Before the

**FEDERAL COMMUNICATIONS COMMISSION**

Washington, D. C. 20554

and

**THE NATIONAL TELECOMMUNICATIONS AND**

**INFORMATION ADMINSTRTION**

Washington, D. C. 20230

In the Matter of )

)

Federal Communications Commission Seeks )

Public Comment on Creation of a Spectrum ) ET Docket No. 06-89

Sharing Test-Bed )

National Telecommunications and )

Information Administration ) NTIA Docket No. 060602142-6142-01

Notice of Inquiry )

)

)

COMMENTS OF ADAPT4, LLC

Adapt4 applauds the FCC and NTIA on their desire to encourage innovation
to improve spectrum usage efficiency. Adapt4 develops, manufactures, and
sells cognitive radios to address this issue. The first product is the
XG1 cognitive radio. This radio can 'harvest' unused bandwidth from
bands currently approved for secondary use. Adapt4 expects that by
participating in the Test-Bed, it can demonstrate that cognitive radio
technology can be used to significantly improve spectrum usage
efficiency.

Adapt4 is proposing a Test-Bed using the XG1 radio, which meets all of
the goals mentioned in the FCC and NTIA initiatives. The existing XG1
radio includes features such as:

Dynamic spectrum access

Support for higher priority users such as Public Safety

Streamlined spectrum coordination process

The proposed Test-Bed would involve the deployment of an XG1 radio
network in an urban area at a frequency band that is currently used by
federal and/or non-federal users. The technology developed by Adapt4 is
frequency-agnostic. Adapt4 proposes the following bands as candidates
for the Test-Bed:

222 -- 242 MHz

420 -- 450 MHz

150 -- 216 MHz

Each of these bands has a collection of existing users including
business/industrial, public safety and federal government agencies. They
are also under-utilized from an efficiency point of view.

The Test-Bed would be used to measure the following metrics:

> Percentage of time channels (6.25 kHz resolution) are used by the
> primary users
>
> Percentage of time channels are used by the XG1 (cognitive) radio
> network

Throughput of the XG1 network

Noise floor level vs. time

Interference with any primary user

The XG1 Network Management System (NMS) already makes these measurements
at 1-minute intervals as part of normal operation. This data is archived
at the end of each day and plots are automatically created. This data
could be used to evaluate the effectiveness of cognitive radio
technology as a means to spectrum sharing.

Adapt4 proposes to establish this Test-Bed in an urban area in central
Florida and operate it over a period of 30-60 days. New radio traffic
would be created by transmitting periodic video surveillance camera
images from remote sites to a central site. This new radio traffic would
compete with existing primary user traffic on a non-interfering basis.
The capacity to transmit periodic video surveillance images is currently
not available without the cognitive radio technology. The use of XG1
radios in a busy urban setting would demonstrate quantitatively the
performance of the Test-Bed against its goals.

The XG1 NMS provides the ability to 'notch-out' specific channels as
each XG1 radio operates on non-contiguous channels using multiple,
low-power carriers which frequency hop at high rates. This design
reduces the impact of any incidental collisions that may occur with
primary users. Many collisions will go unnoticed. If however any
interference is caused, specified channels can be notched out through
the NMS and never used again. Any complaints by primary users will be
logged, and the affected channels permanently notched out for the rest
of the test period. This feature will allow Adapt4 to test in a busy
urban area, but will allow rapid correction of observed adverse affects
on existing users.

Each day that the Test-Bed is operated, logs will be collected, from
every site, archived, and plotted. These logs will contain the metrics
described below. A report will be compiled to summarize overall
performance.

This test would require an experimental license from the FCC for at
least one of the bands listed above for use in a designated geographical
area. If the tests in that band are successful in demonstrating spectrum
usage improvements without interference to the existing users, Adapt4
would seek the FCC's and NTIA's support in a rule change that would
allow the technology to be used on a permanent basis. Adapt4's
motivation to support the Test-Bed is that it will lead to the access of
more spectrum.

Figure 1 shows the typical data that is collected for every site in the
network. Figure 2 shows a spectral plot of the entire view taken when
the XG1 network is idle. This idle period is intentionally created
multiple times each second to measure the instantaneous use of the band
by all other users. A new map of the available spectrum is recomputed
after each view. These spectral plots would also be stored and included
in a final report. These are useful in determining the noise power
density at various times of the day.

Adapt4 would welcome Commission and NTIA personnel to witness the
testing, and assist in selecting the metrics to be collected.

Adapt4's cognitive radio technology is band independent, and therefore,
an ideal platform for implementing a spectrum-sharing Test-Bed. Upon
approval of an experimental license, Adapt4 can provide its standard
product equipment to implement a Test-Bed.

Because other vendors are not as far along in their understanding and
development of cognitive radios, Adapt4 recommends that multiple
non-overlapping test beds be deployed. Adapt4 can use one test-bed to
demonstrate and evaluate the operation of its XG1 cognitive radio, while
other test-beds are used to evaluate other approaches to cognitive
radios.

**Conclusion:**

Adapt4, the leader in cognitive radio technology, strongly supports the
pursuit of Spectrum Sharing Innovation Test-Beds. The company confirms
that it is ready and willing to be a participant in a Test-Bed. In this
response, we have recommended specific spectrum bands and specific
metrics for the Test-Beds. Our interest in the Test-Beds is driven by
our desire for the FCC's support in a rule change that would allow the
demonstrated technology to be used on a permanent basis in the
demonstrated spectrum bands.

> Respectfully submitted,

By: [/S/ Edward Gerhardt]{.underline}

Edward Gerhardt

President

> By: [/S/ Paul Greenis]{.underline}

Paul Greenis

VP, Sales and Marketing

Adapt4 LLC

605 N. John Rodes Blvd

Melbourne, FL 32934

TEL: 321.751.2811

Dated: July 10, 2006

![](media/image1.wmf){width="4.605555555555555in"
height="3.2805555555555554in"}

**Figure 1: Sample Statistics provided by the XG1**

![](media/image2.wmf){width="5.436805555555556in" height="3.06875in"}

**Figure 2: Sample Spectral Plots provided by the XG1**