**Before the**

**Federal Communications Commission**

**Washington, D.C. 20554**

+----------------------------------+----+------------------------------+
| In the matter of                 | *  | ET Docket No. 03-122         |
|                                  | *) |                              |
| Revision of Parts 2 and 15 of    | ** |                              |
| the Commission's Rules to Permit |    |                              |
| Unlicensed National Information  | *  |                              |
| Infrastructure (U-NII) devices   | *) |                              |
| in the 5 GHz band                | ** |                              |
|                                  |    |                              |
|                                  | *  |                              |
|                                  | *) |                              |
|                                  | ** |                              |
|                                  |    |                              |
|                                  | *  |                              |
|                                  | *) |                              |
|                                  | ** |                              |
|                                  |    |                              |
|                                  | *  |                              |
|                                  | *) |                              |
|                                  | ** |                              |
+----------------------------------+----+------------------------------+

**MEMORANDUM OPINION AND ORDER**

**Adopted: June 29, 2006 Released: June 30, 2006**

**By the Commission:** Commissioners Copps, Adelstein and McDowell
issuing separate statements.

# Introduction

1.  By this Memorandum Opinion and Order (MO&O), we respond to requests
    for clarification or reconsideration of our rules for unlicensed
    National Information Infrastructure (U-NII) devices in the 5.25-5.35
    GHz and 5.47-5.725 GHz bands, including Radio Local Area Networks
    (RLANs), which were adopted in the *Report and Order* in this
    proceeding.[^1] Specifically, we are granting a request by the Wi-Fi
    Alliance to clarify the Transmit Power Control (TPC) requirements in
    section 15.407(h)(1), dismissing a request by the Wi-Fi Alliance to
    clarify the channel availability check time requirement in section
    15.407(h)(2)(ii), denying a request by Globespan Virata (Globespan)
    to revise the rules to state that U-NII devices are not required to
    detect and avoid frequency hopping radar signals, and dismissing a
    request by Extreme Networks Inc. (Extreme Networks) to modify the
    definition of a U-NII central controller that must include Dynamic
    Frequency Selection (DFS) capability. We also issue a revised
    measurement procedure for certifying U-NII devices for compliance
    with the DFS requirements in these bands. Our action here will
    ensure that all applications for equipment certification of U-NII
    devices filed on or after July 20, 2006 will comply with all U-NII
    requirements for these bands.[^2]

# BACKGROUND

2.  U-NII devices are unlicensed intentional radiators that operate in
    the frequency bands 5.15-5.35 GHz and 5.47-5.825 GHz and use
    wideband digital modulation techniques to provide a wide array of
    high data rate mobile and fixed communications for individuals,
    businesses, and institutions.[^3] In the *Report and Order*, the
    Commission amended Part 15 of the rules to make 255 megahertz of
    spectrum available in the 5.47-5.725 GHz band for U-NII devices.
    This action aligned the frequency bands used by U-NII devices in the
    United States with the frequency bands used by U-NII devices in
    other parts of the world, thus decreasing development and
    manufacturing costs by allowing for the same products to be used in
    most parts of the world.

3.  Operation in the newly available U-NII spectrum is conditioned upon
    compliance with certain technical requirements. Specifically, the
    new rules require that U-NII devices operating in the 5.25-5.35 GHz
    and 5.47-5.725 GHz bands employ DFS in order to avoid causing
    interference to Federal Government radar systems. DFS is a feature
    that monitors the spectrum and selects for operation a frequency
    that is not already in use. Prior to the start of any transmission,
    a U-NII device equipped with DFS capability must continually monitor
    the radio environment for a radar's presence. If the U-NII device
    determines that a radar is present, it must either select another
    channel or enter a "sleep mode" if no channels are available.

4.  Additionally, the new rules require U-NII devices to employ a TPC
    mechanism when operating in the 5.25-5.35 GHz and 5.47-5.725 GHz
    bands to further protect operations in the Earth
    Exploration-Satellite Service (active) (EESS) and the Space Research
    Service (active) (SRS). TPC is a feature that adjusts a
    transmitter's output power based on the signal level present at the
    receiver. As the signal level at the receiver rises or falls, the
    transmit power will decrease or increase as needed. Therefore, TPC
    will cause the transmitter to operate at less than the maximum power
    when lower signal levels can provide acceptable service.

5.  In addition to the rules adopted in the *Report and Order*, the
    Commission provided an interim measurement procedure to be used by
    the Commission and others in determining whether U-NII devices
    comply with the rules.[^4] The Commission stated that the provisions
    of this test procedure would need to be modified as equipment was
    developed and as testing methodologies were refined. The Commission
    also stated that the OET Laboratory may issue updated measurement
    procedures in the future. Since the release of the *Report and
    Order*, the International Telecommunication Advisory
    Committee-Radiocommunication (ITAC-R) Government/Industry Project
    Team (Project Team) has worked to develop revised measurement
    procedures for performing DFS compliance measurement tests for U-NII
    equipment operating in the 5.25-5.35 GHz and 5.47-5.725 GHz bands.
    Recently, the Project Team reached consensus on revised compliance
    and measurement procedures for DFS, and the National
    Telecommunications and Information Administration (NTIA) presented
    these recommendations to the Commission.[^5] The revised DFS
    measurement procedure includes modified definitions, technical
    requirements (*e.g*., detection thresholds and new response
    requirements), radar test waveforms, test procedures, and test
    report guidelines.

6.  The Wi-Fi Alliance, Globespan, and Extreme Networks each filed
    petitions seeking clarification or reconsideration of various
    aspects of the requirements adopted in the *Report and Order*.[^6]
    After NTIA presented the recommendation of the Project Team on a
    revised compliance and measurement procedure, the Commission, in
    order to refresh the record in this proceeding, issued a *Public*

    *Notice* seeking additional comments on the DFS issues raised in the
    pending reconsideration petitions and how the issues are addressed
    in the revised measurement procedures and Commission's rules.[^7]
    Six comments and two reply comments were filed in response to the
    *Public* *Notice*.[^8]

# DISCUSSION

7.  [The Wi-Fi Alliance Motion for Clarification]{.underline}. In the
    *Report and Order*, the Commission required that U-NII devices
    operating in the 5.25-5.35 GHz band and the 5.47-5.725 GHz band
    employ a TPC mechanism and that they have the capability to operate
    at least 6 dB below the mean EIRP value of 30 dBm. However, the
    Commission also exempted systems with an EIRP of less than 500 mW
    from the requirement.[^9] As set forth in the rules, this
    requirement is currently stated as:

    U-NII devices operating in the 5.25-5.35 GHz band and the 5.47-5.725
    GHz band shall employ a TPC mechanism. The U-NII device is required
    to have the capability to operate at least 6 dB below the mean EIRP
    value of 30 dBm. A TPC mechanism is not required for systems with an
    e.i.r.p. of less than 500 mW.[^10]

8.  In its Motion for Clarification, the Wi-Fi Alliance seeks
    clarification of the TPC requirements for U-NII devices.[^11]
    Specifically, the Wi-Fi Alliance states that the definition of TPC
    in rule section 15.403(s)[^12], along with the TPC requirement in
    rule section 15.407(h)(1), might imply that dynamic TPC must always
    be employed for systems with an EIRP of less than 500 mW.[^13] It
    submits that the first part of the rule states that all U-NII
    devices must employ TPC, while the last sentence exempts systems
    with EIRP of less than 500 mW. The Wi-Fi Alliance states that the
    objective for TPC in the 5 GHz bands, as developed by the
    International Telecommunication Union-Radiocommunication (ITU-R), is
    to reduce interference into satellite based receivers by an average
    of 3 dB below the maximum level allowed. It further contends that
    this reduction can be done in one of two ways. One way of achieving
    this reduction is by using a dynamic mechanism that adjusts the
    transmitter power to meet needs for a transmission to a given
    receiver. The second way to achieve the same result is by limiting
    the maximum transmission power to 500 mW in the case where all
    transmissions are at the same power level. In addition, the Wi-Fi
    Alliance seeks clarification of the meaning of the word "system" in
    section 15.407(h)(1) when applying the 500 mW EIRP threshold. The
    Wi-Fi Alliance says that the word "system" could be read as "a
    transmitter with any of its certified antennas" or "a transmitter
    with a given antenna attached."

9.  Also in its Motion for Clarification, the Wi-Fi Alliance addresses
    the text in section 15.407(h)(2)(ii) regarding the DFS requirement
    for channel availability check time.[^14] The Wi-Fi Alliance states
    that the text in 15.407(h)(2)(ii) (the rule requires a 60 second
    listening period before moving to a channel) can be interpreted to
    prevent fast channel changing in the event of detection of a radar
    signal on the operating channel and that this issue is of concern to
    the wireless LAN industry since it has performance implications. The
    Wi-Fi Alliance notes that this issue and their concerns with the
    interim measurement procedures were being discussed by the Project
    Team and therefore the text in 15.407(h)(2)(ii) may need
    clarification at a later date.

10. *Comments*. In their comments in response to the *Public Notice*,
    the Wi-Fi Alliance and Motorola contend that the issue raised in the
    Wi-Fi Alliance petition regarding the definition of transmit power
    control has been addressed in the revised measurement
    procedure.[^15] With regard to the part of its petition seeking
    change to the channel availability check time in Section
    15.407(h)(2)(ii), the Wi-Fi Alliance states that, since there is no
    consensus on whether or how to modify this rule section, the
    Commission can either take no action and leave this issue pending or
    dismiss without prejudice this issue as part of adopting the test
    procedures, which will allow for industry to continue discussions
    with government on this issue.[^16]

11. *Decision*. The TPC requirement is intended to protect EESS and SRS
    operations by regulating a device's transmit power in response to an
    input signal or a condition (*e.g.*, a command signal issued by a
    controller when the received signal falls below a predetermined
    threshold). We recognize that the first sentence of section
    15.407(h)(1) states that all U-NII devices must employ a TPC
    mechanism, while the last sentence modifies the first sentence by
    indicating that TPC is not required for systems with an EIRP of less
    than 500 mW. Because the wording of the TPC requirement in section
    15.407(h)(1) may be confusing, we clarify, as the Commission stated
    in the *Report and Order*, that there is no need to require TPC for
    a low-power U‑NII device and that TPC is only required for U-NII
    devices operating at power levels higher than 500 mW.[^17] A U-NII
    device with an EIRP less than 500 mW is exempt because the device
    will not interfere with other operations in the 5.25-5.35 GHz and
    5.47-5.725 GHz bands. We also clarify that the TPC requirement
    applies to each U-NII device since a U-NII device's transmission
    output power when combined with antenna gain produces an overall
    power referred to as "EIRP."

12. With regard to further clarification of section 15.407(h)(2)(ii) on
    DFS channel availability check time, the Project Team reached a
    consensus in the revised measurement procedure on a definition for
    channel availability check time that allows for fast channel
    changing.[^18] Since this issue is addressed in the revised
    measurement procedure that we are issuing with this MO&O, we dismiss
    this part of the Wi-Fi Alliance petition. Our action will allow
    industry to continue discussions with the Federal Government on this
    issue as needed, and the Commission's Laboratory may issue updated
    measurement procedures in the future if further modifications are
    needed.

13. [The Globespan Petition for Clarification or
    Reconsideration]{.underline}. In the *Report and Order*, the
    Commission required that U-NII devices operating in the 5.25-5.35
    GHz and 5.47-5.725 GHz bands use DFS to avoid causing interference
    to Federal Government radar operations. Section 15.407(h)(2) of the
    rules provides, in pertinent part, that "U-NII devices operating in
    the 5.25-5.35 GHz and 5.47-5.725 GHz bands shall employ a DFS radar
    detection mechanism to detect the presence of radar systems and to
    avoid co-channel operation with radar systems."[^19] Section
    15.407(h)(2)(iv) of the rules provides that "A channel that has been
    flagged as containing a radar system, either by a channel
    availability check or in-service monitoring, is subject to a
    non-occupancy period of at least 30 minutes. The non-occupancy
    period starts at the time when the radar system is detected."[^20]

14. In its petition, Globespan requests that we clarify our rules to
    state that DFS-equipped U-NII devices are not required to detect and
    avoid frequency hopping radars in the 5.25-5.35 GHz and 5.47-5.725
    GHz bands.[^21] Globespan asserts that such a requirement is
    unnecessary because a U-NII device operating within the provisions
    of the rules would not be expected to cause harmful interference to
    frequency hopping radars. It notes that even if a U-NII device emits
    on one frequency used by a frequency hopping radar, the other
    frequencies used by that radar would be unaffected, so that the
    radar should continue to function successfully. Furthermore,
    Globespan states that the rule requiring a 30 minute non-occupancy
    period for a channel flagged as containing a radar system, if
    applied to each channel used by a frequency hopping radar system,
    would lock out most parts of the U-NII band for long periods of
    time, and in some cases shut down U-NII operation entirely.[^22] For
    these reasons, Globespan argues that a DFS requirement with respect
    to frequency hopping radar systems is both unnecessary to protect
    the radar and detrimental to the operation of the U-NII devices.

15. Globespan argues that if we intended to include frequency hopping
    radars in the DFS requirement, we should reconsider the applicable
    radar test signal and the definition of testing success in the
    interim measurement procedure.[^23] Globespan also states that these
    issues should be delegated to the Project Team for resolution, and
    certification requirements should be limited to fixed-frequency
    radar systems until the Project Team reaches a decision.[^24]

16. *Comments.* In its comments in response to the *Public Notice*, the
    Wi-Fi Alliance states that Globespan's petition asking for
    clarification that DFS does not have to detect frequency hopping
    radars has been mooted by the revised measurement procedure and
    should be dismissed.[^25] Similarly, Motorola comments that the
    revised measurement procedure directly clarifies the questions
    surrounding frequency hopping radars raised by Globespan in its
    petition.[^26]

17. *Decision*. Contrary to Globespan's arguments, we did not intend to
    exclude frequency hopping radars from the DFS requirement. In the
    *Report and Order*, we adopted DFS requirements to protect all
    Federal Government radar systems from interference from U-NII
    devices operating in the 5.25-5.35 GHz and 5.47-5.725 GHz
    bands.[^27] We made no distinction in the protection requirements
    between frequency hopping and other types of radars and Globespan
    points to no language that would support its contention. In fact,
    the interim test procedure appended to the *Report and Order* in
    this proceeding, which was developed by the Project Team, addresses
    the unique sharing challenges of how DFS should perform in the
    presence of frequency hopping radars.[^28]

18. The revised measurement procedure that we are endorsing with this
    MO&O addresses how DFS should perform in the presence of different
    types of radar systems, including frequency hopping radars. More
    specifically, section 6 of the revised measurement procedure
    provides the parameters for the required test waveforms, the minimum
    percentage of successful detections, and the minimum number of
    trials that must be used to determine DFS conformance.[^29]
    Accordingly, the DFS requirement is clearly intended to encompass
    frequency hopping radar systems.

19. [The Extreme Networks Request for Clarification.]{.underline} The
    interim test procedures adopted in the *Report and Order* include
    the DFS requirements that must be met for product certification.
    These procedures specify that an unlicensed device operating in
    master mode (a master device or central controller) must include DFS
    capability and be able to select a channel and establish a network
    by sending enabling signals to other client U-NII devices. On the
    other hand, an unlicensed device operating in client mode (a client
    device) must only operate under the control of the master device and
    not be able to initiate a network transmission.

20. In its request, Extreme Networks seeks clarification of the
    definition of a central controller that must have DFS
    capability.[^30] Extreme states that this definition should include
    not only stand-alone devices, such as an RLAN access point (AP) with
    DFS capability, but also network switches that can offload DFS
    capabilities from radio devices. It states that these radio devices
    can be placed in different locations under the control of an
    expanded central controller or may be grouped together in a cluster
    and share the same frequency and DFS functionality under an expanded
    central controller.[^31] Extreme also contends that a central
    controller may control multiple radio device clusters operating at
    different frequencies as determined by the DFS. Under this
    architecture, Extreme states that an RLAN system could consist of
    several access points that are grouped into one single "AP cluster"
    controlled by a network switch with DFS controllability.

21. *Comments.* In its comments in response to the *Public Notice*,
    Motorola states that Extreme Networks request for clarification on
    central control devices is discussed in the revised compliance
    procedure.[^32] Also, the Wi-Fi Alliance contends that Extreme
    Networks petition seeking clarification on the definition of
    "master" or "controller" does not seek a rule change or a change to
    the testing pass/fail criteria in the revised measurement
    procedure.[^33] Wi-Fi Alliance states that, since the scenario
    raised by Extreme Networks may raise questions about how to conduct
    certification tests, not the compliance criteria, the Commission
    should handle issues like those addressed in Extreme Networks
    petition on a case-by-case basis.[^34] Similarly, Motorola asserts
    that if Extreme has a unique implementation that is not adequately
    addressed in the revised measurement procedure, then the Commission
    should address those issues on a waiver basis.[^35]

22. *Decision.* The intent of the DFS requirement in the rules is to
    ensure that all elements of a system (both master devices and client
    devices) are capable of avoiding causing harmful interference to
    government radars by dynamically switching frequencies. Although
    Section 5 of the revised measurement procedure addresses DFS
    capability for U-NII devices operating in master-client
    configurations, it does not address the specific configuration
    suggested by Extreme Networks.[^36] Nonetheless, Extreme Networks
    does not question the DFS requirement or the compliance criteria in
    the revised measurement procedure.

23. All U-NII implementations will be tested individually as part of the
    equipment certification process. If a unique implementation of DFS
    in U-NII devices is not directly addressed by the revised
    measurement procedure, the application for U-NII device
    certification will be handled on a case-by-case basis. We thus
    decline to clarify at this time the definition of a central
    controller that must have DFS capability as Extreme Networks
    requests and dismiss its petition.

24. [Revised Measurement Procedure.]{.underline} As previously
    mentioned, the Project Team has worked to develop new measurement
    procedures for performing DFS compliance measurement tests for U-NII
    equipment operating in the 5.25-5.35 GHz and 5.47-5.725 GHz bands.
    Recently, the Project Team reached a consensus on revised DFS
    measurement procedures that were presented by the NTIA to the
    Commission on March 30, 2006 as part of this proceeding.[^37]

25. *Comments*. In response to the *Public Notice,* four parties filed
    comments in support of the revised measurement procedure. Covad
    Communication Group (Covad), Motorola, Wi-Fi Alliance, and the 5 GHz
    Coalition state that the revised measurement procedure should be
    implemented promptly in order to expedite the certification and
    deployment of U-NII devices.[^38] On the other hand, Compliance
    Certification Services (CCS) filed comments noting editorial and
    technical errors in the revised measurement procedure that they
    state might have technical implications.[^39] Praveen Rao states
    that the revised measurement procedure could threaten Fujitsu's
    notebook business because of industry's non-readiness of DFS test
    capability and raises concerns with the timeliness of the
    certification process.[^40] In response to CCS's comments, the 5 GHz
    Coalition filed reply comments stating that some of the proposed
    changes by CCS are unimportant editorial changes.[^41] But the 5 GHz
    Coalition contends that some of the other proposed changes by CCS
    are substantive modifications that would decrease device performance
    or unnecessarily increase compliance testing burdens and costs,
    while not providing additional protection to military radars.[^42]

26. *Decision*. In order to allow for immediate implementation of U-NII
    devices in accordance with the rules adopted in the *Report and
    Order* of this proceeding, we are issuing the revised measurement
    procedures recommended by NTIA for certifying U-NII devices as an
    Appendix to this MO&O.[^43] Because these revised procedures
    represent a consensus agreement of industry and government
    participants, we are not making the substantive changes suggested by
    CCS since they may materially affect the implementation of the
    measurement procedures. We encourage industry and government
    entities to continue discussions on these procedures, as needed, and
    note that the Commission's Laboratory may issue further updates to
    the measurement procedures in the future as equipment is developed
    and as testing methodologies are refined. The revised measurement
    procedure that we are issuing with this MO&O does include
    non-substantive editorial changes submitted by CCS. As for the other
    concern, with respect to the certification process, applications for
    certification of U-NII devices will be processed in the order in
    which they are received. Further, with respect to industry readiness
    to test DFS capabilities, we note that the criteria for DFS and TPC
    compliance in U-NII devices have been acknowledged and recognized
    since the adoption of the *Report and Order* in this proceeding.
    Therefore, manufacturers were aware of these new rules for U-NII
    devices well in advance of the July 20, 2006 implementation date.

27. Finally, we note that definitions for some terms used in the revised
    measurement procedure differ in minor respects from those in the
    Commission's rules and that the revised measurement procedure
    defines terms which are not part of the Commission's rules.[^44]
    These differences do not change the underlying requirements for DFS
    capability. The definitions in the revised measurement procedure
    reflect and clarify the procedure and thus apply for compliance
    testing purposes.

# PROCEDURAL MATTERS

## Regulatory Flexibility Certification Analysis

28. The Report and Order[^45] included a Final Regulatory Flexibility
    Certification pursuant to the Regulatory Flexibility Act (RFA).[^46]
    We received no petitions for reconsideration of that Final
    Regulatory Flexibility Certification.

29. The Commission will send a copy of the Memorandum Opinion and Order,
    including a copy of this Regulatory Flexibility Certification
    Analysis, in a report to Congress pursuant to the Congressional
    Review Act.[^47] In addition, the Memorandum Opinion and Order and
    this final certification will be sent to the Chief Counsel for
    Advocacy of the SBA, and will be published in the Federal
    Register.[^48]

## Paperwork Reduction Act of 1995 Analysis.

30. This Memorandum Opinion and Order does not contain an information
    collection subject to the Paperwork Reduction Act of 1995 (PRA),
    Public Law 104-13.

## Contact Person

31. For further information concerning this Memorandum Opinion and
    Order, contact the Office of Engineering and Technology, Shameeka
    Hunt, (202)418-2062, email <Shameeka.Hunt@fcc.gov>.

# ORDERING CLAUSES

32. Accordingly, IT IS ORDERED that pursuant to the Section 1, 4, 301,
    302(a), and 303, of the Communications Act of 1934, as amended, 47
    U.S.C. §§ 151, 154, 301, 302(a), and 303, the Memorandum Opinion and
    Order IS ADOPTED.

33. IT IS FURTHER ORDERED that the Motion for Clarification filed by The
    Wi-Fi Alliance IS GRANTED IN PART AND DISMISSED IN PART, consistent
    with the terms of this Memorandum Opinion and Order.

34. IT IS FURTHER ORDERED that the Request for Clarification filed by
    Extreme Networks, Inc. and the Petition for Clarification or
    Reconsideration filed by Globespan Virata, Inc. ARE DENIED.

35. IT IS FURTHER ORDERED that the Commission's Consumer and
    Governmental Affairs Bureau, Reference Information Center, SHALL
    SEND a copy of this Memorandum Opinion and Order, including the
    Final Regulatory Flexibility Certification, to the Chief Counsel for
    Advocacy of the Small Business Administration.

    FEDERAL COMMUNICATIONS COMMISSION

    Marlene H. Dortch

    Secretary

**APPENDIX**

**COMPLIANCE MEASUREMENT PROCEDURES FOR UNLICENSED-NATIONAL INFORMATION
INFRASTRUCTURE DEVICES OPERATING IN THE 5250-5350 MHz AND 5470-5725 MHz
BANDS INCORPORATING DYNAMIC FREQUENCY SELECTION**

**1. INTRODUCTION**

This document describes the compliance measurement procedures including
acceptable instrument system configurations for performing *Dynamic
Frequency Selection* (DFS) tests under FCC Part 15 Subpart E Rules
required for Unlicensed --National Information Infrastructure (U-NII)
equipment that operates in the frequency bands 5250 MHz to 5350 MHz
and/or 5470 MHz to 5725 MHz.

**2. SCOPE**

The scope of this document includes applicable references, definitions,
symbols and abbreviations with an overview of the DFS operational
requirements, test signal generation and methods of measuring
compliance. The methods include calibration and test procedures for
conducted and radiated measurements. Either conducted or radiated
testing may be performed. Equipment with an integral antenna may be
equipped with a temporary antenna connector in order to facilitate
conducted tests. When the antenna cannot be separated from the device
and a radio frequency (RF) test port is not provided, radiated
measurements will be performed.

General information about radio device compliance testing facilities and
measurement techniques are assumed to be known and not covered here.

**3. REFERENCES**

> \[1\] Recommendation ITU-R M.1652
>
> \[2\] ITU Resolution 229 (WRC-03)

**4. DEFINITIONS, SYMBOLS AND ABBREVIATIONS**

For the purposes of the present document, the following terms and
definitions apply.

**4.1 Definitions**

**[Association:]{.underline}** An active relationship between two
wireless devices in which one device (referred to as a *Master Device*
in this document) exercises certain control functions over other devices
(referred to as a *Client Device* in this document).

**[Available Channel:]{.underline}** A *Channel* on which a *Channel
Availability Check* has not identified the presence of a *Radar
Waveform*.

**[Burst:]{.underline}** A series of radio wave pulses defined by pulse
width, pulse repetition interval, number of pulses, and modulation to
simulate radar transmissions.

**[Channel:]{.underline}** Amount of spectrum utilized by a *Master
Device* and any associated *Client Device(s)*.

**[Channel Availability Check:]{.underline}** A DFS function that
monitors a *Channel* to determine if a *Radar Waveform* above the *DFS
Detection Threshold* is present.

**[Channel Availability Check Time:]{.underline}** The period of time
during which a *Channel Availability Check* is performed.

**[Channel Closing Transmission Time:]{.underline}** The total duration
of transmissions, consisting of data signals and the aggregate of
control signals, by a U-NII device during the *Channel Move Time.*

**[Channel Move Time:]{.underline}** The time to cease all transmissions
on the current *Channel* upon detection of a *Radar Waveform* above the
*DFS Detection Threshold*.

**[Client Device:]{.underline}** A U-NII device operating in *Client
Mode*.

**[Client Mode:]{.underline}** Operating mode in which the transmissions
of the U-NII device are under control of the *Master Device*. A U-NII
device operating in *Client Mode* is not able to initiate a network.

**[Dynamic Frequency Selection:]{.underline}** An interference
mitigation technique for U-NII devices to avoid co-channel operations
with radar systems.

**[In-Service Monitoring:]{.underline}** A DFS function that monitors
the *Operating Channel* for the presence of a *Radar Waveform* above the
*DFS Detection Threshold*.

**[DFS Detection Threshold:]{.underline}** The required detection level
defined by a received signal strength (RSS) that is greater than a
specified threshold, within the *U-NII Detection Bandwidth*.

**[Master Device:]{.underline}** A U-NII device operating in *Master
Mode*.

**[Master Mode:]{.underline}** Operating mode in which the U-NII device
has the capability to transmit without receiving an external control
signal and can perform *Network Initiation*.

**[Network Initiation:]{.underline}** The process by which the *Master
Device* sends control signals to C*lient Device(s)* that allow them to
begin transmissions.

**[Non-Occupancy Period:]{.underline}** The time during which a
*Channel* will not be utilized after a *Radar Waveform* is detected on
that *Channel*.

**[Operating Channel:]{.underline}** Once a U-NII device starts to
operate on an *Available Channel* then that *Channel* becomes the
*Operating Channel*.

**[Radar Waveform:]{.underline}** A *Burst* or series of *Bursts*
designed to simulate a radar signal.

**[Uniform Channel Spreading:]{.underline}** The spreading of U-NII
device *Operating* *Channels* over the 5250-5350 MHz and/or 5470-5725
MHz bands to avoid dense clusters of devices operating on the same
*Channel*.

**[U-NII Device:]{.underline}** Intentional radiators operating in the
frequency bands in the 5150-5350 MHz and 5470-5825 MHz that use wideband
digital modulation techniques and provide a wide array of high data rate
mobile and fixed communications for individuals, businesses, and
institutions.

**[U-NII Detection Bandwidth:]{.underline}** The contiguous frequency
spectrum over which a U-NII device detects a *Radar Waveform* above the
*DFS Detection Threshold*.

**4.2 Symbols**

> For the purposes of this document, the following symbols apply:
>
> ATT Attenuator
>
> B Number of Bins
>
> Burst_Count The number of *Bursts* within a single 12 second Long
> Pulse radar (waveform 5)
>
> Ch~r~ Channel occupied by a radar
>
> D Distance
>
> Dwell Dwell time per bin
>
> G Antenna gain (dBi)
>
> N Number of spectrum analyzer bins showing a U-NII transmission
>
> F~H~ Highest frequency at which detection occurs above the required
> value during the *U-NII* *Detection Bandwidth* test.
>
> F~L~ Lowest frequency at which detection occurs above the required
> value during the *U-NII* *Detection Bandwidth* test.
>
> P~d~1 Percentage of Successful Detections for Waveform 1
>
> P~d~2 Percentage of Successful Detections for Waveform 2
>
> P~d~3 Percentage of Successful Detections for Waveform 3
>
> P~d~4 Percentage of Successful Detections for Waveform 4
>
> P~d~N Percentage of Successful Detections for Waveform N
>
> S Sweep Time
>
> T~channel_avail_check~ The 60 second time period required for the
> *Channel Availability Check*
>
> T~power_up~ Amount of time it takes a U-NII device to turn on,
> initialize, and then begin *Channel Availability Check*
>
> T~0~ Time instant
>
> T~1~ Time instant
>
> T~2~ Time instant
>
> T~3~ Time instant

## 4.3 Abbreviations  {#abbreviations .unnumbered}

For the purposes of this document, the following abbreviations apply:

> ALC Automatic Level Control
>
> AWG Arbitrary Waveform Generator
>
> CW Continuous Wave
>
> DFS Dynamic Frequency Selection
>
> EIRP Equivalent Isotropic Radiated Power
>
> FM Frequency Modulation
>
> IF Intermediate Frequency
>
> IL Insertion Loss
>
> IP Internet Protocol
>
> LO Local Oscillator
>
> MHz Megahertz
>
> MPEG Moving Picture Experts Group[^49]
>
> msec Millisecond
>
> PRI Pulse Repetition Interval
>
> RDD Radar Detection Device
>
> RF Radio Frequency
>
> RMS Root Mean Square
>
> UUT Unit Under Test
>
> U-NII Unlicensed National Information Infrastructure
>
> µsec Microsecond
>
> VSA Vector Signal Analyzer
>
> VSG Vector Signal Generator

**5. TECHNICAL REQUIREMENTS FOR DFS IN THE 5250-5350 MHz AND 5470-5725
MHz BANDS**

## 5.1 DFS Overview {#dfs-overview .unnumbered}

A U-NII network will employ a DFS function to:

-   detect signals from radar systems and to avoid co-channel operation
    with these systems.

-   provide on aggregate a *Uniform Spreading* of the Operating Channels
    across the entire band. This applies to the 5250-5350 MHz and/or
    5470-5725 MHz bands.

Within the context of the operation of the DFS function, a U-NII device
will operate in either *Master Mode* or *Client Mode*. U-NII devices
operating in *Client Mode* can only operate in a network controlled by a
U-NII device operating in *Master Mode*.

Tables 1 and 2 shown below summarize the information contained in
sections 5.1.1 and 5.1.2.

Table 1: Applicability of DFS Requirements Prior to Use of a Channel

+--------------------------------+---------+------------+-------------+
| **Requirement**                | **Oper  |            |             |
|                                | ational |            |             |
|                                | Mode**  |            |             |
+--------------------------------+---------+------------+-------------+
|                                | **M     | Client     | **Client    |
|                                | aster** |            | With Radar  |
|                                |         | **Without  | Detection** |
|                                |         | Radar      |             |
|                                |         | D          |             |
|                                |         | etection** |             |
+--------------------------------+---------+------------+-------------+
| *Non-Occupancy Period*         | Yes     | Not        | Yes         |
|                                |         | required   |             |
+--------------------------------+---------+------------+-------------+
| *DFS Detection Threshold*      | Yes     | Not        | Yes         |
|                                |         | required   |             |
+--------------------------------+---------+------------+-------------+
| *Channel Availability Check    | Yes     | Not        | Not         |
| Time*                          |         | required   | required    |
+--------------------------------+---------+------------+-------------+
| *Uniform Spreading*            | Yes     | Not        | Not         |
|                                |         | required   | required    |
+--------------------------------+---------+------------+-------------+
| *U-NII Detection Bandwidth*    | Yes     | Not        | Yes         |
|                                |         | required   |             |
+--------------------------------+---------+------------+-------------+

Table 2: Applicability of DFS requirements during normal operation

+-------------------------------+----------+-------------+------------+
| Requirement                   | Ope      |             |            |
|                               | rational |             |            |
|                               | Mode     |             |            |
+-------------------------------+----------+-------------+------------+
|                               | Master   | Client      | Client     |
|                               |          |             |            |
|                               |          | Without     | With Radar |
|                               |          | Radar       | Detection  |
|                               |          | Detection   |            |
+-------------------------------+----------+-------------+------------+
| *DFS Detection Threshold*     | Yes      | Not         | Yes        |
|                               |          | required    |            |
+-------------------------------+----------+-------------+------------+
| *Channel Closing Transmission | Yes      | Yes         | Yes        |
| Time*                         |          |             |            |
+-------------------------------+----------+-------------+------------+
| *Channel Move Time*           | Yes      | Yes         | Yes        |
+-------------------------------+----------+-------------+------------+
| *U-NII Detection Bandwidth*   | Yes      | Not         | Yes        |
|                               |          | required    |            |
+-------------------------------+----------+-------------+------------+

The operational behavior and individual DFS requirements that are
associated with these modes are as follows:

### 5.1.1 Master Devices {#master-devices .unnumbered}

a)  The *Master Device* will use DFS in order to detect *Radar
    Waveforms* with received signal strength above the *DFS Detection
    Threshold* in the 5250  5350 MHz and 5470  5725 MHz bands. DFS is
    not required in the 5150  5250 MHz or 5725  5825 MHz bands.

b)  Before initiating a network on a *Channel*, the *Master Device* will
    perform a C*hannel Availability Check* for a specified time duration
    (*Channel Availability Check Time*) to ensure that there is no radar
    system operating on the *Channel*, using DFS described under
    subsection a) above.

c)  The *Master Device* initiates a U-NII network by transmitting
    control signals that will enable other U-NII devices to *Associate*
    with the *Master Device*.

d)  During normal operation, the *Master Device* will monitor the
    *Channel* *(In-Service Monitoring)* to ensure that there is no radar
    system operating on the *Channel*, using DFS described under a).

e)  If the *Master Device* has detected a *Radar Waveform* during
    *In-Service Monitoring* as described under d), the *Operating
    Channel* of the U-NII network is no longer an *Available Channel*.
    The *Master Device* will instruct all associated *Client Device(s)*
    to stop transmitting on this *Channel* within the *Channel Move
    Time*. The transmissions during the *Channel Move Time* will be
    limited to the *Channel Closing Transmission Time*.

f)  Once the *Master Device* has detected a *Radar Waveform* it will not
    utilize the *Channel* for the duration of the *Non-Occupancy
    Period*. [^50]

g)  If the *Master Device* delegates the *In-Service Monitoring* to a
    *Client Device*, then the combination will be tested to the
    requirements described under d) through f) above.

### 5.1.2 Client Devices {#client-devices .unnumbered}

a)  A *Client Device* will not transmit before having received
    appropriate control signals from a *Master Device*.

b)  A *Client Device* will stop all its transmissions whenever
    instructed by a *Master Device* to which it is associated and will
    meet the *Channel Move Time* and *Channel Closing Transmission Time*
    requirements. The *Client Device* will not resume any transmissions
    until it has again received control signals from a *Master Device*.

c)  If a *Client Device* is performing *In-Service Monitoring* and
    detects a *Radar Waveform* above the *DFS Detection Threshold*, it
    will inform the *Master Device*. This is equivalent to the *Master
    Device* detecting the *Radar Waveform* and d) through f) of section
    5.1.1 apply.

d)  Irrespective of *Client Device* or *Master Device* detection the
    *Channel Move Time* and *Channel Closing Transmission Time*
    requirements remain the same.

## 5.2 DFS Detection Thresholds  {#dfs-detection-thresholds .unnumbered}

**Table 3** below provides the *DFS Detection Thresholds* for *Master
Devices* as well as *Client Devices* incorporating *In-Service
Monitoring*.

Table 3: DFS Detection Thresholds for Master Devices and Client Devices
With Radar Detection

+---------------------------------------------+------------------------+
| Maximum Transmit Power                      | Value                  |
|                                             |                        |
|                                             | (See Notes 1 and 2)    |
+---------------------------------------------+------------------------+
| ≥ 200 milliwatt                             | -64 dBm                |
+---------------------------------------------+------------------------+
| \< 200 milliwatt                            | -62 dBm                |
+---------------------------------------------+------------------------+
| Note 1: This is the level at the input of   |                        |
| the receiver assuming a 0 dBi receive       |                        |
| antenna.                                    |                        |
|                                             |                        |
| Note 2: Throughout these test procedures an |                        |
| additional 1 dB has been added to the       |                        |
| amplitude of the test transmission          |                        |
| waveforms to account for variations in      |                        |
| measurement equipment. This will ensure     |                        |
| that the test signal is at or above the     |                        |
| detection threshold level to trigger a DFS  |                        |
| response.                                   |                        |
+---------------------------------------------+------------------------+

## 5.3 Response Requirements {#response-requirements .unnumbered}

**Table 4** provides the response requirements for *Master* and *Client
Devices* incorporating DFS.

Table 4: DFS Response Requirement Values

+-------------------------------------------------+--------------------+
| Parameter                                       | Value              |
+-------------------------------------------------+--------------------+
| *Non-occupancy period*                          | Minimum 30 minutes |
+-------------------------------------------------+--------------------+
| *Channel Availability Check Time*               | 60 seconds         |
+-------------------------------------------------+--------------------+
| *Channel Move Time*                             | 10 seconds         |
|                                                 |                    |
|                                                 | See Note 1.        |
+-------------------------------------------------+--------------------+
| *Channel Closing Transmission Time*             | 200 milliseconds + |
|                                                 | an aggregate of 60 |
|                                                 | milliseconds over  |
|                                                 | remaining 10       |
|                                                 | second period.     |
|                                                 |                    |
|                                                 | See Notes 1 and 2. |
+-------------------------------------------------+--------------------+
| *U-NII Detection Bandwidth*                     | Minimum 80% of the |
|                                                 | U-NII 99%          |
|                                                 | transmission power |
|                                                 | bandwidth. See     |
|                                                 | Note 3.            |
+-------------------------------------------------+--------------------+
| **Note 1:** The instant that the *Channel Move  |                    |
| Time* and the *Channel Closing Transmission     |                    |
| Time* begins is as follows:                     |                    |
|                                                 |                    |
| -   For the Short Pulse Radar Test Signals this |                    |
|     instant is the end of the *Burst*.          |                    |
|                                                 |                    |
| -   For the Frequency Hopping radar Test        |                    |
|     Signal, this instant is the end of the last |                    |
|     radar *Burst* generated.                    |                    |
|                                                 |                    |
| -   For the Long Pulse Radar Test Signal this   |                    |
|     instant is the end of the 12 second period  |                    |
|     defining the *Radar Waveform*.              |                    |
|                                                 |                    |
| **Note 2:** The *Channel Closing Transmission   |                    |
| Time* is comprised of 200 milliseconds starting |                    |
| at the beginning of the *Channel Move Time*     |                    |
| plus any additional intermittent control        |                    |
| signals required to facilitate a *Channel* move |                    |
| (an aggregate of 60 milliseconds) during the    |                    |
| remainder of the 10 second period. The          |                    |
| aggregate duration of control signals will not  |                    |
| count quiet periods in between transmissions.   |                    |
|                                                 |                    |
| **Note 3:** During the *U-NII Detection         |                    |
| Bandwidth* detection test, radar type 1 is used |                    |
| and for each frequency step the minimum         |                    |
| percentage of detection is 90 percent.          |                    |
| Measurements are performed with no data         |                    |
| traffic.                                        |                    |
+-------------------------------------------------+--------------------+

**6. RADAR TEST WAVEFORMS**

This section provides the parameters for required test waveforms,
minimum percentage of successful detections, and the minimum number of
trials that must be used for determining DFS conformance. Step intervals
of 0.1 microsecond for Pulse Width, 1 microsecond for PRI, 1 MHz for
chirp width and 1 for the number of pulses will be utilized for the
random determination of specific test waveforms.

**6.1 Short Pulse Radar Test Waveforms**

**Table 5 -- Short Pulse Radar** Test Waveforms

+---------+-------------+-------------+-------+------------+---------+
| Radar   | Pulse Width | PRI         | N     | Minimum    | Minimum |
| Type    |             |             | umber |            | Number  |
|         | (µsec)      | (µsec)      | of    | Percentage | of      |
|         |             |             | P     | of         |         |
|         |             |             | ulses | Successful | Trials  |
|         |             |             |       | Detection  |         |
+---------+-------------+-------------+-------+------------+---------+
| 1       | 1           | 1428        | 18    | 60%        | 30      |
+---------+-------------+-------------+-------+------------+---------+
| 2       | 1-5         | 150-230     | 23-29 | 60%        | 30      |
+---------+-------------+-------------+-------+------------+---------+
| 3       | 6-10        | 200-500     | 16-18 | 60%        | 30      |
+---------+-------------+-------------+-------+------------+---------+
| 4       | 11-20       | 200-500     | 12-16 | 60%        | 30      |
+---------+-------------+-------------+-------+------------+---------+
| Ag      |             |             |       | 80%        | 120     |
| gregate |             |             |       |            |         |
| (Radar  |             |             |       |            |         |
| Types   |             |             |       |            |         |
| 1-4)    |             |             |       |            |         |
+---------+-------------+-------------+-------+------------+---------+

A minimum of 30 unique waveforms are required for each of the Short
Pulse Radar Types 2 through 4. For Short Pulse Radar Type 1, the same
waveform is used a minimum of 30 times. If more than 30 waveforms are
used for Short Pulse Radar Types 2 through 4, then each additional
waveform must also be unique and not repeated from the previous
waveforms.

The aggregate is the average of the percentage of successful detections
of Short Pulse Radar Types 1-4. For example, the following table
indicates how to compute the aggregate of percentage of successful
detections.

  ----------------- ----------------- ----------------- -----------------
  Radar Type        Number of Trials  Number of         Minimum
                                      Successful        Percentage of
                                      Detections        Successful
                                                        Detection

  1                 35                29                82.9%

  2                 30                18                60%

  3                 30                27                90%

  4                 50                44                88%

  Aggregate                                             
  (82.9% + 60% +                                        
  90% + 88%)/4 =                                        
  80.2%                                                 
  ----------------- ----------------- ----------------- -----------------

2.  **Long Pulse Radar Test Waveform**

**Table 6 -- Long Pulse Radar Test Waveform**

+------+------+------+------+--------+--------+-----------+---------+
| R    | P    | C    | PRI  | Number | Number | Minimum   | Minimum |
| adar | ulse | hirp |      | of     | of     |           | Number  |
| Type | W    | W    | (µ   | Pulses | *B     | P         | of      |
|      | idth | idth | sec) | per    | ursts* | ercentage |         |
|      |      |      |      | *      |        | of        | Trials  |
|      | (µ   | (    |      | Burst* |        | S         |         |
|      | sec) | MHz) |      |        |        | uccessful |         |
|      |      |      |      |        |        | Detection |         |
+------+------+------+------+--------+--------+-----------+---------+
| 5    | 50   | 5-20 | 1    | 1-3    | 8-20   | 80%       | 30      |
|      | -100 |      | 000- |        |        |           |         |
|      |      |      | 2000 |        |        |           |         |
+------+------+------+------+--------+--------+-----------+---------+

The parameters for this waveform are randomly chosen. Thirty unique
waveforms are required for the Long Pulse Radar Type waveforms. If more
than 30 waveforms are used for the Long Pulse Radar Type waveforms, then
each additional waveform must also be unique and not repeated from the
previous waveforms.

Each waveform is defined as follows:

1)  The transmission period for the Long Pulse Radar test signal is 12
    seconds.

2)  There are a total of 8 to 20 *Bursts* in the 12 second period, with
    the number of *Bursts* being randomly chosen. This number is
    *Burst_Count*.

3)  Each *Burst* consists of 1 to 3 pulses, with the number of pulses
    being randomly chosen. Each *Burst* within the 12 second sequence
    may have a different number of pulses.

4)  The pulse width is between 50 and 100 microseconds, with the pulse
    width being randomly chosen. Each pulse within a *Burst* will have
    the same pulse width. Pulses in different *Bursts* may have
    different pulse widths.

5)  Each pulse has a linear frequency modulated chirp between 5 and 20
    MHz, with the chirp width being randomly chosen. Each pulse within a
    *Burst* will have the same chirp width. Pulses in different *Bursts*
    may have different chirp widths. The chirp is centered on the pulse.
    For example, with a radar frequency of 5300 MHz and a 20 MHz chirped
    signal, the chirp starts at 5290 MHz and ends at 5310 MHz.

6)  If more than one pulse is present in a *Burst*, the time between the
    pulses will be between 1000 and 2000 microseconds, with the time
    being randomly chosen. If three pulses are present in a *Burst*, the
    random time interval between the first and second pulses is chosen
    independently of the random time interval between the second and
    third pulses.

7)  The 12 second transmission period is divided into even intervals.
    The number of intervals is equal to *Burst_Count*. Each interval is
    of length (12,000,000 / *Burst_Count*) microseconds. Each interval
    contains one *Burst*. The start time for the *Burst*, relative to
    the beginning of the interval, is between 1 and \[(12,000,000 /
    *Burst_Count*) -- (Total *Burst* Length) + (One Random PRI
    Interval)\] microseconds, with the start time being randomly chosen.
    The step interval for the start time is 1 microsecond. The start
    time for each *Burst* is chosen randomly.

> **A representative example of a Long Pulse Radar Type waveform:**

1)  The total test waveform length is 12 seconds.

2)  Eight (8) *Bursts* are randomly generated for the *Burst_Count*.

3)  *Burst* 1 has 2 randomly generated pulses.

4)  The pulse width (for both pulses) is randomly selected to be 75
    microseconds.

5)  The PRI is randomly selected to be at 1213 microseconds.

6)  *Bursts* 2 through 8 are generated using steps 3 -- 5*.*

7)  Each *Burst* is contained in even intervals of 1,500,000
    microseconds. The starting location for Pulse 1, *Burst* 1 is
    randomly generated (1 to 1,500,000 minus the total *Burst* 1
    length + 1 random PRI interval) at the 325,001 microsecond step.
    *Bursts* 2 through 8 randomly fall in successive 1,500,000
    microsecond intervals (i.e. *Burst* 2 falls in the 1,500,001 --
    3,000,000 microsecond range).

> ![](media/image1.jpeg){width="6.020833333333333in"
> height="4.520833333333333in"}

**Figure 1** provides a graphical representation of the Long Pulse Radar
Test Waveform.

***Figure 1: Graphical Representation of a Long Pulse Radar Type
Waveform***

2.  **Frequency Hopping Radar Test Waveform**

**Table 7 -- Frequency Hopping Radar Test Waveform**

+-----+-----+-----+-----+--------+---------+--------------+---------+
| Ra  | Pu  | PRI | Pul | H      | Hopping | Minimum      | Minimum |
| dar | lse |     | ses | opping | S       | Percentage   | Number  |
| T   | Wid | (µs | per |        | equence | of           | of      |
| ype | th\ | ec) | Hop | Rate   |         | Successful   | Trials  |
|     | (µs |     |     |        | Length  | Detection    |         |
|     | ec) |     |     | (kHz)  | (msec)  |              |         |
+-----+-----+-----+-----+--------+---------+--------------+---------+
| 6   | 1   | 333 | 9   | 0.333  | 300     | 70%          | 30      |
+-----+-----+-----+-----+--------+---------+--------------+---------+

For the Frequency Hopping Radar Type, the same *Burst* parameters are
used for each waveform. The hopping sequence is different for each
waveform and a 100-length segment is selected from the hopping sequence
defined by the following algorithm: [^51]

The first frequency in a hopping sequence is selected randomly from the
group of 475 integer frequencies from 5250 -- 5724 MHz. Next, the
frequency that was just chosen is removed from the group and a frequency
is randomly selected from the remaining 474 frequencies in the group.
This process continues until all 475 frequencies are chosen for the set.
For selection of a random frequency, the frequencies remaining within
the group are always treated as equally likely.

**7. TEST PROCEDURES**

**7.1 Test Protocol**

For a *Master Device*, the DFS conformance requirements specified in
Section 7.8 will be verified utilizing one Short Pulse Radar Type
defined in **Table 5**. Additionally, the *Channel Move Time* and
*Channel Closing Transmission Time* requirements specified in Section
7.8 will be verified utilizing the Long Pulse Radar Type defined in
**Table 6**. The statistical performance check specified in Section 7.8
will be verified utilizing all Radar Types (1-6).

For a *Client Device* without DFS, the *Channel Move Time* and *Channel
Closing Transmission Time* requirements specified in Section 7.8 will be
verified with one Short Pulse Radar Type defined in **Table 5**.

For testing a *Client Device* with *In-Service Monitoring*, two
configurations must be tested.

1\) The *Client Device* detects the *Radar Waveform*. The *Channel Move
Time* and *Channel Closing Transmission Time* requirements specified in
Section 7.8 will be verified utilizing Short Pulse Radar Type defined in
**Table 5** and the Long Pulse Radar Type defined in **Table 6**. The
statistical performance check specified in Section 7.8 will be verified
utilizing all Radar Types (1-6). During this test, it must be ensured
that the *Client Device* is responding independently based on the
*Client Device's* self-detection rather than responding to detection by
the *Master Device*. The signal level of the *Radar Waveform* as
received by the *Client Device* must be set in accordance with the *DFS
Detection Threshold* specified by the DFS technical requirements
(**Table 3**).

2\) The *Master Device* detects the *Radar Waveform*. The *Channel Move
Time* and *Channel Closing Transmission Time* requirements specified in
Section 7.8 will be verified utilizing Short Pulse Radar Type defined in
**Table 5**. During this test, it must be ensured that the *Client
Device* is responding to detection by the *Master Device* rather than
self-detection by the *Client Device*.

For all tests of *Client Devices* (with or without *In-Service
Monitoring*), the *Master Device* to which the *Client Device* is
associated must meet the DFS conformance requirements.

Some of the tests may be performed more readily if a test mode for a
*Master Device* (or Client Device with *In-Service Monitoring*) is
provided that overrides the *Channel* selection mechanism for the
*Uniform Spreading* requirement to allow a specific *Channel* to be set
for startup (*Channel Availability Check*). In this mode it is
preferable that the *Master Device* will continue normal operation upon
starting (i.e. perform *Channel Availability Check* on the chosen
*Channel* and begin normal operation if no *Radar Waveform* is detected
-- or respond normally if a *Radar Waveform* is detected during the
*Channel Availability Check* or *In-Service Monitoring* on the chosen
*Channel*). However, this mode of operation is not required to
successfully complete the testing.

Other tests may be performed more readily if a test mode for a *Master
Device* (or a *Client Device* with *In-Service Monitoring*) is provided
that overrides the *Channel* move mechanism and simply provides a
display that a *Radar Waveform* was detected. In this mode it is
preferable that the UUT will continue operation on the same *Channel*
upon detecting a *Radar Waveform*. However, this mode of operation is
not required to successfully complete the testing.

Once a UUT is powered on, it will not start its normal operating
functions immediately, as it will have to finish its power-up cycle
first (T~power_up~). As such, the UUT, as well as any other device used
in the setup, may be equipped with a feature that indicates its status
during the testing, including, for example, power-up mode, normal
operation mode, *Channel Availability Check* status and radar detection
events.

The test transmission will always be from the *Master Device* to the
*Client Device*.

**7.2 Conducted Tests**

The sections below contain block diagrams that focus on the *Radar
Waveform* injection path for each of the different conducted setups to
be used. Each setup consists of a signal generator, analyzer (spectrum
analyzer or vector signal analyzer), *Master Device*, *Client Device*,
plus power combiner/splitters and attenuators. The *Client Device* is
set up to *Associate* with the *Master Device*. The designation of the
UUT (*Master Device* or *Client Device*) and the device into which the
*Radar Waveform* is injected varies among the setups.

Other topologies may be used provided that: (1) the radar and UUT
signals can be discriminated from each other on the analyzer and (2) the
radar *DFS Detection Threshold* level at the UUT is stable.

To address point (1), for typical UUT power levels and typical minimum
antenna gains, the topologies shown will result in the following
relative amplitudes of each signal as displayed on the analyzer: the
*Radar Waveform* level is the highest, the signal from the UUT is the
next highest, while the signal from the device that is associated with
the UUT is the lowest. Attenuator values may need to be adjusted for
particular configurations.

To address point (2), the isolation characteristic between ports 1 and 2
of a power combiner/splitter are extremely sensitive to the impedance
presented to the common port, while the insertion loss characteristic
between the common port and (port 1, for example) are relatively
insensitive to the impedance presented to (port 2, in this example).
Thus, the isolation between ports 1 and 2 should never be part of the
path that establishes the radar *DFS Detection Threshold*. The 10 dB
attenuator after the signal generator is specified as a precaution;
since many of the radar test waveforms will require typical signal
generators to operate with their ALC turned off, the source match will
generally be degraded from the closed loop specifications.

**7.2.1 Setup for Master with injection at the Master**

![](media/image2.wmf){width="5.4527777777777775in"
height="2.1444444444444444in"}*Figure 2: Example Conducted Setup where
UUT is a Master and Radar Test Waveforms are injected into the Master*

**7.2.2 Setup for Client with injection at the Master**

![](media/image3.wmf){width="5.177083333333333in"
height="2.1444444444444444in"}*Figure 3: Example Conducted Setup where
UUT is a Client and Radar Test Waveforms are injected into the Master*

**7.2.3 Setup for Client with injection at the Client**

![](media/image4.wmf){width="5.446527777777778in"
height="2.1444444444444444in"}*Figure 4: Example Conducted Setup where
UUT is a Client and Radar Test Waveforms are injected into the Client*

**7.3 Radiated Tests**

The subsections below contain simplified block diagrams that illustrate
the *Radar Waveform* injection path for each of the different radiated
setups to be used. The basic setup is identical for all cases.

**7.3.1 Master with injection at the Master**

![](media/image5.wmf){width="4.197916666666667in"
height="2.8652777777777776in"}

*Figure 5: Example Radiated Setup where UUT is a Master and Radar Test
Waveforms are injected into the Master*

**7.3.2 Client with injection at the Master**

![](media/image6.wmf){width="4.197916666666667in"
height="2.8652777777777776in"}

*Figure 6: Example Radiated Setup where UUT is a Client and Radar Test
Waveforms are injected into the Master*

**7.3.3 Client with injection at the Client**

![](media/image7.wmf){width="4.197916666666667in"
height="2.8652777777777776in"}

*Figure 7: Example Radiated Setup where UUT is a Client and radar Test
Waveforms are injected into the Client*

**7.4 Test Signal Generation**

A complete test system consists of two subsystems: (1) the *Radar
Waveform* generating subsystem and (2) the DFS monitoring subsystem.
Method #1 and Method #2 subsystems are described for the *Radar
Waveform* generating subsystem and the DFS monitoring subsystems. These
two subsystems are independent such that the Method #1 subsystem for one
function can be used with the Method #2 subsystem for the other
function.

The Method #1 subsystems schematics and a parts list are available to
those who are interested in replicating the custom hardware devices. The
custom software and data files that control this subsystem will be made
available to those who are interested.[^52]

The Method #2 subsystems used to generate simulated frequency hopping
waveforms will be made available to those who are interested.[^53]

Other instrument configurations may also be used. However, any
deviations from the subsystems described here must be submitted to the
FCC for evaluation.

**7.4.1 Radar Waveform Generating Subsystems**

Computer control is not necessary to generate the Short Pulse *Radar
Waveforms*. However, the Long Pulse *Radar Waveform* and Frequency
Hopping *Radar Waveforms* by their nature require computer control. Both
of the Frequency Hopping *Radar Waveform* generating subsystems can also
generate the required Short Pulse *Radar Waveforms*.

A manually operated Short Pulse *Radar Waveform* generating subsystem is
described, followed by descriptions of the computer controlled Frequency
Hopping *Radar Waveform* generating subsystems.

**7.4.1.1 Short Pulse Radar Waveform Generating Subsystem**

**Figure 8** shows the setup for the Short Pulse *Radar Waveform*
generating subsystem.

The pulse generator is adjusted to the shortest rise and fall times. The
pulse width, PRI, and number of pulses per *Burst* are set according to
the Short Pulse *Radar Waveforms* (**Table 5**). The pulse generator is
triggered manually. The trigger output from the pulse generator can also
be connected to the DFS monitoring subsystem as required to synchronize
the two subsystems.

The Signal Generator is set to the *Channel* center frequency and pulse
modulation mode. The amplitude is adjusted to achieve the specified *DFS
Detection Threshold* (**Table 3**).

![](media/image8.wmf){width="2.1666666666666665in"
height="1.8888888888888888in"}***Figure 8: Short Pulse Radar Waveform
Generating Subsystem***

**7.4.1.2 Method #1 Radar Waveform Generating Subsystems**

With the exception of the Frequency Doubler and the DFS Test Box, the
test and measurement system uses off-the-shelf components with
vendor-supplied software and customized software.[^54] **Figures 9a-9d**
shows the example setup for the Method #1 *Radar Waveform* Generating
Subsystems.

![](media/image9.wmf){width="6.500694444444444in"
height="7.949305555555555in"}

*Figure 9a: Example Short and Long Pulse Radar Waveform Generator*

![](media/image10.wmf){width="6.372222222222222in"
height="8.584722222222222in"}

*Figure 9b: Example Frequency Hopping Radar Waveform Generator*

The first step in generating the Frequency Hopping *Radar Waveform* is
accomplished by entering 274 sets of hopping sequences of the randomized
475 hop frequencies into a frequency list stored in memory in the
fast-switching microwave synthesizer.

Generation of the Frequency Hopping *Radar Waveform* proceeds as
follows: The center frequency of the microwave synthesizer is set
according to the frequency list in the synthesizer's memory. The
microwave synthesizer is set up to run for 10 seconds at a time (one
*Burst* period).[^55] During the ten-second-burst period, every 3
milliseconds the microwave synthesizer switches (hops) to the next
frequency in the frequency list. The microwave synthesizer's center
frequency is pulse modulated by a pulse train that consists of a *Burst*
of 900 pulses (each with a 1 microsecond pulse width) that occurs at the
beginning of the ten-second-burst period. The PRI of the *Burst* is 333
microsecond. Therefore, the hopping sequence length is 300 milliseconds
and there are 9 pulses per frequency hop.

Because the pulses occur within the first 300 millisecond of the
ten-second-burst period, only the first 100 frequencies out of a given
set of 475 randomized frequencies are actually transmitted. Therefore,
it is possible for none of the transmitted frequencies during a
ten-second-burst period to fall within the receiver bandwidth of the
U-NII device being tested. Whenever this occurs the particular
ten-second-burst period will not be included in the performance of the
U-NII device.

![](media/image11.wmf){width="4.083333333333333in"
height="4.677777777777778in"}

*Figure 9c: Example DFS Test Box*

![](media/image12.wmf){width="4.197916666666667in"
height="5.489583333333333in"}

*Figure 9d: Example Reference Oscillator Distribution*

**Quartz Oscillator Frequency Reference**

The quartz oscillator provides a 5 MHz frequency reference signal that
is distributed to the signal generators and measurement equipment via
the distribution amplifier.

**Distribution Amplifier**

The distribution amplifier takes the 5 MHz frequency reference signal
from the quartz oscillator, doubles it and distributes the resulting 10
MHz frequency reference signal to the critical signal generators and
measurement equipment. This ensures synchronization of the signal
generators and measurement equipment.

**Digital Oscilloscope**

The digital oscilloscope is used to examine the down-converted or
detected radar transmissions in a full 500 MHz bandwidth. This is used
to verify that the radar transmissions comply with the parameters as
specified by the radar test waveforms.

**Dual Channel Arbitrary Waveform Generator**

The dual channel arbitrary waveform generator (AWG) is used when the
system is configured to transmit frequency-hopping waveforms. The dual
channel AWG produces two synchronized pulse trains that provide signals
to control the fast-switching microwave synthesizer. One pulse train
controls the microwave synthesizer switches (hops) to the next frequency
in the frequency list. The other pulse train pulse modulates the RF
output of the microwave synthesizer.

**Microwave Detector and Matched Load**

The microwave detector is used to monitor the envelope of the RF radar
transmissions on the digital oscilloscope.

**Radar Transmit Antenna**

For radiated tests a log periodic antenna or equivalent directional
antenna is used to transmit the *Radar Waveforms* to the DFS device
during testing of the U-NII device.

**Single Channel Arbitrary Waveform Generator**

The single channel AWG is used when the *Radar Waveform* generator
system is configured to transmit the Short Pulse Radar Type 1-5
waveforms. The single channel AWG is used to generate a trigger signal
to begin transmission of the *Radar Waveform* and begin recording U-NII
transmissions on the vector signal analyzer (VSA).

**DFS Test Box**

The DFS Test Box is constructed using off-the-shelf components.[^56] The
DFS Test Box facilitates signal routing and monitoring for the radar
transmissions. The radar transmissions are routed to the RF input of the
DFS Test Box. The IF output provides a down-converted version of the RF
radar transmissions. Two ports are available for RF output. One is
connected to the log periodic antenna for radiated testing of the U-NII
devices or directly to the UUT for conducted testing. The other RF
output is connected to a microwave detector to display the envelope of
the RF radar transmissions. Both the IF output and the detector output
can be observed on the digital oscilloscope in a full 500 MHz bandwidth.
This allows observation of the frequency-hopping signal that hops across
475 MHz. Both the IF output and the detector output can be used to
verify *Radar Waveform* characteristics. The detector output can also be
used to verify that an RF output signal is present.

**Vector Signal Generator**

When the *Radar Waveform* generator system is configured to transmit the
frequency hopping signal, the vector signal generator (VSG) is used as a
5225 MHz continuous-wave (CW) signal source for the local oscillator
(LO) input to the DFS Test Box. When the *Radar Waveform* generator
system is configured to transmit radar type 1-5 waveforms, the VSG is
used to transmit the Short Pulse Radar Type 1-5 waveforms. The Short
Pulse Radar Type 1-5 waveforms are created using custom software.[^57]
After the waveforms are created they are loaded into the VSG.

**Personal Computer**

The personal computer is used to generate and load the frequency-hopping
list into and properly set up the fast-switching microwave synthesizer.

**Fast-Switching Microwave Synthesizer**

When the *Radar Waveform* generator system is configured to transmit the
Short Pulse Radar Type 1-5 waveforms, the microwave synthesizer is used
as a 5225 MHz CW signal source for the LO input to the DFS Test Box.
When the *Radar Waveform* generator system is configured to transmit the
frequency-hopping signal, the microwave synthesizer is used to transmit
the frequency-hopping signal. Custom software is used to generate and
load the hopping frequency list into and properly set up the
fast-switching microwave synthesizer. A pulse train generated by the
dual channel AWG controls when the microwave synthesizer switches (hops)
to the next frequency in the frequency list. Another pulse train from
the dual channel AWG pulse modulates the RF output of the microwave
synthesizer to complete the generation of the frequency-hopping signal.

**Vector Signal Analyzer**

The VSA is used for two distinct purposes. One use is to verify the
chirped radar transmissions of the Long Pulse Radar Type 5 waveforms.
The FM demodulation capability is used to verify the chirp frequency
range. The other use of the VSA is to provide 12 and 24 second
recordings of the U-NII device transmissions, with fine-time resolution,
during DFS testing. When Long Pulse Radar Type 5 waveforms are
transmitted, the 24-second recordings (with a time between samples of
approximately 675 nanoseconds) are taken; 12-second recordings (with a
time between samples of approximately 390 nanoseconds) are taken when
all other *Radar Waveforms* are transmitted.

The VSA receives a trigger signal from the *Radar Waveform* generator
system to initiate a recording. When the *Radar Waveform* generator
system is configured to transmit the Radar Type 1-5 waveforms, the
single-channel AWG provides the trigger signal. When the *Radar
Waveform* generator system is configured to transmit the frequency
hopping signal, the microwave synthesizer generates the trigger signal
when the frequency hopping radar transmission first falls within the
*U-NII Detection Bandwidth*.

**7.4.1.3 Method #2 Simulated Frequency Hopping Radar Waveform
Generating Subsystem**

The simulated frequency hopping signal generator system uses the
hardware that is used to manually generate Short Pulse *Radar Waveforms*
shown in **Figure 8**, with the addition of a control computer and a
*Burst* generator to create the hopping trigger pulse pattern. The
simulated signal generation approach produces both time-domain and
frequency-domain simulations of an actual frequency hopping signal. The
hardware configuration for an example Frequency Hopping *Radar Waveform*
generator is shown in **Figure 10**.

![](media/image13.wmf){width="3.3652777777777776in"
height="3.9631944444444445in"}

***Figure 10: Example Simulated Frequency Hopping Radar Generator
System***

**Conceptual Description of Simulated Frequency Hopping Generator**

Time-domain simulation: The simulated hopping system generates the same
number of hops, using identical pulse parameters, at the identical
timing compared to the actual hopping waveform, using a fixed frequency
within the *U-NII Detection Bandwidth*. Thus the detectable RF energy
received by the UUT is identical in both instances.

Frequency-domain simulation: Multiple trials are made, each at a
different fixed frequency. The frequencies selected for each trial lie
within the *U-NII Detection Bandwidth*. Thus the UUT receives RF energy
throughout the *U-NII Detection Bandwidth*.

**Figure 11** and **Figure 12** below show the comparison between an
example frequency hopping waveform and the corresponding simulated
hopping waveform. The horizontal axis is time and the vertical axis is
frequency (although the figures depict 3 pulses per hop, the actual
Frequency Hopping Radar Type 6 waveform contains 9 pulses per hop).

Referring to the actual hopping signal, the hops that are outside the
*U-NII Detection Bandwidth* are shown as three dots in **Figure 11** and
**Figure 12** and the hops that are within the *U-NII Detection
Bandwidth* are shown as three lines. The center of the lines indicates
the frequency of the hop. Note that three hops fall within the *U-NII
Detection Bandwidth*.

Referring to the simulated hopping signal, the hops that are generated
are shown as three lines. Note that three hops are generated, and each
hop is at the same frequency.

***Figure 11: Frequency Hopping Sequence***

***Figure 12: Time Domain Simulation of a Frequency Hopping Sequence***

The frequency hopping *Burst* generator is a programmable pulse
generator that is used to provide a trigger to generate the *Burst*
pattern trigger pulses and the monitoring system.

The pulse generator is configured to generate a single *Burst* of pulses
(refer to **Table 7** for the frequency hopping waveform parameters)
whenever triggered by the hopping *Burst* generator and is used as the
modulation input for the RF signal generator, set to pulse modulation.

**7.5 Setting the Test Signal Level**

The radar test signal level is set at the *Master Device,* or the Client
Device with *In-Service Monitoring*, as appropriate for the particular
test. This device is known as the Radar Detection Device (RDD). The RDD
consists of the applicable device and the device antenna assembly that
has the lowest antenna assembly gain of all available antenna
assemblies. Depending on the UUT, the following configurations exist:

-   When the *Master Device* is the UUT, the *Master Device* is the RDD.

-   When a *Client Device* without Radar Detection is the UUT, the
    *Master Device* is the RDD.

-   When a *Client Device* with Radar Detection is the UUT, and is
    tested for response to the *Master Device* detections, the *Master
    Device* is the RDD.

-   When a *Client Device* with Radar Detection is the UUT, and is
    tested for independent response to detections by the *Client
    Device*, the *Client Device* is the RDD.

A spectrum analyzer is used to establish the test signal level for each
radar type. During this process, there are no transmissions by either
the *Master* *Device* or *Client Device*. The spectrum analyzer is
switched to the zero span (time domain) mode at the frequency of the
*Radar Waveform* generator. The peak detector function of the spectrum
analyzer is utilized. The spectrum analyzer resolution bandwidth (RBW)
and video bandwidth (VBW) are set to at least 3 MHz.

The signal generator amplitude and/or step attenuators are set so that
the power level measured at the spectrum analyzer is equal to the *DFS
Detection Threshold* that is required for the tests. The signal
generator and attenuator settings are recorded for use during the test.

Data demonstrating that the test signal level is correctly set for each
radar type (1-6) will be recorded and reported.

**7.6 DFS Monitoring**

The DFS monitoring subsystem shown in **Figure 13** is used to verify
that the UUT has vacated the *Channel* in the specified time (*Channel
Closing Transmission Time* and *Channel Move Time*) and does not
transmit on a *Channel* for 30 minutes after the detection and *Channel*
move (*Non-Occupancy Period*). It is also used to monitor UUT
transmissions upon start-up (*Channel Availability Check Time*).

**7.6.1 Method #1**

The test setup of the Method #1 DFS monitoring subsystem is shown in
**Figure 13**. This subsystem consists of two major functional blocks.
One measures RF transmissions for a time period of 12 or 24 seconds and
the other measures RF transmissions for a time period of 30 minutes.

The 12 and 24 -second measurement is made with a VSA controlled by a
computer. A log-periodic antenna, or equivalent directional antenna,
connected to the VSA is used to receive the UUT transmissions. Upon
receiving a trigger signal from the signal generator system (AWG from
the Method #1 system and Pulse Generator from the Method #2 system), the
VSA will digitize the UUT transmissions for 12 or 24 seconds and stored.
The stored data are time tagged and the UUT transmissions can be
reviewed in voltage vs. time format using the software in the computer
controlling the VSA or in a suitable computer program to verify that the
UUT complies with the limits.[^58]

The 30 minute measuring time is made with a spectrum analyzer connected
to an omni antenna. Since the power of the UUT transmissions are well
above the noise floor of the analyzer, a preamplifier and tracking
pre-selector are not required for this measurement. The analyzer is set
to zero span, tuned to the center frequency of the UUT operating
*Channel*, with a peak detector function, and a 32 minute sweep time. If
any UUT transmissions occur within the observation time, they are
detected and recorded.

![](media/image14.wmf){width="4.21875in" height="3.4715277777777778in"}

***Figure 13: Example DFS Timing Monitoring Diagram for Method #1***

**7.6.2 Method #2**

The test setup of the Method #2 DFS monitoring subsystem is shown in
**Figure 14**. This provides coarser timing measurements than Method #1
and provides an upper bound measurement of the aggregate duration of the
*Channel Closing Transmission Time*.

![](media/image15.wmf){width="4.021527777777778in"
height="1.8416666666666666in"}

***Figure 14: Example DFS Timing Monitoring Diagram for Method #2***

With the spectrum analyzer set to zero span tuned to the center
frequency of the UUT operating channel at the radar simulated frequency,
peak detection, and max hold, the dwell time per bin is given by:

Dwell = S / B

where **Dwell** is the dwell time per spectrum analyzer sampling bin,
**S** is the sweep time and **B** is the number of spectrum analyzer
sampling bins.

An upper bound of the aggregate duration of the *Channel Closing
Transmission Time* is calculated by:

C = N \* Dwell

where **C** is the Closing Time, **N** is the number of spectrum
analyzer sampling bins showing a U-NII transmission and **Dwell** is the
dwell time per bin.

**7.7 Channel Loading**

System testing will be performed with the designated MPEG test file that
streams full motion video at 30 frames per second for *Channel*
loading.[^59] If the designated MPEG test file is not utilized then an
equivalent test file will be used, subject to FCC approval.

**7.7.1 IP Based Systems**

The MPEG test file will be transferred from the *Master Device* to the
*Client Device* for all test configurations.

**7.7.2 Frame Based Systems**

The MPEG test file will be transferred from the *Master Device* to the
*Client Device* for all test configurations. For frame based systems
with a fixed talk/listen ratio, the ratio will be set to 45%/55% during
the entirety for all test performed for DFS functionality of a
manufacturer's device under test. For frame based systems that
dynamically allocate the talk/listen ratio, the MPEG test file will be
transferred from the *Master Device* to the *Client Device* for all test
configurations.

**7.7.3 Other Systems**

Systems that do not employ IP or frame based architectures, or that
represent a combination of the two, must submit their *Uniform*
*Channel* *Spreading* methodology used in the compliance measurements to
the FCC for evaluation.

**7.8 DFS CONFORMANCE TEST PROCEDURES**

The tests in this section are run sequentially and the UUT must pass all
tests successfully. If the UUT fails any one of the tests it will count
as a failure of compliance. To show compliance, all tests must be
performed with waveforms randomly generated as specified with test
results meeting the required percentage of successful detection
criteria. All test results must be reported to the FCC. One frequency
will be chosen from the operating *Channels* of the UUT within the
5250-5350 MHz or 5470-5725 MHz bands.

**7.8.1 U-NII Detection Bandwidth**

Set up the generating equipment as shown in **Figure 8**, or equivalent.
Set up the DFS timing monitoring equipment as shown in **Figure 13** or
**Figure 14**. Set up the overall system for either radiated or
conducted coupling to the UUT.

Adjust the equipment to produce a single *Burst* of the Short Pulse
Radar Type 1 in **Table 5** at the center frequency of the UUT
*Operating Channel* at the specified *DFS Detection Threshold* level
found in **Table 3**.

Set the UUT up as a standalone device (no associated Client or Master,
as appropriate) and no traffic. Frame based systems will be set to a
talk/listen ratio of 0%/100% during this test.

Generate a single radar *Burst*, and note the response of the UUT.
Repeat for a minimum of 10 trials. The UUT must detect the *Radar
Waveform* using the specified *U-NII Detection Bandwidth* criterion
shown in **Table 4**.

Starting at the center frequency of the UUT operating *Channel*,
increase the radar frequency in 1 MHz steps, repeating the above test
sequence, until the detection rate falls below the *U-NII Detection
Bandwidth* criterion specified in **Table 4**. Record the highest
frequency (denote as F~H~) at which detection is greater than or equal
to the *U-NII Detection Bandwidth* criterion. Recording the detection
rate at frequencies above F~H~ is not required to demonstrate
compliance.

Starting at the center frequency of the UUT operating *Channel*,
decrease the radar frequency in 1 MHz steps, repeating the above test
sequence, until the detection rate falls below the *U-NII Detection
Bandwidth* criterion specified in **Table 4**. Record the lowest
frequency (denote as F~L~) at which detection is greater than or equal
to the *U-NII Detection Bandwidth* criterion. Recording the detection
rate at frequencies below F~L~ is not required to demonstrate
compliance.

The *U-NII Detection Bandwidth* is calculated as follows:

> *U-NII Detection Bandwidth* = F~H~ -- F~L~

The *U-NII Detection Bandwidth* must meet the *U-NII Detection
Bandwidth* criterion specified in **Table 4**. Otherwise, the UUT does
not comply with DFS requirements. This is essential to ensure that the
UUT is capable of detecting *Radar Waveforms* across the same frequency
spectrum that contains the significant energy from the system. In the
case that the *U-NII Detection Bandwidth* is greater than or equal to
the 99 percent power bandwidth for the measured F~H~ and F~L~, the test
can be truncated and the *U-NII Detection Bandwidth* can be reported as
the measured F~H~ and F~L~.

**7.8.2 Performance Requirements Check**

The following tests must be performed for U-NII device certification:
Initial *Channel Startup Check* with a radar *Burst* at start of
*Channel Availability Check* and with a radar *Burst* at end of *Channel
Availability Check*; *In-Service Monitoring*; and the 30 minute
*Non-Occupancy Period*.

**7.8.2.1 Initial Channel Availability Check Time**

The Initial *Channel Availability Check Time* tests that the UUT does
not emit beacon, control, or data signals on the test *Channel* until
the power-up sequence has been completed and the U-NII device checks for
*Radar Waveforms* for one minute on the test *Channel*. This test does
not use any *Radar Waveforms* and only needs to be performed one time.

a)  The U-NII devices will be powered on and be instructed to operate on
    the appropriate U-NII *Channel* that must incorporate DFS functions.
    At the same time the UUT is powered on, the spectrum analyzer will
    be set to zero span mode with a 3 MHz RBW and 3 MHz VBW on the
    *Channel* occupied by the radar (Ch~r~) with a 2.5 minute sweep
    time. The spectrum analyzer's sweep will be started at the same time
    power is applied to the U-NII device.

b)  The UUT should not transmit any beacon or data transmissions until
    at least 1 minute after the completion of the power-on cycle.

This measurement can be used to determine the length of the power-on
cycle if it is not supplied by the manufacturer. If the spectrum
analyzer sweep is started at the same time the UUT is powered on and the
UUT does not begin transmissions until it has completed the cycle, the
power-on time can be determined by comparing the two times.

**7.8.2.2 Radar Burst at the Beginning of the Channel Availability Check
Time**

The steps below define the procedure to verify successful radar
detection on the test *Channel* during a period equal to the *Channel
Availability Check Time* and avoidance of operation on that *Channel*
when a radar *Burst* with a level equal to the *DFS Detection
Threshold* + 1 dB occurs at the beginning of the *Channel Availability
Check Time*. This is illustrated in **Figure 15**.

a)  The *Radar Waveform* generator and UUT are connected using the
    applicable test setup described in the sections on configuration for
    Conducted Tests (7.2) or Radiated Tests (7.3) and the power of the
    UUT is switched off.

b)  The UUT is powered on at T~0~. T~1~ denotes the instant when the UUT
    has completed its power-up sequence (T~power_up~). The *Channel
    Availability Check Time* commences on Ch~r~ at instant T~1~ and will
    end no sooner than T~1~ + T~ch_avail_check~.

c)  A single *Burst* of one of the Short Pulse Radar Types 1-4 will
    commence within a 6 second window starting at T~1~. An additional 1
    dB is added to the radar test signal to ensure it is at or above the
    *DFS Detection Threshold*, accounting for equipment
    variations/errors.

d)  Visual indication or measured results on the UUT of successful
    detection of the radar *Burst* will be recorded and reported.
    Observation of Ch~r~ for UUT emissions will continue for 2.5 minutes
    after the radar *Burst* has been generated.

e)  Verify that during the 2.5 minute measurement window no UUT
    transmissions occurred on Ch~r~. The *Channel* *Availability Check*
    results will be recorded.

> ![](media/image16.wmf){width="5.521527777777778in"
> height="4.2034722222222225in"}

*Figure 15: Example of timing for radar testing at the beginning of the
Channel Availability Check Time*

#####  {#section .unnumbered}

**7.8.2.3 Radar Burst at the End of the Channel Availability Check
Time**

The steps below define the procedure to verify successful radar
detection on the test *Channel* during a period equal to the *Channel
Availability Check Time* and avoidance of operation on that *Channel*
when a radar *Burst* with a level equal to the *DFS Detection
Threshold* + 1dB occurs at the end of the *Channel Availability Check
Time*. This is illustrated in **Figure 16**.

a)  The *Radar Waveform* generator and UUT are connected using the
    applicable test setup described in the sections for Conducted Tests
    (7.2) or Radiated Tests (7.3) and the power of the UUT is switched
    off.

b)  The UUT is powered on at T~0~. T~1~ denotes the instant when the UUT
    has completed its power-up sequence (T~power_up~). The *Channel
    Availability Check Time* commences on Ch~r~ at instant T~1~ and will
    end no sooner than T~1~ + T~ch_avail_check~.

c)  A single *Burst* of one of the Short Pulse Radar Types 1-4 will
    commence within a 6 second window starting at T~1~ + 54 seconds. An
    additional 1 dB is added to the radar test signal to ensure it is at
    or above the *DFS Detection Threshold*, accounting for equipment
    variations/errors.

d)  Visual indication or measured results on the UUT of successful
    detection of the radar *Burst* will be recorded and reported.
    Observation of Ch~r~ for UUT emissions will continue for 2.5 minutes
    after the radar *Burst* has been generated.

e)  Verify that during the 2.5 minute measurement window no UUT
    transmissions occurred on Ch~r~. The *Channel Availability Check*
    results will be recorded.

> ![](media/image17.wmf){width="5.479861111111111in"
> height="4.134027777777778in"}

*Figure 16: Example of timing for radar testing towards the end of the
Channel Availability Check Time*

**7.8.3 In-Service Monitoring for Channel Move Time, Channel Closing
Transmission Time and Non-Occupancy Period**

These tests define how the following DFS parameters are verified during
*In-Service Monitoring;*

-   *Channel Closing Transmission Time*

-   *Channel Move Time*

-   *Non-Occupancy Period*

The steps below define the procedure to determine the above mentioned
parameters when a radar *Burst* with a level equal to the *DFS Detection
Threshold* + 1dB is generated on the *Operating Channel* of the U-NII
device *(In- Service Monitoring).*

a)  One frequency will be chosen from the *Operating Channels* of the
    UUT within the 5250-5350 MHz or 5470-5725 MHz bands.

b)  In case the UUT is a U-NII device operating as a *Client Device*
    (with or without DFS), a U-NII device operating as a *Master Device*
    will be used to allow the UUT (Client device) to *Associate* with
    the *Master Device*. In case the UUT is a *Master Device*, a U-NII
    device operating as a *Client Device* will be used and it is assumed
    that the Client will *Associate* with the UUT (Master). In both
    cases for conducted tests, the *Radar Waveform* generator will be
    connected to the *Master Device*. For radiated tests, the emissions
    of the *Radar Waveform* generator will be directed towards the
    *Master Device*. If the *Master Device* has antenna gain, the main
    beam of the antenna will be directed toward the radar emitter.
    Vertical polarization is used for testing.

c)  Stream the MPEG test file from the *Master Device* to the *Client
    Device* on the test *Channel* for the entire period of the test.

d)  At time T~0~ the *Radar Waveform* generator sends a *Burst* of
    pulses for one of the Short Pulse Radar Types 1-4 in **Table 5** at
    levels defined in **Table 3**, on the *Operating Channel*. An
    additional 1 dB is added to the radar test signal to ensure it is at
    or above the *DFS Detection Threshold*, accounting for equipment
    variations/errors.

e)  Observe the transmissions of the UUT at the end of the radar *Burst*
    on the *Operating Channel* for duration greater than 10 seconds.
    Measure and record the transmissions from the UUT during the
    observation time (*Channel Move Time)*. Measure and record the
    *Channel Move Time* and *Channel Closing Transmission Time* if radar
    detection occurs. **Figure 17** illustrates *Channel Closing
    Transmission Time.*

f)  When operating as a *Master Device*, monitor the UUT for more than
    30 minutes following instant T~2~ to verify that the UUT does not
    resume any transmissions on this *Channel*. Perform this test once
    and record the measurement result.

g)  In case the UUT is a U-NII device operating as a *Client Device*
    with *In-Service Monitoring*, perform steps a) to f).

> ![](media/image18.wmf){width="5.510416666666667in"
> height="1.9402777777777778in"}
>
> *Figure 17: Example of Channel Closing Transmission Time & Channel
> Closing Time*

**7.8.4 Statistical Performance Check**

The steps below define the procedure to determine the minimum percentage
of successful detection requirements found in **Tables 5-7** when a
radar burst with a level equal to the *DFS Detection Threshold* + 1dB is
generated on the *Operating Channel* of the U-NII device *(In- Service
Monitoring).*

a)  One frequency will be chosen from the *Operating Channels* of the
    UUT within the 5250-5350 MHz or 5470-5725 MHz bands.

b)  In case the UUT is a U-NII device operating as a *Client Device*
    (with or without Radar Detection), a U-NII device operating as a
    *Master Device* will be used to allow the UUT (Client device) to
    *Associate* with the *Master Device*. In case the UUT is a *Master
    Device*, a U-NII device operating as a *Client Device* will be used
    and it is assumed that the Client will *Associate* with the UUT
    (Master). In both cases for conducted tests, the *Radar Waveform*
    generator will be connected to the *Master Device*. For radiated
    tests, the emissions of the *Radar Waveform* generator will be
    directed towards the *Master Device*. If the *Master Device* has
    antenna gain, the main beam of the antenna will be directed toward
    the radar emitter. Vertical polarization is used for testing.

c)  Stream the MPEG test file from the *Master Device* to the Client
    Device on the test *Channel* for the entire period of the test.

d)  At time T~0~ the *Radar Waveform* generator sends the individual
    waveform for each of the Radar Types 1-6 in **Tables 5-7**, at
    levels defined in **Table 3**, on the *Operating Channel*. An
    additional 1 dB is added to the radar test signal to ensure it is at
    or above the *DFS Detection Threshold*, accounting for equipment
    variations/errors.

e)  Observe the transmissions of the UUT at the end of the Burst on the
    *Operating Channel* for duration greater than 10 seconds for Short
    Pulse Radar Types 1-4 and 6 to ensure detection occurs.

f)  Observe the transmissions of the UUT at the end of the Burst on the
    *Operating Channel* for duration greater than 22 seconds for Long
    Pulse Radar Type 5 to ensure detection occurs.

g\) In case the UUT is a U-NII device operating as a *Client Device*
with *In-Service*

*Monitoring*, perform steps a) to f).

**7.8.4.1 Short Pulse Radar Test**

Once the performance requirements check is complete, statistical data
will be gathered, to determine the ability of the device to detect the
radar test waveforms (Short Pulse Radar Types 1-4) found in **Table 5**.
The device can utilize a test mode to demonstrate when detection occurs
to prevent the need to reset the device between trials. The percentage
of successful detection is calculated by:

![](media/image19.wmf){width="2.2083333333333335in"
height="0.4583333333333333in"} = Percentage of Successful Detection
*Radar Waveform* N = P~d~N

In addition an aggregate minimum percentage of successful detection
across all Short Pulse Radar Types 1-4 is required and is calculated as
follows:

![](media/image20.wmf){width="1.5965277777777778in" height="0.44375in"}

The minimum number of trails, minimum percentage of successful detection
and the aggregate minimum percentage of successful detection are found
in **Table 5**.

**7.8.4.2 Long Pulse Radar Test**

Statistical data will be gathered to determine the ability of the device
to detect the Long Pulse Radar Type 5 found in **Table 6**. The device
can utilize a test mode to demonstrate when detection occurs to prevent
the need to reset the device between trials. The percentage of
successful detection is calculated by:

![](media/image21.wmf){width="2.2083333333333335in"
height="0.4583333333333333in"}

**7.8.4.3 Frequency Hopping Radar Test**

Statistical data will be gathered to determine the ability of the device
to detect the Frequency Hopping radar test signal (radar type 6) found
in **Table 7**. The device can utilize a test mode to demonstrate when
detection occurs to prevent the need to reset the device between trial
runs. The probability of successful detection is calculated by:

![](media/image21.wmf){width="2.2083333333333335in"
height="0.4583333333333333in"}

**8. DFS TEST REPORT GUIDELINES**

The following items will be included in test reports for DFS testing of
U-NII devices as indicated in the sections below. This section covers
the minimum requirements that will be submitted on the DFS test results.

**8.1 Complete description of the U-NII device**

1.  The operating frequency range(s) of the equipment.

2.  The operating modes (Master and/or Client) of the U-NII device.

3.  For Client devices, indicate whether or not it has radar detection
    capability and indicate the FCC identifier for the Master U-NII
    Device that is used with it for DFS testing.

4.  List the highest and the lowest possible power level (equivalent
    isotropic radiated power (EIRP)) of the equipment.

5.  List all antenna assemblies and their corresponding gains.

    a.  If radiated tests are to be performed, the U-NII Device should
        be tested with the lowest gain antenna assembly (regardless of
        antenna type). The report should indicate which antenna assembly
        was used for the tests. For devices with adjustable output
        power, list the output power range and the maximum EIRP for each
        antenna assembly.

    b.  If conducted tests are to be performed, indicate which antenna
        port/connection was used for the tests and the antenna assembly
        gain that was used to set the *DFS Detection Threshold* level
        during calibration of the test setup.

        i.  Indicate the calibrated conducted *DFS Detection Threshold*
            level.

        ii. For devices with adjustable output power, list the output
            power range and the maximum EIRP for each antenna assembly.

        iii. Indicate the antenna connector impedance. Ensure that the
             measurement instruments match (usually 50 Ohms) or use a
             minimum loss pad and take into account the conversion loss.

    c.  Antenna gain measurement verification for tested antenna.

        i.  Describe procedure

        ii. Describe the antenna configuration and how it is mounted

        iii. If an antenna cable is supplied with the device, cable loss
             needs to be taken into account. Indicate the maximum cable
             length and either measure the gain with this cable or
             adjust the measured gain accordingly. State the cable loss.

6.  Test sequences or messages that should be used for communication
    between Master and *Client Devices*, which are used for loading the
    *Channel*.

    a.  Stream the test file from the *Master Device* to the *Client
        Device f*or IP based systems or frame based systems which
        dynamically allocate the talk/listen ratio.

    b.  For frame based systems with fixed talk/listen ratio, set the
        ratio to 45%/55% and stream the test file from the *Master* to
        the *Client.*

    c.  For other system architectures, supply appropriate *Channel*
        loading methodology.

7.  Transmit Power Control description

> Provide a description.

8.  System architectures, data rates, U-NII *Channel* bandwidths.

    a.  Indicate the type(s) of system architecture (e.g. IP based or
        Frame based) that the U-NII device employs. Each type of unique
        architecture must be tested.

9.  The time required for the *Master Device* and/or *Client Device* to
    complete its power-on cycle.

10. Manufacturer statement confirming that information regarding the
    parameters of the detected *Radar Waveforms* is not available to the
    end user.

11. *Uniform Channel Spreading* requirement for *Master Devices*. For
    *Master Devices*, indicate how the master provides, on aggregate,
    uniform *Channel* loading of the spectrum across all *Channels.*

**8.2 Complete description of the Radar Waveform calibration**

12. Description of calibration setup

    a.  Block diagram of equipment setup, clearly identifying if a
        radiated or conducted method was used.

13. Description of calibration procedure

    a.  Verify *DFS Detection Threshold* levels

        i.  Indicate *DFS Detection Threshold* levels used.

        ii. Consider output power range and antenna gain.

    b.  For the Short Pulse Radar Types, spectrum analyzer plots of the
        burst of pulses on the *Channel* frequency should be provided.

    c.  For the Long Pulse Radar Type, spectrum analyzer plot of a
        single burst (1-3 pulses) on the *Channel* frequency should be
        provided.

    d.  Describe method used to generate frequency hopping signal.

    e.  The *U-NII Detection Bandwidth*

    f.  For the Frequency Hopping waveform, a spectrum analyzer plot
        showing 9 pulses on one frequency within the *U-NII Detection
        Bandwidth* should be provided.

    g.  Verify use of vertical polarization for testing when using a
        radiated test method.

14. When testing a *Client Device* with radar detection capability,
    verify that the *Client Device* is responding independently based on
    the *Client Device's* self-detection rather than responding to the
    *Master Device*. If required, provide a description of the method
    used to isolate the client from the transmissions from the *Master
    Device* to ensure *Client Device* self detection of the *Radar
    Waveform*.

**8.3 Complete description of test procedure**

15. Description of deviations to the procedures or equipment described
    in this document.

16. Description of DFS test procedure and test setup used to monitor the
    U-NII device and *Radar Waveform* transmissions. Provide a block
    diagram of the signal monitoring equipment setup.

    a.  List of equipment

    b.  Test setup photos

17. Description of DFS test procedure and test setup used to generate
    the *Radar Waveforms*.

    a.  Block diagram of equipment setup

    b.  List of equipment

    c.  Test setup photos

    d.  For each of the waveforms that were used for each signal type,
        supply the characteristics (pulse width, pulse repetition
        interval, number of pulses per burst, modulation).

    e.  For selecting the waveform parameters from within the bounds of
        the signal type, describe how they were selected (i.e., random
        selection using uniform distribution).

18. The DFS tests are to be performed on U-NII *Channel(s)* at the
    smallest U-NII *Channel* bandwidth (worst case).

    i.  List each *Channel* frequency that was used for the tests.

    ii. Data Sheet showing the *U-NII Detection Bandwidth* for the
        *Channel(s)* used during the test.

    iii. Plot of RF measurement system showing its nominal noise floor
         in the same bandwidth which is used to perform the *Channel
         Availability Check*, initial radar bursts, *In-Service
         Monitoring*, and 30 minute *Non-Occupancy Period* tests.

19. Timing plot(s) showing compliance with the *Channel Availability
    Check* *Time* requirement of 60 seconds at start up.

    a.  The plot should show the Initial T~power-up~ time.

    b.  The plot should include the Initial T~power-up~ period in
        addition to 60 second period.

20. Timing plot(s) showing compliance with the Initial DFS radar
    detection requirements during the 60 second initial *Channel
    Availability Check* at start up.

    a.  Plot for DFS radar detection for *Radar Waveforms* applied 6
        seconds after the Initial T~power-up~ time period. The minimum
        length of the plot should be 1.5 minutes after the T~power-up~
        time period. The plot should show the radar burst at the
        appropriate time. This test is only required once and the Short
        Pulse radar Type 1 should be used for the test.

    b.  Plot for DFS radar detection for *Radar Waveforms* applied 6
        seconds before end of the 60 second *Channel Availability Check*
        Time. The minimum length of the plot should be 1.5 minutes
        T~power-up~ time period. The plot should show the radar burst at
        the appropriate time. This test is only required once the Short
        Pulse Radar Type 1 should be used for the test.

    c.  The minimum time resolution of the plots should be sufficient to
        show the *Radar Waveform* bursts (overall, not individual pulses
        within the burst).

21. Verification that when the device is "off" that the RF energy
    emitted is below the FCC rules for unintentional radiators:

> For the plots of U-NII RF activity versus time, the device is
> considered to be "off" or not transmitting when intentional U-NII
> signals (beacons, data packets or transmissions, or control signals)
> are below the FCC rules for unintentional radiation due to device
> leakage, oscillator noise, clocks, and other unintentional RF
> generators.

22. Spectrum Analyzer, VSA, or some other data gathering Instrument
    plots showing compliance with the *Channel Move Time* requirements
    during in the *In-Service Monitoring* testing for the Short and Long
    Pulse Radar Types. The plots need to show U-NII device transmissions
    on the *Channel* in the form of RF activity on the vertical axis
    versus time on the horizontal axis. Only one 10 second plot needs to
    be reported for the Short Pulse Radar Types 1-4 and one for the Long
    Pulse Radar Type in a 22 second plot. The plot for the Short Pulse
    Radar Types should start at the end of the radar burst. The Long
    Pulse Radar Type plot only needs to show the device ceased
    transmissions within the 10 second window after detection has
    occurred. The plot for the Long Pulse Radar Type should start at the
    beginning of the 12 second waveform. However, the *Channel Move
    Time* will be calculated based on the plot of the Short Pulse Radar
    type.

> The plots need to show U-NII device transmissions on the *Channel* in
> the form of RF activity on the vertical axis versus time on the
> horizontal axis. Sufficient resolution should be used.
>
> Only one 10 second plot needs to be reported for the Short Pulse Radar
> Types 1-4 and one for the Long Pulse Radar Type test in a 22 second
> plot. The plot for the Short Pulse Radar Types should start at the end
> of the radar burst. The *Channel Move Time* will be calculated based
> on the plot of the Short Pulse Radar Type.
>
> The Long Pulse Radar Type plot only needs to show the device ceased
> transmissions within the 10 second window after detection has
> occurred. The plot for the Long Pulse Radar Type should start at the
> beginning of the 12 second waveform.

a.  The plots and/or data must show the U-NII Device's compliance with
    the 200 milliseconds limit on data transmission and compliance with
    the 60 millisecond aggregate limit found in **Table 4**.

b.  Indicate the total number of times the test was performed.

c.  Indicate a detect/not detect for each waveform within a signal type
    and the number of failures and the number of successful radar
    detection times within the time limit. Sample data sheets are shown
    in **Tables 8-10**.

d.  Verify compliance with the minimum percentage of successful
    detection requirements found in **Tables 5-7**.

```{=html}
<!-- -->
```
23. Spectrum Analyzer plot(s) showing compliance with the 30 minute
    *Non-Occupancy Period* requirement.

> Only one plot is required. This is a separate test that is performed
> in addition to the other *In-Service Monitoring* tests. However, any
> type of *Radar Waveform* can be used for this test.

**Table 8:** **Sample Detection Data Sheet for Radar Types 1, 5, and 6**

**(Use a Separate Data Sheet for Each Radar Type)**

  ------------- ----------- ---------------- -------------- ---------------
  **Radar       **Trial     **Detection**    **Trial \#**   **Detection**
  Type**        \#**                                        

                            **Yes / No**                    **Yes / No**

  **1, 5 or 6** **1**                        **16**         

                **2**                        **17**         

                **3**                        **18**         

                **4**                        **19**         

                **5**                        **20**         

                **6**                        **21**         

                **7**                        **22**         

                **8**                        **23**         

                **9**                        **24**         

                **10**                       **25**         

                **11**                       **26**         

                **12**                       **27**         

                **13**                       **28**         

                **14**                       **29**         

                **15**                       **30**         
  ------------- ----------- ---------------- -------------- ---------------

**Table 9:** **Sample Data Sheet for Radar Types 2, 3, or 4**

**(Use a Separate Data Sheet for Each Radar Type)**

+---------+--------+-----------+-------+-----------+-----------------+
| **Radar | *      | **Number  | **    | **PRI**   | **Detection**   |
| Type**  | *Trial | Pulses**  | Pulse |           |                 |
|         | \#**   |           | Wi    | **(µs)**  |                 |
|         |        | **per     | dth** |           |                 |
|         |        | Burst**   |       |           |                 |
|         |        |           | **(   |           |                 |
|         |        |           | µs)** |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         |        |           |       |           | **Yes / No**    |
+---------+--------+-----------+-------+-----------+-----------------+
| **2, 3, | 1      |           |       |           |                 |
| or 4**  |        |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 2      |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 3      |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 4      |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 5      |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 6      |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 7      |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 8      |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 9      |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 10     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 11     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 12     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 13     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 14     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 15     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 16     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 17     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 18     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 19     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 20     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 21     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 22     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 23     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 24     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 25     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 26     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 27     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 28     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 29     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+
|         | 30     |           |       |           |                 |
+---------+--------+-----------+-------+-----------+-----------------+

**Table 10:** **Sample Parameter Data Sheet for Radar Type 5**

**(Use a separate data sheet for each trial)**

+-----+--------+------+------+-----------+-----------+----------------+
| # R |        |      |      |           |           |                |
| ada |        |      |      |           |           |                |
| r T |        |      |      |           |           |                |
| ype |        |      |      |           |           |                |
|  5  |        |      |      |           |           |                |
| {#r |        |      |      |           |           |                |
| ada |        |      |      |           |           |                |
| r-t |        |      |      |           |           |                |
| ype |        |      |      |           |           |                |
| -5  |        |      |      |           |           |                |
| .un |        |      |      |           |           |                |
| num |        |      |      |           |           |                |
| ber |        |      |      |           |           |                |
| ed} |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| *   |        |      |      |           |           |                |
| *Tr |        |      |      |           |           |                |
| ial |        |      |      |           |           |                |
| Num |        |      |      |           |           |                |
| ber |        |      |      |           |           |                |
| :** |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| **  |        |      |      |           |           |                |
| Num |        |      |      |           |           |                |
| ber |        |      |      |           |           |                |
| of  |        |      |      |           |           |                |
| Bur |        |      |      |           |           |                |
| sts |        |      |      |           |           |                |
| in  |        |      |      |           |           |                |
| Tr  |        |      |      |           |           |                |
| ial |        |      |      |           |           |                |
| :** |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| **B | **Nu   | *    | *    | **Pulse   | **Pulse   | **Starting     |
| urs | mber** | *Pul | *Chi | 1-to-2**  | 2-to-3**  | Location**     |
| t** |        | se** | rp** |           |           |                |
|     | **of** |      |      | **        | **        | **Within       |
|     |        | *    | *    | Spacing** | Spacing** | Interval**     |
|     | **Pu   | *Wid | *Wid |           |           |                |
|     | lses** | th** | th** | *         | *         | **(µsec)**     |
|     |        |      |      | *(µsec)** | *(µsec)** |                |
|     |        | **   | *    |           |           |                |
|     |        | (µse | *(MH |           |           |                |
|     |        | c)** | z)** |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 1   |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 2   |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 3   |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 4   |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 5   |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 6   |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 7   |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 8   |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 9   |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 10  |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 11  |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 12  |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 13  |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 14  |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 15  |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 16  |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 17  |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 18  |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 19  |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+
| 20  |        |      |      |           |           |                |
+-----+--------+------+------+-----------+-----------+----------------+

**STATEMENT OF**

**COMMISSIONER MICHAEL J. COPPS**

 

 

> *Re:    Revision of Parts 2 and 15 of the Commission's Rules to Permit
> Unlicensed National Information Infrastructure (U-NII) Devices in the
> 5 GHz Band, Memorandum Opinion and Order, ET Docket No. 03-122*

I am very pleased that we announce a revised measurement procedure today
for certifying U-NII devices in the 5GHz band. I look forward to seeing
a new wave of devices that make use of this unlicensed band to bring
valuable services to American businesses and consumers.

I am particularly pleased about the cooperative effort between
government and industry that has given rise to the rules we adopt today.
I am very thankful to our excellent Office of Engineering and Technology
(OET), the ITAC-R Government/Industry Project Team, and the National
Telecommunications and Information Administration (NTIA) for their hard
work. The Commission reaches its best results in highly complex areas
like this one when it can draw on the widest body of technical
expertise, and I hope that this proceeding can be a model for future
spectrum rulemakings.

**STATEMENT OF**

**COMMISSIONER JONATHAN S. ADELSTEIN**

*Re: Revision of Parts 2 and 15 of the Commission's Rules to Permit
Unlicensed National Information Infrastructure (U-NII) Devices;
Memorandum Opinion and Order; ET Docket No. 03-122*

I am pleased to support this item because it marks the beginning of a
significant new phase in the development and deployment of wireless
broadband services. The growth of unlicensed devices over the past
several years, in particular, has been an unmitigated success, and our
decision today paves the way for the authorization of devices to use an
additional 255 MHz of spectrum in the 5 GHz band, a significant increase
in spectrum capacity for unlicensed uses.

Much credit for our decision goes to the joint efforts of industry and
Government representatives through our ITAC-R Government/Industry
Project Team. They have worked tirelessly to develop revised equipment
authorization requirements for proposed devices in the band using
dynamic frequency selection (DFS). I am hopeful that their ground
breaking work on DFS and measurement procedures will allow us to develop
innovative and creative spectrum policies in the future.

**STATEMENT OF**

**COMMISSIONER ROBERT M. McDOWELL**

Re: *Revision of Parts 2 and 15 of the Commission's Rules to Permit
Unlicensed National Information and Infrastructure (U-NII) Devices in
the 5 GHz Band*, *Memorandum Opinion and Order, ET Docket No. 03-122*

I am pleased to support this item, which adopts a revised compliance
measurement procedure for certifying devices operating in the 5 GHz
band. I especially acknowledge the Commission's Office of Engineering
and Technology (OET), as well as the members of the International
Telecommunication Advisory Committee -- Radiocommunication (ITAC-R), for
completing this challenging and technically difficult project. This
government-industry partnership is a wonderful example of the myriad
benefits that can result from cooperative collaboration, such as:
protection to government users, certainty to manufacturers seeking to
design and market new equipment, more robust use of the spectrum band,
and delivery of new wireless broadband services to American consumers. I
thank everyone involved.

[^1]: *Revision of Parts 2 and 15 of the Commission's Rules to Permit
    Unlicensed National Information Infrastructure (U-NII) devices in
    the 5 GHz band*, ET Docket No. 03-122, *Report and Order*, 18 FCC
    Rcd. 24484 (2004) ("*Report and Order*").

[^2]: *Revision of Parts 2 and 15 of the Commission's Rules to Permit
    Unlicensed National Information Infrastructure (U-NII) devices in
    the 5 GHz band*, ET Docket No. 03-122, *Order*, 21 FCC Rcd 1816
    (2006). Applications for equipment certification of U-NII devices
    filed on or after July 20, 2006 must comply with the U-NII rules for
    TPC and DFS. All U-NII devices operating in these bands that are
    imported or marketed on or after July 20, 2007 also must comply with
    the TPC and DFS requirements.

[^3]: *See* 47 C.F.R. § 15.403(s).

[^4]: *See* Appendix C of the *Report and Order*: Interim Measurement
    Procedures for DFS-Equipped U-NII Devices.

[^5]: *See* Letter from Fredrick R. Wentland, Associate Administrator,
    NTIA to Julius Knapp, Deputy Chief, OET, filed March 30, 2006, and
    the enclosure *Compliance Measurement Procedures for Unlicensed
    National Information Infrastructure Devices Operating in the
    5250-5350 MHz and 5470-5725 MHz bands Incorporating Dynamic
    Frequency Selection (Compliance Measurement Procedures)*.

[^6]: These petitions were placed on Public Notice, Report No. 2653, on
    April 1, 2004, but no comments were filed.

[^7]: *See* *Public Notice*, ET Docket No. 03-122, DA 06-927, released
    on April 26, 2006.

[^8]: Commenters include Compliance Certification Services, Covad
    Communication Group, Motorola, Praveen Rao, and Wi-Fi Alliance.
    Reply commenters include Compliance Certification Services and the 5
    GHz Coalition (consisting of Cisco Systems, Dell, Intel Corporation,
    Motorola, and Nortel)

[^9]: *See* Appendix B: Final Rules of the *Report and Order*.

[^10]: *See* 47 C.F.R. § 15.407(h)(1).

[^11]: *See* Wi-Fi Alliance Motion for Clarification filed February 19,
    2004.

[^12]: Rule section 15.403(s) is currently 15.403(r).

[^13]: Section 15.403(s) defines TPC as a feature that enables a U-NII
    device to dynamically switch between several transmission power
    levels in the data transmission process, 47 C.F.R. § 15.403(s).

[^14]: Section 15.407(h)(2)(ii) states: "Channel Availability Check
    Time: A U-NII device shall check if there is a radar system already
    operating on the channel before it can initiate a transmission on a
    channel and when it has to move to a new channel. The U-NII device
    may start using the channel if no radar signal with a power level
    greater than the interference threshold values listed in paragraph
    (h)(2) of this part is detected within 60 seconds." 47 C.F.R. §
    15.407(h)(2)(ii).

[^15]: *See* Wi-Fi Alliance comments filed on May 15, 2006. *See also*
    Motorola comments filed May 15, 2006. We note, though, that the
    revised measurement procedure addresses DFS, not TPC, issues.

[^16]: *See* Wi-Fi Alliance comments at 2.

[^17]: *See* *Report and Order* at paragraph 35.

[^18]: *See Compliance Measurement Procedures* at sections 4.1 and 5.

[^19]: *See* 47 C.F.R. § 15.407(h)(2).

[^20]: *See* 47 C.F.R. § 15.407(h)(2)(iv).

[^21]: *See* Globespan Petition for Clarification or Reconsideration
    filed February 19, 2004.

[^22]: *See* Globespan Petition at 2. *See also* 47 CFR §
    15.407(h)(2)(iv).

[^23]: *See* Appendix C: Interim Measurement Procedures for DFS-Equipped
    U-NII Devices of the *Report and Order* for the radar test signal
    and definition of testing success that Globespan refers to.

[^24]: *See* Globespan Petition at 5-6.

[^25]: *See* Wi-Fi Alliance comments at 2.

[^26]: *See* Motorola comments at 3.

[^27]: *See Report and Order* at paragraph 29.

[^28]: *See* Appendix C: Interim Measurement Procedures for DFS-Equipped
    U-NII Devices of the *Report and Order*.

[^29]: *See Compliance Measurement Procedures* at section 6.3.

[^30]: *See* Extreme Petition filed February 17, 2004.

[^31]: *See* Extreme Petition at 1.

[^32]: *See* Motorola comments at 3.

[^33]: *See* Wi-Fi Alliance comments at 2.

[^34]: *Id.*

[^35]: See Motorola comments at 3.

[^36]: *See* *Compliance Measurement Procedures* at section 5.

[^37]: *See infra* note 4.

[^38]: *See* Covad comments at 4, Motorola comments at 1-2, Wi-Fi
    Alliance comments at 1. *See also*, 5 GHz Coalition reply comments
    filed on May 18, 2006 at 1.

[^39]: *See* CCS comments filed on May 11, 2006 and May 15, 2006. *See
    also*, CCS reply comments filed on May 18, 2006.

[^40]: *See* Praveen Rao comments filed on May 8, 2006.

[^41]: *See* 5 GHz Coalition reply comments at 3.

[^42]: *See* 5 GHz Coalition reply comments at 3-6. Some of the
    substantive changes include making the channel availability check a
    minimum value rather than an absolute value, expanding testing to
    include every channel bandwidth the device is capable of, and adding
    additional text to provide for alternate test procedures.

[^43]: *See Compliance Measurement Procedures* in the Appendix. *See
    also* 47 C.F.R. § 2.947 (describing the different standards or
    measurement procedures that the Commission will accept).

[^44]: In the *Report and Order*, the Commission codified some of the
    terms and definitions from the interim measurement procedure (47
    C.F.R. § 15.403), primarily those were used in the U-NII general
    technical requirements rule (47 C.F.R. § 15.407).

[^45]: *See* Appendix A: Final Regulatory Flexibility Analysis of the
    *Report and Order*.

[^46]: *See* 5 U.S.C. § 601-612, as amended by the Small Business
    Regulatory Enforcement Fairness Act of 1996, Pub. L. No. 104-121,
    Title II, 110 Stat. 857 (1996).

[^47]: *See* 5 U.S.C. § 801(a)(1)(A).

[^48]: *See* 5 U.S.C. § 605(b).

[^49]: MPEG is the name of a family of standards used for coding
    audio-visual information (e.g., movies, video, music) in a digital
    compressed format.

[^50]: Applies to detection during the Channel Availability Check or
    In-Service Monitoring.

[^51]: If a segment does not contain at least 1 frequency within the
    *U-NII Detection Bandwidth* of the UUT, then that segment is not
    used.

[^52]: [http://ntiacsd.ntia.doc.gov/dfs/]{.underline}

[^53]: [http://www.elliottlabs.com/wireless/dfs_alternate_hopper.htm]{.underline}

[^54]: A complete description of the setup described in this document is
    available at [http://ntiacsd.ntia.doc.gov/dfs/]{.underline}.

[^55]: Up to 40 ten-second-burst periods may be run with unique random
    frequency hop sets. These 40 ten-second-burst periods may be
    transmitted one at a time or any number of them may be transmitted
    contiguously. After all 40 ten-second-burst periods have been
    transmitted, the test needs to be restarted at the beginning of
    either the current frequency list or a newly loaded, different
    frequency list.

[^56]: A complete description of the example DFS Test Box is available
    at [http://ntiacsd.ntia.doc.gov/dfs/]{.underline}.

[^57]: A complete description of the software is available at
    [http://ntiacsd.ntia.doc.gov/dfs/]{.underline}.

[^58]: An example computer program is available at
    [http://ntiacsd.ntia.doc.gov/dfs/]{.underline}.

[^59]: The designated MPEG test file and instructions are located at:
    [http://ntiacsd.ntia.doc.gov/dfs/.]{.underline}