**Before the**

**Federal Communications Commission**

**Washington, D.C. 20554**

In the Matter of )

)

Inquiry Regarding Software Defined Radios ) ET Docket No. 00-47

)

)

**NOTICE OF INQUIRY**

**Adopted: March 17, 2000 Released: March 21, 2000**

By the Commission: Commissioner Ness issuing separate statement.

**Comment date:** **\[75 days from publication in Federal Register\]**

**Reply comment date:** **\[105 days from publication in Federal
Register\]**

**INTRODUCTION**

1.  Number range level0Number range level1Number range level2Number
    range level3Number range level4Number range level5Number range
    level6Number range level7The Commission is initiating this inquiry
    to obtain comments from the public on a variety of issues related to
    software defined radios. Software defined radios could offer
    tremendous advantages to consumers over currently available wireless
    equipment. These benefits include lower cost, a greater variety of
    features, and the ability to adapt to multiple communication
    standards. They could also offer advantages to manufacturers, such
    as increased economies of scale in production, increased worldwide
    market opportunities, and a decrease in the number of devices that
    must be maintained in inventory. Software defined radios could
    expand access to broadband communications for all persons and
    increase competition among telecommunication service providers.
    Through this inquiry, we seek input to help us evaluate the current
    state of software defined radio technology, and to determine whether
    changes to the Commission's rules are necessary to facilitate the
    deployment of this technology. Upon review of the responses to this
    inquiry, we will determine whether to propose any changes to the
    rules.

BACKGROUND

2.  The Commission has noted developments in the area of software
    defined radio with interest because this technology could have far
    reaching implications for the way the Commission allocates and
    licenses spectrum and authorized radio equipment. Software defined
    radios have the potential to vastly improve the efficiency of
    spectrum usage at a time when the demand for wireless communications
    services is rapidly increasing. They also have the potential to
    overcome some of the incompatibilities that exist between various
    communications services both domestically and worldwide.

3.  In a software defined radio, functions that were formerly carried
    out solely in hardware, such as the generation of the transmitted
    radio signal and the tuning and detection of the received radio
    signal, are performed by software residing in high-speed digital
    signal processors. The fact that these functions are carried out in
    software means that the radio can be programmed to transmit and
    receive over a wide range of frequencies and to emulate virtually
    any different desired transmission format. The operating parameters
    of such a radio can be readily altered in the field by a simple
    software change. For example, a software defined radio could have
    the ability to transmit and receive in the various cellular and PCS
    frequency bands and transmission standards used in the United States
    and around the world.

4.  Software defined radio technology was originally developed for the
    United States military. The "SPEAKeasy" project was undertaken by
    the Department of Defense with the goal of developing a multi-band,
    multi-mode software programmable radio that could allow different
    branches of the military to communicate in times of war. The first
    demonstration of a SPEAKeasy software programmable radio came in
    1995, and a smaller and more reliable version was developed for
    evaluation by the armed forces in 1997.[^1] The successful
    demonstration of the SPEAKeasy radio led a group of more than 50
    domestic and foreign companies to form the Modular Multifunction
    Information Transfer System (MMITS) Forum, later renamed the
    Software Defined Radio (SDR) Forum.[^2] The goals of the SDR Forum
    are to accelerate the development, deployment and use of software
    defined radios, and to work toward the adoption of an open
    architecture for the equipment. This open architecture would allow
    different manufacturers to make software for radio equipment, just
    as different manufacturers make software for personal computers.

5.  The FCC Technological Advisory Council (TAC) has also been studying
    issues related to software defined radio. The Commission established
    the TAC in 1998 to provide technical advice and to make
    recommendations on the issues and questions presented to it by the
    Commission.[^3] In May 1999, the TAC was requested to assess and
    report to the Commission the current state of the art for software
    defined radios, cognitive radios, and similar devices and, to the
    extent possible, predict future developments for these
    technologies.[^4] The TAC was also requested to suggest ways that
    the availability of such devices might affect the Commission's
    traditional approaches to spectrum management, as well as ways the
    agency could facilitate experimentation and commercial deployment of
    such devices.[^5]

6.  While the TAC is continuing their work in the area of software
    defined radios, we note that there are other parties that also have
    an interest in software defined radios. We believe it is important
    for the Commission to obtain input on the subject from all
    interested parties to ensure a widespread representation of
    viewpoints. We are therefore issuing this notice of inquiry seeking
    comment from the public on a number of issues related to software
    defined radios.

DISCUSSION

7.  The introduction of software defined radios could have wide ranging
    implications for radio technology and our regulatory policies.
    Software defined radios have the potential to change the way users
    can communicate across traditional services and to promote efficient
    use of spectrum. We believe that software defined radios could
    significantly affect a number of Commission functions, including
    spectrum allocation, spectrum assignment, and equipment approval.
    The purpose of this inquiry is to gather information on the state of
    software defined radio technology, interoperability issues, spectrum
    efficiency issues, equipment authorization processes, and other
    relevant issues.

8.  [State of software defined radio technology]{.underline}. With the
    advent of moderate cost microprocessor and phase locked loop
    frequency synthesizer technologies in the past two decades, many
    mobile radio systems now contain such technology for frequency
    control and power control. These radios have firmware[^6] installed
    at the factory that controls these functions, but it is not readily
    replaceable by the user. Thus these systems are a precursor to
    software defined radios and share some of their characteristics. By
    five years ago, the state of digital filter technology advanced to
    the point that a commercially available high performance high
    frequency (HF) band (1-30 MHz) receiver using digital filters for
    almost all its filtering and all of its demodulation functions
    became available. Extending this technology to higher frequencies,
    larger bandwidths, transmitter functionality, and lower cost systems
    also appears to be an evolutionary step.

9.  The SPEAKeasy project showed that a software defined radio is
    feasible. Nevertheless, there are many technological hurdles that
    must be overcome before software defined radios can be widely
    deployable. For example, there are limitations on the speed and
    dynamic range of current analog to digital converters, physical
    limitations on the frequency range over which an antenna can
    operate, and speed and cost constraints on digital signal processing
    circuitry. In addition, standards that would allow interoperability
    between hardware and software produced by different manufacturers
    are still under development. Therefore, in order to assist us in
    understanding the current state of software defined radio
    technology, we seek comment in the following areas.

### What features in a radio are apt to be controlled by software? For example, could the operating frequency, output power, and modulation format be software controlled?

-   What are the specific limitations of current software defined radio
    technology? What are the cost implications?

-   What capabilities could software defined radios have that are not
    found in current radio technology?

-   When could software defined radios be deployed commercially, and for
    what services or purposes?

-   What work is being done on software defined radios internationally,
    and are there any steps the Commission should take to encourage this
    work?

10. [Interoperability]{.underline}. The Commission's rules are divided
    up into a number of parts that contain the requirements for various
    licensed radio services.[^7] The rules for each service specify the
    operating frequencies and other technical requirements for radio
    equipment in that particular service. In some cases there is overlap
    between these frequencies and other requirements, so equipment can
    be developed to operate in more than one service. However, in most
    cases, equipment designed to operate in one service can not
    communicate with equipment designed to operate in another service,
    and in some cases can not even communicate with other equipment in
    the same service due to lack of common transmission standards or
    operating frequencies.

11. The inability of users to communicate due to non-uniform standards
    within services or between services can be a serious problem. For
    example, different public safety agencies responding to an emergency
    may be unable to communicate with each other due the inability to
    operate on each other's frequencies. The lack of common transmission
    standards can also cause problems in the commercial wireless
    services. For example, a handset designed to operate on a particular
    PCS system may not operate on another PCS system that uses different
    technology. Further, in the event the operator of a wireless system
    wants to change to a more efficient transmission system, the
    operator must replace all of the base stations transmitters and
    mobile units in the field, which can be a cumbersome and expensive
    process. The ability of software defined radios to change frequency
    and transmission standards would appear to be a way to overcome the
    lack of interoperability between different wireless systems. We are
    therefore asking for comment on the following questions.

-   To what extent can software defined radios improve interoperability
    between different public safety agencies?

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-   To what extent can software defined radios improve interoperability
    between equipment and services using differing transmission
    standards?

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-   To what extent would software defined radios move toward uniformity
    in standards within or across bands?

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-   To what extent can software defined radios be used to facilitate
    transitions from one technical standard to another, such as the
    transition mandated by the land mobile "refarming" proceeding?[^8]

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-   What particular means could be employed by software defined radios
    to facilitate interoperability?

12. ::: Definition-Term
    [Improving spectrum efficiency and spectrum sharing]{.underline}.
    The Commission allocates bands of spectrum to the various radio
    services in the rules, and maintains a table of these frequency
    allocations.[^9] In order to operate within a service, a license
    issued by the Commission is required.[^10] The rules for each
    service specify eligibility requirements for obtaining a license,
    and the technical requirements for operation, including location,
    power and frequency. Licenses may be issued through an application
    process, or through a competitive bidding process.
    :::

13. ::: Definition-Term
    In some cases, the service rules contain channelization requirements
    within the allocated bands, such as for the cellular service under
    Part 22 or the private land mobile services under Part 90.[^11] More
    recently, the Commission has declined to specify the channelization
    within an allocated band of spectrum and has simply specified the
    minimal technical requirements necessary to avoid interference
    between licensees. The licensed users are then permitted to
    determine the most efficient method of utilizing the spectrum. This
    approach is used in a number of different services, such as the
    Personal Communication Service under Part 24 and the Wireless
    Communication Service under Part 27.[^12]
    :::

14. Because of the ability to be easily reprogrammed, a software defined
    radio would not be limited to operation within a single fixed
    frequency band or on a limited set of pre-programmed channels. It
    could have the capability of operating on any frequency within the
    limits of its design, and could operate on channels of varying
    widths with varying modulation formats. Further, it should be
    possible to design the equipment with some "intelligence," which
    would let it monitor the spectrum to detect usage by other parties
    and transmit on open frequencies. These capabilities could open up
    new possibilities in the area of spectrum allocation and licensing.
    For example, instead of relying upon a user to find an open
    frequency in a congested area of spectrum before transmitting, a
    radio could monitor a wide range of spectrum and find a "hole" with
    sufficient bandwidth where the user could operate.

15. The use of software defined radios may also enable new types of
    spectrum sharing that are currently precluded by today\'s
    conventional equipment. For example, our PCS rules permit wide
    flexibility in terms of the services offered and technology employed
    in the PCS spectrum.[^13] In the event that a PCS licensee has
    spectrum available in excess of its immediate needs, it could lease
    that spectrum on a short-term basis to a third party. Software
    defined radio could facilitate such sharing. A third party could,
    for example, acquire from a manufacturer software defined radio
    equipment capable of being configured to offer different services in
    the various frequency ranges. Having negotiated for spectrum use, it
    would be in a position to rent a package of equipment and
    \"airtime\" to end users needing communications capacity on a
    short-term basis.[^14] It would load the appropriate software to
    properly configure the equipment at the time the end user enters
    into the rental agreement. Another alternative would be for the end
    user to contract directly with the licensee for the necessary
    spectrum and then rent the properly configured software defined
    radio equipment. With today\'s technology, such short-term sharing
    is difficult or impossible to accomplish due to the difficulties
    associated with quickly configuring radios for different
    applications in novel spectrum configurations. As a result, we
    believe that significant public benefits might flow from software
    defined radio technology. The public benefits include increased
    communications capacity for end users and better utilization of the
    spectrum resource. We seek comments regarding these potential
    benefits and what regulatory steps we might take to permit the use
    of software defined radios to enable such sharing arrangements.

16. In a slightly different sharing scenario, the licensee of a block of
    spectrum that is not fully utilized might negotiate with a second
    party to permit the use of a portion of the spectrum at times when
    it is available. The licensee could use a beacon system to ensure
    that it has primary access to the spectrum. Under such a system the
    primary user transmits a beacon signal when the band is available
    for use by the second user. The second user's transmitters must
    check for the presence of the beacon signal continuously and must
    immediately cease use of the block if the beacon signal disappears.
    These checking/cessation capabilities within software defined radios
    guarantee the primary user quick reliable access to the spectrum
    when needed. The shared spectrum is thus "interruptible". While
    interruptible spectrum is not appropriate for some applications, it
    may be appropriate for other applications, particularly those in
    which users are willing to pay less for less reliable service and in
    data applications where alternative transmission exists.

17. Functions such as the ones described in the previous paragraphs have
    the potential to allow spectrum to be utilized more efficiently. We
    are therefore seeking comment on the following areas related to
    frequency allocation and licensing.

-   To what extent could software defined radios improve the efficiency
    of spectrum usage?

-   What particular functions related to spectrum usage could a software
    defined radio perform? Could it locate free spectrum, dynamically
    allocate bandwidth, and enable better sharing of the spectrum?

-   How specifically could it carry out these functions?

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-   What are the benefits of the spectrum sharing arrangements described
    above, and what steps might we take to permit the use of software
    defined radios to enable such sharing arrangements?

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-   What changes may be appropriate for the way the Commission currently
    allocates spectrum?

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-   If changes are warranted, how could we make the transition from the
    current allocation and licensing model to a new model?

18. [Equipment approval process]{.underline}. Section 302 of the
    Communications Act of 1934, as amended, authorizes the Commission to
    make reasonable regulations, consistent with the public interest,
    governing the interference potential of equipment that emits radio
    frequency energy.[^15] The Commission carries out its
    responsibilities under this section by establishing technical
    regulations for transmitters and other equipment to minimize their
    potential for causing interference to radio services, and by
    administering an authorization program to ensure that equipment
    reaching the market complies with the technical requirements. The
    authorization program requires that equipment be tested either by
    the manufacturer or at a private test laboratory to ensure that it
    complies with the technical requirements. The majority of radio
    transmitters require the submission of an application that must be
    reviewed and approved before the equipment can be marketed,[^16]
    although certain transmitters may be authorized through a
    manufacturer's self-approval process.[^17]

19. A transmitter is approved to a specific set of technical parameters,
    including the operating frequencies, output power, and types of
    radio frequency emissions. If a manufacturer changes these
    parameters after a piece of equipment has been authorized, the FCC
    issues a new approval before the unit may be marketed with the
    changes.[^18] By design, the operating parameters of a software
    defined radio can be readily changed in the field by altering its
    software. Such a change could violate the terms of the transmitter's
    equipment authorization by causing it to operate in modes for which
    it has not been approved. Also, our rules do not allow parties other
    than the grantee of the equipment authorization to make
    modifications to approved equipment without obtaining a new
    approval.[^19] Even if a new approval were obtained by the original
    grantee, the rules require the modified transmitter to be labeled
    with a new FCC identification number,[^20] which would be
    impractical for software modification of equipment that is already
    in the field. We therefore seek comments on the following issues
    related to the authorization of software defined radio transmitters.

### Should we approve the radio hardware, the software or the combination of them?

### Are the currently required measurements in Part 2 of the rules appropriate for software defined radios?[^21]

### How should software defined radio equipment be tested for compliance, including compliance with SAR requirements?[^22] What type of approval process and labeling would be appropriate?

### Should we regulate who changes the software and the manner in which it is done? If so, should the Commission maintain records of such modifications?

-   What are the various means that may be used to download new
    software? We anticipate, for example, that software could be
    downloaded by methods such as direct connection to a programming
    device or over the airwaves. To what extent will the software
    interfaces be standardized?

### Should we require anti-tampering or other security features? How would such security features work? Could equipment be designed to prevent it from transmitting in certain designated frequency bands, such as those allocated exclusively for government use, as a safeguard against causing interference?

-   Do we need to adopt additional requirements for software defined
    radios to ensure the privacy of users' communications?

20. One possible scenario for an approval process for software defined
    radios could be as follows. The software could be tested and
    approved to ensure that the transmitter meets the applicable
    technical requirements under all operating conditions. In order to
    ensure that untested and unapproved software could not be loaded,
    such transmitters would have an authentication system that checks
    the software for an authentication code added to it by the FCC or a
    Telecommunications Certification Body (TCB). The software itself
    would be submitted for approval in a process similar to today's
    application process except that a copy of the object code would be
    supplied in machine-readable form. Upon approving the software
    application, which would involve a test of the hardware and software
    together similar to today's tests, the FCC or TCB would compute the
    authentication code for the submitted source code and send it to the
    applicant. The authentication system would be a two key system in
    which the key needed to compute the authentication code would be
    known to only the FCC or TCB, and the key needed to check in a
    transmitter object code which is being loaded would be publicly
    available.[^23]

21. In an analogy to the current requirement for labeling a
    transmitter[^24], there may be a need for a method to allow users to
    determine whether the desired operating software is currently loaded
    in a transmitter, and to allow Commission enforcement personnel to
    verify that the software has been approved. To meet this need, the
    transmitter could display information about the software installed
    by a means such as a liquid crystal display (LCD) screen in response
    to an input from a keypad. The identification information about the
    software installed in the radio could include such information as
    the technical operating parameters, the source of the software, and
    the name of the body that approved it. The user manual and the
    authorization application would describe how to access this
    information. Since such radios are expected to have displays for
    user information and input mechanisms for the user in normal use, we
    do not think this requirement would be burdensome. We seek comments
    on the following questions about this possible approval method.

-   Is there a need for such an approval system, and is it feasible and
    practical?

###  {#section .unnumbered}

### What type of authentication system should be used? Should there be one system or alternative systems? Who should have responsibility for generating the authentication codes: the FCC, TCBs, equipment manufacturers, or some other party?

-   In the case of transmitters subject to verification how should
    authentication of software be handled? For example, could an
    "authentication only" service be offered in which the FCC or TCB
    computes the authentication code for the software after all elements
    of compliance with the FCC rules are verified by the manufacturer?

-   How should simple changes to software be handled that do not affect
    the operating parameters of the equipment but require the
    computation of a new authentication code?[^25] Could an
    "authentication only" service be offered for them?

-   Is there a need for a method to display information about the
    software loaded in a transmitter? If so, what method should be used
    and what information should be displayed?

22. [Other matters]{.underline}. The questions raised in this notice are
    intended to solicit information to assist the Commission in deciding
    whether to propose rule changes as a result of the developing
    software defined radio technology. We realize that these questions
    do not necessarily encompass all of the issues raised by this
    technology. For example, commenters may want to address whether
    software defined radio technology could help parties comply with
    Sections 255 and 251(a) of the Communications Act. These sections
    require manufacturers of telecommunications equipment and providers
    of telecommunications services to ensure that such equipment and
    services are accessible to persons with disabilities, if readily
    achievable.[^26] Commenters may also wish to address how we would
    enforce any new rules for software defined radios. Accordingly,
    comments are invited on any other matters or issues that may be
    pertinent to software defined radios.

PROCEDURAL MATTERS

23. This is an exempt notice and comment rule making proceeding. *Ex
    parte* presentations are permitted, except during any Sunshine
    Agenda period. *See generally* 47 C.F.R. §§ 1.1200(a), 1.1203, and
    1.1204(b).

24. Pursuant to Sections 1.415 and 1.419 of the Commission\'s rules, 47
    C.F.R. §§ 1.415, 1.419, interested parties may file comments on
    before **\[75 days after publication in the Federal Register\]**,
    and reply comments on or before **\[105 days after publication in
    the Federal Register\]**. Comments may be filed using the
    Commission\'s Electronic Comment Filing System (ECFS) or by filing
    paper copies. *See Electronic Filing of Documents in Rulemaking
    Proceedings*, 63 Fed. Reg. 24,121 (1998).

25. Comments filed through the ECFS can be sent as an electronic file
    via the Internet at \<http://www.fcc.gov/e-file/ecfs.html\>.
    Generally, only one copy of an electronic submission must be filed.
    If multiple docket or rulemaking numbers appear in the caption of
    this proceeding, however, commenters must transmit one electronic
    copy of the comments to each docket or rulemaking number referenced
    in the caption. In completing the transmittal screen, commenters
    should include their full name, Postal Service mailing address, and
    the applicable docket or rulemaking number. Parties may also submit
    an electronic comment by Internet e-mail. To get filing instructions
    for e-mail comments, commenters should send an e-mail to
    ecfs@fcc.gov, and should include the following words in the body of
    the message, \"get form \<your e-mail address\>.\" A sample form and
    directions will be sent in reply.

26. Parties who choose to file by paper must file an original and four
    copies of each filing. If more than one docket or rulemaking number
    appear in the caption of this proceeding, commenters must submit two
    additional copies for each additional docket or rulemaking number.
    All filings must be sent to the Commission\'s Secretary, Magalie
    Roman Salas, Office of the Secretary, Federal Communications
    Commission, The Portals, 445 Twelfth Street, S.W., Room TW‑A325,
    Washington, D.C. 20554.

27. Parties who choose to file by paper should also submit their
    comments on diskette. These diskettes should be submitted to:
    Hugh L. Van Tuyl, Office of Engineering and Technology, Federal
    Communications Commission, The Portals, 445 Twelfth Street, S.W.,
    Room 7-A133, Washington, D.C. 20554. Such a submission should be on
    a 3.5 inch diskette formatted in an IBM compatible format using Word
    for Windows or compatible software. The diskette should be
    accompanied by a cover letter and should be submitted in \"read
    only\" mode. The diskette should be clearly labeled with the
    commenter\'s name, proceeding (including the lead docket number, in
    this case ET Docket No. 00-47, type of pleading (comment or reply
    comment), date of submission, and the name of the electronic file on
    the diskette. The label should also include the following phrase
    \"Disk Copy - Not an Original.\" Each diskette should contain only
    one party\'s pleadings, preferably in a single electronic file. In
    addition, commenters must send diskette copies to the Commission\'s
    copy contractor, International Transcription Service, Inc., 1231
    20th Street, N.W., Washington, D.C. 20037.

28. Comments and reply comments will be available for public inspection
    during regular business hours in the Reference Information Center
    (Room CY-A257) of the Federal Communications Commission, The
    Portals, 445 Twelfth Street, S.W., Washington, D.C. 20554. Copies of
    comments and reply comments are available through the Commission\'s
    duplicating contractor: International Transcription Service, Inc.
    (ITS, Inc.), 1231 20th Street, N.W., Washington, D.C. 20036, (202)
    857‑3800, TTY (202) 293‑8810.

29. Alternative formats (computer diskette, large print, audio cassette
    and Braille) are available to persons with disabilities by
    contacting the Consumer Information Bureau, Consumer Education
    Office at (202) 418-2514, TTY (202) 418-2555, or at fccinfo@fcc.gov.
    The *Notice* can also be downloaded at: www.fcc.gov/dtf/.

30. IT IS ORDERED, that pursuant to Sections 4(i), 301, 302, 303(e),
    303(f), 303(r), 307 and 332(b) of the Communications Act of 1934, as
    amended, 47 U.S.C. Sections 154(i), 301, 302, 303(e), 303(f),
    303(r), 307 and 332(b), this Notice Inquiry is hereby ADOPTED.

31. For further information regarding this Notice of Inquiry, contact
    Mr. Hugh L. Van Tuyl, Office of Engineering and Technology, (202)
    418-7506.

    FEDERAL COMMUNICATIONS COMMISSION

    Magalie Roman Salas

Secretary

**Separate Statement of Commissioner Susan Ness**

# *Re: Inquiry Regarding Software Defined Radios* {#re-inquiry-regarding-software-defined-radios .unnumbered}

I am bullish about the prospect of "software defined radio" (SDR), a new
generation of technology that potentially will allow communications
equipment to adapt to multiple standards and add service features
without changes to the equipment's hardware. The Notice of Inquiry we
release today is both a culmination of efforts and the beginning of a
new initiative. While work still lies ahead, SDR holds the potential to
enhance our participation in the global economy, to access new services,
and to utilize the spectrum more efficiently.

The Notice is the outgrowth of efforts by the Department of Defense
(DOD), members of the SDR Forum, and the FCC's Technical Advisory
Council (TAC). DOD and members of the SDR Forum have pioneered the first
generation of SDR, seeking to generate equipment that can be programmed
to transmit and receive on any frequency within a wide range using a
variety of transmission formats. The FCC has held several forums on new
technologies and spectrum use, at which the potential benefits of SDR
technology have been demonstrated. The TAC has reviewed SDR technology
over the past year, studying the ways in which this technology may
assist us in managing our precious resource -- spectrum. This Notice is
the result of such study. Hopefully, it will launch us in the direction
of new products that better serve consumers; these products can be
governed by streamlined rules that place the products in the marketplace
more rapidly.

As a consumer, I am excited about SDR because it has the potential to
add new meaning to the words "anywhere, anytime." As envisioned, SDR
devices can be adapted to work anywhere on the planet through software
changes or upgrades that can be installed or downloaded from remote
locations. Such devices also could download new service applications as
they are developed and made available.

As a spectrum manager, I am excited about SDR because it augments the
tools we have to more efficiently manage spectrum. Today, we struggle to
squeeze multiple services into spectrum, or to mandate specific
standards to permit communications devices to work seamlessly. With SDR,
the software could make such decisions, not the FCC. The availability of
such software also might make it easier for different users to share
crowded spectrum. Of course, protection of other spectrum licensees from
interference resulting from SDR devices is paramount.

Given the promise of SDR, it is my hope that industry participants will
help us address the complex issues raised in the Notice, so that we can
move quickly to make any necessary changes in our rules. I am
particularly interested in ways that we might revamp or streamline our
equipment approval process to accommodate SDR. Any rules that would
enable new and innovative products to reach the marketplace more quickly
without compromising safety and interference protection for existing
services would most certainly serve the public interest.

[^1]: *See 'SPEAKeasy' Reduces Equipment / Logistics Requirements --
    Increases Interoperability*, available at
    <http://www.afrl.af.mil/successstories/emerg_tech/>.

[^2]: The SDR Forum's Internet address is
    [www.sdrforum.org](http://www.sdrforum.org/).

[^3]: *See Public Notice, FCC Requests Nominations for Membership on the
    Technological Advisory Council*, released December 1, 1998,
    available at
    [www.fcc.gov/Bureaus/Engineering_Technology/Public_Notices/1998/pnet8024.html](http://www.fcc.gov/Bureaus/Engineering_Technology/Public_Notices/1998/pnet8024.html).
    The TAC consists of 25 individuals from industry and academia, plus
    a designated Federal Officer.

[^4]: *See Official Requests from the Federal Communications Commission
    to the Technological Advisory Council*, dated May 26, 1999,
    available at
    [www.fcc.gov/oet/tac/requests.pdf](http://www.fcc.gov/oet/tac/requests.pdf).

[^5]: *See*
    [www.fcc.gov/oet/tac/focusgroups.html](http://www.fcc.gov/oet/tac/focusgroups.html)
    for further information about the work of the TAC on software
    defined radio, including links to papers and presentations submitted
    to the TAC.

[^6]: Firmware is software installed in a device, which is typically
    stored in a read only memory (ROM) or a programmable read only
    memory (PROM).

[^7]: *See* 47 C.F.R. Part 5 - *Experimental radio service*, Part 20 -
    *Commercial mobile radio services*, Part 21 - *Domestic public fixed
    radio services*, Part 22 - *Public mobile services*, Part 23 -
    *International fixed public radiocommunication services*, Part 24 -
    *Personal communications services*, Part 25 - *Satellite
    communications*, Part 26 - *General wireless communication service*,
    Part 27 - *Wireless communications service*, Part 73 - *Radio
    broadcast services*, Part 74 - *Experimental radio, auxiliary,
    special broadcast and other program distributional services*, Part
    78 - *Cable television relay service*, Part 80 - *Stations in the
    maritime services*, Part 87 - *Aviation services*, Part 90 -
    *Private land mobile radio services*, Part 95 - *Personal radio
    services*, Part 97 - *Amateur radio service*, Part 100 - *Direct
    broadcast satellite service*, and Part 101 - *Fixed microwave
    services*.

[^8]: In the land mobile "refarming" proceeding, the Commission mandated
    that the channel spacing in the private land mobile bands be reduced
    from 25 kHz to 12.5 kHz, then to 6.25 kHz. *See* Replacement of Part
    90 by Part 88 to Revise the Private Land Mobile Radio Services and
    Modify the Policies Governing Them and Examination of Exclusivity
    and Frequency Assignment Policies of the Private Land Mobile Radio
    Services, PR Docket 92-235, *Report and Order and Further Notice of
    Proposed Rule Making*, 10 FCC Rcd 10076 (1995).

[^9]: *See* 47 C.F.R. § 2.106.

[^10]: *See* 47 U.S.C. § 301. Certain services are "licensed by rule"
    and are exempt from the general licensing requirement, but operation
    in these services must still meet the applicable eligibility and
    technical requirements. *See* 47 U.S.C. § 307(e).

[^11]: *See* 47 C.F.R. §§ 22.905 and 90.20.

[^12]: *See* 47 C.F.R. §§ 24.129, 24.249 and 27.5.

[^13]: *See* 47 C.F.R. § 24.3 (allowing PCS licensees to provide any
    mobile communications service and fixed service on a co-primary
    basis but prohibiting Broadcasting as defined by the Communications
    Act); *see also* 47 C.F.R. § 24.229-24.238 (minimal technical
    standards to prevent interference to other services with no
    requirements for channelization, bandwidth or transmission format).

[^14]: The spectrum may include segments from multiple licensees who
    have agreed to temporary use by another party.

[^15]: *See* 47 U.S.C. § 302(a).

[^16]: The Commission recently made changes to Part 2 of the rules that
    will allow designated private organizations, called
    Telecommunication Certification Bodies (TCBs), to approve equipment
    in the same manner as the Commission. *See Report and Order* in GEN
    Docket 98-68, 13 FCC Rcd 24687 (1999). As of this date, no TCBs have
    yet been designated to approve equipment.

[^17]: Certain types of transmitters operating under Parts 73, 74, 78,
    80, 87, 90 and 101 of the rules may be authorized under the
    verification procedure. *See* 47 C.F.R. §§ 73.1660(a), 74.655(f),
    78.107(a), 80.1103(a), 87.145(c)(4), 90.203(l) and 101.139(a).

[^18]: *See* 47 C.F.R. § 2.1043(a).

[^19]: *See* 47 C.F.R. § 2.1043(b)(3).

[^20]: *See* 47 C.F.R. § 2.925.

[^21]: Part 2 of the rules requires the following measurements on
    transmitters used in licensed services: RF power, modulation
    characteristics, occupied bandwidth, spurious emissions at antenna
    terminals, field strength of spurious emissions and frequency
    stability. *See* 47 C.F.R. §§ 2.1046 through 2.1055.

[^22]: For the purpose of safety, certain transmitters designed to
    operate within 20 cm of the user are subject to limits on the
    specific absorption rate (SAR) of radiofrequency energy by the body.
    *See* 47 C.F.R. § 2.1093.

[^23]: For further information on software authentication, see N.
    Doraswamy and D. Harris, IPSEC: The New Security Standard for the
    Internet, Intranets, and Virtual Private Networks, Prentice Hall,
    1999, p. 12-17 and Computer Science and Telecommunications Board,
    National Research Council, Trust in Cyberspace, National Academy
    Press, 1999, p. 122-126

[^24]: *See* 47 C.F.R. § 2.925.

[^25]: Under the current rules, changes to an approved device that do
    not affect the radiofrequency emissions are considered Class I
    permissive changes. No filing with the Commission or a TCB is
    required for a Class I permissive change. *See* 47 C.F.R. §
    2.1043(b).

[^26]: *See* 47 U.S.C. §§ 255 and 251(a)(2).