Sept 2005 doc.: IEEE 802.15-05-0435-00-004a Sept 2005 Project: IEEE P802.15 Working Group for Wireless Personal Area Networks (WPANs) Submission Title: [UWB regulation in Europe : consideration of mitigation techniques for 802.15.4a systems] Date Submitted: [19-Sept-05] Source: [Patricia Martigne] Company [France Telecom R&D] Address [] Voice:[+33 4 76 76 44 03], FAX: [+33 4 76 76 44 50], E-Mail:[patricia.martigne@francetelecom.com] Re: [Coexistence demonstration when drafting 802.15.4a ] Abstract: [ Discussion on mitigation techniques for 802.15.4a systems and on arguments for European regulators] Purpose: [This document is for discussion on mitigation techniques for 802.15.4a systems which would ensure 802.15.4a coexistence with other systems with regards to regulatory debates in Europe] Notice: This document has been prepared to assist the IEEE P802.15. 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 P802.15. Patricia Martigne, FT R&D

Liaison with European regulation Sept 2005 doc.: IEEE 802.15-05-0435-00-004a Sept 2005 UWB regulation in Europe : consideration of mitigation techniques for 802.15.4a Patricia Martigne FT R&D Liaison with European regulation Patricia Martigne, FT R&D

EUROPEAN REGULATORY CONTEXT Sept 2005 doc.: IEEE 802.15-05-0435-00-004a Sept 2005 EUROPEAN REGULATORY CONTEXT CEPT was mandated by the European Commission Creation of CEPT/ECC/TG3 Elaboration of Report ECC 64 : "The protection requirements of radiocommunications systems below 10.6GHz from generic UWB applications" ECC Report to the European Commission, approved in February; UWB PSD limits for protection of the existing services, using worst case scenarios; including detailed annexes (approx.350 pages). Existing services considered in the ECC studies (Report64) : 1 Fixed Service (FS); 2 Mobile Satellite Service (MSS); 3 Earth Exploration Satellite Service (EESS); 4 Radio Astronomy Service (RAS); 5 Digital video broadcasting: DVB–T; 6 Digital audio broadcasting: T–DAB; 7 Bluetooth PAN; 8 Radio LAN; 9 Public Land Mobile Service (MS): IMT-2000; 10 Radio Navigation Satellite Service (RNSS); 11 Fixed Satellite Service (FSS); 12 Amateur/Amateur Satellite Services (Amateur) ; 13 Maritime mobile service (Maritime), including Global Maritime Distress & Safety Systems (GMDSS); 14 Aeronautical Mobile Service and radio determination service (Aeronautical, AMS, ARNS); 15 Meteorological Radars. Patricia Martigne, FT R&D

EUROPEAN REGULATORY CONTEXT Sept 2005 doc.: IEEE 802.15-05-0435-00-004a Sept 2005 EUROPEAN REGULATORY CONTEXT (Report 64 quoted – extract from §4.2) "It is vital for all existing and planned radiocommunications services that the impact of emissions from UWB devices on the victim receiver be maintained at a level, which does not jeopardise at all the operation of the concerned services. Since the interference from UWB devices may appear as an increase of the background noise, the tolerable interference levels for the several radiocommunications services needed to be defined very carefully. Depending on its dimension, an increase of background noise at the receiver always leads to a decrease of quality of service to a certain degree, in terms of: - loss of capacity, - loss of coverage, - loss of link availability. Any significant impact by UWB devices on the existing operating conditions of all other radiocommunications services is totally unacceptable and must be avoided to the greatest extent possible." Patricia Martigne, FT R&D

EUROPEAN REGULATORY CONTEXT Sept 2005 EUROPEAN REGULATORY CONTEXT Generic UWB PSD limits required to protect all studied victim radiocommunications services Patricia Martigne, FT R&D

EUROPEAN REGULATORY CONTEXT Sept 2005 doc.: IEEE 802.15-05-0435-00-004a Sept 2005 EUROPEAN REGULATORY CONTEXT Basis of the generic mask for Europe = ECC Report 64, describing the protection requirements of radiocommunication systems below 10.6 GHz from generic UWB applications. A “simplified generic mask” was derived for analysis purpose from the results of technical studies, with emission levels that ensure the protection of most radiocommunication services in all circumstances. For the services for which full protection is not achieved with this generic mask, adequate regulatory measures would be required to protect these services. Patricia Martigne, FT R&D

EUROPEAN REGULATORY CONTEXT Sept 2005 doc.: IEEE 802.15-05-0435-00-004a Sept 2005 EUROPEAN REGULATORY CONTEXT This generic mask does not take into account mitigation techniques, is a worst-case analysis, likely to represent the lower bound of the result of the impact analysis. In order to possibly facilitate introduction of UWB devices, ECC TG3 recognized the need to fine-tune some assumptions in the technical studies and to perform complementary technical studies focusing primarily on selected UWB coexistence scenarios and taking into account new interference mitigation techniques. Patricia Martigne, FT R&D

EUROPEAN REGULATORY CONTEXT Sept 2005 EUROPEAN REGULATORY CONTEXT The revised Terms of Reference for ECC TG3 call for the provision of the following for consideration by ECC at its meeting June 2005: “Provisional technical parameters and regulatory provisions for indoor UWB communication applications” New mandate for ECC TG3 to develop provisions for regulation of indoor UWB devices on the basis of an impact analysis initially considering a PSD limit of -55 dBm/MHz in the band 3.1 10.6 GHz, taking into account technical studies, measurement campaigns and mitigation techniques. Patricia Martigne, FT R&D

EUROPEAN REGULATORY STATUS Sept 2005 doc.: IEEE 802.15-05-0435-00-004a Sept 2005 EUROPEAN REGULATORY STATUS Draft ECC Decision as elaborated and approved in TG3 September meeting Patricia Martigne, FT R&D

Draft ECC Decision as elaborated and approved in TG3 September meeting doc.: IEEE 802.15-05-0435-00-004a Sept 2005 Draft ECC Decision as elaborated and approved in TG3 September meeting Note 1: In the frequency band 3.1 to 4.95 GHz, CEPT administrations support investigation of DAA mechanisms in order to ensure compatibility of UWB devices with radio services in the band with a view of allowing UWB devices in this band with maximum average e.i.r.p. density of –41.3 dBm/MHz and a maximum peak e.i.r.p. density of 0dBm/50MHz. ECC will review the decision in the light of the results of these investigations. TG3 discussion on DAA mitigation technique, Sept.2005 A demo of Detect and Avoid (DAA) prepared by Wisair (see document TG3#11_28R1) was arranged at this meeting. The principle of DAA mitigating technique is widely supported by the UWB industry. ECC encourages further research and standardization activities on this matter. Discussions have shown however that the specification of such DAA mechanisms is not trivial and its feasibility was not yet demonstrated. IEEE sept. Meeting in Garden Grove : example of the implementation of the DAA technique = presentation made by Jim Lansford in Garden Grove on the 20th of September 2005 (doc.802.19-05-34r0 – DAA for MB-OFDM) Patricia Martigne, FT R&D

Draft ECC Decision as elaborated and approved in TG3 September meeting doc.: IEEE 802.15-05-0435-00-004a Sept 2005 Draft ECC Decision as elaborated and approved in TG3 September meeting [Note 2: In the frequency band 3.1 to 4.95 GHz, UWB devices are permitted with a maximum average e.i.r.p density of [–41.3/-45] dBm/MHz, a maximum peak e.i.r.p density of 0dBm/50MHz and a maximum duty cycle of 5% over one second and 0.5% over one hour] [Editor’s note: the acceptance of the Duty Cycle restriction as a mitigation technique needs to be assessed by ECC TG3 before final adoption of this Decision, recognising that the efficiency of this mitigation technique has not been fully demonstrated]. [Note 3: In the frequency band 4.2 to 4.8 GHz, UWB devices are permitted until 30 June 2010 with a maximum average e.i.r.p density of –41.3 dBm/MHz and a maximum peak e.i.r.p density of 0dBm/50MHz] [Editor’s note: the acceptance of this solution needs to be assessed by ECC before final adoption of this Decision, recognising associated regulatory difficulties]. These LDC values were proposed by a FT/French contribution to TG3 : doc TG3#11_39R0, and justified by other FT contributions to previous TG3 meetings. Discussions of TG3 on Low duty cycle mitigation technique, sept.2005 : Regarding the LDC mitigation, it was pointed out that, regarding the protection of BFWA indoor application, the studies has shown that the proposed limitations in eirp density and activity may have acceptable impact on the data layer control (MAC layer); however, the impact on the physical layer (i.e. the carrier recovery mechanism that is not a standardised item in any IEEE 802.16 or ETSI Hiperman systems) has not been specifically considered for BFWA equipment (in particular with marginal receive signal level) and would need more technical analysis, possibly confirmed by practical tests on real equipment. Some members reserved therefore their position on LDC, as the technique may not mitigate interference, as it is dependent on the UWB burst repetition rate in relation to the frame length of future services sharing the band. Furthermore the duty cycling will not reduce the aggregate power at all in cases where the averaging period of the measurement (1ms) exceeds the periodicity of the bursts. Note 3 : The band 4.2 – 4.8 GHz may be allowed for UWB operation in this frequency band until at least 2010 without DAA mechanisms. If this band is identified for indoor systems at WRC-07, then, from 2010, new products would have either to operate in other bands or to implement DAA, pending demonstration of DAA efficiency. Patricia Martigne, FT R&D

EUROPEAN REGULATORY STATUS Sept 2005 doc.: IEEE 802.15-05-0435-00-004a Sept 2005 EUROPEAN REGULATORY STATUS Draft ECC Decision as elaborated and approved in TG3 September meeting Patricia Martigne, FT R&D

EUROPEAN REGULATORY STATUS Sept 2005 doc.: IEEE 802.15-05-0435-00-004a Sept 2005 EUROPEAN REGULATORY STATUS Draft ECC Decision as elaborated and approved in TG3 September meeting The type of UWB technology, application or device permitted under this general regulation is generic. Some categories of UWB devices are however excluded for the scope of this draft Decision as they can present a significant risk of interference to radio services (e.g. outdoor infrastructure) Draft ECC Decision extract : "Decides … 3. that this ECC Decision is not applicable to: - [toys and ]flying models, - outdoor installations and infrastructure, including those with externally mounted antennas, - devices installed in road and rail vehicles, aircraft and other aviation; 4. that the following restrictions on use apply to devices permitted under this ECC Decision: [operation not allowed aboard an aircraft, operation not allowed aboard a ship,] operation not allowed at a fixed outdoor location, Patricia Martigne, FT R&D

EUROPEAN REGULATORY STATUS Sept 2005 EUROPEAN REGULATORY STATUS Schedule : Draft ECC Decision to be reviewed at the ECC meeting in October (24-28 Oct. 2005) : arguments for LDC as a mitigation technique shall be made available for this meeting if we want it to be kept as a way of opening the 3,1-5GHz band for UWB Draft Decision as approved by the ECC in October will be submitted into public enquiry for 3 months Final Decision expected to be available end of January 2006 URGENT Patricia Martigne, FT R&D

Sept 2005 ACTION EXPECTED FROM 15.4a LDC as a mitigation technique : demonstration to the ECC before their October meeting Are LDC values proposed in the current Draft ECC Decision acceptable for 15.4a? (hopefully at least for some of the intended applications) To find arguments to demonstrate non-interference from LDC applications to the particular Wimax case…(any program to provide simulation results?) Special concerns expressed by some Wimax people to be considered and answers to be sent back to them. Patricia Martigne, FT R&D