DoD'S WOLFOWITZ WANTS TIMELINE FOR UWB RULES DELAYED AT FCC
Deputy Defense Secy. Paul Wolfowitz asked Commerce Secy. Donald Evans to advocate delay in final regulatory decision on ultra-wideband (UWB) until “at least February.” Expectation of some industry observers had been that UWB could be taken up at FCC’s Dec. 12 agenda meeting, although timing was unclear because NTIA still must submit final input to FCC on rulemaking, sources said. FCC Chmn. Powell told House Appropriations Subcommittee earlier this year that Commission could issue UWB rulemaking by year-end, although he said at time that agency was awaiting final evaluation from govt. on UWB interference issues (CD May 23 p7). In letter to Evans last week, Wolfowitz said DoD’s review of preliminary draft of FCC’s UWB rules “indicates they will not provide adequate protection for GPS and other critical DoD systems… They also raise significant national spectrum management policy issues such as the intentional operation of nonlicensed devices in nationally restricted bands and in internationally designated passive-only bands.” Several sources said item on UWB began circulating on 8th floor at FCC earlier this week.
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Wolfowitz told Evans DoD had been working with NTIA staff and other federal agencies for several months to develop regulations and technical criteria that would let technology move ahead “while protecting existing authorized federal government systems.” He said NTIA, Transportation Dept. and industry tests concluded UWB devices had “significant potential for causing harmful interference” to GPS and other key DoD systems. Letter obtained by Communications Daily refers to initial list of technical and regulatory limitations that DoD has provided to Commerce Dept. as being critical to safeguarding existing DoD systems. Recommendations are generally in line with recent NTIA proposal, Wolfowitz said. Among apparent considerations that DoD has raised is that UWB operations not be permitted below 3.1 GHz to protect GPS and other safety-of-life systems, source said.
FCC asked that all significant federal agency comments be provided to Commission by end of this month so proceeding could appear on Dec. meeting agenda, Wolfowitz said. “This short deadline, and the lack of a complete and final draft, impedes our efforts to provide a thorough review and makes it very unlikely that existing differences can be resolved in a reasonable manner,” he said. He asked Evans to seek “at least” 60 more days from time that final draft report and order is available for federal agency review. Wolfowitz said he also would like to see FCC action put off until “at least” Feb. If Commission believes some commercial UWB capability should be available before then, he suggested it could be provided only “on a provisional basis” subject to full review by federal agencies later and “to NTIA limitations that incorporate recommendations of this department.” Such limits can be achieved through filter that has at least 35 dB attenuation of transmitted signal power spectral density below what is required for Part 15 devices for all frequencies at or below 4.2 GHz, he told Evans. “NTIA continues to work to balance security concerns while promoting 21st century technologies,” Evans spokesman said. Copies of letter also were sent to National Security Adviser Condoleeza Rice and Chmn. Powell.
Several sources said Wolfowitz letter raised concerns similar to those flagged for Evans by agencies such as DoT, which raised serious questions about impact of UWB on GPS- based systems used by FAA. At heart of issues raised by several federal agencies is ability of FCC to authorize emissions in bands restricted to govt. operations, such as GPS, one industry source said. However, another industry source said federal agencies themselves hadn’t been in agreement on what shape they wanted federal UWB policy to take, with even different parts of DoD falling short of consensus. In addition, critical infrastructure facilities such as nuclear power plants apparently have expressed increased interest in UWB since Sept. 11 for services such as tracking security assets and employees.
Earlier this month, Time Domain reiterated in FCC filing its belief that testing showed UWB could operate at levels set in FCC’s notice of proposed rulemaking (NPRM) without causing harmful interference to existing services. Time Domain conceded that order approved for UWB might be more constraining than FCC’s original proposal. Areas of compromise outlined by Time Domain in Nov. 14 filing included: (1) Limiting UWB operation to indoor use according to emissions mask outlined in NPRM. That would provide additional 9 to 12 dB attenuation of UWB signals below level set out in NPRM. (2) Allowing 2-way communications only when at least one device that was communicating was AC-powered if operation of peer-to-peer communications devices was prohibited. Filing said FCC had raised possibility of barring peer-to-peer communications devices for UWB. (3) Allowing outdoor tracking and radar below 6 GHz for eligible industrial and commercial entities only at power levels in NPRM and allowing operation of UWB above 6 GHz at levels in original FCC proposal. (4) Setting operating parameters for public safety, law enforcement and homeland security applications. That would permit operation of UWB devices by eligible parties at full Part 15 Class B power for both outdoor and indoor use. “Eligibility would be limited to entities eligible for assignment of frequencies from the Part 90 public safety pool of frequencies,” filing said. Applications that would be covered under that provision would include through-wall motion detection. Such uses would be limited to emergency scenarios and training.
UWB developer XtremeSpectrum also made ex parte filing at FCC this week saying that its proposals for UWB operation would resolve “all interference issues -- including those related to government systems.” Similar to Time Domain’s stance, XtremeSpectrum said it supported FCC position that outdoor receivers could be protected by limiting UWB operations to indoors. “But the specific mechanism proposed to enforce it -- detection of a nearby AC-powered ultra- wideband unit -- would actually rule out most indoor operation,” XtremeSpectrum said. Instead, it urged FCC to ban outdoor infrastructure for UWB and give manufacturers choice of either complying with peer-to-peer operation for indoor-only use at NPRM levels or developing peer-to-peer operation “at greatly reduced emissions levels.” While postponement beyond Dec. FCC meeting “may become necessary, any such delay should not slip beyond January,” company wrote.
On other side of issue, wireless carriers also have continued to press their interference concerns at FCC. In filing, several carriers voiced concern that UWB developers hadn’t met burden of demonstrating that their devices wouldn’t cause harmful interference to PCS licensees. Their position is that authorization for UWB products in PCS band shouldn’t move forward until test data confirm that devices won’t cause harmful interference. Among these concerns are potential impact to indoor operations of Enhanced 911 operations that rely on GPS for location identification.