# Presentation: 542888

## Presentation of 3M Company

**for the**
**Special Meeting of the IRAC**
**on**
**GPS Repeaters**
***October 28, 2005***

- by Harold Mordkofsky
- Blooston, Mordkofsky, Dickens, Duffy & Prendergast
- 202-828-5520  / halmor@bloostonlaw.com

## 3M’s interest in GPS repeaters (or re-radiators)

- For use in conjunction with OpticomTM GPS system

## 3M’s proposal will include restrictions on use and operation 

- GPS repeaters will not fall into the wrong hands
- Use will not compromise conventional GPS equipment
- Use will not cause interference to other GPS users

## Implementation of 3M’s proposal will:

- Significantly contribute to safety of life and property
- Satisfy the concerns of regulators

## 3M is seeking experimental authorization to:

- Demonstrate equipment to prospective purchasers
- Test equipment – obtain regulatory approval
- Conduct field studies to evaluate interference potential

## OpticomTM GPS system features 

- Controls traffic signal priority
- Does not disrupt normal traffic flow

## Need for GPS repeaters 

- Emergency vehicles must acquire GPS signal quickly
- GPS signal provides location and timing synchronization

## How the 3M OpticomTM GPS system works

- Transmitter on emergency vehicle sends 2.4 GHz signal
- Receiver near intersection converts signal to electronic communication
- Phase selector in controller cabinet request priority advantage to control traffic light
- Traffic light turns green as emergency vehicle approaches intersection
- GPS repeater assures that all of this takes only seconds from start of run

## How the 3M OpticomTM GPS system works

- Emergency vehicles shielded from GPS signal since housed in closed buildings
- Use of GPS repeater allows vehicle to be “locked on” to GPS signal at all times

## Without GPS repeater, acquisition of GPS signal is delayed by:

- Time to start up vehicle and exit the building
- Shielding from trees, tall buildings and other obstacles
- Critical delay of up to _five minutes_ before emergency vehicle could lock on to GPS signal
- Precious time may be lost in emergency circumstances!

## 911 Emergency ResponseManagement – Travel and Response Time

**0%**

**Before 4 minutes 42% survived**

**After****4 minutes****7% survived**

**Time In****Minutes**

**	****1****	****2****	****3****	****4**

**Survival Rate – Cardiac Arrest**
** ****Cole and Corday “Four-minute Limit for Cardiac Resuscitation”**

***911 Emergency ******Response******Management – ******Travel and Response Time***

**minutes**

## Flashover

**Fire test jointly conducted by Factory Mutual Research and Harvard University**

***911 Emergency ******Response******Management – ******Travel and Response Time***

## Typical GPS repeater installation:

- GPS repeater in building in view of vehicle
- EIRP limited to -140 dBm at 100 ft.
- With 3 dB antenna, ERP limited to 39.8 pW
- Notification to FCC of particulars of operation
- location, number of units
- power, emission designator
- any other information deemed pertinent

## 3M’s use of GPS repeaters would be within present regulatory limitations

- Radiation below level permitted by FCC for spurious emissions

## Adherence to NTIA policy objectives:

- Individual license for each GPS repeater
- FCC will have full particulars of operation
- No operation for more than six months without regular license
- Use of GPS repeater terminates if any reported interference cannot be eliminated
- Two-year license term and listing of approved sites in accessible database

## Potential interference is strictly limited 

- Use under control of public safety officials – well known in their communities.
- Other users of GPS notified of use of GPS repeaters
- “Stop buzzer” phone no. available 24/7
- GPS repeater shuts down pending investigation and remediation
- Other emergency uses of GPS not compromised

## 3M will provide periodic reports as requested by FCC

- Proposed use of GPS repeaters will contribute to development of standards
- Will provide federal government with valuable information

## Summary 

- Proposal strictly tailored to limit use and avoid interference
- Will operate inside buildings
- Will operate at lowest power possible
- Will be under supervision of local government public safety officials

## Summary

- Use of GPS repeaters will save lives!
- serves an important function of FCC’s regulation of radio
- 3M will institute rulemaking based on information developed during experimental operations