1. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 1 TV white space update 1 Date: 2009-01-18 Authors:

2. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 2 Abstract On November 4 th the FCC voted to allow Part 15 devices to operate on unused TV channels www.fcc.gov/sptf www.fcc.gov/sptf New FCC part 15 rules will become law the day of publication in the Federal Register What the rules provide Discussion about 802.11 interests

3. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 3 FCC 04-186 TV white space FCC Adopts Rules For Unlicensed Use of Television White Spaces November 4, 2008 News Release: Word | Acrobat Copps Statement: Word | AcrobatWordAcrobatWordAcrobat FCC 08-260 Rules November 17, 2008 http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC- 08-260A1.pdf Erratum DA 09-20 January 9, 2009 http://www.fcc.gov/Daily_Releases/Daily_Business/2009/d b0109/DOC-287799A1.pdf

4. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 4 US TV channel allocations http://www.fcc.gov/mb/engineering/usallochrt.pdf –2,3,454-72 MHz (wavelength ~six meters) –5,676-88 MHz –7-13174-216 MHz –14-20470-512 MHz –21-51512-692 MHz (wavelength ~60 cm) –Note that channel 37 is reserved for radio astronomy (608-614 MHz) and Medical Telemetry can use channels 36, 37 and 38 in thirteen urban markets 15.707(a) –Note that some of channels 14-20 are shared with Land Mobile Systems in thirteen urban markets 47 CFR 90.303(a)

5. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 5 There are unused TV channels everywhere TV bands are licensed everywhere, but not all TV spectrum is utilized everywhere The FCC has protected all existing licensed uses (A)Digital TV stations, (B)Digital and analog Class A TV stations, (C)Low power TV stations, (D)TV translator and booster stations, (E)Broadcast Auxiliary Service stations, (F)Cable TV headends, (G)TV translator station receive sites, (H)Sites where low power auxiliary, including wireless microphones and wireless assist video devices are used, and their schedules for operation Licensed uses continue to be protected to their full extent of operation TV white space at a location is the unused TV channels at that location at that time (wireless microphones come and go) FCC TV Bands Engineering Report –http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-08-2243A3.pdfhttp://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-08-2243A3.pdf

6. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 6 The FCC allows access under Part 15 rules National databases of TV bands saying what TV white space is present at the location you ask about – I am here, what channels are free? Fixed devices allowed 1W tx power/4W EIRP –TV channels 2, 5-36, 38-51 nationwide* ~240 MHz –Must sense signals to -114 dBm –Fixed devices must consult TV bands database daily Personal/portable devices allowed 100 mW EIRP –TV channels 21-36, 38-51 nationwide* ~180 MHz –Must sense signals to -114 dBm –Master mode devices must consult TV bands database daily or after changing location

7. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 7 Part 15 rules provide few rights 15.5(a) Persons operating radiators have no right to continued use of any frequency by virtue of prior registration or certification of equipment 15.5(b) No harmful interference is caused, and interference must be accepted that may be caused by the operation of an authorized radio station 15.5(c ) The operator of a radio frequency device shall be required to cease operating the device upon notification by a Commission representative that the device is causing harmful interference

8. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 8 Use of low frequencies compared with 5 GHz bands Low frequency signals like TV have long wavelengths ~ 50 cm to 6 meters vs ~5 cm The absorption of building materials (wood, concrete, glass) of RF is not particular different from 600 MHz to 6000 MHz The "noise" present in the environment is dramatically lower above 1 GHz - essentially zero vs many dB below 1 GHz The shorter the wavelength, the more rapidly a receiver's acquired signal varies in space due to multipath effects (MIMO and SDR work worse at low frequencies)

9. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 9 Use of TV white space is interesting Take the value of US 2.45 GHz band market as a proxy, and apply it to more and better spectrum –BlueTooth, Wi-Fi and a host of others; ~2 billion BlueTooth chipsets, 387 million Wi-Fi chipsets shipped in 2008. –83.5 MHz * 305M people = 25,467 MHz POPs US TV band white space is 290M people * up to 180 MHz for Personal/Portable –Hard to value the US TV white space market because the bigger the city, the less free spectrum is available. Only after the TV band database is fully populated, will we know exactly how much white space there is. If the average household can receive 7 over-the-air TV channels, on average 23 channels are available for personal/portable use. US TV band white space is 290M people * up to 240 MHz for Fixed –An Intel filing indicates that the average household has at least 6 white space channels (slide 6) –http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=65 17611737http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=65 17611737

10. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 10 Key concepts FCC Definitions and how they protect all existing services What must be known - frequencies, location and what is in the TV bands database for that location –Rate of TV bands database update by master devices – daily or online? Time- limited certificates? –Register to receive messages, database changes are pushed to affected Master stations Master / Client situations where client devices are controlled by a master device What must be sent by master devices –Identifying information is FCC Type ID, Unit number and location 15.711(e) What must be sensed (and who must sense) –Alternatives to all devices must sense wireless microphones microphones

11. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 11 TV bands database and master devices 15.711(b) (iii) If a fixed or mode II TVBD fails to contact the TV bands database during any given day, it may continue to operate until 11:59 PM of the following day at which time it must cease operations unless it has contacted the TV bands database during the intervening period. The consequence of this rule is that constant sensing by all devices is imperative to protect others during the interval between updates from the TV bands database. Constant sensing costs energy. One alternative to daily contact is to have each master device receive a certificate of time-limited operation from the TV bands database. When the certificate expires the master must renew it or cease operation. The time-limit is variable, based on the location of operation and activities of others. Another alternative is to have each master device provide an Internet contact address, and the TV bands database will push changes in channel availability to affected master devices. Master devices would be required to verify their Internet connectivity hourly or cease operation.

12. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 12 Sensing rules and 802.22 discussions 15.711(c )(i) All fixed and personal/portable TVBDs must be capable of detecting ATSC digital TV, NTSC analog TV and wireless microphone signals using analog or digital modulation methods. The required detection thresholds are. –(A) ATSC signals: -114 dBm, averaged over a 6 MHz bandwidth; –(B) NTSC signals: -114 dBm, averaged over a 100 kHz bandwidth; –(C) Wireless microphone signals: -114 dBm, averaged over a 200 kHz bandwidth. This means even more energy consumption!! For a discussion of issues, look at https://mentor.ieee.org/802.22/file/08/22-08-0334-06-0000-fcc-r-o- 08-260-items-for-discussion.doc https://mentor.ieee.org/802.22/file/08/22-08-0334-06-0000-fcc-r-o- 08-260-items-for-discussion.doc –Item 2 is discussion of sensing (last few paragraphs and 22-08/338r1)

13. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 13 Personal/portable device sensing issue As wireless microphones evolve and digital microphones become more popular, the radio characteristics to be sensed will change, just as radio characteristics of radars change - sensing wireless microphones is a journey Note that ETSI radar band rules allow a master radar sensing device for all stations that operate under its control – the sensor typically is mounted on the roof and communicates with all RLANs in the building An alternative to requiring that all devices must sense everything is to increase the contact between master devices and the database and relax the sensing requirements for client devices

14. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 14 Straw Polls 41 people in the room Should 802.11 support a Petition for Reconsideration of the TV bands database(s) and their interaction with Master devices? –Yes 23 No 0 (21 said 802.11, 2 said 802.15 is principle interest) Should 802.11 support a Petition for Reconsideration of the requirement that client devices must sense wireless microphones? –Yes 16 No 0 (15 said 802.11, 1 said 802.15 is principle interest) Should 802.11 support a Petition for Reconsideration of the requirement that personal/portable devices must sense wireless microphones? –Yes 3 No 0 (3 said 802.11 is principle interest)

15. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 15 Straw polls (2) Should 802.11 support a Petition for Reconsideration of the requirement that Part 15 devices must sense wireless microphones? –Yes 4 No 0 (3 said 802.11 is principle interest) Should 802.11 support a Petition for Reconsideration of the requirement that Part 15 devices must sense? –Yes 0 No 2 (1 said 802.11 is principle interest)

16. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 16 Timeline for action on rules New FCC part 15 rules will become law the day of publication in the Federal Register When they are published, there is just thirty days to submit Petitions for Reconsideration, then thirty days for submitting reply comments to the Petitions for Reconsideration As the Erratum was available January 9 th, the rules can be published next week, and the thirty day window would close before the March 9 th plenary opens. IEEE 802.18 adjourns Thursday evening, and taking an 802.11 position to 802.18 after this week requires a 15-day letter ballot.

17. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 17 Motion The IEEE 802.11 Working Group supports an IEEE 802 Petition for Reconsideration of FCC rules 47 CFR 15.711(b)(iii) and 47 CFR 15.711(c )(i) that discusses the alternative concepts presented in slides 11 and 13 of 11- 09/0077r3. Moved Seconded Vote Motion

18. doc.: IEEE 802.11-09/0077r3 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 18 References FCC Proceeding 04-186 http://fjallfoss.fcc.gov//prod/ecfs/comsrch_v2.cgihttp://fjallfoss.fcc.gov//prod/ecfs/comsrch_v2.cgi FCC 08-260 rules http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-08-260A1.pdf http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-08-260A1.pdf FCC Erratum DA 09-20 January 9, 2009 http://www.fcc.gov/Daily_Releases/Daily_Business/2009/db0109/DOC- 287799A1.pdf IEEE Std 802.11-2007 and amendments 1, 2 and 3 http://standards.ieee.org/getieee802/802.11.html http://standards.ieee.org/getieee802/802.11.html IEEE 802.11 TV white space documents https://mentor.ieee.org/802.11/file/08/11-08-1254-03-0wng-tv-white-space- fcc-action.ppt https://mentor.ieee.org/802.11/file/08/11-08-1439-01-0wng-fcc-08-260-clauses- devices-and-pops.xls IEEE 802.22 documents https://mentor.ieee.org/802.22/documents https://mentor.ieee.org/802.22/documents