1. doc.: IEEE 802.11-09/0077r2 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 1 TV white space update 1 Date: 2009-01-18 Authors:

2. doc.: IEEE 802.11-09/0077r2 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 802.11-09/0077r2 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 802.11-09/0077r2 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 dense urban markets 15.707(a) –Note that some of channels 14-20 are shared with Land Mobile Systems in dense urban markets 47 CFR 90.303(a)

5. doc.: IEEE 802.11-09/0077r2 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 The FCC has protected some TV band Private Land Mobile Radio Services/Commercial Mobile Radio Services in 13 metro areas TV white space at a location is the unused TV channels at that location at that time (wireless microphones come and go) Licensed uses continue to be protected to their full extent of operation

6. doc.: IEEE 802.11-09/0077r2 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 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

7. doc.: IEEE 802.11-09/0077r2 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 802.11-09/0077r2 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 802.11-09/0077r2 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 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 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 802.11-09/0077r2 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 10 Key concepts FCC Definitions and how they protect all the existing services What must be known - frequencies, location and what is in the TV bands database for that location –Rate of the database update – daily or 15 minutes? Transmit Power and Master / Client situations What must be sent - identifying information is FCC Type ID, Unit number and location 15.711(e) What must be sensed (and how much accuracy sensing requires) –Alternatives to microphone sensing Register to receive messages, database changes push model

11. doc.: IEEE 802.11-09/0077r2 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 11 Primary WG Interest Survey of room 802.3 802.11 802.15 802.16 802.20 802.21 802.22

12. doc.: IEEE 802.11-09/0077r2 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 12 Straw Poll 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)

13. doc.: IEEE 802.11-09/0077r2 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 13 Straw poll (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) 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)

14. doc.: IEEE 802.11-09/0077r2 Submission January 2009 Peter Ecclesine, Cisco SystemsSlide 14 References FCC Proceeding 04-186 http://fjallfoss.fcc.gov//prod/ecfs/comsrch_v2.cgi http://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 802.22 documents https://mentor.ieee.org/802.22/documents https://mentor.ieee.org/802.22/documents