UWB: Getting Right A Watershed Decision

1
UWB Getting Right A Watershed Decision

• Presentation
• to
• CGSIC
• By
• F. Michael Swiek, Executive Director
• U.S. GPS Industry Council
• At
• Salt Lake City

2
UWB NPRM

• Asks the key question
• The real question or a Trojan Horse?
• Answered test data definitive
• Strategic Issue protect the noise floor
• Implications for GPS, PCS, DARS, other affected
  services

3
UWB NPRM (Continued)

• Industry coalition position
• FCC needs help
• Way forward strategic solution
• Users and agencies must engage to protect
  equities
• ( help the FCC)

4
UWB NPRM Question

• Under existing FCC Part 15 rules for consumer
  devices, does a UWB device qualify as an
  unintentional emitter?

5
UWB NPRM Question(Continued)

• Yes means
• UWB can operate across allocated services in 1-6
  GHz on a non-interfering basis
• Like a hairdryer
• But, for UWB this requires
• Watershed rule change removal of current
  restrictions against transmissions in restricted
  bands, including safety-of-life and GPS

6
UWB NPRM Question(Continued)

• No means
• New NPRM
• New strategic solution
• because spectrum overlay is
• - Not feasible
• Zero sum
• Not market-driven evolution but
  regulatory-driven destructive phenomenon

7
The Real Question Or A Trojan Horse?

• UWB, UWB GPRs, are Trojan horses for broader
  commercial pressures to gain unlicensed free
  spectrum
• More than stealth radio
• Label used to gain access to free spectrum for
  mobile internet
• 25 of center frequency or 500 MHz
• Any emerging ultra-wideband modulation technique,
  including
• OFDM or ultrawideband CDMA

8
The Real Question Or a Trojan Horse?(Continued)

• 3 GHz bandwidth at FCC Part 15 levels provides
  network range of 1 kilometer at 100 Kbaud
• Less than 10,000 UWB GPRs today
• Commercial utility is below 1 GHz
• Wireless device manufacturers seek new spectrum
• Intense pressure for free spectrum to create next
  IT wave - especially as 3G falters

9
NPRM Question Answered Test Data Is Definitive

• Test data shows UWB devices are intentional
  emitters under existing FCC Part 15 rules and
  operate at levels far below rule limits

10
Test Data Is Definitive UWB Devices Are Not
Part 15
11
Strategic Issue Preservation of the Noise
Floor

• UWB Trojan Horse below 6 GHz means
• Proliferation of competing, overlapping networks
  other than military pulse position modulation
• High probability of commercial exploitation means
  the noise floor threat is real
• Loss of control of the noise floor

12
Strategic Issue Preservation of the Noise
Floor(Continued)

• To date, device manufacturers are unable to
  manage the noise floor through self-regulation in
  license-free bands (eg. 2.4 GHz)
• Once the noise floor is damaged, there is no
  recovery
• SHARING EXPERIMENTATION IS NOT FEASIBLE DUE TO
  UNBOUNDED RISK
• Precedent of untested transmissions into
  restricted bands

13
FCC Rule on UWB Implications for GPS Other
Services

• FCC rule allowing UWB use below 6 GHz will
  either
• Put spectrum foundation of GPS positioning
  timing infrastructure (safety-of-life, national
  security and commerce) existing wireless
  infrastructure at risk
• OR
• Protect spectrum foundation of GPS positioning
  timing wireless infrastructure
• Rule will set standards for global action at WRC

14
National PriorityProtect Spectrum Foundation
of GPS Existing Wireless Services

• U.S. must preserve existing FCC Part 15
  restrictions prohibiting intentional transmission
  in, or across, the GPS band
• Slows rise in the noise floor
• Preserves military options
• Noise floor rise imposes new costs on civilians
  and military
• GPS evolving applications operate below the noise
  floor
• Also, PCS and others

15
ITU Recognized Sharing with GPS Is Not Feasible

• At WRC 2000, ITU delegates requested specific
  language, excluding GPS frequency bands in both
  Resolutions proposing spectrum sharing with MSS,
  due to recognized extreme sensitivity of these
  bands
• Preserve ITU ARNS designation for safety-of-life
  use

16
Industry (Below 6 GHz) Coalition

• Air Transport Association of America, Inc.
  Aircraft Owners and Pilots Association
• ARINC ARRL, The National Assoc. for Amateur
  Radio Astrolink International
• ATT Wireless Services, Inc. Ellipso, Inc.
  Ericsson Inc Garmin International,
  Inc.
• General Aviation Manufacturers Association
  LocatorNet Lockheed Martin Corporation
• Magellan Corporation Motorola, Inc.
  National Business Aviation Association

17
Industry (Below 6 GHz) Coalition

• Nokia, Inc. Nortel Networks, Inc.
• Omnistar, Inc Outreach
• QUALCOMM Incorporated Rockwell Collins
  Satellite Industry Association
• SiRF Technology Sirius Satellite Radio
  Spatial Technologies Industry Association
• Sprint Corporation Trimble Navigation Ltd.
  US GPS Industry Council
• WorldCom XM Radio Inc.

18
The Train Has Left the StationIndustry
Coalition Position

• test results to date demonstrate that such
  devices have unique transmission characteristics
  that produce intentional transmissions that cause
  significant harmful interference to GPS, other
  safety-of-life services, wireless services, such
  as PCS, as well as to satellite services, such as
  DARS
• Letter to FCC Chairman Powell, May 18, 2001

19
Industry Coalition Position(Continued)

• these tests show that other characteristics of
  the proposed UWB signals also vary greatly from
  the characteristics of unintentional emitters
• Consequently, the signatories recommend that UWB
  devices be limited to spectrum above 6 GHz, not
  be allowed to operate in any restricted band,
  including safety-of-life service bands, and be
  subject to a licensing regime separate and
  apart from Part 15

20
Legacy Spectrum Decision

• Balancing needs
• To provide unlicensed free spectrum for mobile
  internet and innovation
• To preserve commercial utility of allocated
  spectrum requiring predictable noise floor

21
Legacy Spectrum Decision(Continued)

• Balancing needs (continued)
• To preserve the safety of the spectrum foundation
  of the National Airspace (NAS), including GPS and
  bands restricted for safety-of-life
• To preserve secure spectrum for evolving national
  security needs military options, including GPS,
  com, satcom
• To protect the public interest

22
FCC Needs Help

• UWB decision will affect auctions
• Existing services claim exclusive rights in their
  allocation, including
• Mineral rights due to operations below the noise
  floor
• Expectation of the ability to manage the noise
  floor to preserve the commercial utility of their
  allocation to recoup their investment
• Right to assume purchase of usable land, not swamp

23
Way Forward A Strategic Solution

• Allow unlicensed UWB in a band segment above 6
  GHz providing
• Appoint a shared use band manager to ensure
  accountability for noise floor
• Any technology under the UWB label using this
  band on an unlicensed, free of charge basis will
  pay for noise floor studies compensation of
  performance degradation of authorized users

24
A Way Forward A Strategic Solution

• Band manager to undertake a comprehensive
  baseline study of noise floor
• Study to be peer reviewed (including government
  agencies, academia and others)
• Any increase in the noise floor causing
  performance degradation to existing services must
  pay to upgrade victim systems

25
Affected Users Must Engage To Protect Equities

• Government can promote innovation without
  compromising national security and safety
• Your self-interest in GPS existing services
  requires participation to focus NTIA FCC
  rule-making process to conduct this strategic
  experiment in an appropriate band segment
• Consequences can be permanent

26
Conclusion

• Support free spectrum for the mobile internet and
  the safe introduction of UWB technologies on a
  strategic experiment basis
• Avoid creating a Spectrum Super Fund Spectrum
  EPA