1. doc.: IEEE 802.22-05/0044r0 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 1 [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless RANs Date: 2005-06-14 Authors: Notice: This document has been prepared to assist IEEE 802.22. 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 grants a free, irrevocable license to the IEEE to incorporate material contained in this contribution, and any modifications thereof, in the creation of an IEEE Standards publication; to copyright in the IEEE’s name any IEEE Standards publication even though it may include portions of this contribution; and at the IEEE’s sole discretion to permit others to reproduce in whole or in part the resulting IEEE Standards publication. The contributor also acknowledges and accepts that this contribution may be made public by IEEE 802.22. Patent Policy and Procedures: The contributor is familiar with the IEEE 802 Patent Policy and Procedures http://standards.ieee.org/guides/bylaws/sb-bylaws.pdf including the statement "IEEE standards may include the known use of patent(s), including patent applications, provided the IEEE receives assurance from the patent holder or applicant with respect to patents essential for compliance with both mandatory and optional portions of the standard." Early disclosure to the Working Group of patent information that might be relevant to the standard is essential to reduce the possibility for delays in the development process and increase the likelihood that the draft publication will be approved for publication. Please notify the Chairhttp://standards.ieee.org/guides/bylaws/sb-bylaws.pdf Carl R. StevensonCarl R. Stevenson as early as possible, in written or electronic form, if patented technology (or technology under patent application) might be incorporated into a draft standard being developed within the IEEE 802.22 Working Group. If you have questions, contact the IEEE Patent Committee Administrator at patcom@ieee.org.patcom@ieee.org >

2. doc.: IEEE 802.22-05/0044r0 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 2 Abstract This is a DRAFT outline of a proposed ex parte presentation to the FCC, explaining 802.22’s charter, studies and conclusions to date, goals, etc. This document is intended for WG approval, review and approval by 802.18, and review and approval by the 802 EC before it may be formally presented to the FCC.

3. doc.: IEEE 802.22-05/0044r0 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 3 IEEE 802.22 WG Scope and Purpose The IEEE 802.22 WG on Wireless Regional Area Networks (“WRANs”) has the following charter, per its approved PAR: –To develop “Cognitive Wireless RAN Medium Access Control (MAC) and Physical Layer (PHY) specifications” … “(specifying) the air interface, including the medium access control layer (MAC) and physical layer (PHY), of fixed point-to-multipoint wireless regional area networks operating in the VHF/UHF TV broadcast bands between 54MHz and 862 MHz.” –“This standard is intended to enable deployment of interoperable 802 multivendor wireless regional area network products, to facilitate competition in broadband access by providing alternatives to wireline broadband access and extending the deployability of such systems into diverse geographic areas, including sparsely populated rural areas, while preventing harmful interference to incumbent licensed services in the TV broadcast bands.”

4. doc.: IEEE 802.22-05/0044r0 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 4 Background The IEEE 802.22 WG started as a Study Group in the IEEE 802.18 RR-TAG (approved November 2003) –We noted the Commission’s interest in the possibility of making unused TV spectrum available for use by license-exempt devices, starting with the Spectrum Policy Task Force, NOI, ET 02-380, etc.) –We thought it prudent to begin studies on how this spectrum might best be put to use, should it become available. –We wanted to explore the issues surrounding coexistence/non-interference with the licensed incumbents. All interested stakeholder communities were represented in the Study Group and are actively participating in the 802.22 WG (MSTV, NAB, CEA, wireless microphone interests, PLMRS interests, and “traditional” IEEE 802 participants) The PAR for the 802.22 WG was approved iu September 2004, the WG held its first meeting in November 2004, and has been meeting regularly since then.

5. doc.: IEEE 802.22-05/0044r0 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 5 802.22 Progress to Date The following slides will summarize the results of our studies and discussions to date – many of which have resulted in broad agreement and point to somewhat different requirements and methodologies than were outlined by the Commission in its NPRM.

6. doc.: IEEE 802.22-05/0044r0 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 6 Fundamental requirements for WRAN systems to protect TV broadcasting P-MP System with base station professionally installed at known location, Customer Premises Equipment (“CPE”s) should be user- installable, though some operators may opt to require professional installation of CPEs Master/Slave relationship between base station and CPEs Cognitive radio approach to sensing/avoiding (protecting) incumbents Distributed sensing by ALL CPEs across the entire network cell Systems should NOT operate on N or N±1 within the protected contour of a DTV station Need to consider DTV D/U’s and DTV receiver saturation for N±2 channels and beyond and the resulting proposed “EIRP profile” Our studies indicate that Part 15.209(a) out-of-band emission levels are insufficient to protect DTV receivers for N±2 and beyond We have developed an out-of-band emission mask, based on an agreed deployment scenario

7. doc.: IEEE 802.22-05/0044r0 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 7 Distributed sensing and Master/Slave control (for DTV protection) Base station initially programmed with “keep out” channels, based on site survey/system engineering Cognitive radio sensing threshold of -116 dBm in 6 MHz bw (based on sensing DTV pilot at 11.3 dB below total power in the channel), with sensing done by ALL CPEs and centralized intelligence/control at the base station CPEs may NOT transmit, absent receipt of a control signal from a base station Base station totally controls RF operation of CPEs –Frequencies that may be used –Modulation, Timing, TX power control –Commands to perform sensing on used channel during quiet periods or to scan other channels and report results Adaptive ability of cognitive radio sensing will preclude interference despite future changes in incumbent locations and channel assignments

8. doc.: IEEE 802.22-05/0044r0 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 8 Fundamental requirements for WRAN systems to protect Part 74 licensed operations such as wireless microphones OOB emissions requirements similar to protecting DTV Cognitive radio sensing threshold of -107 dBm in 200 kHz bw for sensing wireless microphones is a best effort but is not sufficient to fully protect Part 74 wireless microphone operation since the interference range of the CPEs would be larger than their sensing range Likelihood of false alarms from unlicensed wireless microphones would render WRAN operation very susceptible to potential unintentional (and/or intentional) interference Use of beacons by the Part 74 wireless microphone operators would alleviate the two previous problems [no agreement yet as to whether this can be stated or not]

9. doc.: IEEE 802.22-05/0044r0 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 9 References