SpectrumTalk

noreply@blogger.com (MJM) — Fri, 13 Nov 2009 19:13:00 +0000

FCC's Changing Its Image

Lots of news media have reported the appointment of Yul Kwon as Deputy Chief of the FCC's Consumer & Governmental Affairs Bureau. He is third from left in the above photo from Survivor: Cook Islands which he won. However, his Wikipedia bio makes a convincing case that he is well qualified for this job.

Some excerpts:

Kwon was born in Flushing, New York, to South Korean immigrants. He moved to Concord, CA and attended Northgate High School, where he graduated valedictorian and played varsity water polo and track & field. Kwon attended college at Stanford University, graduating in 1997 with a B.S. degree in Symbolic Systems. As a student, he earned recognition for both academic achievement (Phi Beta Kappa) and community service.

Kwon’s professional career spanned a variety of roles across technology, law, business, and government. He worked at two law firms - Venture Law Group and Harris, Wiltshire & Grannis. He served a judicial clerkship with Judge Barrington D. Parker, Jr. on the Second Circuit Court of Appeals. He also worked as a legislative aide to U.S. Senator Joseph Lieberman in Washington, DC.

Kwon is involved with numerous charitable projects. After Survivor, he helped his co-finalist, Becky Lee, establish Becky’s Fund, a nonprofit helping victims of domestic violence. He works with several nonprofits to raise awareness of the need for more minority bone marrow donors, and is a spokesperson for the Asian American Donor Program and the National Marrow Donor Program.

During the 2007-2008 U.S. presidential campaign, Kwon supported then-Senator Barack Obama and campaigned for him as a surrogate in the Asian American community.

Kwon, with business partners, became the Northern California franchisee for Red Mango, a national frozen yogurt brand specializing in healthy probiotic yogurt and yogurt-based foods.

So while he did make the following lists in 2006/2007: People Magazine’s Sexiest Men Alive, People Magazine's Hottest Bachelors, and Extra TV's Most Eligible Bachelors, he has some real qualifications for his job at FCC.

The last media celebrity I recall working at FCC was Adrian Cronauer, the inspiration for the Robin Williams character in Good Morning, Vietnam.

noreply@blogger.com (MJM) — Wed, 11 Nov 2009 19:36:00 +0000

Unfortunately, You Can't Make

the Wireless Microphone

Problem Go

Away by Taking a Different

Tack in TV White Spaces

There seem to be repeated rumors coming out of FCC that maybe they should take a different approach to utilizing TV "white spaces" by licensing them for broadband. Perhaps some think this will solve the wireless microphone problem painlessly - it won't.

TV white spaces are the inevitable result of TV broadcast licensing, especially when there is uneven terrain and uneven population distribution. There will always be places where there is no usable TV signal on a channel and were lower power use of that channel by other services is possible without interference. Under analog TV there was a lot more such white space due to the "UHF taboos" necessary to avoid neighboring channel interference to TV sets with mediocre selectivity. (FCC efforts in the 1970s to improve TV selectivity and decrease white spaces went down in flames due to broadcaster opposition.)

Wireless mics can use TV white space to provide a useful service, but in doing so inevitably use spectrum inefficiently compared to other possible users of white space. Why? Wireless mic use is intermittent in both space and time and only uses a tiny fraction of the space/time/spectrum resource made available by TV white spaces. Hence use is heavy in the Broadway theatre district of Manhattan and in a few other theatre districts. Use is heavy near churches for a few hours a week. But reserving TV white spaces for the exclusive use of wireless mics denies the spectrum to other that can use it much more intensely.

The current wireless mic mess is a result of both benign neglect of FCC towards this sector and aggressive merchandising by mainly Shure, Inc. to large numbers of users ineligible under current FCC rules to use them. (The hypocrisy of the TV broadcasters for opposing Part 74 eligibility for the churches and theatres for years, if not decades, and then becoming Shure's "best buddy" during Docket 04-186 is certainly a case of "strange bedfellows".)

I have repeatedly written here that "wireless mics are a legitimate use of spectrum (that) deserves more from FCC than benign neglect that allows most users only criminal spectrum squatting" . Yet FCC has taken no action even on the relatively simple issue in Docket 08-166 of evicting wireless mics from the spectrum that is now licensed to others after the DTV transition, let alone the more complex issue in Docket 08-167 of whether action should be taken against anyone for flaunting the Commission's rules and creating a de facto reallocation of spectrum.

The only way to avoid the inefficient use of white space that would result from preserving the present squatting of large numbers of users is to move towards a new method of serving wireless mic needs that does not give them exclusive, hence inefficient, spectrum. Let me note that CMRS licensees already have the regulatory flexibility offer femtocell-like systems that transmit wireless mic signals on CMRS spectrum without interconnection to the public network - one way connections from the microphone to the theatre/church audio panel. While the microphones and analog-to-digital convertors (DAC) used in cell phones are not of sufficient sound quality for many wireless mic applications, there is enough CMRS bandwidth available now to permit adequate quality with better mics and DACs. If the CMRS crowd really wants 800 MHz below 3 GHz , maybe it should seriously think about helping FCC by proposing a practical alternative to the wireless mic impasse.

Another approach to solving wireless mic spectrum problems is to move this use to another band where it will have a compatible spectrum sharing partner. Since wireless mics are a distinctly short range service, such sharing should be possible. For starters, the 1435-1525 MHz aeronautical telemetry band might be considered.

But letting wireless mics just sit in white spaces will inevitably cause problems for both the current policy adopted under Docket 04-186 and any alternative path the Commission might go down.

noreply@blogger.com (MJM) — Sat, 07 Nov 2009 14:41:00 +0000

GPS

and

The Big Dig:

1) If GPS amplifier use in underground highways causes no problems, why is it illegal?

2) If it is illegal, why don't FCC and NTIA care about enforcement?

A few months ago I was in Boston staying with relatives in the Northern suburbs. I was invited to give a talk at the Massachusetts Department of Telecommunications and Cable, located at South Station in the center of Boston. Without thinking too much I punched the address into my trusty GPS and headed South. I am a native of Boston but hadn't thought of the impact of the "Big Dig", the major highway reconstruction in Boston that moved several key highways to underground bringing the harbor back to the cityscape. As I entered Boston from Cambridge it was an "Oh, sh.." moment as I realized that I was entering a Big Dig tunnel and my GPS would lose signal. However, it did not and even followed me through the tunnel and told me what exit to take. Amazing?

Recently I had a similar occurrence in the I-395 tunnel in downtown Washington. Not unrelated is noticing that my GPS works in rental car parking garages at certain airports such as Phoenix. Why do these things happen?

The most likely explanation is the use of GPS amplifiers - amplifiers with an outdoor antenna that receives a GPS signal and a second antenna in an area that has no GPS signal which it "illuminates". THESE ARE ILLEGAL (except with a license this can only be obtained in special circumstances.) Why are they illegal? The main GPS frequency, 1575 MHz, is an exclusive Federal Government band and is listed in 15.205 as a "restricted band" - forbidding all unlicensed systems. NTIA has provisions in its "Red Book", the analog to FCC Rules, for use of this band. This gives terms for federal agencies to use systems other than GPS in this band. FCC and NTIA have an understanding that is documented nowhere on the public record that nonfederal users, e.g. FCC regulatees, may apply to FCC for an experimental license for use of this band and it will be reviewed by NTIA in accordance with Red Book Section 8.3.28. If NTIA agrees with the request, an experimental license can be issued by FCC. While 8.3.28 does not say so, senior staff at NTIA have said that they will only approve GPS amplifiers in connection with testing GPS receivers - not for use in tunnels and garages. It appears that this unwritten policy is applied inconsistently.

In any case, a search of the FCC database shows no valid experimental licenses for this band in Boston. It would appear that the GPS signals are coming from an illegal transmitter.

(I thought the GPS amplifiers in question might have been put there to support cellular base stations in the tunnel as cellular base stations usually need GPS input for both frequency and time reference. However, some inquiries revealed that several cellular carriers in Boston collaborated in a fiber optic system that brings the GPS information to their underground base stations without reradiating them in the tunnel. Do all the cellular carriers in the Big Dig use this system? I don't know.)

As you can see from the map at the top of this page, the Big Dig is close to Logan Airport.

Has the illegal system in the tunnel caused any problems? It certainly has helped the public traveling through the Big Dig.
If it hasn't caused any problems, why does NTIA continue to forbid this type of spectrum use?
Since it is illegal and NTIA insists it is a safety-related issue, why doesn't FCC take some enforcement action?

Perhaps NTIA and FCC could explain their views on this issue for the benefit of readers.

noreply@blogger.com (MJM) — Tue, 03 Nov 2009 22:06:00 +0000

Neutrality on

FCC Website

A Surprising Feature of ULS -
the "Universal" Licensing System

I ventured into ULS this week for the first time. Most of my work with FCC involves experimental (Part 5) licenses or rulemakings so I had never entered an application on ULS. For those who also haven't dealt with ULS, here is the official party line:

The Universal Licensing System (ULS) is the easy, online answer to your wireless licensing and research needs. ULS simplifies the application and licensing processes and provides secure, world-wide access through the Internet. This results in reduced filing time and financial savings for both customers and the federal government.

The ULS is browser-based, for ease of use, and provides built-in security. It contains everything you need for electronic filing. You will select the service and the purpose of your application, and the system will dynamically create a screen that will only ask you for the information that is needed. Likewise, if you want to make an administrative change in our licensing database or are required to submit a filing on a specific call sign, you'll be able to access your records with a password and immediately make the changes. Determining the status of an application is just as fast and easy.

Keeping Pace with Technology - The ULS incorporates the latest technical advances that are revolutionizing personal communications and information access to provide wireless radio licensees with online access to their FCC license records. Use your Web connection to keep abreast of fast-breaking developments, and use the ULS to keep your existing registrations up to date as changes occur. (Emphasis added)

Despite its name and the discussion above, ULS is not universal within FCC although it is "universal" within the world of the Wireless Telecommunications Bureau. Other Title III wireless/radio licensing systems at FCC include:

Broadcast Radio and Television Electronic Filing System (CDBS)
Cable Operations and Licensing System (COALS)
International Bureau Electronic Filing System (MyIBFS)
OET Experimental Licensing System Electronic Filing

(The OET-maintained General Menu Reports System (GenMen) allows access to review licenses across all 5 systems, but does not allow input of information.)

But the real surprise was the problem I encountered which is shown in the screen shot in the upper left corner of this posting. ULS supports Windows 98, NT, 2000, ME, XP and Windows Vista. It also supports the following browsers: IE8, IE6, Firefox 2, Netscape 8.1 .

Firefox 3, Safari, Chrome - no guarantees. But it is good to know that Netscape 8.1 is still supported! The site also says:

"NOTE: ULS does not support Linux, Unix,

Sun Solaris, or Macintosh operating systems."

I suppose Mac fans like me should not be too jealous because even Windows 7 isn't supported.

But I hope the new team at FCC reviews this issue and sets some goals to prevent this type of problem in the future. Clearly these quirks of ULS have been around for a while and can't be fixed overnight. But recognizing them can help guide revision of the FCC website.

Why should FCC, presumably the most tech savvy agency in the federal government, have web-based systems that are so fussy about the users' systems?

I don't know what the traffic to the FCC website looks like, but the traffic to this blog uses the browsers shown below. In the past 500 readers, nary a Netscape user! Lots of IE 7, Firefox 3, Safari, and even a few Chrome and Opera users. I assume FCC website visitors have a similar spectrum of software systems.

(Click on chart to get clearer version)

noreply@blogger.com (MJM) — Tue, 03 Nov 2009 18:15:00 +0000

IEEE Wireless Communications

10/09 Spectrum Policy

Column Now Published

Your blogger's regular column on spectrum policy in IEEE Wireless Communications magazine was published this week. Unlike this blog, the IEEE column describes issues and tries to avoid advocating positions.

The new column is entitled "Wireless Innovation and Spectrum Policy: The FCC Opens a New Inquiry" and deals with Docket 09-157. It boldly stated that "(t)he final deadline for comments in thsi inquiry is after the publication date of this magazine". This became incorrect when the FCC delayed reply comments and IEEE was very timely with the publication.

noreply@blogger.com (MJM) — Mon, 02 Nov 2009 22:11:00 +0000

France's "CTIA"
on
RF Safety Issues

I was visiting France recently, went into a store of one of the major cellular operators and bought a new SIM card to activate my old French GSM unit during my visit. With the card came all sorts of literature, but what caught my attention was the brochure shown at left - the picture is linked to a .pdf of the whole brochure on the website of Association Française des Opérateurs Mobiles (AFOM), the French counterpart to CTIA.

Now, based on my high school French study and 3 years living in Paris, I am not exactly a certified translator, so what follows is the gist of what it says. But feel free to consult the original text with someone of more professional skills if you don't believe me.

The brochure clearly says that the health authorities do not think that cell phone use is a health issue at exposure levels required by governments.

(Actually the French use the European standard of an SAR limit of 2.0 W/kg vs the FCC limit of 1.6 . Furthermore, details of how the European standard is measured actually makes it actually somewhat higher than it would appear numerically.)

So what does the real CTIA have to tell the public about RF safety? Surf on over and see. You will find statements like

To date, the available scientific evidence does not show that any health problems are associated with using wireless phones. Many studies of low-level RF exposure, such as that which occurs with wireless devices, have not discovered any negative biological effects. Some studies have suggested such a connection, but their findings have not been replicated or supported in additional research.

You find similar statements on the AFOM site and in this document. But you will also find the section shown at left entitled "Comment réduire mon exposition aux ondes radio quand je téléphone ?" Which your nonexpert translates has "How can I reduce my RF exposure while using the phone?" As I have said before, RF exposure doesn't do you any good, so why not try to reduce it?

AFOM reports that the health authorities recommend using what we would call a Bluetooth headset during calls. Health authorities also advise, according to AFOM, that pregnant women keep cell phones away from their abdomen (" il est conseillé aux femmes enceintes d’éloigner le téléphone du ventre et aux adolescents de l’éloigner du bas ventre. ")

Finally, AFOM tells us that the "health authorities" advise that you should use your phones in areas with good reception, that is more bars. (On the phone, not drinking establishments nearby! In French it is unambiguous.) ("Elles conseillent également de téléphoner de préférence dans les zones où la réception est de bonne qualité. La qualité de la réception est indiquée par le nombre de barrettes sur l’écran de votre téléphone.") That, perhaps should be obvious, but I must admit I have never thought of it before.

So this guidance does not come from some radical left wing tree-hugging environmentalists opposed to capitalism, but from a CTIA-like trade association of major French operators. I agree with CTIA that there is no evidence the cell phones cause health problems, but why not encourage people to think about selecting models with lower SAR, using Bluetooth headsets, and using handsets in areas with better reception?

I note that Verizon Wireless puts SAR date for each cell phone model it sells on the web pages for the models. But the other major operators that are CTIA members do not appear to have the information on their websites - perhaps it is there but hidden in obscurity.

Cell phones are useful devices that have contributed both to economic growth and public safety. It is a shame that CTIA starts acting like the former Tobacco Institute when it concerns any possible negative impact of cell phones.

noreply@blogger.com (MJM) — Thu, 29 Oct 2009 21:14:00 +0000

"Broadcasters Ponder

FCC Spectrum

Reclamation"

A recent Broadcasting and Cable article had this surprising headline.

The article started with this revelation,

A source confirms that broadcasters at last week's NAB board meeting in Dallas discussed the possibility of turning much of their digital spectrum back in to the government in exchange for a cut of the proceeds when that spectrum was reauctioned for wireless broadband. "There was not much support for the idea," said the source.

The "not much support" was not surprising. But the mere fact that they discussed a socially progressive potential economic stimulus concept that flies in the face of rigid broadcaster dogma and someone in the sacred inner circles of NAB had the temerity to leak it is what is surprising.

The issue at hand is the so called "big bang" proposal by Evan Kwerel and John Williams of FCC in 2002 in OPP Working Paper 38 in conjunction with the FCC's Spectrum Policy Task Force.

The abstract of the report states,

To facilitate the rapid transition from administrative allocation of spectrum to market allocation, this paper proposes that the FCC (1) reallocate restricted spectrum to flexible use; (2) conduct large-scale, two-sided auctions of spectrum voluntarily offered by incumbents together with any unassigned spectrum held by the FCC, and (3) provide incumbents with incentives to participate in such “band restructuring” auctions by immediately granting participants flexibility and allowing them to keep the proceeds from the
sale of their spectrum.

The proposal was not well received at the time.

But perhaps the NAB Board had read your blogger's comments to the FCC Innovation NOI.

Since NAB paid so much attention, here is the section they probably were thinking about:

Para. 54 (of the NOI) seeks comment on “innovations in the use of renewable energy and other green technology to makes wireless networks more energy efficient or address other environmental concerns.” At the risk of saying the obvious, the TV broadcast band uses a large amount of electric power to transmit RF signals that are actually received by an ever decreasing number of subscribers. The main apparent need for these transmitters is to guarantee to broadcast licensees “must carry” status with CATV systems. The use of electric power and the RF occupancy appears to be mainly a byproduct of this desired endgoal that gives 90+% of the viewership of licensed TV broadcasters. While over-the-air broadcasting gives consumers access to broadcast signals at no marginal cost compared to the pricing of MVDS service, policy options exist to offer basic MVDS service as comparable cost. For example, part of fees from new users utilizing former TV spectrum could be used to finance “lifeline” MVDS service.

MSS has no objection to giving present TV broadcasters long term must carry status, but questions why this must be accompanied with the waste of electric power and squatting on spectrum to deny it to others. While it is no possible under present law to let broadcasters keep must carry status without transmitting largely “unreceived” signals, MSS urges the Commission to explore and make recommendations to Congress for giving TV broadcasters incentives to cease using large amounts of electric power and cease filling spectrum with largely unwatched signals while retaining today’s must carry rights.

Reuters coverage: U.S. broadcasters balking at FCC spectrum plan

noreply@blogger.com (MJM) — Tue, 27 Oct 2009 10:53:00 +0000

FiOS has a Bad Day!

We have been FiOS customers since we returned from France 2 years ago. In general the service has been great. But Wednesday, disaster struck and Verizon responded very poorly.

So, Mr. Seidenberg, if you are reading, here is how your firm treats customers.

Wednesday morning my wife was calling France on our Vonage line. Why Vonage if we have FiOS triple play? Simply put, VZ's international rates are an anachronistic throwback to the AT&T monopoly era. $3.43/minute for calls to France? VZ offers its payphone customers cheaper rates than that! Hasn't VZ heard that the real going rate for international calls to industrialized countries is about $.10/minute. Why should you have to pay VZ a monthly retainer to get market rates? FCC deregulated international calls a decade or so, assuming their would be effective competition. VZ showed they were wrong.

But I digress. In the middle of her call, the line died and so did all our Internet service. As little checking showed that it was probably the FiOS router since all the lights on it were now out. This is a nonstandard router with clear warnings not to use a normal router as a replacement. So I called VZ and had a discussion. The help center quickly agreed the router was dead and offered to send me a new one overnight UPS. I asked if I could get it faster. They checked and said that I could get one at a VZ store and gave the address for the one in Montgomery Mall, a few miles away. So I got the the Mall when it opened at 10:30 AM to discover the booth there had no hardware of any type. They thought the Wheaton Mall store was large and might have it. But they couldn't say where the store actually was, "next to the old Circuit City and some government office" and the only phone number they had just reached a computerized call center.

So off to Wheaton Mall. In all fairness, the VZ staff there was very nice and very apologetic about their bumbling colleagues to had sent me on a wild goose chase. So back home empty handed. Fortunately, I had bought a VZ Wireless cellphone with an unadvertised feature: with a $20 extra cable you can connect it to a computer and use it as a wireless broadband modem. BUT unless the other specialized modems VZW sells, you can turn the high priced broadband service on and off subject only to 3 changes/account/month. So I call VZW, obviously could not reach them by Internet at this point, and turned the wireless broadband feature on. Thus we limped along for the next day or so.

1 PM Thursday the UPS guy shows up with the new router. It says run the CD with it when you connect it. Turns out the CD is Windows only! As you might guess, your blogger is a Mac fan. Another call to VZ and lots of apologies, turns out the CD shouldn't ne needed if you had run the previous one with the old router. OK, but the new router still didn't work. After 30 minutes of more resets of various equipment - I must admit it is impressive how they can troubleshoot problems without a truck roll. We are back in business.

Then I ask if I can get credit for the lost service. You can ask and in 2 months (!!) you will find out what they decide. Will they just wipe the VZW broadband charge off the books? No one could understand that logic.

So, Mr. Seidenberg, if you are reading this, could you look into this accounting credit? Could you also explain why none of your staff in the DC area has an extra router that customers can pickup in case of hardware failure?

noreply@blogger.com (MJM) — Fri, 23 Oct 2009 16:20:00 +0000

FCC Announces Workshop
on ex parte Reform

Faithful readers may recall that ex parte reform has been a recurring issue in this blog. (A B C D) No doubt as a response to this grass roots campaign, the Commission announced yesterday a workshop Wednesday on ex parte reform that will be simulcast over the web. I hope you watch it, or better yet, come and ask questions.

Washington, D.C. --The Federal Communications Commission will hold a staff workshop on October 28, 2009 to explore possible revisions to the Commission’s ex parte rules and processes to enhance the transparency of the Commission’s actions while at the same time maximizing the exchange of information between the public and the Commission.

This workshop follows an internal study of the current ex parte rules by Commission staff which identified a number of areas in which the current rules might be improved or updated. The workshop will also explore new issues posed by the increasing use of Internet-based media of communication and expression, such as blogs.

The workshop participants consist of practicing attorneys as well as representatives of companies, trade associations, and public interest groups, all of whom have substantial experience with the ex parte rules. The panelists will provide their perspectives on the successes and shortcomings of the current rules and suggest alternatives to better balance the goals of fairness, openness, and efficiency. A moderating panel of senior FCC staff will direct the panel discussions and pose questions.

noreply@blogger.com (MJM) — Tue, 20 Oct 2009 19:06:00 +0000

RF Filters: An Important but Often Overlooked Issue in Spectrum Policy

Problems With the New 3G and 4G Frequency Band

by Mike Alferman*, Guest Blogger

The current big push to ‘mobilize’ the Internet is raising the awareness in the industry to the capabilities and requirements for a passive component that normally doesn’t get into the spotlight. However, this component – the RF Bandpass Filter, has been a key item in radio spectrum policy for years. With the efforts to open up new frequency bands for wireless internet use, the RF Filter may in fact start doing some driving. However, without some intervention, it could be that the commercial realization of the needed filters may not happen.

Historically, the FCC allocated frequency bands and added additional spectrum as ‘Guard Bands’ to prevent the interference between services operating on adjacent frequency bands. In addition, the in-band frequency use was coordinated based on the best practice engineering requirements of the time. As commented in the this blog, when UHF TV was first licensed in the US, (with non-critical services located on either side of the allocated bands) the adjacent channels were left unoccupied as it was determined that the discrete component LC RF and IF Filters available in the TV receiver Tuners when the band was opened were incapable of the high performance required to eliminate adjacent stations from interfering with each other. Thus, due to the poor performance of the receiver tuner’s RF filters, large areas of the allocated spectrum were left unused. This spectrally wasteful practice wasn’t significant as there was enough spectrum capacity for the needs at that time. Obviously, times have changed.

The FCC is currently responding to the need to use every possible MHz of the public’s valuable spectrum and has eliminated the practice of adding significant Guard Bands between new services. While being more efficient in spectrum use, this has created a real problem! The reality of all RF Filter design is that a certain amount of frequency is required for the transition from the Passband to the Stopband (the roll-off). It should be noted that the theoretical ‘brick wall’ filter will forever remain theoretical because in addition to the roll-off of the basic filter design, allowances must be made in the design of practical filters for the shift of the filter due to temperature as well as for manufacturing tolerances. This means that current practical commercial RF Bandpass Filters for the new frequency allocations are not capable of preventing some interference between services.

To be certain, RF Filter performance has come a long way since the days of the old UHF TV tuner! Filters then were large multi-stage discrete LC units with modest performance – and to operate had to be aligned in manufacturing. In the late 80’s, Surface Acoustic Wave (SAW) filters became common in TV tuner IF stages. The performance of the SAW Filters was significantly better than what could be achieved with LC filters with much better manufacturability - in a much smaller package. In the last 20 years SAW Filters have continued to improve. The performance of the relatively low frequency SAW IF Filters of the late 80’s is now possible with SAW RF Filters at the much higher operating frequencies. At this time, the operating frequency for commercial SAWs has increased to above 2.5 GHz, the Filter rejection ‘skirts’ have greatly improved, the Insertion Loss of an average SAW Filter has been minimized – and all achieved at the same time as a 94% decrease in the package size and cost. BAW (Bulk Acoustic Wave – also called FBAR) Filters became common in the last 5 years and have yet higher frequency capability and better roll-off than SAW filters. However the cost, packaging and development time of BAW Filters are still a few years behind that of SAW filters.

Technically, in order to better meet the requirements for the new frequency bands, the needs for the improvement of both SAW and BAW Filter performance are similar. Adding a frequency trimming step in manufacturing improves the manufacturing yields, but adds costs and increases the price of each filter. Both SAW and BAW Filters shift with operating temperature due to the materials they are made with. Decreasing this temperature shift has been the focus of development work for several years, and it’s clear that it will be a few years before the manufacturability and electrical performance of the temperature compensated filters will be at the same point as the current generation filters.

SAW and BAW filters have become the most widely used RF Bandpass filters in the world, with Billions being used each year in Cell phones. There is no filter technology that can provide better performance in a small, cost-effective solution for the standard frequency bands around the globe. However, the move to create new frequency bands for 3G and 4G services has been regional. The US has come up with several bands which will not be allocated worldwide and the spectrum auctions have resulted in a limited number of licensees that will use a particular band. This means that instead of unifying (standardizing) the frequencies to be used, competing services will be using different frequency bands. This market fragmentation creates a limited market for the RF Filters for each band. This is a problem for the commercial SAW and BAW Filter manufacturers. It should be noted that the new requirements (without Guard Bands) make the design of the filters for each band significantly different from the design for other bands – significantly increasing the design effort required and even requiring special materials and special processing. This means it is unlikely that the filter manufacturers can profitably produce the new more technically challenging RF Bandpass Filters at the low prices demanded by the equipment manufacturers. It should be noted that this uncertain profitability falls in the Passive Component industry, which currently only has single-digit profit margins and is fighting for survival.

The new materials and special processing needed to increase the technical performance of the SAW and BAW Filters for these new bands add both high costs and uncertainty of the electrical performance. The structures being developed for the new filter designs will take a few years before they reach the stable manufacturing of the current generation of filters. If you add up the factors of the relatively small market for each new frequency band with the higher costs for producing the filters and the uncertainties of the manufacturers making a profit, you begin to realize that the commercial issues may well rival the technical challenges. When combining these significant challenges, it can be seen why there is currently a strong reluctance by the SAW and BAW filter manufacturers to move forward to develop all the necessary RF Filters.

What can be done to make the development of necessary higher-performance RF Filters attractive to develop? For one, it must be realized by the community that the RF Filters for the new bands are not just a simple commodity on which the usual high-volume pricing pressure can be applied. They are a critical component which must meet the tough new requirements – or else the rest of the higher profit radio will not function properly. In addition, as suggested by MSS in the Comments to the FCC NOI, there must be a dialog with the FCC, the NTIA and the major RF filter manufacturers to assess what can be possible with commercial technology – including discussion on both sides of performance roadmaps. Also, equipment manufacturers can not just assume that because there is a need, someone will develop technology that works as they want – and it will be the same low prices as Cellular filters.

=====

* Mike Alferman, mikealferman2@embarqmail.com, has been active with RF for 40 years: 12+ years at EPCOS/Siemens as head of RF Applications Engineering and Product Marketing for SAW/BAW Filters and Modules. Key role in developing RF filtering solutions for cellular handsets, WiFi consumer equipment and WiMAX RF modules. 9 years at Andersen Laboratories as SAW Filter Design Engineer and SAW Applications Engineer. Key role in developing cellular Basestation IF Filters, HDTV IF Filters and Radar Chirp Filters. Held various other Communications Technician, Engineering Technician and Field Engineering positions. Significant Experience with Cellular Systems and Handsets, Land Mobile Radio and Radar/EW systems.Holder of Commercial General Radiotelephone License (formerly called First Class) and Amateur Radio Advanced Class License (WA2NAS)

noreply@blogger.com (MJM) — Sun, 18 Oct 2009 15:27:00 +0000

Mobile DTV Standard Adopted by Industry

On Friday the Open Mobile Video Coalition (OMVC), "an alliance of U.S. commercial and public broadcasters formed to accelerate the development and rollout of mobile DTV products and services" issued this press release:

OMVC ... today announced it is “All Systems Go” for a new era of television service on mobile devices. With Thursday’s adoption of a final mobile digital television (Mobile DTV) broadcast standard by the Advanced Television Systems Committee (ATSC), U.S. broadcasters are poised to roll out an array of digital program services that will be available to consumers on devices ranging from in-car screens to portable DVD players and mobile phones.
“I congratulate ATSC for its remarkable achievement in bringing this standard to fulfillment. Mobile DTV utilizes the same digital spectrum that local TV stations use to send beautiful HD programming to the nation’s living rooms. With adoption of the ATSC Mobile DTV standard, small-screen versions of that programming and other services also will now be available over mobile devices,” said Brandon Burgess, president of the OMVC and CEO of ION Media Networks.

OMVC today demonstrated the services enabled by the new standard during a Mobile DTV briefing for government officials and others on a bus traveling around the Nation’s Capital. Seven Washington-area TV stations transmitted live local news, weather, sports and favorite programs to Mobile DTV compatible devices including mobile phones, laptop computers and netbook PCs. Senior representatives of the participating DTV stations, ATSC, the Association for Maximum Service Television (MSTV), the National Association of Broadcasters (NAB) and technology companies participated in the dialog about the new standard and the new mobile services it will support.

Broadcasting & Cable, the prime cheerleader for broadcasters, has this quote:

Paul Karpowicz, NAB Television Board chairman and president of Meredith Broadcast Group, added, "This milestone ushers in the new era of digital television broadcasting, giving local TV stations and networks new opportunities to reach viewers on the go. This will introduce the power of local broadcasting to a new generation of viewers and provide all-important emergency alert, local news and other programming to consumers across the nation."

In case you want to know what this system actually is, an ATSC document with real details is here. A brief summary from p. 12-13 of this document states:

The M/H system provides mobile/pedestrian/handheld broadcasting services using a portion of the ~19.39 Mbps ATSC 8-VSB payload, while the remainder is still available for HD and/or multiple SD television services. The M/H system is a dual-stream system—the ATSC service multiplex for existing digital television services and the M/H service multiplex for one or more mobile, pedestrian and handheld services.
Central to the M/H system are additions to the physical layer of the ATSC transmission system that are easily decodable under high Doppler rate conditions. The requirements for these additions are defined in this Part. Extra training sequences and forward error correction (FEC) are added to assist reception of the enhanced stream(s).

So the new system, formally A/153, just takes capacity from the 19.4 Mb/s that "free"/over-the-air DTV is sending in a 6 MHz TV channel and diverts it to mobile services. Since the mobile services are in a much more difficult reception situation due to poor antennas and motion that results in doppler shifts, this shift of capacity is not a zero sum game. Every b/s of end capacity used for mobile reception will divert more than 1 b/s from home DTV reception. Thus having bought a new big DTV receiver, you may find that the number of b/s available from "free TV", hence picture quality, will decrease as broadcasters go after a new market using spectrum they didn't pay for to compete against others who paid for spectrum. (If broadcasters directly sell services to viewers, then they must split the income with Uncle Same per existing legislation.)

While this technology can be introduced without any additional FCC action due to the deregulatory nature of FCC technical regulation these days, it is likely that the broadcasting establishment will use this as a justification to get even more protection for their signals and limit spectrum options for others.

NY Times coverage

noreply@blogger.com (MJM) — Fri, 16 Oct 2009 17:11:00 +0000

New ECFS to be Unveiled
Next Friday

Those of us who are communications policy wonks are endless frustrated by the workings of the Commission’s Electronic
Comment Filing System (ECFS), first introduced in 1998 and planned under the Hundt Chairmanship. I saw Chmn. Hundt recently at a social event and he was surprised to hear that the original systems is still in use with only minor updates.

On October 14th the Commission announced the new system and scheduled a public demo for 10/23. They described the new features as following:

With the 2.0 upgrade, ECFS will including many new features, including fully Section 508 compliance; the ability for users to file multiple documents to multiple rulemakings in a single submission; advanced search and query of rulemakings; ability to extract comments; RSS (Really Simple Syndication) feeds; and the ability to export data results to Excel or PDF formats.

Oddly, there is no explicit announcement of when the new system will be available.

The announced new features are certainly welcome. But we would like to see if they have solved some of the following problems:

1. Allowing people with overseas addresses to file directly without an obscure "work around" of giving misleading addresses.

2. Allow viewing of documents that "fall between the cracks" now and are not viewable such as new petitions for rulemaking and petitions for review of actions that do not have docket or file numbers.

3. Will more documents be posted with text that can be copied electronically. Some parties now file scanned .pdf files or locked .pdf files that can not be copied. This complicates the work of both FCC staff in preparing comment summaries and outside parties preparing reply comments.

4. ECFS 1.0 has an undocumented and unsupported feature that is very useful: you can derive a URL for a specific docket and use it to go directly to the current list of comments for that docket. For example, the comments for Docket 04-186 are (or at least have been_http://fjallfoss.fcc.gov/cgi-bin/websql/prod/ecfs/comsrch_v2.hts?ws_mode=retrieve_list&id_proceeding=04-186 I hope ECFS 2.0 has a similar feature.

noreply@blogger.com (MJM) — Wed, 14 Oct 2009 13:29:00 +0000

TWENTY-ONE DAY EXTENSION OF TIME TO FILE REPLY COMMENTS
ON
WIRELESS INNOVATION AND INVESTMENT NOTICE OF INQUIRY

GN Docket No. 09-157
GN Docket No. 09-51

Revised Reply Comment Deadline: November 5, 2009

From an FCC PN:

On August 27, 2009, the Commission issued the Wireless Innovation and Investment Notice of
Inquiry (NOI),which provided that comments were due on September 28, 2009, and that reply comments
were due on October 12, 2009. On September 10, 2009, the Commission released the Public Noticein
this proceeding, extending the comment and reply comment deadlines to help ensure development of a
more complete record. The Commission established a new pleading cycle for the NOI, with comments
due on September 30, 2009 and replies due on October 15, 2009.

On October 2, 2009, CTIA –The Wireless Association (“CTIA”) and Public Knowledge filed a
joint request for a 21-day extension of the reply comment deadline “[to] enable interested parties to
review and evaluate the record submitted in the initial comment round.” CTIA and Public Knowledge
state that the current deadline for reply comments is just 15 days after the initial comments were filed,
that it coincides with filing deadlines in other pending Commission proceedings, and that extending the
due date for reply comments would serve the public interest by affording interested parties participating
in the proceedings a more feasible sequence of filing deadlines, thereby providing sufficient time to digest
the record and formulate meaningful responses on reply.

I suppose CTIA and Public Knowledge don't agree on much, so it was best to go along with their joint recommendation.

But I could also point out that while CTIA said on October 2 that it needed more time to file reply comments, it did have time to prepare for meetings with Chmn. Genachowski and Comm. Copps on the same day it filed.

FCC transparency would improve if large trade associations filed comments on time rather than rush to have secretive meetings not available to other parties in the same proceeding at the same time they claim they need filing extensions.

noreply@blogger.com (MJM) — Thu, 08 Oct 2009 15:11:00 +0000

Without Opposition, Senate Approves Bill Directing FCC to Start Prison Jamming Rulemaking

Those of us in Maryland received this message from Governor Martin O'Malley:

Thanks to the leadership of Senator Barbara Mikulski in the United States Senate, this week we came one step closer to eliminating the use of illegal cell phones in our prisons. The Senate unanimously passed the Safe Prisons Communications Act of 2009 which, if implemented, would provide us the tools to use technology to block illegal inmate cell phone calls from within the walls of our prisons.

The use of cell phones by inmates constitutes a significant threat to public safety in Maryland's neighborhoods. The ability to communicate with the outside world illegally provides prisoners the ability to continue their criminal activity, and in some cases, threaten witnesses in their own criminal cases.

While the dedicated professionals in Maryland's prisons have stepped up their efforts to seize illegal cell phones, the only way we can definitively end the illegal calls is by blocking their signal. This legislation would give us the ability to do just that, providing us the access to urgently needed jamming technology.

I want to thank Senator Mikulski for her co-sponsorship of this bipartisan legislation and for her tireless work to improve the public safety here in Maryland. As the Safe Prisons Communications Act makes its way through the House of Representatives, we will continue to monitor its progress and advocate for its passage.

There is no public comment yet on the usually up to date CTIA website, although their fact sheet saying

"The fundamental issue is that wireless phones are a contraband problem, not a telecommunications policy issue."

remains. Apparently the Senate disagrees.

Senate Report

Text of Legislation

noreply@blogger.com (MJM) — Sun, 04 Oct 2009 05:54:00 +0000

Equipment Approval and Early Revelation of New Models:

A Poorly Publicized Existing Option at FCC Can Prevent This

Ever notice news articles about innovative wireless devices that are revealed not by their developers but as a byproduct of FCC equipment authorization? Here are three recent examples.

http://reviews.cnet.com/8301-13746_7-10302110-48.html
http://news.cnet.com/8301-17938_105-10318292-1.html
http://news.cnet.com/8301-17938_105-10350839-1.html
http://www.slashgear.com/cisco-flipsharetv-streamer-system-outed-by-fcc-3062285/

Apparently these major manufacturers are not aware of an obscure 2004 FCC Public Notice that is not well publicized by FCC. Another option would be to ask the TCB that does the approval on behalf of FCC to delay notifying FCC until the last minute.

For the benefit of loyal SpectrumTalk readers, here is the text of the 2004 Notice:

OET Equipment Authorization System Upgrade
Permits Electronic Submittal of
Short-Term Confidentiality Requests

An upgrade to the Office of Engineering and Technology’s (OET) Equipment
Authorization System will be implemented effective 06/15/2004. This upgrade will provide
additional flexibility for electronic submittal of requests for confidentiality of certain
commercially sensitive information that is submitted in conjunction with applications for
equipment authorization.

Pursuant to the provisions of Sections 0.457 and 0.459 of the Commission’s rules (47
CFR §§ 0.457, 0.459), the Office of Engineering and Technology currently accepts requests to
hold in confidence certain attachments to the electronic Application for Equipment Authorization
(Form 731). These requests are granted indefinitely, and are strictly reserved for limited types of
technical information.

The new electronic process will include a provision for temporary confidentiality for
certain additional portions of an application for equipment authorization. This will give
manufacturers and distributors the ability to import and/or distribute devices following
equipment authorization, while maintaining the confidentiality of detailed technical information
about the product prior to product launch. Electronic submittal of a request for such
confidentiality will ensure expedited approval and will make it less burdensome for
manufacturers and distributors to comply with the marketing regulations in 47 CFR §2.803 and
the importation rules in 47 CFR §2.1204, while ensuring that business sensitive information
remains confidential until the actual marketing of newly authorized devices. Such
confidentiality will extend for 45 days from the date of the Grant of Equipment Authorization,
and, absent any other action, the subject exhibits will be automatically placed on the public
database at the end of this period. However, if prior to the expiration of the 45 day period, an
applicant engages in public marketing activities or otherwise publicizes a device for which
temporary confidential treatment has been granted, the applicant must coincidentally notify the
FCC or the TCB issuing the equipment authorization so that the subject exhibits may be placed
in the public database immediately.

This limited confidentiality will be granted for the following exhibit types when an
applicant requests and justifies such confidentiality in conjunction with the Form 731, or a TCB
submits such information and justification in conjunction with the TC Form 731: External
Photos, Test Setup Photos, Block Diagram, Schematics, User’s Manual, Internal Photos, Parts
List / Tune-up Procedures, and Operational Description. Exhibits containing certain types of
technical information (e.g. Block diagram, Schematics, Parts List / Tune up Procedures, and
Operational Description) that have heretofore been granted indefinite confidential treatment will
continue to be so treated upon request. The confidentiality fee described in 47 CFR §1.1103 must
be submitted with the Form 731; however, only one confidentiality fee per FCCID is charged
regardless of the length of the confidentiality request.

If an applicant requires more than the original grant of confidentiality of 45 days, the
applicant can request an extension of the limited confidentiality for an additional 45 days. To do
so, the applicant must notify the FCC, or the TCB that issued the grant, a minimum of 7 calendar
days prior to the expiration of the original 45 day grant of confidentiality.

noreply@blogger.com (MJM) — Sat, 26 Sep 2009 21:05:00 +0000

MSS Comments in Wireless Innovation NOI

Your blogger has filed comments in the Wireless Innovation NOI, Docket 09-157. Here is a convenient link to all the filed comments using an undocumented feature of the FCC web site.

The MSS comments reviewed the following issues:

I. Introduction
II. Lessons of Pioneer’s Preference
III. Section 7 Issues
IV. “Receivers use spectrum not transmitters”
V. Innovative Wireless Systems Need Both Spectrum and Antennas
VI. “Green” Wireless Technologies
VII. Enforcement and Spectrum Options
VIII. More Effective G/NG Sharing
IX. Are the FCC and NTIA “Test-Beds” real or an Illusion?
X. Decision Making Issues
XI. The Role of Wireless Standards

Among the issues discussed is the question the Commission raised about "green" wireless technologies. In particular the MSS comments raise the question about why broadcasters must use hundreds of kilowatts of AC power to broadcast signals few watch in order to be eligible for "must carry" rights. This is a followup and modification to the pioneering proposals in OPP Working Paper 38 by Evan Kwerel and John Williams.

An observation: The NYTimes has a website that has more viewers than the printed edition. Does anyone require them to cut down trees and process wood pulp in order to get access to the Internet? Why must broadcasters both use large amounts of electric power and deny others the use of spectrum just to get the must carry rights that get them the overwhelming majority of their viewers? Under current law this is most likely necessary and there might even be some constitutional issues involving the rights of cable operators - but shouldn't FCC at least consider the issue?

The comments also urge FCC to work with NTIA to explore the possibility of future federal government systems that are designed from the beginning to share unused spectrum with FCC licensees. Such system need not be as conservative as cognitive radio systems in order to guarantee high confidence radio communications for the primary federal users. I had previously discussed this issue in a New American Foundation paper and at an IRAC meeting.

noreply@blogger.com (MJM) — Fri, 25 Sep 2009 15:05:00 +0000

FDA Asks National Academies to Review Its Approval Process
for New Technologies:
Why Doesn't FCC Ever Do This?

I have previously discussed the June 5, 2008 IEEE-USA letter to Chairman Martin (that never was answered in any way) that suggested improvements to FCC technical policy deliberations.

Part of the letter said,

• The National Academies. In the past FCC, like other federal regulatory agencies with technical jurisdiction, sought advice on long-term policy issues from the National Academies including the National Academy of Sciences and the National Academy of Engineering.

However, the last time the FCC asked for studies from the National Academies was in the 1970s when such studies laid the groundwork for two major changes in technical policy: the Part 68 interconnection rules and the sharing of the C band between terrestrial and satellite systems. Both of these issues were tremendously controversial at the time but the basic frameworks suggested by these studies formed the basis for major changes in FCC policy.

Such studies are time consuming and expensive and should not be used for routine policy deliberations, but it is clear that in the 30 years since FCC last used such studies there have been multiple cases where they could have been of value. It is not clear why FCC practice differs from other regulatory agencies in the use of the Academies.

To show that real federal regulatory agencies do exactly this type of thing even in this day and age, here is some recent news from FDA which has gotten "egg on its face" for some recent approvals of medical devices.

An FDA news release of 9/23/09 starts,

FDA: Institute of Medicine to Study Premarket Clearance Process for Medical Devices

The U.S. Food and Drug Administration today announced that it has commissioned the Institute of Medicine (IOM) to study the premarket notification program used to review and clear certain medical devices marketed in the United States.

The IOM study will examine the premarket notification program, also called the 510(k) process, for medical devices. While the IOM study is underway, the FDA’s Center for Devices and Radiological Health (CDRH) will convene its own internal working group to evaluate and improve the consistency of FDA decision making in the 510(k) process.

“Good government conducts periodic reviews and evaluations of its programs,” said Jeffrey Shuren, M.D., acting director of CDRH. “Our working group and the IOM’s independent evaluation will help us determine how the 510(k) process can be improved to better support FDA’s mission to protect and promote the public health.” (Emphasis added)

The Institute of Medicine is the medical counterpart of the National Academy of Engineering, a member of the National Academy family. The press release goes on to say how FDA has asked the IOM to perform a $1.3 million 2 year study to review its processes and make recommendations. The study will include 2 public workshops.

Perhaps FCC deliberations for approval of new spectrum technologies merits the same type of objective review?

N.Y. Times article on this issue

noreply@blogger.com (MJM) — Thu, 24 Sep 2009 14:55:00 +0000

New Report on Value of Unlicensed Spectrum

Rich Thanki of Perspective Associates, a UK consulting firm, has completed a report on the value of unlicensed spectrum, commissioned by Microsoft.

Here is an abstract from the report:

The report provides quantification of the growing popularity of unlicensed applications, the value of some existing unlicensed applications, and the potential value in the so-called 'white spaces'. It also speaks more broadly to the innovative potential of the unlicensed approach. The report suggests that shipments of devices using unlicensed spectrum will surge over the next 5 years. By 2014, it finds that hybrid devices using both unlicensed and licensed spectrum could be outselling devices relying solely on licensed spectrum, including televisions, radios and some cellular phones. Sales of both could be overtaken substantially by sales of device using only unlicensed connectivity.

The report establishes a minimum value of unlicensed by analysing three existing applications: Wi-Fi in homes, Wi-Fi in hospitals, and RFID in clothing retail outlets in the US. Conservative estimates put the existing economic value being delivered by Wi-Fi in American homes at $4.3 - 12.6 billion a year. In combination these three uses could generate an economic value of $16 - 37 billion a year over the coming 15 years. The modelled uses only account for 15% of the total projected market for unlicensed chipsets in 2014, and therefore significantly underestimates the total value being generated by unlicensed usage over this time period. The paper also estimates the economic value that might be generated from existing Wi-Fi applications improved through using the white spaces as $3.9 -7.3 billion a year over the next 15 years.

The one area where I disagree somewhat with the report is the relationship between innovation and unlicensed spectrum. I agree that there has been tremendous innovation in unlicensed spectrum and am proud to have been partially responsible for getting it rolling.

The report says (p. 43)

But I think that a lot of the explanation has to do with issues besides whether there is a license or not. In Europe there is a de jure technical monoculture of DECT for unlicensed cordless phones. Under this type of traditional CEPT regulation, there is little innovation because it is effectively forbidden. By contrast, the US has no technical regulation of the air interface of cordless phones other than those strictly related to interference. Thus you can buy many types of cordless phones here, even DECT.

Europe also has a technical monoculture for cell phones thanks to CEPT and the European Commission: only GSM and the newer UMTS/3GSM. No surprise that CDMA, a technological core of UMTS, was first developed and commercialized in the US. In Europe, CEPT and ETSI require multinational consensus before such technologies can reach the market and this is near impossible for "disruptive innovation" such as CDMA in its early days.

The report correctly points out that in commercial licensed networks such as cellular there is a contractual relationship between users and the network and innovation has to evolve so that it does not disrupt the network. In Wi-Fi systems there is more distributed ownership that can response to new technology.

But the key issue here is not the presence or absence of a license, the key issue is deregulation. A major reason why unlicensed networks have been so innovative is that the descendants of the FCC Docket 81-413 rulemaking, e.g. Wi-Fi, Bluetooth, and Zigbee have been in spectrum bands with great technical flexibility.

Cellular systems of necessity have to evolve more slowly, although the legal stricture that ETSI must approve any change to GSM and UMTS/3GSM not permitted in the current standard does not make any sense to me. With over 1 billion GSM mobiles in use, there are ample market place forces to keep evolving technology backward compatible.

If you overregulate unlicensed systems, they can stagnate just as much as licensed one often do.

noreply@blogger.com (MJM) — Wed, 23 Sep 2009 18:33:00 +0000

Excellence in Engineering at FCC:

No Secrecy This Time,
But Issues Remain

I wrote previously how the ancienne regime made recognition of good engineering work at FCC almost an embarrassing secret. By contrast the Excellence in Economics Awards at FCC have always been well publicized. The only tip that the awards were given last time in 2007 was a speech to the awardees on Comm. Tate's website - possibly because no one told her it was a secret. Additional ferreting was needed to find out who the winners were at that time.

Thus it was refreshing that at the end of the 8/27 Commission meeting, the winners of this year's Excellence in Engineering awards were publicly announced:

Stephen C. Buenzow (WTB)
Navid Golshahi (OET)
John Healy (PSHSB)
Brian Marenco (PSHSB)
James McLuckie (IB)
Chris Miller (WTB)
Michael Mullinix (IB)
Group Award: Alison Neplokh and John Gabrysch (MB)
Group Award: Tom Mooring, Peter Georgiou, David Sturdivant, Juan Guerra (OET)
Group Award: Dennis Loria, David Viglione, (EB) Tracy Simmons, Troy Sieg (PSHSB)

Oddly there has been no written announcement to date. But see 2:21 at the following link http://www.fcc.gov/realaudio/mt082709.ram

My congratulations to all the winners for a job well done!

noreply@blogger.com (MJM) — Sun, 20 Sep 2009 18:50:00 +0000

info Publishes
Special Issue on
Wi-Fi History

info: The journal of policy, regulation and strategy for telecommunications, information and media has recently published a special issue on "The genesis of unlicensed spectrum policy". My congratulations to Chuck Jackson who was both the organizer of the April 2008 seminar at George Mason University, "Unleashing Unlicensed - How Wi-Fi got its regulatory groove", that resulted in the writing of these papers and Guest Editor of this issue. Below is the table of contents of the issue with links to the papers. These links are free only to subscribers but the original versions of the papers are still available at the GMU site.

	Unlicensed to kill: a brief history of the Part 15 rules Kenneth R. Carter (pp. 8-18) View HTML \| View PDF (96 KB) \| Reprints & Permissions
	Wi-Fi and Bluetooth: the path from Carter and Reagan-era faith in deregulation to widespread products impacting our world Michael J. Marcus (pp. 19-35) View HTML \| View PDF (393 KB) \| Reprints & Permissions
	History of wireless local area networks (WLANs) in the unlicensed bands Kevin J. Negus, Al Petrick (pp. 36-56) View HTML \| View PDF (371 KB) \| Reprints & Permissions
	Licence-exempt: the emergence of Wi-Fi Vic Hayes, Wolter Lemstra (pp. 57-71) View HTML \| View PDF (119 KB) \| Reprints & Permissions
	Grazing on the commons: the emergence of Part 15 Henry Goldberg (pp. 72-75) View HTML \| View PDF (50 KB) \| Reprints & Permissions
	Unleashing innovation: making the FCC user-friendly Stephen J. Lukasik (pp. 76-85) View HTML \| View PDF (85 KB) \| Reprints & Permissions
	Has “unlicensed” in Part 15 worked? A case study Tim Pozar (pp. 86-91) View HTML \| View PDF (227 KB) \| Reprints & Permissions

Guest editorial



	The genesis of unlicensed wireless policy Vol : 11 Issue: 5 Special Issue: The genesis of unlicensed wireless policy Author(s): Charles L. Jackson View HTML

noreply@blogger.com (MJM) — Mon, 14 Sep 2009 02:53:00 +0000

USA Today Article on
Cell Phones' SAR Data
and FCC

On September 8, USA Today published an article entitled "Cellphone radiation levels vary widely, watchdog report says" . It began with this line the CMRS industry probably didn't want to hear, "Some cellphones emit several times more radiation than others, the Environmental Working Group found in one of the most exhaustive studies of its kind."

Specific Absorption Rate (SAR) is a measurement of how much radio power from a cell phone is absorbed in body. Usually the head is the key area for cell phones since they are held there. The FCC limit for SAR is 1.6 Watts/kilogram. It found phones that ranged from as low as 0.35 to as high as 1.55. Interestingly, Motorola had both one of the highest units as well as one of the lowest.

I have no personal knowledge or firm opinion about whether radio signals from cell phones affects health. However, there is no reason to believe it does any good to your health* so I understand why people might want to decide to minimize exposure even though the CMRS establishment thinks this is unnecessary. I think it is a matter of consumer choice in the face of uncertainty and government should make reasonable efforts to make relevant data available so market forces can work. Thus I am proud that while at FCC I helped break the impasse on making this information public by proposing a method for doing so that did not require unaffordable redesign of the FCC website.

At the end of the USA Today article, it stated

"The FCC currently doesn't require handset makers to divulge radiation levels. As a result, radiation rankings for dozens of devices, including the BlackBerry Pearl Flip 8230 and Motorola KRZR, aren't on the group's list."

This statement is misleading to wrong. The SAR data is submitted to FCC and is in the publicly available file on equipment approval for each model. The required report is difficult to read for the nonexpert, but in the process of reviewing it, FCC extracts the key numbers and puts them in a place that can be found relatively easily.

I posted the following to the USA Today site to clarify this point ans tell the public how to find the data for any model sold (legally) in the US. (Since FCC spends little resources on equipment marketing enforcement, one can never be sure that all models sold are actually legally authorized.):

The article says
"The FCC currently doesn't require handset makers to divulge radiation levels." When FCC decided about 10 years ago to follow a UK precedent and make the information public, it had no money to revise its website to make the information simple to find. Also industry was lobbying strongly against making the information public - actually it always was public but the key number was in an obscure detailed report.

If you can't find the data for a specific phone on a nongovernment website, you can look it up yourself. First find the FCC ID of the cell phone in question. It is often under the battery. Then go to https://fjallfoss.fcc.gov/oetcf/eas/reports/Gene ricSearch.cfmI The first 3 characters go in the first box and then the rest go in the second box. Then hit "Start Search" at the bottom of the page.

When the next screen appears, hit the checkmark icon under "Display Grant". You will get a copy of the FCC approval for that model. Just below the section with 6 columns of data is a statement of the SAR data.
So for the Nokia model with FCC ID PDNRM-421, enter PDN in the first box and then RM-421.

Like many cell phones, this model can transmit on several frequencies so there is different data for each band.

The process is not simple, but it is straightforward. This is how the private sites get their data to make it more usable for the public.

===============================
* By contrast, there is a controversial theory dealing with ionizing (nuclear) radiation called radiation hormesis that states that small doses of such radiation actually improve health. However, I am not aware of anyone supporting a parallel theory for radio radiation.

noreply@blogger.com (MJM) — Mon, 07 Sep 2009 19:16:00 +0000

IEEE Spectrum
Publishes Article

on

"Radio's Regulatory Roadblocks:

How the FCC slows new wireless technologies - and what to do about it"

The September 2009 Issue of IEEE Spectrum has the above article by Mitchell Lazarus that should be of interest to readers of this blog. Mitchell is a lawyer and a noted practitioner of spectrum policy. He played a key role in Wi-Fi's early regulatory issues.

We agree on many things, but disagree on others. But at this point let me just point others to the article and not bias you by what details I disagree on. You should read it and think about it first.

It may be a helpful reference for those drafting comments to the FCC Innovation Inquiry.

noreply@blogger.com (MJM) — Fri, 04 Sep 2009 21:34:00 +0000

Welcome Back RCR!

noreply@blogger.com (MJM) — Fri, 04 Sep 2009 12:16:00 +0000

The Return of the TAC

The Commission's Technological Advisory Council seems to be coming back in a circuitous way. In April the Commission asked for nominations. Then last Monday they asked again.

Interestingly, all traces of the old TAC web page have disappeared recently from the Commission webs site, possibly as a cleanup drive to get ready for the new one.

The stated explanation of the renewed nomination request is

"Concurrent with the establishment of the TAC, the Commission was charged by Congress to develop a plan that seeks to ensure that people of the United States have access to broadband capability. In support of this and related efforts, the Commission is now seeking additional nominations to the TAC to ensure that its membership best serves the needs of the Commission."

Several suggestions for the new TAC, readers are encouraged to comment - after all this is a blog not a magazine.

The Commission has stated "The Council will consist of recognized technical experts in telecommunications and related fields." The previous TAC and its counterpart at NTIA have been overly heavy with representatives from every conceivable party practicing before the Commission with token public representatives. The credentials of some have been questionable other than their employment. A simple and realistic goal would be for at least 50% of the TAC members to have significant peer recognition such as being members of the National Academy of Engineering or Fellow of the IEEE.

Brookings has published a book entitled The Advisers that surveys use of technical advisory committess at several federal agencies. I urge senior commission staff to review this survey and decide which type of advisory committee the Commission really wants. I would urge the Defense Science Board model.

The previous FCC leadership was ambivalent at best on using the TAC for any issue or subissue related to ongoing policy deliberations. Thus the TAC debated vague issues about future problems - none of which had any impact. It can been seen from The Advisers that other regulatory agencies use advisory committees in more substantive ways. Mitchell Lazarus and I recently had an exchange on his blog on whether the TAC should get involved in advising the Commission whether the exponent of the field strength drop from BPL emissions is 2,3, or 4. Mitchell commented,
"Rather than consult the Technological Advisory Committee, I would rather see the FCC technical staff base its recommendations on data from actual, reproducible experiments, whether conducted in public by the FCC itself or submitted from outside."
There are a lot of good things presidential appointees like the 5 FCC commissioners can do but I think the issue of exponents of electromagnetic fields is not one they are good at and their skill in this area was never reviewed at Senate confirmation hearings.

noreply@blogger.com (MJM) — Thu, 27 Aug 2009 21:41:00 +0000

FCC Begins Inquiry
into
Wireless Innovation
and
Investment

At today's Commission meeting a new NOI was adopted on this topic.

[See update below]

Comment Date: September 28, 2009
Reply Comment Date: October 12, 2009

The news release states

The Federal Communications Commission (FCC) announced a Wireless Innovation and Investment Notice of Inquiry(“NOI”) that seeks to identify concrete steps the Commission can take to support and encourage further innovation and investment in the wireless marketplace. This NOI also seeks to better understand the factors that encourage innovation and investment throughout this area.

Innovation in wireless, an increasingly significant part of the communications sector, can be an engine for near-term economic recoveryand long-term economic growth. In furtherance of this goal, the NOI seeks comment broadly on all ideas that will foster wireless innovation and investment. In particular, the NOI focuses on spectrum availabilityand use, wireless networks, devices, applications, and business practices. The NOI also seeks comment on how the public has used wireless services and technology to solve real-world problems in areas such as health care, energy, education, and public safety.

More generally, the NOI seeks to develop a framework for analyzing wireless innovation and investment, including any metrics or data sources that should be considered. This framework, together with the record developed in response to the Mobile Competition Report NOI adopted today, will serve as a base of knowledge to inform Commission consideration of wireless regulatory issues going forward.

Chmn. Genachowski added,

we seek to identify appropriate and concrete steps the Commission can take to support and encourage further innovation and investment in this area, and to understand better the factors that encourage innovation and investment in wireless.

UPDATE
Revised deadlines

Comments 9/30/09
Replies 10/15/09

ex parte rules now also apply.

	Unlicensed to kill: a brief history of the Part 15 rules Kenneth R. Carter (pp. 8-18) View HTML \| View PDF (96 KB) \| Reprints & Permissions
	Wi-Fi and Bluetooth: the path from Carter and Reagan-era faith in deregulation to widespread products impacting our world Michael J. Marcus (pp. 19-35) View HTML \| View PDF (393 KB) \| Reprints & Permissions
	History of wireless local area networks (WLANs) in the unlicensed bands Kevin J. Negus, Al Petrick (pp. 36-56) View HTML \| View PDF (371 KB) \| Reprints & Permissions
	Licence-exempt: the emergence of Wi-Fi Vic Hayes, Wolter Lemstra (pp. 57-71) View HTML \| View PDF (119 KB) \| Reprints & Permissions
	Grazing on the commons: the emergence of Part 15 Henry Goldberg (pp. 72-75) View HTML \| View PDF (50 KB) \| Reprints & Permissions
	Unleashing innovation: making the FCC user-friendly Stephen J. Lukasik (pp. 76-85) View HTML \| View PDF (85 KB) \| Reprints & Permissions
	Has “unlicensed” in Part 15 worked? A case study Tim Pozar (pp. 86-91) View HTML \| View PDF (227 KB) \| Reprints & Permissions