WASHINGTON-The volatile debate surrounding the rules allowing or restricting the use of ultra-wideband technologies got louder as companies commented on ambient noise test results from the FCC’s Office of Engineering and Technology.
The National Aeronautics and Space Administration said the tests were not relevant. “NASA believes that the material presented in the [Federal Communications Commission] test measurements is not relevant to the questions being posed by the commission in this proceeding. The FCC is attempting to make an illogical, scientifically unsound linkage between incidental, unwanted noise (what the current report addresses) and intentional transmissions filtered to achieve required out-of-band emission levels (what the UWB first Report & Order addressed). Until such time as `real world’ UWB devices and networks can be laboratory and field tested with respect to potential interference to other authorized services, no changes in current rules regarding UWB should be considered,” said David Struba, of the NASA Office of Space Flight.
The FCC had no comment on the NASA letter because it had not received it. Per procedure, the letter was sent through the Interdepartment Radio Advisory Committee.
The NASA letter is not expected to become part of the UWB record at the FCC, said Michael Gallagher, deputy director of the National Telecommunications and Information Administration. By law NTIA leads IRAC.
“That letter is an internal IRAC document that normally, if rarely, would be placed in the FCC docket. … [NTIA has] great respect for NASA. That said, the ultimate reservoir for spectrum management and federal position rests with NTIA. [NASA’s view] needs to be tempered and improved through the NTIA process,” said Gallagher.
NTIA was not expected to file comments on the OET tests, but instead will make “technical contributions to the discussion,” said Gallagher.
Other agencies are not at liberty to express their views to the FCC, said Gallagher. “We are the ones that speak by law for the federal government on spectrum policy.”
But it is not just federal-government spectrum users who are upset about the OET ambient noise test results.
Qualcomm Inc., which makes GPS chips for mobile phones, said there were discrepancies in the results.
“Qualcomm has identified a number of significant discrepancies in the FCC OET staff report. Consequently, this report does not represent the rigorous testing required for fact-based rulemaking. Qualcomm believes that these test measurements are inconclusive and recommends that no changes in the FCC’s rules should be adopted based on the data in the OET staff report,” said Qualcomm.
Qualcomm said it conducted its own tests and those results prove UWB rules should not be lessened. “The data shows, contrary to the FCC OET staff report, that the existing levels of ambient noise in indoor environments are not well above the UWB emission limits. Thus, the existing levels of ambient noise indoors provide no basis for the commission to modify the UWB emission limits to allow greater UWB emissions. To the contrary, all of Qualcomm’s testing has shown that for reliable, highly accurate [enhanced] 911 service, the PCS, cellular and GPS bands need greater protection from UWB emissions than the FCC’s current rules provide, especially when taking aggregation into consideration,” said Qualcomm.
Those who favor UWB believe the tests prove their arguments.
“Permitted UWB emissions are not only safe in these environments, but in most cases will be completely undetectable. The first Report & Order achieved a balanced result that meets the legitimate needs of both nascent UWB industry and safety-of-life spectrum users. The rules applicable to indoor and handheld UWB devices should be affirmed without change,” said Mitchell Lazarus, outside counsel for XtremeSpectrum Inc.
Time Domain Corp. was expected to argue that the FCC tests do not support “taking aggregation into consideration” as suggested by Qualcomm, said Jeffrey Ross, Time Domain vice president of corporate development & strategy.
In another development, a coalition of airlines, aviation and communications vendors, including Qualcomm, urged the FCC last week to withdraw the UWB authorization for Time Domain.
“Nowhere in the opposition does [Time Domain] deny that emissions data on out-of-band must be submitted as part of the equipment authorization application. … TDC states that its equipment authorization application demonstrates without question that there are no unauthorized emissions emanating from the device. However, TDC’s bald assertions are unsupported by actual test data to demonstrate compliance with the rules. … It is far from clear what the level of emissions actually are between 0.96 and 3.1 GHz because TDC never reports this data, even though such reporting is required by the [FCC’s] rules,” said the group.
The groups also object to the testing that Time Domain claims the OET conducted on TDC’s device. “No actual data were placed in the record. OET indicates that it observed out-of-band emissions in the 1227-1536 MHz band, but the emissions were `relatively narrow-band’ and that it only `intuitively anticipated’ that the emissions were due to digital circuitry contained within the device; however, OET cannot know with certainty unless the device is tested. … Petitioners cannot adequately respond unless the commission shares its `intuition’ with us,” said the group.
One of the main disagreements appears to be whether the emissions must come from the antenna to be considered under UWB rules. Time Domain believes that emissions emanating from the device, but not from the antenna, should not be considered. “Any emissions emanating from components of the device intended to generate the UWB emissions are obviously associated with the intentional emissions and, consequently, should not be categorized as unintentional for purposes of the digital circuitry exception,” said the groups.
Not surprisingly, Time Domain disputed the coalition’s assertions. “The FCC laboratory staff evaluated not only the data submitted by Time Domain, they also were provided with the actual device. We’re quite confident that the equipment was thoroughly tested before the application was filed and that the commission’s engineers took the extra step of carefully examining the equipment provided to the agency before the application was granted. This latest effort is but one more step in a misguided campaign to derail the development of beneficial technology that can save lives and provide a new level of short-range connectivity at extraordinarily low power levels of less than 75 billionths of a watt at any one megahertz,” said Ross.
