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Kenneth R. Nichols Chief, Laboratory Division May 22, 2001

Software Defined Radios A Regulatory Perspective Presented at the National Spectrum Managers Association Annual Conference. Kenneth R. Nichols Chief, Laboratory Division May 22, 2001. Definition in the NPRM. The Commission's proposal

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Kenneth R. Nichols Chief, Laboratory Division May 22, 2001

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  1. Software Defined RadiosA Regulatory PerspectivePresented at theNational Spectrum Managers AssociationAnnual Conference Kenneth R. Nichols Chief, Laboratory Division May 22, 2001

  2. Definition in the NPRM • The Commission's proposal • A software defined radio is a radio that includes a transmitter in which the operating parameters of the transmitter, including the frequency range, modulation type or maximum radiated or conducted output power can be altered by making a change in software without any hardware changes. • Have we already approved software defined radios based on this definition? May 22, 2001 FCC Laboratory

  3. Key Issues • What documentation is needed by the Commission to ensure compliance with the Rules • Likelihood that more interference will be generated • Likelihood that the interference will be more difficult to locate • Likelihood that RF exposure limits will be exceeded • Ease of software modification • Who has the authority to make the changes • Who has the ability to make the changes May 22, 2001 FCC Laboratory

  4. Notice of Inquiry • Notice of Inquiry, released March 21, 2000 • State of Technology • Improving Interoperability between Radio Services • Improving Spectrum Efficiency and Spectrum Sharing • Equipment Approval Process May 22, 2001 FCC Laboratory

  5. Equipment Approval Process • Whether to approve the hardware, the software or the combination • Whether all the currently required measurements in Part 2 are appropriate • Appropriate test procedures, approval process and labeling requirements • Regulation of software changes and the records of modifications • Need for requirements on anti-tampering May 22, 2001 FCC Laboratory

  6. Notice of Proposed Rule Making • The hardware and software must be approved together • Only the original grantee will be able to modify software via a Class III permissive change • Keep Part 2 requirements and test each mode the SDR can use • The grantee is responsible for ensuring that their approved software/hardware combination is not modified May 22, 2001 FCC Laboratory

  7. Definition in the NPRM • The Commission's proposal • A software defined radio is a radio that includes a transmitter in which the operating parameters of the transmitter, including the frequency range, modulation type or maximum radiated or conducted output power can be altered by making a change in software without any hardware changes. • Have we already approved software defined radios based on this definition? May 22, 2001 FCC Laboratory

  8. Existing Environment • Yes, one can make a case that we have already approved SDRs • Many transmitters we approve today have a microprocessor and "software" to control some or all of their fundtions • The "software" may be called "firmware" but the basic function is the same • A software program is used to control the key characteristics of the transmitter • One critical difference is control of the software May 22, 2001 FCC Laboratory

  9. Recent Application • Denied an application for a modulation that did not comply with Rules • TCB granted an application from the same applicant we had just denied • The TCB grant was for the same frequency band and the device would perform a similar function • We audited the TCB grant • The schematic diagrams for granted application and the denied application were identical! May 22, 2001 FCC Laboratory

  10. Recent Application continued • We had been concerned that we might have a case of forum shopping • Denied by one organization but submit to another and maybe get lucky • Previous case • An applicant had been denied by the Laboratory • The applicant changed FCC ID by one character and submitted to a TCB for approval • Received approval in error by TCB • Was this another case? May 22, 2001 FCC Laboratory

  11. Software Is Critical • No! This was not a case of forum shopping. • The transmitters were completely different • They used the same hardware but had completely different software configurations • The configuration approved by the TCB complied with the Rules while the one we denied did not • If you don't know what software is used in the hardware you don't have enough information to determine if the radio complies with the Rules May 22, 2001 FCC Laboratory

  12. Just beginning.. • We are just at the beginning of the software defined radio evolution • Software defined radios have great potential to solve many of our present problems • SDR also has the potential to cause great harm • We need to determine the best way to authorize SDR now before we generate a lot of problems that will be much more difficult to clean up after millions of these devices enter service May 22, 2001 FCC Laboratory

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