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

1. Project: IEEE P802.15 Working Group for Wireless Personal Area Networks (WPANs) Submission Title: [216 – 222 MHz Spectrum Considerations] Date Submitted: [16 January, 2012] Source: [Jon Adams] Company [Lilee Systems, Ltd.] Address [2905 Stender Way, Suite 78, Santa Clara, CA 95054, USA] Voice:[+1 480.628.6686], FAX: [Add FAX number], E-Mail:[jonadams@ieee.org] Re: [If this is a proposed revision, cite the original document.] [If this is a response to a Call for Contributions, cite the name and date of the Call for Contributions to which this document responds, as well as the relevant item number in the Call for Contributions.] [Note: Contributions that are not responsive to this section of the template, and contributions which do not address the topic under which they are submitted, may be refused or consigned to the “General Contributions” area.] Abstract: [Review of US 216 to 222 MHz radio spectrum, licensing rules, usages] Purpose: [For the PTC Study Group to use as an informative information as it moves forward.] 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. Jon Adams, Lilee Systems

2. 216 – 222 MHz Spectrum Considerations Jon Adams Lilee Systems Jon Adams, Lilee Systems

3. Uncertainties and Need for Standards • Mandated deadline for rollout of PTC systems is the end of 2015, less than 48 months away • No radio frequency band mandated for PTC wireless communications • No extensive deployments of PTC in real-world environments • The spectrum that has been acquired to date by the class one railroads and others for the stated purposes of PTC is in bits and pieces • Uncertain the frequency selection and the available spectrum will be sufficient to provide the necessary functionality that PTC may ultimately require Jon Adams, Lilee Systems

4. New Applications Breed Uncertainty • Don’t know what we don’t know • 3GPP (worldwide cellular standard) • Established its first 3G specification, Release-99, in the year 2000 • 7 full specification releases since then • Challenging to predict future use based on current expectation • Far more spectrum usage than was originally considered • Average service life of radio equipment in rail and transit applications is in excess of 10-15 years • System design may remain in place for 20-25 years • Over-the-air protocol and spectrum usage standardization critical Jon Adams, Lilee Systems

5. From US DOC NTIA Spectrum Chart, 2003 Jon Adams, Lilee Systems

6. ERP NTE Channel Spacing Channel Bandwidth 217.080 216.880 SPASUR* 216 217 218 219 220 221 222 TV Ch 13 Part 95.629 LPRS Part 95 Subpart F Part 97 Ham Radio Part 97 Ham Radio AMTS Part 80 Subpart H Part 90 subpart K (legacy) Part 90 Subpart K Part 90 Subpart T * SPASUR: USAF Space Fence. 80.385 (2) AMTS operations must not cause harmful interference to the U.S. Navy (now Air Force – ed.) SPASUR system which operates in the band 216.880–217.080 MHz. May have impact on AMTS operations in Southern California, central Arizona, southern New Mexico, along the Oklahoma/Texas border, central Alabama and Georgia. Jon Adams, Lilee Systems

7. 802.15.4 PTC Amendment • PHY-centric • Absolutely must adapt to new frequency bands, modulation modes, channel models, robustness and reliability issues • MAC changes • Mostly to support PHY needs • May want to visit time slotting features to ensure utility • Reliability and Robustness Jon Adams, Lilee Systems

8. Current Spectrum Usage by RR/Transits • No mandated spectrum for rail or PTC • Bands currently used by RR/Transit include • Licensed (all Part 90) • 44.56-44.60 MHz • 160.0-161.565 MHz • 452/457 MHz paired • 700 and 800 MHz trunked • 896-987 / 935-936 MHz paired • 928-952 MHz narrow band • License-free (all Part 15) • 902-928 MHz spread-spectrum, frequency hopping • 2400-2483.5 MHz spread spectrum Jon Adams, Lilee Systems

9. 216 – 222 MHz • A large amount of contiguous spectrum that may be underutilized (depending on your “ox”) • Operates under Part 80, 90, 95, and 97 rules • Constraints on use due to extant licensees and intended uses Jon Adams, Lilee Systems

10. Wireless Spectrum Review • Wireless spectrum in the US is a precious commodity • 216 – 222 MHz band, which is being targeted by the Class One railroads (BNSF, UP, CXS, NS) as home for PTC • Concern has already been raised that there’s not enough spectrum there to support all the users that may need PTC • 220 – 222 MHz band is a general land-mobile service band that was established in the late 1980s for “super-narrow” band voice and data services. As such, the channelization for the band was set at 5 kHz, which at the time was extremely challenging from an implementation point of view. • The freight and passenger rail entities, and municipal/regional rail transit authorities, also use existing, licensed frequencies in the 160, 450, 800 and 900 MHz spectrum regions. • There is the adjacent 216 - 217 MHz, paired 217 – 218 and 219 – 220 MHz spectrum, under FCC part 80, allocated around 15 years ago for the Automated Maritime Telecommunications System (AMTS). The idea behind AMTS was to enable communications service providers to supply both voice- and data-communications to maritime users on all inland waterways, and those along the US coast inside the 12-mile limit. The rules were written such that the spectrum could be used in Part 90 Land Mobile Radio (LMR) Service systems so long as the LMR systems avoid interference to AMTS stations. As a result, this spectrum may be useful for freight, passenger or transit rail entities that are away from inland waterways or coastal regions. The 25 kHz channelization is different from that of the 220 – 222 MHz band, and as such is subject to the FCC’s Narrowbanding mandate, due to go into effect in 2013. Jon Adams, Lilee Systems

11. Part 95 Uses (“10-4 Gud Buddy”) • Part 95 Personal Radio Service (home of Citizen’s Band Radio Service) specifies the use of two different segments in the spectrum adjacent to the 220 MHz band • Low Power Radio Service (Part 95 subpart G) at 216 – 217 MHz • 260 channels spaced at 5 kHz intervals • Transmitters may operate at ERPs as high as 500mW • Does not require licensing by location • Possibility of itinerant users in proximity to transit or rail facilities must be considered • (Part 95, subpart F) 218 – 219 MHz • Allows for fixed and mobile stations. • Base stations, called Cell Transmitter Stations (CTS), have power outputs up to 20 W ERP • Licensing by Economic Area region Jon Adams, Lilee Systems

12. Don’t Forget about KCOP (Ch 13) • 216 - 222 MHz is adjacent to broadcasting TV channel 13 (210 – 216 MHz) • Existing channel 13 broadcaster has an antenna at significant height above average terrain, transmitting with an equivalent radiated power (ERP) of 50 kilowatts or more • Since railroad right of way and TV broadcasting tower are generally both legacy installations, the new PTC installation will have little chance to cause either operator to relocate • Special caution required to prevent nearby powerful TV transmitter from blocking PTC receiver Jon Adams, Lilee Systems

13. Oh, and Did I mention TV White Spaces? • US FCC TV White Space Ruling • In place as of Jan 2011 • Allows license-free transmitters to use with limited coordination any TV channel not occupied by an existing broadcaster or other protected use Jon Adams, Lilee Systems