576-6758], E-Mail:[John.Barr@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. Dr. John R. Barr, Motorola

2. Unfolding Event TimelineProcess Is Matter Of Public Record • 26Aug2004 – MBOA SIG Leadership Intel, TI, Staccato, Alereon, and Wisair files petition to for waiver of FCC rules • 30Aug2004 – FCC Issues DA-04-2793 -- starts proceeding 04-352 • 30-day comment window -- Comments due 29 Sept 2004 followed by • 15-day reply window -- Replies due 14 Oct 2004 • All comments and exparte meeting notes are open to public • http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi • Search on proceeding 04-352 • MBOA SIG asks for 7 day extension to reply period • Reply period extended to October 21 • FCC TAC (technical advisory committee) meeting on October 27 • Meeting is chaired by Ed Thomas, Chief of OET (Office of Engineering and Technology) • OET is the part of FCC that issued the UWB rules and is considering the waiver request • Invited talks given by Steven Wood and John McCorkle • Video and slides available on FCC web site • http://www.fcc.gov/oet/tac/meetings_2004.html • 3Nov04 – TI, Intel, Staccato, and Philips meet with FCC OET • 5Nov04 – Freescale meets with FCC OET Dr. John R. Barr, Motorola

3. MBOA SIG Waiver Purpose “Based on these test results and he analysis which follows, MBOA-SIG seeks a waiver of the commission’s frequency hopping measurement procedures to allow MB-OFDM systems to be tested for average emissions under normal operating conditions, rather than with band sequencing stopped. Additionally, MBOS-SIG seeks a waiver of the pulse “gating” procedures set forth in Section 15.521(d) of the rules to the extent that these procedures apply to MB-OFDM systems. A waiver of these test procedures will serve the public interest, as it will permit MB-OFDM systems to compete fairly for public acceptance in the market, without increasing the threat of interference from UWB devices.” From MBOA SIG petition to FCC OET on 26August04 and recorded as part of ET Docket No. 04-352 Dr. John R. Barr, Motorola

4. The “Stop The Hopping/Gating” Rules DO Apply To MB-OFDM • The FCC’s announcement of proceeding 04-352 proves that the “stop the hopping/gating” rules DO apply to MB-OFDM • The waiver makes no sense if the “stop the hopping” rules do not apply • The Law of Contradiction does not allow one to say, “The rules both apply and don’t apply” • You can’t waive nothing (i.e. a non existing rule) • If the waiver is denied, then • All of the ranges reported by MBOA must be cut in half • Or, all the data rates must be cut in 1/4 for all reported ranges • The MB-OFDM proposal would not meet the 110 Mbps at 10m requirements for IEEE 802.15.3a (03/030r0) Dr. John R. Barr, Motorola

5. What Must An Applicant ShowIn Order To Obtain A Waiver? “The standards for obtaining a waiver are well established: an applicant must show that a grant of the waiver is in the public interest and does not increase the risk of harmful interference.” (pg 4) Dr. John R. Barr, Motorola

6. Summary of 29Sept Comments • Against grant of the waiver: • Motorola, Freescale, C-Band Coalition, Satellite Industry Association, Pulse~LINK, 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 Dr. John R. Barr, Motorola

7. Reasons To Grant The Waiver • No new material except for Philips comments • All simply reference statements made in the request • Philips comments present an analysis using APDs(Amplitude Probability Distribution) • Claimed their APD analysis showed susceptibility of victim receivers to MB-OFDM was acceptable • In reply comments, the APDs analysis was proven flawed • Counter example proof showed two signals with equal APD yet resulting in significantly different BER impact • APDs ignore time, which is clearly a factor in susceptibility • Susceptibility conclusions cannot be based on APDs Dr. John R. Barr, Motorola

8. Reasons To Deny Waiver (1) • Filing misrepresents MBOA - MBOA SIG members not consulted, no advanced notice that the filing was going to be made (Time Derivative, Pulse~LINK) • Current test procedures DO apply to MB-OFDM (PL) • FCC rules DO apply to MB-OFDM waveform (Cingular, TD) • Waiver increases allowed power which can only increases interference (PL, TD, SIA) • 6 dB added power in MB-OFDM burst pulses cause a large number of symbol errors in many systems (SIA, CBC) • Inconsistent with Telecommunications Act of 1996 (PL, TD) • “without regard to any specific technology” • but waiver is special carve out for MBOA • Granting waiver would disadvantage conforming UWB devices that also transmit in bursts, but cannot average power. (FSL) • Creates unfair advantage FOR MB-OFDM devices (PL, TD) • Doesn’t meet minimum bandwidth requirement (MOT) • Changes the rules for small companies not aligned with the MBOA-SIG (PL) • Develop appropriate test procedures (TD) • Insufficient analysis and experience. Current rules still to be proven. Affects of accepting a waiver has not been adequately analyzed. (FSL, MOT) • Measurement techniques used by the MBOA SIG were flawed. (CBC) Dr. John R. Barr, Motorola

9. Reasons To Deny Waiver (2) • Waiver is wrong mechanism – Needs NPRM rulemaking (Cingular, FSL, MOT) • Waiver is not urgent (FSL, MOT) • MB-OFDM can be certified under current rules • MBOA spokesman have stated it does not affect marketing plans • MBOA spokesman have stated that products are not likely to hit store shelves for about 1 year (Steven Wood at FCC TAC meeting, Roberto Aiello at IEEE Berlin) • Waiver is not needed • Claimed benefits are not the result of hopping (instead are from underlying OFDM) • MBOA proponents have published alternative approaches that do not hop • Waiver is not (and Petition fails to prove) in the public interest. (Cingular, 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) • Claimed benefits only benefit the manufacturer, not the public • FCC previously stated that changes should be based on commercially available products, which have not yet been provided. (MOT) • Petitioner has not demonstrated non-interference of commercially available products with all varieties of the incumbent spectrum users. (MOT) Dr. John R. Barr, Motorola

10. Summary of October 21 Comments • Against grant of the waiver: • Freescale, Motorola, decawave • For grant of the waiver: • MBOA SIG Dr. John R. Barr, Motorola

11. 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) (15-04-0497-04-003a-berlin-tg3a-meeting-minutes.doc) • Stephen Wood of Intel: “The timeline is not dependent upon the waiver request. Obviously, there will be performance variation depending on what the outcome is of the waiver.” (answer to questions posed by Ed Thomas at 27Oct04 FCC TAC meeting regarding whether waiver request would affect MBOA member product plans) (http://www.fcc.gov/realaudio/mt102704.ram at 3:27) • 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. (MOT) • 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, via adaptive & ad hock MAC protocols such as CSMA, operate in a synchronized manner that effectively produces continuous emissions across the entire band that are 5.9 dB above the -41.3 dBm limit – raising potential interference. (FSL) Dr. John R. Barr, Motorola

12. Current Rules Force Continuous Transmissions During Compliance Testing And Limit All UWB Equally • DS-UWB is also gated, bursting packets, but must be measured while transmitting continuously From Freescale presentation to FCC OET on 5Nov04 filed for ET Docket No. 04-352 Dr. John R. Barr, Motorola

13. MB-OFDM Waiver Request From Freescale presentation to FCC OET on 5Nov04 filed for ET Docket No. 04-352 Dr. John R. Barr, Motorola

14. Synchronization of Closely Spaced MB-OFDM Devices Results In Continuous Emissions Across The Entire Band That Are 5.9 dB Above The Limit From Freescale presentation to FCC OET on 5Nov04 filed for ET Docket No. 04-352 Dr. John R. Barr, Motorola

15. 3 Close Full Band Devices Must Time-Share From Freescale presentation to FCC OET on 5Nov04 filed for ET Docket No. 04-352 Dr. John R. Barr, Motorola

16. Conclusion • DS-UWB has already been certified and has no regulatory issues • Hopping rules DO apply to MB-OFDM • If the waiver is denied, then • All of the ranges reported by MBOA must be cut in half or • All the data rates must be cut in 1/4 for all reported ranges • The MB-OFDM proposal would not meet the required 110 Mbps at 10m • MBOA SIG members will go forward with their product plans outside of the IEEE • If a waiver is granted • We do not know today exactly what will be granted • Therefore the effect cannot be known today Dr. John R. Barr, Motorola

17. 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 band sequencing on • Must turn band sequencing 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-Technical-Requirements.doc) • Regulatory approval required (“The alt-PHY standard will comply with necessary geopolitical or regional regulations.” 03030r0P802-15_TG3a-Technical-Requirements.doc) Dr. John R. Barr, Motorola

18. 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 Two Futures Dr. John R. Barr, Motorola

19. IEEE 802.15.3a Call for Proposal Call For Intent/Call For Proposal (CFI/CFP) Call For Intent/Call For Proposal was issued on 03Dec02, the latest version which includes the approved documents from the Jan03 meeting is here or -02/372r8, MS Word (49KB) or via the 21Jan03 2nd notice. Call For Intent (CFI) Respondents Approved, TG3a Technical Requirements -03/030r0, MS Word (1086KB) Approved, P802.15.3a Alt PHY Selection Criteria -03/031r6, MS Word (381KB)  Approved, TG3a Down Selection Voting Procedure -03/041r7, MS Word (105KB) Dr. John R. Barr, Motorola

20. TG3a Vote on 03/030r0 (15Jan03) • Chairman Bob Heile called the session to order at 3:33 p.m. He said that the business of the session was to conduct two roll call votes—one each on the Technical Requirements document (03/030r0) and Selection Criteria document (03/031r4). • On motion (24 for, 9 against, 6 abstentions), the following text was inserted at the end of the introduction in 03/031: • “It is recognized by the committee that the effort required to respond to all of the selection criteria for all three data rates is substantial. To help proposers prioritize their efforts, simulation results for the mandatory minimum rate (>= 110 Mbps) are expected from the proposers during the first round of presentations. Results for the higher mandatory rate of > 200 Mbps and the optional rate of 480 Mbps or more can be provided in subsequent presentations by proposers if desired.” • A roll call technical vote was conducted by the vice chairman, Chuck Brabenac, on 03/030r0, with the result 40 for, 3 against, 3 abstentions. • See: 03012r6P802-15_TG3a-Ft-Lauderdale-Meeting-Minutes.doc and 03051r0P802-15_TG3a-030r0-Technical-Requirements-Voting-Results.xls Dr. John R. Barr, Motorola