Report : Fifth Meeting of the FCC Technological Advisory Council

Executive Overview

The Federal Communications Commission Technological Advisory Council
(FCC TAC) held its fifth meeting on Wednesday, June 28, 2000 in
Washington, D.C. As described in previous meeting reports, the Council
is to provide scientifically supportable information on those emerging
technologies likely to fundamentally impact the work of the FCC. The TAC
is currently organized into three focus groups with moderators to
address: spectrum management; network interconnection and access; and
access to telecommunications by persons with disabilities. Each of these
groups reported out findings developed in the interim and expanded each
area during a roundtable discussion.

The Spectrum Management Focus Group is organized into three working
subgroups. The TAC previously accepted the recommendation from the
*noise environment* subgroup of a proposed noise study. The FCC fully
supports the objectives of the proposal and the TAC has decided to
solicit funding for a study some of the noise floor issues---most
importantly a review of the existing literature. Funds would be
collected from the organizations that the TAC members are associated
with, but the National Science Foundation (NSF) would handle the actual
project management and disbursements. It is our understanding that there
is no legal problem if money is solicited only from the TAC members.
Several TAC members have already indicated their willingness to
contribute. We have suggested \$10,000 per member, with a \$1000
minimum.

Weighing heavily on the decision to allow the approval of UWB (Ultra
Wideband), a spectral overlay technology, is a growing sense that there
is already excessive interference and congestion in the Part 15 bands.
The TAC *UWB subgroup* will determine if this is indeed true and try to
see if there are some possible solutions that could be recommended to
the FCC by the TAC. To set the stage for a comprehensive analysis, an
overview of some of the issues surrounding congestion in the Part 15
bands was presented.

The *software defined radio (SDR) subgroup* reminded us that we are now
waiting for replies to the SDR Notice of Inquiry (released by the FCC on
March 21, 2000). After analysis of the NOI contributions, it is
anticipated that it will first be necessary to delineate the rights and
responsibilities of SDRs -- what we have previously referred to as "Part
X" regulations --including a general philosophy of certification.
Introduction of SDRs will likely start as overlay devices in existing
bands, followed by domination by intelligent devices with widespread
multiband deployment.

Concern has been voiced over the harm that might be done to victim
receivers by UWB transmitters. Additionally, SDR transmitters require a
cooperating receiver. The noise floor only becomes an issue when it
interferes with a receiver. In light of all these issues, it was
instructive to look at the regulatory status of receivers relative to
that of transmitters and a review of receiver regulation was presented

As we move into an era of software defined *everything* we need to
construct operating principles that are derived from a somewhat higher
point of view than we have been considering up until now. We need a
"Bill of Rights" that would be the permanent basis for the governance of
all intelligent devices. The target is to create a document which, like
the original Bill, could remain relevant for hundreds of years. It would
anticipate a wireless-rich world with millions of wirelessly
interconnected appliances of various types. The group has begun the task
of identifying fundamental guiding principles so as to produce a
compelling one-page document, not a rule book. This is an ongoing
activity open to all who care to participate.

The Interconnection and Network Access Focus Group gave an overview of
the issues associated with Internet interconnection. The 1996 Telecom
Act requires "telecommunications service providers" to interconnect, but
Internet Service Providers (ISPs) are not currently subject to this
requirement. The question is: Do ISPs adequately interconnect today?
And, as QoS (quality of service) is introduced into the Internet, will
the largest ISPs have an economic incentive to interconnect for the
provision of QoS? The question for the FCC is whether the free market is
motivated to solve this problem or if intervention is needed. It is
risky to make rules before all of the key technologies are fully
developed. On the other hand, with so much of the economy being bet on
the Internet it is risky to be wrong on this issue. TAC must also
consider the possibility that transport will become so inexpensive that
the whole problem will vanish in the rising tide of massive capacity
improvement The TAC should act in an "early warning" mode on this issue.
To be sure that we are aware of the latest developments in this area, an
expert speaker will be invited to the next meeting to review the current
state of QoS and interconnection related technology.

Themes being addressed by the Access to Telecommunications by Persons
with Disabilities Focus group include exploring: how changing
technologies affect access for the disabled which the FCC is assigned to
address; the different types of assistive technologies (AT) and the
implications of compatibility; and whether or not the FCC from a
technical viewpoint can help facilitate the migration away from older,
legacy AT (such as TTY). The FCC must address the basic issue of whether
it is necessary to promulgate new regulations to require companies to
make their products and services accessible to people with disabilities,
and, if there are accessibility regulations which apply to a particular
technology, should the same regulations carry over to new technologies
as the new technologies evolve and take over the role of the old
technologies.

The next formal TAC meeting will be on Wednesday, September 27,2000.

Prepared by J. A. Bellisio

Approved by R.W. Lucky

August 1, 2000

**[Report: Fifth Meeting of the FCC Technological Advisory
Council]{.underline}**

1.0 Introduction

# As announced, the fifth meeting of the FCC TAC took place on Wednesday, June 28, 2000 at The Portals, 445 S. 12th Street, SW., Washington, D.C. Designated Federal Officer (DFO) David Farber opened the meeting. This report is a reorganization and distillation of discussions at that meeting written to facilitate the work of the Council. A complete videotape of the meeting serves as the verbatim minutes (see Annex 1).This report reviews the presentations and remarks made at the open meeting, but does not, per se, necessarily represent the final recommendations of the TAC as a whole.

The mission and operating principles of the TAC were described in the
Report of the First Meeting of the TAC (April 30, 1999), available on
the FCC web site <http://www.fcc.gov/oet/tac/> . As described in that
report, the FCC has made five official requests to the TAC for technical
work. These requests fall into three major areas: spectrum management;
network interconnection and access; and accessibility for disabled
persons. Focus groups with moderators were formed at the first meeting
to address each of the three areas. At this fifth meeting, the
activities of each of the groups was reviewed. The meeting's roundtable
discussion, which followed each presentation, and resulting action items
are also reported. Additional and more extensive information relative to
each of the working groups can be found on the web sites for those
groups. *See Annex 4.*

The next formal TAC meeting will be on Wednesday, September 27,2000. A
meeting has also been scheduled December 6, 2000.

2.0 Agenda

TECHNOLOGICAL ADVISORY COUNCIL

Agenda -Fifth Meeting

# **Wednesday, June28, 2000**

Federal Communications Commission Meeting Room

The Portals, 445 12TH Street, SW

Washington, D.C.

10:00 AM Opening and Remarks by DFO David Farber

> Designated Federal Officer

10:20 AM Introductions of Council Members Council Members

> with Brief Remarks (if any)

10:30 AM Report of Interconnection and Network Marvin Sirbu

> Access Focus Group

10:50 AM Access to Telecommunications by Persons with Gregg Vanderheiden

Disabilities Focus Group

11:40 AM Report of Ad-Hoc Group on Software

> Defined Radio "Bill of Rights" Bran Ferren

12:00 PM Break

1:00 PM Report of Spectrum Focus Group Chuck Jackson

2:00 PM Discussion of new Topics for Study Chair Bob Lucky

2:40 PM Assignments, Organization and Chair Bob Lucky

> Going Forward

3:00 PM Wrap Up - Meeting Adjourned David Farber

> Designated Federal Officer

3.0 Membership of the Technological Advisory Council

Dr. Stagg Newman is appointed as the newest member of the TAC. Dr.
Newman had served as the first DFO of the TAC. A short biography of Dr.
Newman is in *Annex 2*. The First Meeting Report contains biographies of
other members.

Except as indicated(\*), all of the following were present at the Fifth
Meeting:

***TAC Chairperson***:

Dr. Bob Lucky -- Corporate Vice President, Applied Research, Telcordia
Technologies

*Members of Council*:

\*Mr. Bruce Allan -- Vice President and General Manager, Harris
Corporation

\*Mr. Jose M. Alvarez Caban -- Assistive Technology Specialist, Puerto
Rico Assistive Technology Project, University of Puerto Rico

Dr.Jules A.Bellisio,*TAC Executive Director*, Chief Scientist and
Telcordia Fellow, Executive Director, Applied Research, Telcordia
Technologies

Dr. Vinton Cerf -- Senior Vice President, Internet Architecture and
Technology, MCI Worldcom

Ms. Susan Estrada -- President and CEO, Aldea Communication

Mr. Bran Ferren -- President, Applied Minds

\*Dr. Richard Green -- President and CEO, CableLabs

\*Ms. Christine Hemrick - Vice President, Technology Communications,
Office of the CTO, Cisco Systems, Inc.

Mr. Dewayne Hendricks -- CEO - Dandin Group

Mr. Ross Ireland -- Vice President -- Engineering, SBC.

Dr. Charles E. Jackson -- Independent consultant.

Mr. Kalle Kontson -- Division Technology Manager, Center for
Electromagnetic Science and Vice President IIT Research Institute

Dr. William Lee -- Chief Scientist, AirTouch / Vodaphone.

Dr. Paul Liao -- Chief Technology Officer, Panasonic and President of
Panasonic Technologies.

Dr. Wah Lim --Vice President, Corporate Technology and Ventures, Hughes
Electronics Corporation

Dr. Robert Martin -- Chief Technology Officer of Bell Labs, Lucent.

\*Dr. David Nagel -- President AT&T Labs and CTO for AT&T

Dr. Stagg Newman -- Senior Telecommunications Practice Expert, McKinsey
and Company

\*Mr. Glenn Reitmeier, Vice President, DTV and Web Media, Sarnoff
Laboratories.

Mr. Dennis Roberson -- Vice President & CTO, Motorola.

Dr. Marvin Sirbu -- Professor of Engineering and Public Policy,
Professor of Electrical & Computer Engineering, Professor -- Graduate
School of Industrial Administration, and Chairman of the Information
Networking Institute, Carnegie Mellon University.

Dr. Gregg Vanderheiden -- Professor -- Human factors Group, Dept. of
Industrial Engineering, University of Wisconsin, and Director of Trace
Research and Development Center.

\*Mr. Jack Waters -- Chief Technology Officer, Level 3 Communications.

Dr. Pat White - Senior Advisor, Safeguard Scientifics, Inc

Mr. Robert Zitter -- Senior Vice President, Technology Operations, Home
Box Office.

*Designated Federal Officer*

Mr. David Farber, Chief Technologist, Federal Communications Commission.

*Alternate Designated Federal Officer*

Mr. Dale Hatfield, Chief, Office of Engineering and Technology, Federal
Communications Commission.

\**Not present at fifth meeting.*

About 50 members of the public observed the meeting and comments from
the public are reported as appropriate.

4.0 Summary of Remarks by Representatives of the FCC

The Chair asked members of the Commission and TAC members to comment on
what they felt was the biggest technical problem facing their part of
the industry. Mr. David Farber, Chief Technologist, Federal
Communications Commission, in his introductory remarks listed among his
concerns: stability and security of the Internet; the adaptation of the
regulatory framework from its original, slow moving origins to one that
can work at speeds required today; the retention and training of people
in advanced computer science programs in the face of the strong
attraction of industry; and the related problem of faculty being drained
off into lucrative commercial enterprises.

Mr. Hatfield's top concerns were related to the scarcity of spectrum.
Mr. Sicker added that interconnection was a key issue.

4.1 Concerns of TAC Members

In response to the same general question from the Chair, members of the
TAC each described their single biggest current technical concern:

Zitter: Appropriate architecture for the next generation of television -
which we expect will be a system meant to be viewed as a customized
nonlinear stream in time.

White: The re-engagement of the dot-com economy

Vanderheiden: Communicating what we have learned (about access for the
disabled) with new companies just entering the field so that we can
avoid repeating the mistakes of the past.

Sirbu: Deciding which technology will be the most economical for
bringing broadband to the residence.

Roberson: Improving software productivity

Newman: Getting to the true high speed broadband Internet.

Martin: Quality of Service in packet networks.

Lim: Spectrum scarcity and must-carry rules.

Liao: Determining what consumers really want in their living rooms.

Kontson: Achieving the full potential of wireless technology in the face
of rapidly changing spectrum policies and regulations.

Ireland: Scaling new optical networks.

Hendricks: The scarcity of qualified technical people, especially in
Silicon Valley.

Ferren: Finding the appropriate business model for new companies
embracing new technology, and dealing with obsolete regulations.

Estrada: Solving the telecom problems of a small company in a geographic
area not equipped for full communications services.

Cerf: The scaling problems of making the Internet bigger.

Bellisio: The best way to build the large scale, high capacity, *mobile
wireless* Internet.

Lucky: The business model problem posed by the conundrum that most
traffic is data but most of the money is in voice.

5.0 Report of Interconnection and Network Access Focus Group

Marvin Sirbu gave an overview of the issues associated with access. With
respect to Internet interconnection, the '96 Telecom Act requires
"telecommunications service providers" to interconnect, but Internet
Service Providers (ISPs) are not currently subject to this requirement.
The question is: Do ISPs adequately interconnect today? And, as QoS
(quality of service) is introduced into the Internet, will the largest
ISPs have an economic incentive to interconnect for the provision of
QoS? Right now, there are over 5000 North American Internet Access
Providers (IAPs) who are regional or national, provide Internet access
to end user customers using dialup or leased lines, and are customers of
ISP Backbones. There are also 40 to 50 Tier 1 ISPs who , national or
international, interconnect with other ISPs at Network Access Points
(NAPs), (public NAPs or private bilateral peering points) and exchange
traffic without settlements.

![](media/image1.wmf){width="4.9in" height="3.1034722222222224in"}

Figure 1 - Internet Tiered Architecture

A current interconnection issue is that packet loss at peering points
seems to be substantially greater than within a backbone. In theory, the
larger ISPs have an incentive to degrade interconnection in order to
induce customers to connect to them directly. The evidence is a
substantial rise in the demand for multihoming, and the creation of
commercial "multihoming providers" such as Internap. Recently, major
banks have created group to pressure ISPs to resolve peering problems.

The industry is developing QoS technologies for the Internet based on
the "Differentiated Services" framework. Customers contract for specific
QoS profiles with policing at the network periphery. In Fig.2, each
"cloud" contracts for aggregate QoS traffic profiles, with policing at
cloud-cloud boundary. This supports simple, bilateral business
agreements.

SLA: Service Level Agreement

![](media/image2.wmf){width="5.479166666666667in"
height="2.1666666666666665in"}

*-Domains provide their customers with the service specified in SLA*

Figure 2 - Differentiated Service Architecture (Logical)

The Service Level Agreement (SLA) defines what forwarding service the
customer will receive. The Traffic Conditioning Agreement (TCA) defines
what the client must do to achieve the desired service and what the
service provider will do to enforce limits. The client may be another
service provider. At the current state of development, standards for
per--hop behaviors are well developed and appearing in router products,
but standards for bandwidth brokers and inter-domain QoS are lagging,
and there are no signaling standards or well developed business models.
It is virtually certain that intra-domain QoS will be introduced prior
to inter-domain. During the period when only intra-domain QoS exists,
the largest networks, offering greater network externality benefits,
will have a distinct advantage over smaller networks. The longer this
condition exists, the greater the risk of a tipping toward market
dominance by one or two providers. We might ask: Should the FCC monitor
the quality of interconnection by ISPs or jawbone the ISPs to move more
quickly on inter-domain QoS?

5.1 Interconnection and Network Access Group Discussion

Since frame relay has been defined as a telecommunications service, it
is interesting to see if interconnection is working better there. Vinton
Cerf remarked that this is very challenging to do in frame relay. When
customers are allowed to assign a QoS, there is little incentive for
them to choose anything but the best level unless there is strong
policing. We will probably see experimental QoS strategies introduced
into the intradomain environment first, because until operators know
exactly what is being traded, what the business models are, and it will
be less difficult to introduce brokering. On the positive side, lack of
firm definitions enhances good experimentation.

The question for the FCC is whether the free market is motivated to
solve this problem or if intervention is needed. It is risky to make
rules before all of the key technologies are fully developed. On the
other hand, with so much of the economy being bet on the Internet it is
risky to be wrong on this issue. We must also consider the possibility
that transport will become so inexpensive that the whole problem will
vanish in the rising tide of massive capacity improvement..

5.2 Interconnection and Network Access - *Action Items*

The TAC should act in an "early warning" mode on this issue. To be sure
that we are aware of the latest developments in this area, it is
requested that the group mediator invite an expert speaker to the next
meeting to review the current state of QoS and interconnection related
technology.

6.0 Report of Access to Telecommunications by Persons with Disabilities
Focus Group and Group Discussion

Gregg Vanderheiden organized his presentation around three themes:
(theme 1) how do changing technologies (technology advancements) affect
access for the disabled which the FCC is assigned to address; (theme 2)
what are the different types of assistive technologies (AT) and what
does compatibility imply; and (theme 3) can the FCC facilitate the
migration away from older, legacy AT (such as teletypewriters, TTY)? The
FCC must address the basic issue of whether it is necessary to
promulgate new regulations to require companies (or anyone) to make
their products and services accessible to people with disabilities, and,
if there are accessibility regulations which apply to a particular
technology, should the same regulations carry over to new technologies
as the new technologies evolve and take over the role of the old
technologies.(For example, should regulations which apply to PSTN
telephony also apply to IP telephony?) Should access regulations be
treated the same as competition regulations (or more like fraud or other
public good regulations)? Is it \"a level playing field\" to require
companies providing a service using one technology (e.g., PSTN) to
comply with accessibility rules that other companies, providing an
essentially identical service, using another technology (e.g., IP) are
not subject to?

There are fiscal implications of all policies. If current
telecommunication services contribute to a universal service fund (or to
purchase special equipment for people with disabilities), should the
same charges be applied to new technologies (e.g. IP telephony) or
should the charges only be paid by companies using the older technology
(e.g., PSTN)? Does this provide for a level cost playing field? If the
funds are only attached to older technologies, does that mean that the
fund would eventually dry up and go away? With the new technologies will
it be necessary for there to be a fund? Or will all users with
disabilities be able to fully communicate using standard technologies -
so no need for fund?

There are even more questions needing resolution. Are all types of
access equally important or are some types more important than others?
Is it politically and financially possible to migrate people using old
technologies (e.g. TTYs) to new emerging technologies to ease or
eliminate compatibility problems (at least in the long run)? What would
be required of the new technologies to do this? What could industry or
what could government do to facilitate this?

The group has come up with some preliminary conclusions:

The "readily achievable" concept or similar language is important to
separate what is doable for all products from what is difficult or very
difficult to do for standard products. Term "readily achievable" also
important for allowing innovation. Essentially it allows all innovation
to proceed and almost no innovation is blocked.

There are essentially three types of accessibility issues:

-   Product designs which interfere with the assistive technologies used
    by people with disabilities (especially when there isn't an
    alternative).

-   Product designs (features which are either present or absent) which
    would put people with disabilities further behind everyone else.
    (increase the gap)

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-   Product features which empower people with disabilities, that is,
    allow people with disabilities to do things with a phone that users
    ordinarily don't use a phone for such as controlling other devices,
    accessing labels on other products etc.

Everyone in the TAC subcommittee agreed that, although TTY's would
clearly fade into history some day, it would be useful to lay out a road
map for how this process might be facilitated so that the natural
migration process would proceed more quickly.

### 

### 6.1 Access to Telecommunications by Persons with Disabilities - *Action Items*

At the TAC meeting preliminary notes regarding the TTY migration topic
were presented. These will need to be considerably revised in
communication with stakeholders and others working in this area. A
working group is being formed to study and work on this topic. A series
of discussions with stakeholders is also being conducted. Persons
(including those who are not members of TAC) interested in participating
in the working group or participating in the stakeholder discussions
please contact Gregg Vanderheiden at <gv@trace.wisc.edu> or Jim Tobias
at <tobias@inclusive.com> .

7.0 The "Software Defined Radio Bill of Rights"

As described in the report of the previous meeting, Bran Ferren made a
crucial observation. As we move into an era of software defined
*everything*, an era where complexity and interaction are beyond the
grasp of most people, we need to construct operating principles that are
derived from a somewhat higher point of view than we have been
considering up until now. By analogy to the Federal Constitution which
provides a timeless and robust framework upon which all other laws can
be tested, we need a "Bill of Rights" that would be the permanent basis
for the governance of all intelligent devices. It would guide the
responsibilities, obligations, rights and behavior of such devices so as
to provide for both freedom of action and respect for the rights of
humans and of other like devices. We need a set of high-level,
overarching principles that describe how sophisticated equipment in
conjunction with their human or mechanical users should behave so as to
achieve the freedom and the equality of rights we desire.

A new ad-hoc focus group has been formed to address this concept, and
Bran reported on the work in progress. The intent is to keep the
thinking at a very high level and to use the real Bill of Rights and how
people interact in real life as models. The target is to create a
document which like the prototype, could remain relevant for hundreds of
years. It would anticipate a wireless-rich world with millions of
wirelessly interconnected appliances of various types. Uses with a
hierarchy of values to the public should be accommodated. As with human
interaction, the wireless radio equivalent of falsely shouting "fire"
should be prohibited.

The group has begun the task of identifying fundamental guiding
principles. Because this exercise is tied to technology, basic
properties of range and propagation will have to be taken into account.
Similarly, because we are moving to a software defined environment where
over-the-air reprogramming is feasible, the whole importance of
grandfathering legacy devices must be revisited. It may be possible to
simply require that existing equipment reconfigure by download to new
rules or waveforms.

7.1 Bill of Rights Initiative *-- Action Items*

The objective of this activity is to produce a compelling one-page
document, not a rule book. This is an ongoing activity open to all who
care to participate. Persons interested in supporting this activity
should contact either Bran Ferren (
[bran@appliedminds.net](../bran@appliedminds.net) ) or the TAC Executive
Director ( <jules@research.telcordia.com> ). Bran should arrange to have
a website for this group.

8.0 Report of Spectrum Focus Group and Group Discussion

Since the last meeting, a solution has been found to the funding and
management issues associated with the noise floor study proposed and
described in previous reports. According to advice received from FCC
counsel, it appears to be both legal and appropriate for members of the
TAC or the organizations which they represent to contribute to a fund to
support the noise study. At this time, we can not recommend accepting
money from entities other than those mentioned above. It is also
proposed that the NSF (National Science Foundation) be engaged to both
handle the money and act in a review capacity for the project. It is our
understanding that the NSF can act quickly in this process and will can
also arrange for the scientific peer review of the results. More details
of this activity will be given below.

Chuck Jackson introduced the reports produced by the Spectrum Management
Working Group which are summarized here. The Group is divided into three
working subgroups, and the roundtable discussion of the meeting was
organized around each of these areas. Full versions of the presentation
visuals can be found at
<http://www.jacksons.net/tac/#June28Presentations>. The first
presentation was review of receiver regulation by Charles (Chuck)
Jackson.

**8.1 A Review of Receiver Regulation**

Concern has been voiced over the harm that might be done to victim
receivers by UWB transmitters. Additionally, SDR transmitters require a
cooperating receiver. The noise floor only becomes an issue when it
interacts with a receiver. In light of these situations, it is
instructive to look at the *regulatory status* of receivers relative to
that of transmitters.

According to a theorem attributable to Coase, "Property rights and easy
negotiations (zero transactions costs) result in efficient outcomes."
[^1] But the problems are joint with transmitters and receivers. We
observe, no receivers, no problems or, equivalently, no transmitters, no
problems! Despite the fact that interference requires *both*
transmitters and receivers, the FCC regulates transmitters extensively
and receivers hardly at all. Similarly, the EPA regulates smokestacks
but not lungs. The design of lungs was frozen some time ago, but the
configuration of radio receivers is still evolving and amenable to
control.

Historically, most regulation to control interference has focused on
transmitters. Transmitter regulation is significant in most radio
services. For example, we have limits on total power, specified
modulation, specified frequency, and limits on out-of-band energy. In
contrast, FCC regulation of receivers has been quite limited. In
comparing this with other recommendations in the same area, we find that
the NTIA has promulgated its own receiver standards. For selectivity,
NTIA specifies that the passband be no greater than the authorized
bandwidth of emission and that the selectivity characteristic outside
the passband roll off at at least 100 dB/kHz. NTIA conforming equipment
also must be capable of operation on any frequency within its tuning
range (or 100Hz multiples with a synthesizer). For Federal government
radio systems and civil receivers, we find that government systems can
legally interfere with co- or adjacent-channel civil systems. Even if
such civil systems are theoretically secondary or suffer interference
due to poor receiver selectivity, the outcome is often that the
government system must adjust (i.e., voters trump bureaucrats).

For completeness, we cite a Korean Statute: (Standards for Prevention of
Electromagnetic Interference, etc.) -- "The standards for preventing any
electromagnetic interference by apparatus that causes the
electromagnetic interference (hereinafter referred to as \"apparatus
causing electromagnetic interference\") and those for protection from
electromagnetic waves of apparatus influenced by electromagnetic waves
shall be prescribed by the Ordinance of the Ministry of Information and
Communication." The European Radiocommunications Committee (ERC) in
Recommendation (00)06 for Receiver Parameters says: "Where justified,
administrations should seek to get receiver parameter limits included as
essential parameters in harmonised standards or in national regulated
interface specifications on a case by case basis ..." But by contrast
Industry Canada now says that with the exception of receiver spurious
emissions, receiver standards are *no longer part of the RSS* (Receiver
Standards Specification).

The issues that must be considered in the design of a receiver include
connectivity, interoperability, privacy, performance, interference
susceptibility and efficient spectrum use.

There are existing rules covering many of these items:

-   FCC Receiver Regulation: Connectivity/Interoperability

-   Competition: Sections 314 and 322 of the '34 ACT

-   Interconnection: Maritime watch requirements (section 355)

-   Section 624A (CE Compatibility)

-   Cable Television (CATV)

-   FCC Receiver Regulation: Privacy

-   Section 705, Prohibitions on receiving messages meant for others

-   Section 302(d), Prohibition of cellular scanners

-   FCC Receiver Regulation: Performance

-   All-channel receiver act

-   Sections 303(s) and 330

-   CUB petition on UHF Noise Figure/Attached Antennas

-   FCC adopted specific rules

-   Closed captioning

-   V-Chip

-   FCC Receiver Regulation: Interference Susceptibility

-   Interference\--302(b)(2) establishing minimum performance standards
    for home electronic equipment and systems to reduce their
    susceptibility to interference from radio frequency energy.

-   FCC Inquiry on CB Interference to TV

-   General Docket No. 78-369

-   Staff report

-   Mandatory standards

-   Voluntary standards

-   Combined transmitter/receiver liability

-   Other transmitter liability

-   Labeling

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-   FCC Receiver Regulation: Efficient Spectrum Use and Repacking

-   Better receivers allow squeezing in more service

-   Incentive problem

-   What are the incentives for adopting more spectrum-efficient
    receivers?

There are many examples of problems where it is not clear where the most
appropriate solution lies. Many hearing aids act as inadvertent
receivers of TDMA cellular and PCS transmissions. Is the problem due to
the radio transmitter or the design of the hearing aid? There are also
examples of the impact of policy. We see repacking being applied to
television with respect to UHF Taboos and the digital TV transition, in
audio broadcasting, in the closer spacing of C-band satellites ( from 4
degree to 2 degree spacing), in refarming in traditional land mobile,
and in Cellular/PCS.

There needs to be a proper set of incentives if we are to have better
receivers. More selective receivers increase costs but provide no new
services in the short run---why should consumers buy them? If consumers
have no incentive to buy, why should manufacturers build? This incentive
problem appears to be most severe in broadcast services. As an example,
double conversion, SAW filters at IF, and improved circuits would double
the number of possible stations on the UHF TV band, but new receivers
have to be in place before the new stations can operate. What are the
incentives for consumers and manufacturers? In Washington, D.C., on May
17, 2000, the National Association of Broadcasters urged the Federal
Communications Commission to adopt \"strong, specific and decisive\"
pro-consumer actions to ensure a successful transition to digital
television, including a requirement that all TV sets have the capability
of receiving DTV signals.

We observe that the FCC often regulates receivers - but rarely in order
to improve spectrum efficiency, and that weak incentives for the
adoption of spectrum-efficient receivers lead to inefficient spectrum
use in some services.

.

8.2 Noise environment

Dennis Roberson reported on the activities and findings of the Noise
Environment Subcommittee. At a previous meeting, the group both accepted
the recommendation from the subcommittee of a proposed noise study and
officially forwarded it to the Chairman with the full support of this
body. The first step of the proposed work would be a literature survey,
followed by measurements of the noise sources themselves and then a
modeling and analysis of the overall situation.

With respect to funding, FCC counsel agrees that it is acceptable and
appropriate under FACA (Federal Advisory Committee Act) rules for
organizations which have TAC members to donate money to a fund for the
purpose of supporting the desired study. At this time it is not
recommended that money be solicited from or accepted from organizations
which do not employ TAC members. It was understood that for the results
of studies such as the one proposed to have maximum impact, it was
critical that there be no suggestion that the results were tainted by
virtue of the funding source.

The National Science Foundation has both a review mechanism and a
process for cross-agency funds transfer, and it is it expected that
these capabilities will be used to implement the study. It is projected
that about \$100K to \$150K will be need to fund the first phase - the
literature study. It was formally and unanimously agreed to proceed with
a solicitation of funds from the TAC. Contributions of \$10K from each
member (with a \$1K minimum) are recommended.

**8.21 Noise environment - *Action Items***

The Chair will send a letter to TAC members to solicit financial support
for the noise study.

.

8.3 Software Defined Radio (SDR)

Kalle Kontson reminded us that we are now waiting for replies to the SDR
Notice of Inquiry (released by the FCC on March 21, 2000). After
analysis of the NOI contributions, it is anticipated that if a result
favorable to SDRs is achieved there will be three phases to the
implementation of the SDR concept:

-   A delineation of the rights and responsibilities of SDRs -- what we
    have previously referred to as "Part X" regulations. This would
    include a general certification philosophy and an understanding of
    the operating space that can be logically reached in the future by
    means of software downloads to already deployed devices.

-   Introduction of SDRs as overlay devices in existing bands.

-   Transition to domination by intelligent devices with widespread
    multiband deployment.

**8.40 Ultrawideband Radio (UWB)**

Weighing heavily on the decision to allow the approval of UWB, a
spectral overlay technology, is a growing sense that there is already
excessive interference and congestion in the Part 15 bands. Complaints
have already come into the FCC from the general public. The TAC should
determine if this is indeed true and try to see if there are some
possible solutions that could be recommended to the FCC by the TAC. To
set the stage for this, Dewayne Hendricks provided an overview of some
of the issues surrounding congestion in the Part 15 bands.

At a previous TAC meeting, we decided to study the issue of Part 15
congestion. An approach to the first phase would be to size the problem,
gather facts, bring other TAC members up to speed on problem, then
determine where to take the study next. To frame the problem we should
limit the survey to Part 15.247 and 15.249 (spread spectrum, and low
power emission rules) and look at both outside and inside use. We should
form an opinion on whether or not the current FCC approach of labeling
is still feasible. Labeling of equipment with the rules ( which some
have referred to as "Mirandizing"), in effect leaves it up to the
consumer to deal with the issue.

To further scope the work, we will look at the following bands:

-   902-928 MHz

-   2400-2483.5 MHz

-   5.15-5.25 GHz, 5.25-5.35 GHz, 5.725-5.875 GHz (U-NII)

-   5.725-5.85 GHz (Spread spectrum)

Will we also consider various classes of users, such as various
government entities, Part 18 (ISM -- Industrial, Scientific, Medical)
users, location services (e.g., "Lojak" / 900 MHz), amateur radio
service (ARS) operators, and various Part 15 devices.

To reinforce the urgent nature of this work, we can point to anecdotes
which have been appearing in the press. An April 27, 2000 article in the
New York Times entitled "Preparing for a Collision of Wireless Services"
reads: "If wireless networks proliferate as fast as many researchers
predict, is it possible for the airwaves to become overloaded? Cell
phones and some handheld organizers transmit and receive scores of
messages a day. With laptop computers and other devices added to the
mix, will there eventually be one big wireless traffic jam?"

Another example comes from the amateur radio world. ARS is 'Amateur
Radio Service', (FCC Part 97) and has allocations in all of the Part 15
bands. ARS is a licensed service and has higher priority access then
Part 15. In some cases, ARS has primary access to parts of the bands and
can use power levels up to 1.5 kW for most emission modes and up to 100
W for spread spectrum (SS) with an automatic power control to force
power minimization. There is very little use of SS today, but rules were
changed last October to allow more liberal use of SS. The most used
modes are FM repeaters and TV. A repeater in SF Bay area, operating
since 1996, has seen a continuously rising noise floor over the last
several years. This year the level has finally affected the base station
operation, a problem mostly caused by outside high EIRP Part 15
operations, showing that things are definitely changing for the worse.

Another are of concern is the desire to use r-f for light fixture
excitation. These are Part 18 (ISM) devices that operate in 2400-2500
MHz ISM band, centered on 2450 MHz with *very* high power levels
in-band. Rulemaking is now pending (ET 98-42) but Part 15 interests want
the Commission to limit emission levels.

Some of the results of gathering facts in this area show that the press
has picked up on the problem, that over 400 regional and local ISP's are
using Part 15 for last mile bypass, and that there seems to be both
disagreement inside the Commission as to exact role of Part 15, and
consumer and manufacturer confusion about how Part 15 is intended to
work. There is some belief that several of the current uses of Part 15
devices were unanticipated and unintended. Furthermore, while the
industry seems to be in denial about the overall problem, more devices
are being deployed on 2.4 GHz than anyone imagines. There may be 1
billion "Bluetooth" devices by 2005.

Problems outlined above are not an indication of the failure of Part 15,
but rather are the result of the enormous popularity and innovative
usage that has been stimulated by the success of unlicensed operation.
As we revisit this issue, we should devise a philosophy that relieves
some of the interference but continues to allow innovation to flourish.

##### 9.0 Going Forward

Each focus group leader should summarize the action items as they see
them for their group, and specific actions should be assigned as an
individual responsibility to persons in the group for reporting at the
next meeting.

The next scheduled formal TAC meeting is Wednesday, September 27,2000. A
meeting has also been scheduled December 6, 2000.

### Annex 1: Meeting Videotape

A VHS videotape of the June 28, 2000 meeting serves as a set of
comprehensive minutes of that meeting. Copies of the tape can be
obtained from the Commission\'s contracted copier,

In Focus. They may be reached by phone at:

703.843.0100 ext. 2278

### Annex 2: Member Biography

Dr. Stagg Newman

*Senior Telecommunications Practice Expert*

*McKinsey and Company*

Stagg joined McKinsey & Company, Inc., in January 2000 as Senior
Telecommunications Practice Expert, where he provides technology advice
and strategic technology analysis to client teams across the Firm's
telecommunications practice.

Prior to joining McKinsey Stagg served as Chief Technologist at the FCC
where he advised the Commissioners and senior staffers on strategic
technology issues. Much of his work centered on the FCC's market opening
initiatives for advanced telecommunications capabilities. This work
included developing policy that encouraged competition in broadband
access among cable companies, incumbent telephone companies, new entrant
telephone companies and broadband wireless companies. Another theme of
his work was "keeping the Internet safe from traditional telco style
regulation."

Stagg started his telecommunications career with Bell Labs in 1976 and
worked for various descendents of Ma Bell in voice, data, video, and
wireless networking until his appointment to the FCC in Sept. 1997. From
1994 to 1997 he was Vice President, Network Technology and Architecture,
Applied Research at Bellcore where he led the optical networking,
wireless, and network access research program.

Stagg received his B.S. from Davidson College and his M.S. and Ph.D.
from Cornell in Mathematics.

Stagg_Newman@mckinsey.com

Annex 3: FCC staff

*FCC staff available to address questions from the TAC:*

Contact David Farber as the DFO. With respect to specific Federal
Advisory Committee Act (FACA) questions, a resident expert is FCC
attorney:

Paula Silberthau, at: PSILBERT@fcc.gov

Phone 202-418-1874

Additional FACA information is at the Office of Government Policy web
page at:

[http://www.policyworks.gov](http://www.policyworks.gov/)

Annex 4: Focus groups , moderator, and group web addresses for
interaction.

Spectrum Management (Charles L. Jackson, Moderator)

<http://www.jacksons.net/tac>

Jules Bellisio jules@research.telcordia.com

Bran Ferren bran@appliedminds.net

Christine Hemrick hemrick@cisco.com

Dewayne L. Hendricks dewayne@dandin.com

Charles L. Jackson chuck@jacksons.net

Kalle Kontson kkontson@iitri.org

William C. Y. Lee william.lee@airtouch.com

Wah L. Lim Wah.Lim@hughes.com

Robert L. Martin bobmartin@lucent.com

Glenn Reitmeier greitmeier@sarnoff.com

Dennis Roberson Dennis.Roberson@motorola.com

Patrick White pwhite@safeguard.com

Accessibility for Disabled Persons (Gregg Vanderheiden, Moderator)

<http://trace.wisc.edu/docs/fccadv/disability.htm>

Jose M. Alvarez Caban jalvarez@coqui.net

Jules Bellisio jules@research.telcordia.com

Vinton G. Cerf vcerf@mci.net

Susan Estrada sestrada@aldea.com

Bran Ferren bran@appliedminds.net

Dewayne L. Hendricks dewayne@dandin.com

Charles L. Jackson chuck@jacksons.net

Paul F. Liao pliao@research.panasonic.com

David C. Nagel nagel@ipo.att.com

Gregg C. Vanderheiden gv@trace.wisc.edu

John F. Waters jack.waters@level3.com

Robert M. Zitter robert.zitter@hbo.com

Network Interconnection and Access (Marvin Sirbu, Moderator)

[http://www-fcc.ini.cmu.edu/FCC/index.html](http://www.ini.cmu.edu/FCC/index.html)

Jules Bellisio jules@research.telcordia.com

Vinton G. Cerf vcerf@mci.net

Susan Estrada sestrada@aldea.com

Bran Ferren bran@appliedminds.net

Christine Hemrick hemrick@cisco.com

Dewayne L. Hendricks dewayne@dandin.com

Ross Ireland ri4181@txmail.sbc.com

Paul F. Liao pliao@research.panasonic.com

Wah L. Lim Wah.Lim@hughes.com

Robert L. Martin bobmartin@lucent.com

David C. Nagel nagel@ipo.att.com

Glenn Reitmeier greitmeier@sarnoff.com

Dennis Roberson Dennis.Roberson@motorola.com

Marvin Sirbu sirbu@cmu.edu

Gregg C. Vanderheiden gv@trace.wisc.edu

John F. Waters jack.waters@level3.com

Patrick White pwhite@safeguard.com

Robert M. Zitter robert.zitter@hbo.com

**Intelligent Device Bill of Rights *ad-hoc* working group** (Bran
Ferren, Moderator)

Jules Bellisio <jules@research.telcordia.com>

David Farber DFARBER@fcc.gov

Bran Ferren bran@appliedminds.net

Dale Hatfield <DHATFIEL@fcc.gov>

David Hughes dave@oldcelo.com

David S. Isenberg isen@isen.com

Kalle Kontson <kkontson@iitri.org>

Paul F. Liao pliao@research.panasonic.com

William C. Y. Lee william.lee@airtouch.com

Arthur H.M.Ross a.ross@ieee.org

Marvin Sirbu sirbu@cmu.edu

Gregg C. Vanderheiden gv@trace.wisc.edu

Robert M. Zitter robert.zitter@hbo.com

[^1]: Coase, Ronald, \"The Problem of Social Cost.\", Journal of Law and
    Economics, Vol. 3 (1960)