# Presentation: 353731

## UWB:  Getting Right A Watershed Decision

- Presentation
- to
- CGSIC
- By
- F. Michael Swiek, Executive Director
- U.S. GPS Industry Council
- At
- Salt Lake City

## UWB NPRM

- Asks the key question
- The real question or a Trojan Horse?
- Answered:   test data definitive
- Strategic Issue:   protect the noise floor
- Implications for GPS, PCS, DARS, & other affected services

## UWB NPRM (Continued)

- Industry coalition position
- FCC needs help
- Way forward:  strategic solution
- Users and agencies must engage to protect equities
- (& help the FCC)

## UWB NPRM Question

- Under existing FCC Part 15 rules for consumer devices, does a UWB device qualify as an *unintentional *emitter?

## UWB NPRM Question(Continued)

- “Yes” means:
- UWB can operate across allocated services in 1-6 GHz on a *non-interfering* basis
- Like a hairdryer
- But, for UWB this requires:
- _Watershed rule change_:  removal of current restrictions against transmissions in restricted bands, including safety-of-life and GPS

## UWB NPRM Question(Continued)

- “No” means:
-  New NPRM
-  New strategic solution
- because spectrum overlay is:
- -   Not feasible
-  Zero sum
-  Not market-driven evolution but regulatory-driven “destructive” phenomenon

## The Real Question Or A Trojan Horse?

- UWB, & UWB GPRs, are Trojan horses for broader commercial pressures to gain unlicensed free spectrum:
- More than stealth radio
- Label used to gain access to free spectrum for mobile internet
- > 25% of center frequency or 500 MHz
- Any emerging ultra-wideband modulation technique, including:
- OFDM or ultrawideband CDMA

## The Real Question Or a Trojan Horse?(Continued)

- 3 GHz bandwidth at FCC Part 15 levels provides network range of 1 kilometer at 100 Kbaud
- Less than 10,000 UWB GPRs today
- Commercial utility is below 1 GHz
- Wireless device manufacturers seek new spectrum
- Intense pressure for free spectrum to create next IT wave - especially as 3G falters

## NPRM Question Answered:  Test Data Is Definitive

- Test data shows UWB devices are *intentional* emitters under existing FCC Part 15 rules and operate at levels far below rule limits

## Test Data Is Definitive:  UWB Devices Are Not Part 15

## Strategic Issue:  Preservation of the Noise Floor

- UWB Trojan Horse below 6 GHz means:
- Proliferation of competing, overlapping networks other than military pulse position modulation
- High probability of commercial exploitation means the noise floor threat is real
- Loss of control of the noise floor

## Strategic Issue:  Preservation of the Noise Floor(Continued)

- To date, device manufacturers are unable to manage the noise floor through self-regulation in license-free bands (eg. 2.4 GHz)
- Once the noise floor is damaged, there is no recovery
_**SHARING EXPERIMENTATION IS NOT FEASIBLE DUE TO UNBOUNDED RISK**_
- Precedent of untested transmissions into restricted bands

## FCC Rule on UWB:  Implications for GPS & Other Services

- FCC rule allowing UWB use below 6 GHz will either:
- Put spectrum foundation of GPS positioning & timing infrastructure (safety-of-life, national security and commerce) & existing wireless infrastructure at risk
- 				OR
- Protect spectrum foundation of GPS positioning & timing & wireless infrastructure
- Rule will set standards for global action at WRC

##  National Priority:Protect Spectrum Foundation of GPS & Existing Wireless Services

- U.S. must preserve existing FCC Part 15 restrictions prohibiting intentional transmission in, or across, the GPS band
- Slows rise in the noise floor
- Preserves military options
- Noise floor rise imposes new costs on civilians and military
- GPS evolving applications operate below the noise floor
- Also, PCS and others

## ITU Recognized Sharing with GPS Is Not Feasible

- At WRC 2000, ITU delegates requested  specific language, excluding GPS frequency bands in *both* Resolutions proposing spectrum sharing with MSS, due to recognized “extreme sensitivity of these bands”
- Preserve ITU ARNS designation for safety-of-life use

## Industry (Below 6 GHz) Coalition 

***Air Transport Association of America, Inc.   ·   Aircraft Owners and Pilots Association***
***ARINC   ·   ARRL, The National Assoc. for Amateur Radio   ·   Astrolink International***
***AT&T Wireless Services, Inc.   ·   Ellipso, Inc.   ·   Ericsson Inc   ·   Garmin International, Inc.***
***General Aviation Manufacturers Association   ·   LocatorNet   ·   Lockheed Martin Corporation***
***Magellan Corporation   ·   Motorola, Inc.   ·   National Business Aviation Association***

## Industry (Below 6 GHz) Coalition 

***Nokia, Inc.   ·   Nortel Networks, Inc.***
***  ******Omnistar, Inc  *  Outreach***
***QUALCOMM Incorporated   ·   Rockwell Collins   ·   Satellite Industry Association***
***SiRF Technology   ·   Sirius Satellite Radio   ·   Spatial Technologies Industry Association***
***Sprint Corporation   ·   Trimble Navigation Ltd.   ·   US GPS Industry Council***
***WorldCom   ·   XM Radio Inc.***

## The Train Has Left the StationIndustry Coalition Position:

- “test results to date demonstrate that such devices have unique transmission characteristics that produce intentional transmissions that cause significant harmful interference to GPS, other safety-of-life services, wireless services, such as PCS, as well as to satellite services, such as DARS”
-  Letter to FCC Chairman Powell, May 18, 2001

## Industry Coalition Position(Continued)

- “these tests show that other characteristics of the proposed UWB signals also vary greatly from the characteristics of unintentional emitters”
- “Consequently, the signatories recommend that UWB devices be limited to spectrum above 6 GHz, not be allowed to operate in any restricted band, including safety-of-life service bands, and be subject to a licensing regime”  [“separate and apart from Part 15”]

## Legacy Spectrum Decision

- Balancing needs:
- To provide unlicensed free spectrum for mobile internet and innovation
- To preserve commercial utility of allocated spectrum *requiring predictable noise floor*

## Legacy Spectrum Decision(Continued)

- Balancing needs (continued):
- To preserve the safety of the spectrum foundation of the National Airspace (NAS), including GPS and bands restricted for safety-of-life
- To preserve secure spectrum for evolving national security needs & military options, including GPS, com, & satcom
- To protect the public interest

## FCC Needs Help

- UWB decision will affect auctions:
- Existing services claim exclusive rights in their allocation, including:
- Mineral rights due to operations below the noise floor
- Expectation of the ability to manage the noise floor to preserve the commercial utility of their allocation to recoup their investment
- Right to assume purchase of usable land, not swamp

## Way Forward:  A Strategic Solution

- Allow unlicensed UWB in a band segment above 6 GHz providing:
- Appoint a shared use “band manager” to ensure accountability for noise floor
- Any technology under the UWB label using this band on an unlicensed, free of charge basis will pay for noise floor studies & compensation of performance degradation of authorized users

## A Way Forward:  A Strategic Solution

- Band manager to undertake a comprehensive baseline study of noise floor
- Study to be peer reviewed (including government agencies, academia and others)
- Any increase in the noise floor causing performance degradation to existing services must pay to upgrade victim systems

## Affected Users Must Engage To Protect Equities

- Government can promote innovation without compromising national security and safety
- Your self-interest in GPS & existing services requires participation to focus NTIA & FCC rule-making process to conduct this strategic “experiment” in an appropriate band segment
- Consequences can be permanent

## Conclusion

- Support free spectrum for the mobile internet and the safe introduction of UWB technologies on a “strategic experiment” basis
- Avoid creating a Spectrum Super Fund & Spectrum EPA