Project: IEEE P802.15 Working Group for Wireless Personal Area Networks

1. Project: IEEE P802.15 Working Group for Wireless Personal Area Networks Submission Title: [Update on WCA Petition to Change FCC Regulations Governing the Unlicensed 57 – 64 GHz Band] Date Submitted: [November 2005] Source: [Gary Baldwin] Company [SiBEAM, Inc.] Address [840 W. California Drive, Suite 110, Sunnyvale, CA 94086] Voice: [(408) 245-3120], E-Mail: [gbaldwin@sibeam.com] Re: [WCA Petition RM-11104 Filed with FCC, September 2004] Abstract: [Since the filing by the WCA of a proposed change in the regulations that govern the use of the unlicensed 57 – 64 GHz band, the IEEE has filed an opposing opinion. Members of 802.15.3cTG have since met with representatives of the WCA to seek common ground. This brief report summarizes progress to date.] Purpose:[Contribution to 802.15 TG3c at November 2005 meeting in Vancouver] 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.

2. Summary Actions on WCA Petition Gary Baldwin, Director of Corporate Development SiBEAM, Inc.

3. WCA petition2 • Convert to EIRP1 instead of power density • Increase to 82 dBm EIRP1, less 2 dBm for each dB gain below 51 dB • Exempt indoor “window links” from Call sign ID. Key 15.255regulations (existing) 57 – 64 GHz unlicensed band: FCC Regulations Part 15.255 • Radiation limits measured by power density in the far field • Power limited to 9 mW/cm2at 3 m (40 dBm EIRP1) • Call sign ID required to identify interferers, indoors and outdoors Note 1: Equivalent Isotropically Radiated Power Note 2: Filed September 30, 2004: RM-11104

4. Brief History of Presentations and Actions on WCA Petition • WCA petitioned FCC to change Part 15.255 (September 2004) • Ex parte filings by various industrial groups (HP, SiBEAM, Freescale) • IEEE 802 Standards Committee filed petition with FCC on August 23, 2005, opposing WCA petition on all three counts outlined above! • WCA convened “mini-summit” to discuss petition and alternatives September 15, 2005

5. Progress on the Issues • Substantive agreement on points 1 and 3: all agree that measurements should be made in the far field; and all would like to make field-programmable caller-ID an option. • Issue #2 still unsettled • It is the combination of antenna gain and radiated power, i.e., the potentially high EIRP, proposed in the WCA petition that concerned us the most. • The potential for scattered or reflected radiation is significant. Data show that as much as 50% of radiation incident on ordinary window glass can be reflected back. This could wreak havoc on a low-power 60 GHz system, operating within existing Part 15.255 regulations.

6. Calculations of Power Received by Unintentional Transmission through Windows Transmitted EIRP = 82 dBm – 2 dBm for each dBi of antenna gain below 51 dBi = 62 dBm

7. Brief History of Presentations and Actions on WCA Petition • WCA petitioned FCC to change Part 15.255 (September 2004) • Ex parte filings by various industrial groups (HP, SiBEAM, Freescale) • IEEE 802 Standards Committee filed petition with FCC on August 23, 2005, opposing WCA petition on all three counts outlined above! • WCA convened “mini-summit” to discuss petition and alternatives September 15, 2005 • WCA will either withdraw petition or, at a minimum, modify petition • Bridgewave (Levin) calculations to show unintentional impact of outdoor- mounted point-to-point links on indoor systems • No further action to date