# Presentation: 658823

## Will Changes toPart 15 of the FCC Rules & RegulationsEncourage Innovation?

- Opinions of Members of the FCC Technological Advisory Council

## “One thing I’m sure OET would be interested in is the existing rules, the Part 15 rules.  Is there anything inhibiting in them to innovation?  I would love to have this group make some commentary on it, that’s worth its weight in gold to me.  Certainly you could use examples of some of these things and take the position that ‘if this did not exist as a restriction, we could do all sorts of good things.’  I would suggest that as something that has a great deal of value.”

*“**One thing I’m sure OET would be interested in is the existing rules, the Part 15 rules.  Is there anything inhibiting in them to innovation?  I would love to have this group make some commentary on it, that’s worth its weight in gold to me.  Certainly you could use examples of some of these things and take the position that ‘if this did not exist as a restriction, we could do all sorts of good things.’  I would suggest that as something that has a great deal of value.”*
- Ed Thomas, FCC OET Chief
- FCC TAC Meeting, June 12, 2002

- FCC TAC Part 15 Survey, G. Lapin

- Dec 4, 2002

## What Do We Mean by  ‘Part 15’?

- We are concerned with Intentional Radiators.
- Devices operate on an unlicensed basis.
- Devices usually share spectrum with licensed services.
- Devices must not interfere with licensed services and must accept interference from licensed services.

- FCC TAC Part 15 Survey, G. Lapin

- Dec 4, 2002

## Survey Questions

- Do you think that FCC Part 15 Regulations inhibit innovation?
- Should the FCC deal with interference issues with licensed services in a different way?  What?
- For individual (possibly non-technical) users in the home....
- In a spectrum with no rules, how can individual users be assured of effective communications?

- FCC TAC Part 15 Survey, G. Lapin

- Dec 4, 2002

## TAC Response

- Replies: 12
- Proxies*: 2
- Abstentions: 2
- **A “Proxy” is a reply by someone else in a TAC member’s company in place of the TAC member.*

- Respondents include:
- Part 15 device manufacturers
- Part 15 device users
- Licensed device manufacturers
- Licensed device users

- FCC TAC Part 15 Survey, G. Lapin

- Dec 4, 2002

## 1. Do you think that FCC Part 15    Regulations inhibit innovation?

- “The real solution is: there needs to be a new category, not Part 15, for highly regulated and controlled, type accepted equipment, used for unlicensed very low power applications over the broadest possible spectrum choices. ”
- “Part 15 regulations have fostered a great deal of innovation by limiting only a minimal number of characteristics.”
- “...it is also worthy to note that “Free-For-All” networks have sprung up creating unlicensed networks using 802.11 technology – that was clearly NOT in the original scope of the FCC’s intent for private, unlicensed LAN technology.  Ad-Hoc networking is certainly innovative.”

- FCC TAC Part 15 Survey, G. Lapin

- Dec 4, 2002

## 1a. Are the regulations too limiting?      If so, what specific limitations      should be changed?

- 	_Limitations:_
- Power & antenna (ERP)?
- Modulation?
- Frequency?
- “...there is much to be said for regulatory stability. A great deal has been and is planned to be invested assuming the existing rules, and I fear that the prospect of an unstable playing field will do more to inhibit innovation than any small adjustment we can propose.”

- FCC TAC Part 15 Survey, G. Lapin

- Dec 4, 2002

## 1b. Could more stringent regulations,      insuring that there will be no      unknown types of interference,      permit additional innovation?

- “Instituting stringent regulations may permit more innovation and allow additional players into the game. “
- “... constraints can often force innovation to occur as opposed to being able to use a more obvious, less innovative solution.”

- FCC TAC Part 15 Survey, G. Lapin

- Dec 4, 2002

## 2. Should the FCC deal with    interference issues with licensed    services in a different way?

- Currently, Part 15 intentional radiating devices are constrained by the following: “*Operation is subject to the following two conditions: (1) this device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation.*”
- “No, these are the fundamental principles.”

- FCC TAC Part 15 Survey, G. Lapin

- Dec 4, 2002

## 3a. Can users in the home control      their own spectrum and make      decisions on how to deal with      interference issues that may      arise between Part 15 devices?

- “Amazingly yes, but with brutal consequences to manufacturers and service providers.  Consumers are thoroughly capable of prioritizing...”
- “...if they [are] able to understand how the interference could be mitigated.  However, in most cases, this is a trial-and-error situation at best, in which they are at the mercy of whatever the manufacturer of the equipment has provided...”

- FCC TAC Part 15 Survey, G. Lapin

- Dec 4, 2002

## 3b. Can home users be guaranteed      that there will be no interference      from, or to, users in nearby      homes or apartments?

- “As more devices proliferate it will become more difficult for a consumer to determine the reasons their products do not operate if the reason is interference.”

- FCC TAC Part 15 Survey, G. Lapin

- Dec 4, 2002

## 4. In a spectrum with no rules, can    individual users be assured of    effective communications?

- “...regulatory rules are not the only option for enabling effective communication.  Technology that prescribes when and how radios operate can also be used.”

- FCC TAC Part 15 Survey, G. Lapin

- Dec 4, 2002