1. 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:[ ], FAX: [],
Re: []
Abstract: [Regulatory Liaison Report to /11 WG]
Purpose: [Advise WG about current IEEE actions.]
Notice: This document has been prepared to assist the IEEE 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
Septemberr 2009
doc.: IEEE /0668r0
Dr. John R. Barr, JRBarr, Ltd.
John Barr, JRBarr, Ltd.

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

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

4. FOCUS: Proposal for TG11 For operation under EN 300 328 rules:
September 2009
FOCUS: Proposal for TG11
For operation under EN 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

5. 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

6. 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 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

7. Shortcomings of Method One
September 2009
Shortcomings of Method One
While the proposed elements of duty cycle may facilitate sharing with 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

8. September 2009
Method Two
A variation that we believe will suit not only the short range devices, but also protect devices, like 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

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

10. ERM TG11 Response Timeline
September 2009
ERM TG11 Response Timeline
Milestone
Date
Finalize /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