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SPECTRUM WARS 2002 The FCC’s RF Lighting Proceeding (ET Docket 98-42)

SPECTRUM WARS 2002 The FCC’s RF Lighting Proceeding (ET Docket 98-42). Robert D. Primosch, Esq. Wilkinson Barker Knauer, LLP Washington, D.C. robert.primosch@wbklaw.com. What is RF Lighting?. Devices that produce light by using RF energy to stimulate gases contained inside a lamp

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SPECTRUM WARS 2002 The FCC’s RF Lighting Proceeding (ET Docket 98-42)

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  1. SPECTRUM WARS 2002The FCC’s RF Lighting Proceeding (ET Docket 98-42) Robert D. Primosch, Esq. Wilkinson Barker Knauer, LLP Washington, D.C. robert.primosch@wbklaw.com

  2. What is RF Lighting? • Devices that produce light by using RF energy to stimulate gases contained inside a lamp • Utilized to light large commercial areas (warehouses, parking lots, shopping malls, etc.) • Regulated under Part 18 of the FCC’s Rules. • Fusion Lighting: high-power RF lamp for commercial use that operates in the 2400-2500 MHz band (the “ISM” band). • Affected Parties: SDARS (2320-2345 GHz) and Part 15 License Exempt (2.4 GHz)

  3. Why Is It Important? • High-Power, Ubiquitous, Outdoor Device • Reflects growing regulatory tension between licensed and license-exempt services • Raises fundamental issues of what levels of interference are unacceptable, and who pays for it

  4. Timeline • 1985: FCC classifies RF lighting devices as Part 18 ISM equipment • 4/9/98: FCC releases NPRM in ET Docket No. 98-42: • Two types of devices: GE Lamp (2.2 and 2.8 MHz) and Fusion Lighting (2.4 GHz) • FCC proposes to relax line-conducted emission limits and adopt radiated emission limits above 1 GHz • 1/21/99: Fusion Lighting and Part 15 interests ask for delay re: rules for non-consumer RF lighting devices • 6/16/99: First Report and Order – FCC defers action on non-consumer RF lighting devices • 2/29/00: Fusion Lighting files Petition for Further Rulemaking

  5. What’s On the Table • Issue: Appropriate out-of-band emission limits for Fusion Lighting devices • Current Limit: 71 dBu V/m @ 3M • FCC Proposal: 54 dBu V/m @3M (85% reduction from current limit) • Fusion Lighting: 44 dBu V/m @ 3M (95% reduction), plus “safe harbor” • SDARS: 18.7 dBu V/M @ 3M

  6. What’s On The Table (cont’d) • Issue: In-Band Limits to Protect Part 15 Operations • Bluetooth: Limit RF Lighting “pollution” to top one-third of 2.4 GHz band • Part 15 Interests: • 2400-2460 MHz: 10 mV/m @ 3M • 2460-2480 MHz: 330 mV/m @ 3M • 2480-2500 MHz: 10 mV/m @ 3M

  7. Going Forward . . . • 5/14/02: Fusion Lighting Proposes “Real World” Testing Procedures • SDARS Has Committed to Renewed Joint Testing

  8. What to Look For • Post-UWB Approach to Interference: less reliance on “worst case” analysis • Who pays? Is it the responsibility of the party receiving the interference to design better receivers? • Treatment of “safe harbor” issue • Relationship to other licensed vs. license-exempt proceedings

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