1. 1 FREQUENCY ALLOCATIONS and SHARING Ultra-wideband Technologies Presented to: National Spectrum Managers Association Spectrum Management 2002 May 22, 2002 James E. Hollansworth NASA Glenn Research Center Cleveland, Ohio

2. 2 Understanding NASA shares what we understand to be the core principals underlying the FCC’s NPRM on this issue. UWB’s are a promising and singular technology worthy of future exploitation. Benefits to both Government and Private Industry appear attractive.

3. 3 Background In 1998, the Federal Communication Commission (FCC) began a detailed examination of Ultra-Wideband (UWB) technology and devices with an aim toward establishing rules for their use on an UNLICENSED BASIS under Part 15 of the Rules. Notice of Inquiry (NOI) ET Docket 98-153 dated August 20, 1998 titled “Revision of Part 15 of the Commission’s Rules Regarding Ultra-Wideband Transmission Systems”. In 2000, the Commission issued an NPRM on UWB Notice of Proposed Rulemaking (NPRM) ET Docket 98-153 dated May 10, 2000 titled “Revision of Part 15 of the Commission’s Rules Regarding Ultra- Wideband Transmission Systems”. This NPRM sought comment on a wide range of issues relating to the use of these devices

4. 4 UWB Test Programs As a result of RFI concerns, several test programs were conducted in the US to assess the susceptibility of various radio services and devices to interference caused by UWB operations. Major test programs and analyses that were conducted and filed in this Docket: National Telecommunications and Information Administration (NTIA) NTIA Report 01-383 “The Temporal and Spectral Characteristics of Ultrawideband Signals” January 2001. NTIA Special Publication 01-43 “Assessment of Compatibility Between Ultrawideband Devices and Selected Federal Systems” January 2001. NTIA Special Publication 01-45 “Assessment of Compatibility Between Ultrawideband (UWB) Systems and Global Positioning System (GPS) Receivers” February 2001. NTIA Report 01-384 “Measurements to Determine Potential Interference to GPS Receivers from Ultrawideband Transmission Systems” February 2001.

5. 5 UWB Test Programs (Cont) US Department of Transportation (DOT) Stanford University “ Potential Interference to GPS from UWB Transmitters – Test Results” Phase 1A: Accuracy and Loss-of-Lock Testing for Aviation Receivers” October 2000 “ Potential Interference to GPS from UWB Transmitters – Phase II, Test Results: Accuracy, Loss-of-Lock, and Acquisition Testing for GPS Receivers in the Presence of UWB Signals” March 2001 University of Texas/The Johns Hopkins University/Time Domain “Final Report UWB-GPS Compatibility Analysis Project” March 2001 Private industry filings (all with multiple filings describing potential interference scenarios) Qualcomm Sprint XM Radio Sirius Radio MSSI

6. 6 UWB Test Programs Summary NTIA testing as well as DOT testing has indicated potential interference to Federal systems (particularly GPS) unless UWB emissions are restricted Qualcomm, Sprint, XM Radio and Sirius Radio have all indicated potential RFI to their networks unless UWB emissions are restricted. FCC indicated at their February 14, 2002 adoption of the R&O (and at the subsequent press conference) that the Commission intends to conduct RFI testing of UWB devices.

7. 7 FCC Report and Order (R&O) At its February 14, 2002 meeting, the FCC adopted a R&O authorizing UWB devices to operate across US Government restricted bands at or below current Part 15 limits. Emissions in the GPS bands must be 34 dB less than Part 15 limits for indoor systems. DOT, FAA and NASA voiced additional RFI concerns and suggested the FCC issue a Further Notice of Proposed Rulemaking to allow time for additional study and testing. The FCC issued a First Report and Order on UWB use under Part 15 on April 22, 2002. Published in Federal Register May 16, 2002. The FCC intends to revisit this issue within 6-12 months with an aim at implementing “more flexible technical standards and to address operation of additional types of UWB operations and technology.” Commission believes that the standards contained in the R&O are extremely conservative.

8. 8 UWB Emission Limits for GPR's, Wall Imaging, & Medical Imaging Systems Source: FCC Operation is limited to law enforcement, fire and rescue organizations, scientific research institutions, commercial mining companies, and construction companies. 235 SDARS FSS PCS TV GPS

9. 9 Operation is limited to law enforcement, fire and rescue organizations. Surveillance systems may also be operated by public utilities and industrial entities. UWB Emission Limits for Thru-wall Imaging & Surveillance Systems Source: FCC FSS 235 GPS PCS SDARS TV

10. 10 UWB Emission Limit for Indoor Systems Source: FCC FSS 235 SDARS PCS GPS TV

11. 11 UWB Emission Limit for Outdoor Hand-held Systems Source: FCC 235 FSS SDARS PCS GPS TV

12. 12 UWB Emission Limits for Vehicular Radar Systems Source: From data contained in FCC 02-48 -40 -90 -50 -60 -70 -80 10221.60.962931 23.6-24 GHz NASA,NOAA,NSF 2005 2010 2014 -66 -71 -76 Note: Emissions in the passive band at 23.6-24 GHz shall be reduced to the levels shown by the year indicated for directions greater than 30 degrees above the horizontal plane. -41 dBm Frequency (GHz) -61 GPS UWB Emission Level in dBm -51 -61 Not to scale

13. 13 International Implications Xtreme Spectrum launches global Ultra-wideband initiative (May 6, 2002 Company Press Release). Hires VP to direct worldwide regulatory affairs. ITU-R WP 8A Ad-hoc UWB correspondence group. Established to consider implications of UWB ITU-R WP 1A and 1B are also examining introduction of UWB technology globally. ITU allocations footnote S5.340 prohibits emissions in exclusive passive bands. International considerations likely to take several years. European Meeting – “2 nd Workshop on Introduction of Ultra Wideband Services to Europe” 11 April 2002 Mainz http://www.ero.dk

14. 14 Controversial Issues Potential RFI issues remain unresolved. Global Positioning System Cellular Phones E-911 GPS services Passive sensors Text contained in R&O may interfere with NTIA authority to regulate US Government spectrum use (Para 273). DOD working with NTIA to draft comments to para 273. FCC intends to revisit rules contained in R&O within 6-12 months. Aim is to relax regulations and possibly authorize new types of UWB devices. Can we gain enough operational sharing experience during the next 6-12 months to effectively change the rules?

15. 15 Controversial Issues (Cont) Telecommunications and the Internet Subcommittee (Chairman Upton, R-Mich.) of House Energy and Commerce Committee will hold a hearing titled "The Federal Communication Commission's UWB [ultra wideband] Proceeding: An Examination of the Government's Spectrum Management Process." June 4, 10:00 a.m., 2123 Rayburn Bldg.

16. 16 Summary and Conclusions NASA is concerned for the continued viability of critical safety of life systems such as the GPS and the continued viability of Earth resources data from sensitive satellite borne passive sensors. Federal agencies expect the UWB issue to continue to require a great deal of spectrum management vigilance. Some agencies fear that a dangerous precedent is being set with respect to US Government restricted bands and in non- Government bands as well. R&O fails to implement substantive provisions for regulating and enforcing the rules contained in the R&O.

17. 17 Stay Tuned………… ACHIEVING A GOOD BALANCE BETWEEN NEW TECHNOLOGIES AND EXISTING SPECTRUM USERS TAKES TIME.