DEBATE ON INTERNATIONAL UWB POLICY TEED UP AT ITU

State Dept.’s International Telecom Advisory Committee- Radiocommunications created ad hoc preparatory group in fall to work on contributions to new ITU group. Study group adopted blueprint for policy issues to be evaluated on compatibility between UWB devices and other services. U.S. contributions have been closely watched because this is first national administration to draft technical rules for UWB. Participants have included representatives of AT&T Wireless, Defense Dept., Delta, FAA, Intelsat, Lucent, Motorola, NASA, Nokia, NOAA, PanAmSat, Time Domain, Transportation Dept., U.S. GPS Industry Council, Xtreme Spectrum. ITU policy formation comes as countries such as Canada have been closely monitoring U.S. regulations and as Europeans are moving toward regulatory decision that could come later this year, source said. “Other countries are going to be looking to the ITU for some guidance on the issue,” source said. “That’s why the ITU process is important.”

How ITU policy proposals are shaping up in other countries isn’t clear yet and contributions to study group aren’t expected to be available until about week before 4-day meeting starts Jan. 21, said FCC’s Ron Chase, chmn. of U.S. Task Group 1/8 on UWB. This month’s meeting will be first of international task group 1/8 on UWB, he said. While some of reference documents in U.S. have been hotly contested in months leading up to meeting, Chase said proposals appeared to be coming together, with some parties reaching accommodation to get papers out. Consensus within task group wasn’t reached on all documents that were forwarded late last month to ITAC’s national committee. Before U.S. contribution is submitted to ITU group, it will be reviewed and subject to approval in next few weeks by State Dept. in consultation with NTIA and FCC as part of ITAC-R National Committee process, Chase said. Task group has been working with major condition that papers must be consistent with U.S. policy set out in UWB order, he said. In some cases, he said, “there have been differing views as to what that means.”

In some cases differences between agencies or private sector interests over provisions of U.S. proposal at ITU had been bridged recently “more out of exhaustion than anything else,” industry source said. “The U.S. side spends 90% of its effort fighting among itself and as an afterthought we have to negotiate this with the rest of the world. I don’t have a sense of how this will play out in Geneva.”

Among broader policy areas with which more than 100 industry and govt. participants have wrestled is extent to which FCC’s UWB order may change. Several petitions for reconsideration challenge emission limits in order. Commission also had indicated it would revisit limits in rules within year of adoption of Feb. order. Included in draft policy proposals circulating for comment in fall before submission to ITU Study Group was language that would have cautioned that U.S. emission levels could be subject to change. “We now have levels that are the ‘law of the land’ and we need to stand by them until they change,” Defense Dept. said. To do otherwise would distract international policy process with domestic U.S. issues that should have been resolved in FCC’s report and order, comments said.

One hotly debated issue in U.S. Task Group has been whether ITU rules bar national administrations from authorizing UWB vehicular radar on unlicensed, noninterfering basis at 23.6-24 GHz. Short Range Automotive Radar Frequency Allocation (SARA) group represents auto and component manufacturers involved in 24 GHz UWB-based auto radar systems. Those systems use UWB-based radar systems to provide safety services such as crash detection and near- collision avoidance. Vehicular radar systems are one of 3 types of UWB devices for which FCC order set operating parameters under Part 15. Part of ITU Radio Regulations, No. 4.4, spells out that national administrations have sovereign right to use spectrum in manner they choose without causing harmful interference to other administrations operating under those rules. One concern raised by some federal agencies, including NOAA, was that Article 15 of Radio Regulations bars emissions in certain bands, including 23.6-27 GHz. In comments on documents, NOAA acknowledged that govts. had ability under ITU spectrum sovereignty provisions.

SARA group, in spectrum management paper, disputed earlier draft version of task group document. That would have barred administrations from authorizing UWB-based vehicular radar at 23.6-24 GHz. SARA argued that U.S. and other countries had ability under sovereignty language of No. 4.4 to allow those operations, even in light of restrictions that Article 15 imposed on band. Group also noted U.S. already had decided UWB in-vehicle radars could operate in band without creating harmful interference to passive services, such as spaceborne passive sensors below 25 GHz. NOAA had contended that while administrations could operate under sovereignty provisions of Radio Regulations, if such operations created harmful interference to stations that complied with rules, Article 15’s prohibitions against harmful interference would apply. Debate centered, in part, on footnote to Article 15 that was designed to protect passive services such as earth exploration satellite services, source said. Issue is whether footnote, intended to keep those bands clear of potential sources of harmful interference, bars administration from allowing nonconforming uses. Sovereignty provisions of Radio Regulations, which is key part of ITU treaty language, lets administration manage spectrum to allow use that doesn’t conform to ITU rules on noninterference basis if it concludes operation won’t cause harmful interference to another service, source said. Concerns raised by some agencies about protection of passive services in those bands has been that footnote bars other uses of such bands even if risk of harmful interference is ruled out, source said. SARA argument has been that national administrations have purview to allow such operations to move forward and U.S. already has done so in UWB order.

Meanwhile, back-and-forth has continued in FCC filings on UWB limits in order last Feb. Ericsson in Dec. 20 filing submitted test results to Commission that it contended showed UWB emission limits of -53 dB at 1610-1900 MHz were “at least” 20-30 dB too high. “If UWB devices operate in these bands, in accordance with the emission levels now in place, they will unacceptably interfere with the performance and capacity of existing PCS systems,” Ericsson said. “As a result, consumers will experience service interruptions, an inability to access the network to place calls and degradation in signal quality. UWB technology must not be authorized at the expense of existing services.”

Ericsson submitted results that calculated interference of single UWB transmitter with “generic” wireless receiver and interference results for multiple UWB devices. Equipment-maker said that based on its analysis and preliminary aggregate simulations, FCC rules were “not sufficient to protect existing licensed services, like cellular services, from harmful interference.” It said Commission analysis failed to adequately take into account close proximity with which UWB devices were expected to operate to existing wireless systems, such as wireless local area networks, cordless phones or cellular receivers. Ericsson said UWB devices and receivers that could experience interference could be integrated into same PC. FCC should consider “very small separation distances” when calculating potential interference effects, from 20 cm to 1 m, filing said. Ericsson told FCC that UWB technologies “should not be introduced at this time” because: (1) Its “independent evaluations” of UWB emission limits showed that FCC sharing criteria between UWB and existing services weren’t sufficient. (2) Numerous pending petitions for reconsideration on UWB order pinpointed “factual and legal concerns regarding the impropriety of overlaying UWB technology in accordance with existing guidelines.” (3) FCC staff report on background emissions data for evaluating UWB emissions limits in GPS bands was “based on inappropriate testing methodology and produced inapplicable data.”

Other issues that cropped up during U.S. task group discussions included limits for UWB devices proposed by some satellite digital audio radio service proponents. Some concerns were raised that proposed limits would be far below those set out in FCC order and could have onerous impact on other unlicensed devices as well.