Millimeter Wave Regulation IEEE EMC – DC/No. VA Mitchell Lazarus 703-812-0440 | lazarus@fhhlaw.com January 31, 2012

1. Millimeter Wave Regulation IEEE EMC – DC/No. VA Mitchell Lazarus 703-812-0440 | lazarus@fhhlaw.com January 31, 2012 File copy provided by http://www.wll.com

2. Overview • FCC restricted bands • Communications • 57-64 GHz (unlicensed) • 92-95 GHz (unlicensed) • 71-76, 81-86, 92-95 GHz (licensed) • Radar – Current Rules • 57-64 GHz • 76-77 GHz • Radar – Waivers and Proposed Rules • 76-77 GHz • 77-81 GHz • 78-81 GHz File copy provided by http://www.wll.com

3. Millimeter Wave Signals in General • Advantages • tight beams from small antennas • can reuse same frequency nearby • high data capacity • Disadvantages • need direct line-of-sight • high free space attenuation • high rain attenuation • poor penetration of walls and terrain. At X GHz, a one-foot antenna has a diameter of X wavelengths. File copy provided by http://www.wll.com

4. FCC Restricted Bands • In the late 1980s, the FCC listed 64 “restricted bands”: • closed to unlicensed transmitters • range from 90 kHz to 36.5 GHz • to protect sensitive receivers: – GPS, radio astronomy, satellite downlinks, air traffic radars, etc. • FCC also declared all bands above 38.6 GHz to be “restricted” • Authorizing unlicensed use above 38.6 GHz always requires removal from the restricted list • part of the FCC rulemaking proceeding. File copy provided by http://www.wll.com

5. Communications File copy provided by http://www.wll.com

6. 57-64 GHz (Unlicensed) – 1 • Max average power 9 µW/cm² at 3 meters (40 dBm EIRP) • max peak 500 mW • Disadvantage: attenuation by O2 molecules in atmosphere • WiGig Alliance: • in-room data communications • 1-6 Gbits/sec • wireless HDMI, gaming, home storage network, etc. • proposed IEEE 802.11ad. 16 dB/km 8 57–64 GHz 0 Source: Adelia C. Valdez Va Tech 2001 50 60 70 Frequency (GHz) File copy provided by http://www.wll.com

7. 57-64 GHz (Unlicensed) – 2 • Rulemaking proposal: • average power 82 dBm EIRP • minus 2 dB for every dB that antenna gain is below 51 dBi • antenna must be outdoors or pointed outdoors • Pending since June 2007 • new rules possible in 2nd or 3rd quarter 2012. File copy provided by http://www.wll.com

8. 92-95 GHz (Unlicensed) • Coextensive with 92-95 GHz licensed band (next slide) • Max average power 9 µW/cm² at 3 meters (40 dBm EIRP) • max peak 500 mW • indoor only – minimizes interference to and from licensed users • No FCC certifications issued to date. File copy provided by http://www.wll.com

9. 71-76, 81-86, 92-95 GHz (Licensed) • Each applicant receives a non-exclusive, nationwide license • no limit on number issued • For each link: • electronic, real-time interference checks with Federal gov’t and non-gov’t incumbents • interference cases are rare (except on certain rooftops) • Max power 55 dBm EIRP • No licensed use on 94-94.1 GHz • reserved for Federal research applications • Minimum bit rate: • 71-76, 81-86: 0.125 bits/sec/Hz • 92-95 GHz: 1.0 bits/sec/Hz. File copy provided by http://www.wll.com

10. Radar(Current Rules) File copy provided by http://www.wll.com

11. 57-64 GHz • 61.0-61.5 GHz fixed field disturbance sensors: • max average power 9 µW/cm² at 3 meters (+40 dBm EIRP) • peak power density 18 µW/cm² at 3 meters (+43 dBm EIRP) • non-fixed or elsewhere in band: • max peak power density 9 nW/cm2 at 3 meters (+10 dBm EIRP) • max peak transmitter output power 0.1 mW • Unlicensed. File copy provided by http://www.wll.com

12. 76-77 GHz • Vehicle-mounted radars only • Unlicensed. • Power limits: File copy provided by http://www.wll.com

13. Radar(Waivers and Proposed Rules) File copy provided by http://www.wll.com

14. 76-77 GHz (Proposed Rule) • 100 watt (50 dBm) power limit • regardless of direction; moving or stopped • any application (not just vehicle-mounted) • Pending since May 2011. File copy provided by http://www.wll.com

15. 76-77 GHz (Waiver) • Fixed use of 10 radars at Atlanta airport • for tracking aircraft and vehicles on ground • Must meet emissions limits for forward-looking, in-motion vehicle radars ( +48.3 dBm EIRP) • Granted September 2009. File copy provided by http://www.wll.com

16. 77-81 GHz (Proposed Rule & Waiver) • Use as in-tank level probing radars • limited to commercial use at fixed locations • Unlicensed • Proposed emissions limits: • +23 dBm EIRP average (measured with no tank wall) • +43 dBm EIRP peak (measured with no tank wall) • but pulse radars often have >20 dB P/A ratio • –41.3 dBm EIRP (§15.209) (measured through metal or concrete) • FCC acknowledges need to protect radio astronomy operations • Pending since January 2010 • Waiver granted pending rulemaking • subject to above emissions limits. File copy provided by http://www.wll.com

17. 78-81 GHz (Proposed Rule & Waiver) • Airport use to detect “foreign object debris” (FOD) on runways • aircraft parts, tools, equipment and supplies, rocks, pavement fragments, luggage, wildlife • FCC open to allowing other applications • No proposal as to licensed vs. unlicensed • No proposal as to power limits • FCC acknowledges need to protect radio astronomy operations • Pending since December 2011 • Waiver granted pending rulemaking: • airport FOD detection only • 35 dBW EIRP • license required. File copy provided by http://www.wll.com

18. Conclusion • Millimeter wave spectrum is the target of extensive engineering innovation • FCC rules at 57 GHz and above are badly out of date • FCC moving to update rules, but regulatory process is inherently slow. File copy provided by http://www.wll.com

19. Thank you! Mitchell Lazarus 703-812-0440 | lazarus@fhhlaw.com File copy provided by http://www.wll.com