Michael J. Marcus, Sc.D., F-IEEE 

1. Wi-Fi and Bluetooth: The Path from Carter and Reagan-era Faith in Deregulation to Widespread Products Impacting Our World Michael J. Marcus, Sc.D., F-IEEE Federal Communications Commission (Retired)Director, Marcus Spectrum Solutions LLC mjmarcus@alum.mit.edu www.marcus-spectrum.com

2. Origins of Wi-Fi/Bluetooth • Roots are twofold: • Technological • Spectrum Policy • Convergence of the two at FCC in the 1980s enabled a unique blossoming of technologies in a field normally subject to “command and control” policies • Was not focused on either petitions or WLANs • Subsequent more focused proceedings (u-PCS and U-NII were less sucessful

3. Origins of Wi-Fi/Bluetooth • FCC action was a self initiative • Was not focused on either external petitions or WLANs • Subsequent more focused proceedings (U-PCS and U-NII [and HIPERLAN in Europe]) were less successful

4. Traditional FCC Spectrum Policy • Has its roots in the 1930s • When frequencies were limited • Technological options few • Faith in government high • Rules could be easily changed • But these all changed with • Post-WWII technological explosion • 1946 Administrative Procedures Act • Just as new technology became available, regulations slowed down!

5. Traditional FCC Spectrum Policy • FCC (and other spectrum regulators) traditionally depended on petitioners spelling out “requirements” and then specifying band and technology to meet such “requirements” • Hard to impossible to keep up with technological change and needs of a changing society and economy

6. Deregulation Comes to FCC (and Stays) • Carter Administration brought a focus on deregulation as a means to stimulate economic growth • CAB Chairman Alfred Kahn was a leader within administration on the effectiveness of deregulation • FCC Chairman Ferris embraces concepts • For Both Titles II and III

7. Chmn. Ferris & Spectrum • Chmn. Ferris challenges his spectrum team to identify promising technologies that are blocked by anachronistic regulations • Recognizes the delay and transactions costs associated with waiting for petitions in all cases • Goal was not to force new technology but get out of its way

8. Searching for Candidate Technologies • Ferris recruits former ARPA chief S. J. Lukasik to head Office of Science & Technology starting in Summer of 1979 • Challenges him to identify candidate technologies to remove barriers from • New emphasis on market forces not “command & control”

9. Serendipity in Action • I encounter Lukasik in May 1979 at a classified Army Science Board electronics warfare panel meeting in Chicago • Had previously met while I administered ARPA R&D projects in nuclear test detection during military service • Due to Army efficiency, “MA” certain to sit next to “LU” • Electronic warfare similar to spectrum management except for intent

10. Serendipity in Action • Chicago encounter leads to question: • What radio technologies might bloom if dated regulations were removed? • Within a few days reply with list: • Spread spectrum • Adaptive antennas • Millimeter wave bands (>30 GHz) • Lukasik replies with job offer at FCC • My ticket out of military-industrial complex

11. Spread Spectrum Background • Like the computer, the basic technology, spread spectrum, has no single specific inventor • As is often reported in popular press, Hedy Lamarr was awarded an early frequency hopping spread spectrum patent during WWII • But invention was not reduced to practice

12. Developed by Paul Green as a thesis project One of earliest PN systems Technology of the day limited size 1953 MIT Lincoln Lab System

13. Early Literature • In the 1950-1970’s spread spectrum generally remained a classified technology with only occasional references in the open literature. • My first exposure was at a classified 1972 conference • Only “text book”-like discussion was a classified Sylvania report

14. My First Real Contact • Joining the Institute for Defense Analyses in 1975, I was assigned to studying options for communications ECCM • 1973 Mid East War showed an unexpected amount of communications EW • DoD had minimized EW threat to communications up to that point and was concerned about options to increase preparedness against “new” threat

15. First comprehensive, though mathematically inelegant, treatment of spread spectrum Introduced a generation of designers to the technology Dixon’s Book 1975

16. Magnavox produces a “civil” version of AN/ARC-50/90 Japan MPT purchases and tests for possible civil applications Concludes no practical value for civil use Commercial Spread Spectrum c. 1979

17. Publications became more common But most publications still focused on military applications Possibly to justify DoD funding Circa 1980

18. FCC had encountered MITRE Corp. in connection with deliberations of JTIDS use of L band First FCC step in 12/79 was commission MITRE for a report on options for civil use of spread spectrum Since then FCC has never commissioned such a report unless ordered by Congress Early FCC Action - Phase I Available from NTIS as PB81-165284

19. MITRE Report Not very useful in hindsight Very useful and significant

20. 6/30/81 - The Regulatory Struggle Begins • 2 initiatives begun: • Chmn. Fowler supports action • Docket 81-413 – General use • Docket 81-414 – Amateur radio use • No specific proposals • “designed to serve two purposes. We hope to gather information to: 1) assist us in identifying specific radio services presently authorized by the Commission, as well as ideas for new services, where the authorization of wideband modulation techniques would serve the public interest; and 2) identify the technical parameters which characterize a wideband emission, including procedures used to measure these parameters, and identify technical standards necessary to insure operation on a minimum interference basis.” • Do not mention unlicensed or RLANs but does mention ISM bands

21. Reaction to Phase II • “It was felt that there are many useful communications applications which could be achieved with spread spectrum techniques that could not be satisfactorily developed with any other technology. • “However, many had reservations about the particular implementation of spread spectrum systems and expressed concern over the potential for interference with existing communications systems. Because the technology is so new, many urged the Commission to proceed slowlywith its implementation until we have had successful operating experience with these systems, including the identification and measurement of spread spectrum signals and their interference potential. • “There was particular concern among some parties that regular communications might be interrupted and the Commission might not be able to detect the source of the interference.”

22. Reaction to Phase II • Discussion of “overlays” lead to a preview what what would happen in later UWB rulemaking: NIMBY • “Both GE and RCA objected to authorizing spread spectrum systems in the Industrial, Scientific and Medical (ISM) bands because many Part 15, low power consumer devices, such as home security devices and video disc systems, have already been authorized to operate in some of the bands.” • The major mobile manufacturer saw any civil spread spectrum use as a prelude to CDMA which would threaten their market hegemony

23. Focus of technical publications on spread spectrum continues to be military applications 1983

24. While interest in the US was minimal, others were interested 1984

25. 6/16/84 NPRM Phase III • “It appears that most low power communication devices, currently authorized under Part 15 of our Rules and Regulations, could be considered as potential candidates for spread spectrum.” • “ At the same time, the Commission might be spared the immediate need to allocate additional spectrum space for these services and for other requested services such as cordless telephones.”

26. 6/16/84 NPRM Phase III • “The authorization of spread spectrum systems under Part 15 of the Rules and Regulations would be unrestrictive and unregulatory in nature, since devices operating under Part 15 do not have to be licensed and users do not face eligibility requirements, content regulation, or coordination requirements. This would allow the forces of the marketplace to drive the implementation of this new technology, unhampered by regulations other than those needed to prevent harmful interference to licensed systems.”

27. Response to NPRM • “Of the parties submitting comments that opposed the proposed authorization of spread spectrum systems, RCA was the only one that supported its position with analysis. RCA's analysis dealt with possible interference to FM and television broadcasting from spread spectrum systems operating in the broadcast bands.” • NIMBY and fear of overlays is major concern • 2 IEEE groups file supportive comments • Chairman Fowler supportive of deregulatory concepts

28. May 9, 1985 FCC adopts spread spectrum rules in ISM bands Same basic rules until 2002 1 W limit PN or FH Almost any application incorporated July 1985 1985

29. Original Rules: WYSIWYG “§15.126 Operation of spread spectrum systems. Spread spectrum systems may be operated in the 902-928 MHz, 2400-2483.5 MHz and 5725-5850 MHz frequency bands subject to the following conditions: • They may transmit within these bands with a maximum peak output power of 1 watt. • (b) RF output power outside these bands over any 100 kHz bandwidth must be 20 dB below that in any 100 kHz bandwidth within the band which contains the highest level of the desired power. The range of frequency measurements shall extend from the lowest frequency generated in the device (or 100 MHz whichever is lower) up to a frequency which is 5 times the center frequency of the band in which the device is operating. (c) They will be operated on a noninterference basis to any other operations which are authorized the use of these bands under other Parts of the Rules. They must not cause harmful interference to these operations and must accept any interference which these systems may cause to their own operations. (d) For frequency hopping systems, at least 75 hopping frequencies, separated by at least 25 kHz, shall be used, and the average time of occupancy on any frequency shall not be greater than four-tenths of one second within a 30- second period. The maximum bandwidth of the hopping channel is 25 kHz. For direct sequence systems, the 6 dB bandwidth must be at least 500 kHz. (e) If the device is to be operated from public utility lines, the potential of the RF signal fed back into the power lines shall not exceed 250 microvolts at any frequency between 450 kHz and 30 MHz.

30. Immediate Results • No near term career benefits for this action: • Had not been sensitive enough to concerns of other FCC staffers • OST subject to major reorganization with abolishment of 3 top positions including mine • Received lowest senior performance appraisal in 6 years of SES system at FCC • Probably intended to guarantee demotion or dismissal • Transferred to vague job in Enforcement Bureau predecessor • Returned from “internal exile” in 1994

31. 7/87 IEEE Communications Magazine Article • Gave a paper on new rules at GLOBECOM ‘85 • FCC management tried to prevent such discussion • 7/87 update of paper raised possibility of RLANS in ISM bands

32. In 1988 the first real commercial spread spectrum product appeared – an RLAN “First Light”

33. Gambatte MIDI LAN Limited production but very popular with top rock musicians! Derivative system still used in nuclear power plants “Second Light”

34. Equipment Trends • After slow start, equipment authorizations has had exponential growth

35. Equipment Trends II • Is growth inversely proportional to rule complexity?

36. “Myth or Reality” Many key players went to Quebec woods to discuss the future of spread spectrum 1991

37. LANs discussed Available products focused on cordless phones and PDA-like systems 1992

38. Unlicensed point-to-point was unexpected but permitted by liberal rules Undersold traditional Part 101 systems Popular in cellular industry for quick installation without paperwork Non-LAN Systems

39. Lessons Learned • Since technology moves faster than regulations, there are often anachronistic regulations that block new technologies • Transactions costs of changing regulations decreases interests in technologies adversely affected • Removing barriers to new technology while maintaining a level playing field can stimulate innovation

40. Lessons Learned • Studying promising technologies that do not have petitioners can lower investment barriers • While consensus decision making has benefits, it is not always the right model for spectrum policy decisions • The public interest is not always the interest of the immediately affected parties in an FCC proceeding

41. Lessons Learned • While FCC has internal resources for most decisions, some innovative areas need outside support not now available: • “Think tank” studies • Technical advisory committee • NAS/NRC study committees • Often used by other agencies

42. More info on website Thanks for Listening Questions? www.marcus-spectrum.com