Submission Title: [WG-September Regulatory Report]

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Project: IEEE 802.15 Working Group for Wireless Personal Area Networks (WPANs) Submission Title: [WG-September Regulatory Report] Date Submitted: 22September09 Source: [John Barr] Company [JRBarr, Ltd.] Address [21939 Old Farm Road, Deer Park, IL 60010] Voice:[+1 847 962-5407], FAX: [], E-Mail:[barr@ieee.org] Re: [] Abstract: [Regulatory Liaison Report to 802.15/11 WG] Purpose: [Advise 802.15 WG about current IEEE 802.18 actions.] Notice: This document has been prepared to assist the IEEE 802.15. It is offered as a basis for discussion and is not binding on the contributing individual(s) or organization(s). The material in this document is subject to change in form and content after further study. The contributor(s) reserve(s) the right to add, amend or withdraw material contained herein. Release: The contributor acknowledges and accepts that this contribution becomes the property of IEEE and may be made publicly available by 802.15. Septemberr 2009 doc.: IEEE 802.15-09/0668r0 Dr. John R. Barr, JRBarr, Ltd. John Barr, JRBarr, Ltd.

September 2009 Voting Items ERM TG11 Response (802.11 driven) 18-09-0103-01-0000-regulatory-updates FCC Smart Grid NOI (Clint Powell?) 18-09-0102-00-0000-fcc-smart-grid-noi-report 802.16m ITU Advanced Submission Thursday AM1-AM2 Dr. John R. Barr, JRBarr, Ltd.

ERM TG11 Following slides from Rich Kennedy’s presentation to 802.18 IEEE 802.11 and 802.15.1/.4 are not affected Only new entrants using the spectrum must meet the current and new proposed rules Should not be an issue for 802.15 WG Dr. John R. Barr, JRBarr, Ltd.

FOCUS: Proposal for TG11 For operation under EN 300 328 rules: September 2009 FOCUS: Proposal for TG11 For operation under EN 300 328 rules: A technology neutral limit, based on the maximum average transmitted energy during a busy second, and assuming that peak transmit power limits are unchanged. We realize that a single approach or a single formula may not suffice as a method for determining if a particular device/technology will produce an acceptable level of interference. What follows are two methods, either of which may be used to assess the Medium Utilization. The inability to pass either requires that additional sharing mechanisms must be employed. Rich Kennedy, Research In Motion

Proposal Summary Measure the following parameters: September 2009 Proposal Summary Measure the following parameters: Maximum Tx-On Time: Time transmitter active over any 4ms Minimum Tx-Off Time: Time transmitter inactive over any 4ms Duty cycle: Percentage of time Tx on divided by 4ms for any 4ms MU: Energy in milliJoules over any 1sec A system may operate at TX power higher than 10mW only if it satisfies at least one of the following requirements: Max Tx-On < 0.4ms, Min Tx-Off > 0.1ms, Duty cycle < 10% Max MU < 4 mJ Some hybrid combination of Min Tx-Off, Duty cycle, and MU Slide 5 Rich Kennedy, Research In Motion

September 2009 Method One RLAN manufacturers present during the last TG11 meeting clearly stated that the MU approach only works if duty cycle is further restricted in terms of maximum Tx-on time, minimum Tx-off time, max averaging period, etc… as otherwise a single Duty Cycled system can cause continuous interference into an 802.11 RLAN system. In order for duty cycled systems to operate at TX power higher than 10mW, the following should be respected: Max. Tx-on time: 0.4 mSec Min. Tx-off time: 0.1 mSec Averaging time: 4.0 mSec Maximum duty cycle: 10% Rich Kennedy, Research In Motion

Shortcomings of Method One September 2009 Shortcomings of Method One While the proposed elements of duty cycle may facilitate sharing with 802.11 devices, it may still be incompatible with other technologies, especially those with modulations that do not use constant transmit power, e.g., W-CDMA systems. Current applications in 2.4 GHz use a wide range of different technologies, each having their own needs w.r.t. maximum Tx-on time and minimum Tx-off time making it impossible to agree on a single set of values that could be beneficial for all technologies. Rich Kennedy, Research In Motion

September 2009 Method Two A variation that we believe will suit not only the short range devices, but also protect devices, like 802.11 devices, that have optimized active sharing mechanism Medium Utilization = Energy in millijoules measured over 1 second ; the limit is MU < 4 millijoules Examples 100 mW for 100 milliseconds (out of 1 second) = 10 millijoules 10 mW for 1 second (DC – 100%) = 10 millijoules Compared to the current agreement, the 4 Millijoules represents a lower threshold, but on the other hand, apart from the measuring period of 1 second, no further restrictions are applied on modulation e.g. the Tx-on time and Tx-off time Joules preferred over ‘Power x Time’ to allow non-constant envelope modulations, or technologies that operate at variable power to benefit from those transmissions where they do not operate at full power. Rich Kennedy, Research In Motion

September 2009 Conclusions We believe that either of these alternatives will enable the provisions of Paragraph 4.3.5 Spectrum Sharing Mechanisms to allow SRDs to operate at higher power limits than the current limits of EN 300 440 without causing unacceptable interference into Wideband Transmission Systems that have depended on EN 300 328 for market access for many years. Rich Kennedy, Research In Motion

ERM TG11 Response Timeline September 2009 ERM TG11 Response Timeline Milestone Date Finalize 802.11/15 position September 14, 2009 Complete REG AHC discussion September 17, 2009 (on REG AHC call) Submit to RR-TAG (802.18) September 21, 2009 Approval by RR-TAG September 22, 2009 (in Hawaii) Submit to ExCom September 24, 2009 ExCom approval 5 day review Submit to ERM TG11 October 5, 2009 Present to ERM TG11 October 12 – 14, 2009 Rich Kennedy, Research In Motion