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Project: IEEE 802.15 Working Group for Wireless Personal Area Networks (WPANs)

Project: IEEE 802.15 Working Group for Wireless Personal Area Networks (WPANs) Submission Title: [ECC Tg3 Regulatory Effort] Date Submitted: [16Mar2005] Source: [John Barr] Company [Motorola] Address [1303 E. Golf Road, Schuamburg, IL 60196]

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Project: IEEE 802.15 Working Group for Wireless Personal Area Networks (WPANs)

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  1. Project: IEEE 802.15 Working Group for Wireless Personal Area Networks (WPANs) Submission Title: [ECC Tg3 Regulatory Effort] Date Submitted: [16Mar2005] Source: [John Barr] Company [Motorola] Address [1303 E. Golf Road, Schuamburg, IL 60196] Voice:[+1 847 576-8706], FAX: [+1 847 576-6758], E-Mail:[John.Barr@Motorola.com] Re: [“Final Report to EC in response to the Mandate on UWB” (ECC TG3), ECC Report 64 “The Protection Requirements of Radiocommunications Systems Below 10.6 GHz from Generic UWB Applications” (Helsinki, February 2005)] Abstract: [Summary of current ECC TG3 reports, their impact on UWB deployment in EU, and support from UWB proponents required to establish reasonable regulatory framework for EU.] Purpose: [ECC TG3 has prepared two documents for consideration by the ECC to set regulatory policy for operation of UWB devices in Europe. These documents have been prepared with minimal participation of UWB proponents, and are not aligned with current regulatory rules in the US. The next step in the process is for UWB proponents to provide additional application requirements justifying need for the current FCC mask, and to provide possible mitigation techniques to address the many concerns of the EU regulators about operation of UWB devices.] Notice: This document has been prepared to assist the IEEE 802.15. It is offered as a basis for discussion and is not binding on the contributing individual(s) or organization(s). The material in this document is subject to change in form and content after further study. The contributor(s) reserve(s) the right to add, amend or withdraw material contained herein. Release: The contributor acknowledges and accepts that this contribution becomes the property of IEEE and may be made publicly available by 802.15. Dr. John R. Barr, Motorola

  2. ECC TG3 History • First meeting April 19, 2004 • ECC TG3 on UWB is mandated by the ECC: • To develop the draft ECC Report on UWB • To develop the draft ECC responses to the European Commission mandate to CEPT to harmonise radio spectrum use for Ultra-wideband Systems in the European Union • To coordinate European positions in preparation for ITU-R TG1/8 on Ultra Wide-band issues • Schedule • July 2004 - Draft First Report • November 2004 - Draft Interim Report • March 2005 - Draft Final Report • Participation • Limited to CEPT administrations plus EC, ERO, chairman of ETSI ERM TG31A and representative from “UWB Cluster” Dr. John R. Barr, Motorola

  3. First Meeting Summary • TG3#1_10R1_Report of the first meeting of ECC TG3.doc • Starting assumptions: • “UMTS Forum is of the opinion that for UWB, as a short range communications technology, bands above 6 GHz could present a viable, long term spectrum management solution. This contribution will be considered at the second meeting of ECC TG3.” • “As for the FCC regulations on UWB initially adopted 14 February 2002, the Chairman of SE24 indicated that SE24 had studied in detail the impact of the FCC limits on radiocommunication services and concluded that CEPT could not endorse these limits (i.e. FCC mask).” • The near-totality of UWB applications, in particular UWB communication and positioning applications, are expected to be operated without requirement for an individual right to use radio spectrum (“licence-exempted”) and on a “no protection, no harmful interference” basis. • Working Groups: • WG1: UWB characteristics and measurement techniques • WG2: UWB Compatibility • WG3: Frequency management and regulatory issues Dr. John R. Barr, Motorola

  4. ECC TG3 Meeting Schedule • TG3#1, 19 April 2004, Maisons-Alfort, France • TG3#2, 17-19 May 2004, Copenhagen, DK • TG3#2bis, 24-28 MAY 2004, Copenhagen, DK • TG3#3, 23-24 August 2004, Copenhagen, DK • TG3#4, 27 Sep - 1 Oct 2004, Mainz, Germany • TG3#5, 20-22 October 2004, Mainz, Germany • TG3#6, 10-14 January 2005, Copenhagen, DK • TG3#7, 1-3 March 2004, Brest, France • TG3#8, 26-29 April 2004, Helsinki, Finland Dr. John R. Barr, Motorola

  5. French Proposed Mask • TG3#2 submission from France: • [400 MHz or x] ≤ f < 2700 MHz Pmax = -85 dBm/MHz • 2700 MHz ≤ f < 5925 MHz Pmax = -75 dBm/MHz • 5925 MHz ≤ f < 10.15 GHz Pmax = -70 dBm/MHz • 10.15 GHz ≤ f < [y] GHz Pmax = -67 dBm/MHz Dr. John R. Barr, Motorola

  6. ECC TG3 Scope (802.15 emphasis) • UWB Applications: (draft First Report to EC) • 1.1.1 Communication applications • UWB technology is an emerging technology for wireless communication over short distances, with the potential for high data rate communication (up to 500 Mbps). This is achieved by spreading the transmitted signal over a wide bandwidth (one definition of UWB is that the bandwidth is at least 20% of the operating frequency). Applications that have been proposed for UWB include ad-hoc wireless networks, intra-home and intra-office communication.UWB radio can also be used in applications requiring only medium- to low data rates (e.g. in sensor networks for high-resolution indoor positioning, tracking of assets and people, intrusion detection in security systems, obstacle avoidance and motion sensing). Dr. John R. Barr, Motorola

  7. Multiband UWB Summary • Karl Löw - Deutsche Telekom • The multiband approach for UWB enable a more efficient use of the spectrum with respect to the unwanted emissions in the out-of-band and spurious domains (and, of course, with respect to the wanted UWB signal, too). • The multiband approach is an important and advanced technology and, therefore, should be included in the relevant Annex 1 on the characterisation of UWB. Dr. John R. Barr, Motorola

  8. UWB Cluster (EU project PULSERS) • UWB Applications and European Market & Technical Characteristics • Device Types • Class A: Devices supporting a high data rate (HDR: 50 … 500 Mb/s) or a very high data rate (VHDR: >500 Mb/s); • Class B: Devices supporting a low data rate (LDR: few kb/s to ~10 Mb/s) or a localization and tracking (LT: ranging accuracy of ~1 m over a range up to several tens of meters) or a combination of both LDR and LT (LDR-LT). • Class A Applications • Wireless Fast Ethernet Interface Link (1.5 - 5 Gbps) • Wireless PAN in the Home or Office • Outdoor Peer to Peer Network • Class B Applications • Intelligent Wireless Area Network • Sensor Positioning and Identification Network • Wireless Outdoor Sensor Network • Wireless Body Area Network • LDR Wireless Personal Area Network Dr. John R. Barr, Motorola

  9. PULSERS VHDR Scenarios Dr. John R. Barr, Motorola

  10. PULSERS HDR Scenarios Dr. John R. Barr, Motorola

  11. PULSERS LDR Scenarios (partial) Dr. John R. Barr, Motorola

  12. PULSERS Activity Factors Dr. John R. Barr, Motorola

  13. Organization of ECC TG3 Work Dr. John R. Barr, Motorola

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  15. TG3#5 - Interim Report Approved • Three classes of UWB Applications • Communications Equipment • Imaging Systems (includes motion detection) • Short Range Radar (not addressed) • Industry focusing on DS-UWB and MB-OFDM and research includes PULSERS • “This ECC Report considers the protection requirements of radiocommunication systems below 10.6GHz from generic UWB applications. The study is based mostly on theoretical analysis. The following conclusions are based on currently available data on the UWB technical characteristics and propagation models, bearing in mind that no specific mitigation techniques for UWB applications were taken into account as they are still under development.” Dr. John R. Barr, Motorola

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  19. PULSERS Position on Report 64 • Thus, we would like to declare our concerns and disagreement on the following points pertaining to Draft ECC Report 64: • UWB deployment scenarios have been developed based on historical applications supported by RLANs and with a lack of consideration for realistic characteristics of future UWB systems and applications, which will have much more limited coverage and radio access schemes than classic RLANs; • Use of theoretical models that are derived from both grossly pessimistic (and highly unlikely) worst-case deployment scenarios and extremely conservative protection criteria for incumbent services; • Use of unrealistic UWB devices deployment scenarios that lead to a pessimistic overestimation of the effects of cumulative UWB interference in outdoor environments; • No consideration given to possible mitigation techniques at the system and operational levels (currently under evaluation and development within the industry) that could ease concerns related to coexistence of UWB devices with incumbent services deployed between 3.1 to 10.6 GHz; • Insufficient consideration given to the already available (typically more benign) results established by means of laboratory tests and field measurements, performed under practical operating conditions for various radio services. Dr. John R. Barr, Motorola

  20. ECC Report 64 Approved • TG3#6 Note on Activity Factors: • The conclusions from ECC Report 64 remain based on the set of generic deployment scenarios defined by ECC TG3 for reference in the compatibility studies. • The incorporation of alternative scenarios taking into consideration the WPAN approach was not supported during the formal review of the public consultation comments as this would modify all the studies, which cannot be agreed within the resolution meeting especially as the revised studies are not available. • Note rejecting Report 64 Activity Comments: • This should modify all the studies. May be submitted as an input document to TG3 WG3 and as material for a contribution to TG 1/8. • Not relevant. The activity factors used for the compatibility studies in ECC Report 64 are based on generic UWB-deployment scenarios agreed within ECC TG3. Dr. John R. Barr, Motorola

  21. EC Comments on CEPT Work (15R0) • To recall, CEPT was mandated to undertake all necessary work to identify the most appropriate technical and operational criteria for the harmonised introduction of UWB-based applications in the European Union. The Commission’s current assessment of activities in this respect is that the underlying objectives of the Mandate would not be met if the CEPT work was finalised exclusively according to the technical results presented in the Interim Report. • The Commission urges all interested parties working within CEPT and ETSI on the respective EC Mandates to explore further the means of enabling the regulated placing on the market of mass-market UWB devices in Europe in a harmonised way while affording adequate protection to incumbent services. • [TG3#6 Minutes] ECC TG3 largely recognized that the current CEPT limits do not allow a satisfactory answer to the Commission mandate and that concerns raised in document TG3#6_15R0 should be seriously addressed. The challenge for regulators is obviously to find and appropriate balance between protection of existing services and facilitating the introduction of UWB. Dr. John R. Barr, Motorola

  22. EC New Mandate for Future Work (15R0) • incorporation of empirical test results carried out in TG3 and elsewhere to assist in developing realistic and proportionate conditions of use; • in-depth consideration of feasibility and impact of mitigation techniques to enable a more permissive set of conditions of use for UWB than those identified by worst-case mathematical models (“bottom-up” approach); • evaluation of theoretical and, where possible, practical operational and economic impact on “victim” services of a number of alternative UWB regulatory scenarios (“top-down” approach); • selection of most appropriate operating conditions for UWB, seeking to optimise benefits while maintaining a cautionary approach for the first generation of mass-marketed UWB-enabled devices. If no clear-cut optimal result emerges from the process, CEPT will be invited to present “options” to be discussed and selected in the Radio Spectrum Committee. • development of a first harmonised regulation for mass-market UWB applications, including possible common monitoring and reviewing mechanisms. • development of separate harmonised regulation for professional-use low scale applications, such as Ground and Wall Probing Systems. Dr. John R. Barr, Motorola

  23. Possible Future EC Measures (15R0) • RSPG Opinion: The Radio Spectrum Policy Group may be requested by the Commission to study how to ensure that new wireless technologies which are being developed for operation in a “commons” or “underlay” spectrum environment will be allowed on the market in Europe in a timely but controlled fashion. In this context, some general approaches issuing from the RSPG discussion (for instance, on experimental rights) could be applied to UWB regulation in the longer term. • UWB public hearing: As well as opportunities, the introduction of UWB is generating concerns on the part of the many sectors which fear being affected. It is therefore important to continue consulting with all interested parties and disseminating information to them. A workshop or hearing could be envisaged in Brussels around the middle of next year to provide a public platform for open discussions of regulatory approaches, possibly assisted by real-life UWB demonstrations supplied by IST RTD projects. Dr. John R. Barr, Motorola

  24. ECC TG3 WG3 to describe possible regulatory solution(s) • The following should be retained as a general guidance to WG3 for its work: • Current Generic UWB PSD limits from ECC Report 64 and the concept of a “generic mask” derived from these limits do not allow a satisfactory answer to the Commission mandate. • The development of possible regulatory solution(s) should include the consideration of: • Mitigation techniques • Regulatory measures • Application specific regulatory approach • UWB requirements • A plan for additional studies on “impact analysis” may be included in the Final CEPT Report. The 1st step on this work item shall consist of a case study on the Fixed Service in order to clarify concretely what can be expected from such additional studies • The “mask derived from ECC Report 64” should be the starting point of future discussions on UWB PSD limits as it reflects the agreed outcome of the technical work conducted over the last three years Dr. John R. Barr, Motorola

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  27. TG3#7 Draft Final Report - March 2005 • A two-step approach is proposed in response to the mandate on UWB: • An interim solution should be developed on the basis of the Impact analysis of a -55 dBm/MHz PSD limit in the band 3.1-10.6 GHz for indoor equipment. • Future work should be performed based on latest UWB requirements and taking into account detailed mitigation techniques. Dr. John R. Barr, Motorola

  28. CEPT ECC TG3 Conclusions • The main conclusions of the CEPT studies in response to EC Mandate on UWB are: • the FCC Indoor UWB mask does not by itself provide adequate protection from interference to the existing services, • the majority of the radio services considered requires more stringent generic limits than defined in the FCC masks, indoor as well as outdoor, • The solution could be the two step approach as described above. Dr. John R. Barr, Motorola

  29. UWB Proponents “Future Work Proposal” • For the robust operation of UWB communication and measurement applications and for a much needed globally compatible UWB Regulatory Framework in Europe, it is requested to develop a regulatory framework which would allow UWB communication and measurement applications to operate with an effective isotropic radiated power (EIRP) spectral density (PSD) limited to –41.3 dBm/MHz in the frequency range 3.1 to 10.6 GHz in Europe. Dr. John R. Barr, Motorola

  30. Regulatory Framework Approach • It is proposed to accommodate the recognized needs for protection of radiocommunication services from possibly harmful interference from UWB applications by introducing certain differentiating i) regulatory, ii) operational and iii) technical (device level) measures. • ECC TG3 should conduct further compatibility and measurement studies considering this differentiated approach, and adopt adequate assumptions in term of deployment, propagation models, activity factors and aggregation. Dr. John R. Barr, Motorola

  31. Proposed Regulatory Framework • This regulatory framework would provide an UWB application/deployment differentiated approach compared to the “generic approach” conducted in previous compatibility studies. These areas have not yet been considered by TG3, and therefore it is premature to simply adopt a very low PSD limit without consideration of this new approach to regulate UWB technology. • Procedurally, after ECC TG3 has defined the PSD limits (mask) – based on a set of regulatory and operational criteria – it is proposed that CEPT/ECC (TG3) cooperates with ETSI to define and standardize mitigating measures at the detailed technical level (physical device), should such a need still arise. Dr. John R. Barr, Motorola

  32. Limit Study to 3.1 - 5 GHz • In order to allow HDR devices to operate with an effective isotropic radiated power (EIRP) spectral density (PSD) limited to –41.3 dBm/MHz it’s proposed that the ‘in-band’ frequency range under consideration could be reduced from the current 3.1-10.6 GHz to a range of 3.1-5 GHz, and out of band emissions would be defined below 3.1 GHz and above 5 GHz. • This limitation would reduce the number of potentially affected victim services, to four current services: • Fixed services, • Fixed satellite services, • Radio astronomy services, • Aeronautical services. • This range is based upon the current operational range of devices developed by the majority of UWB proponents, and for which it is envisaged to implement features compliant with the proposed regulatory measures in order to complement regulatory rules being considered up to now (e.g FCC limits). • Extension to 10.6 GHz could be considered at a later time. Dr. John R. Barr, Motorola

  33. Introduce an Indoor Deployment Limitation • In addition to the defined PSD limits, regulatory measures should include application and deployment specific constraints, and for High and Very High Data rate WPAN applications, a deployment limitation to indoor environments should be specified, by precise measures such as: • No outdoor infrastructure for High and Very High Data rate WPAN systems • This would further reduce the impact on potentially affected victims by limiting outdoor activity to infrequent peer to peer exchanges between handheld devices. Dr. John R. Barr, Motorola

  34. Operational Domain • In this category, are system level solutions providing operational and interoperability functions based on realistic deployment and coexistence. Certain alternate techniques at a system’s operational level will be considered, since the potential for effective mitigation is rather sizable at these levels. The most viable (based on complexity and cost estimation) measures are: • Radio access schemes (TDMA): Within such network cells, only one UWB device is allowed to transmit at any given time. This relatively simple measure effectively limits signal aggregation within a piconet or cell area of typically up to a few 100’s m2. • The “10 seconds rule” (Transmission stops after [10sec] if no response to ARQ): In this case, any device that is unable to establish a connection with an associated receiver in a piconet (or network cell or subnet) within 10 seconds should cease to transmit until a later time period. • Introduction of limits on UWB device activity, according to UWB device classification (very high bit rate, high bit rate, low bit rate) Dr. John R. Barr, Motorola

  35. Technical Domain • Typical solutions would reduce UWB device emissions, while keeping the overall system performance compliant with the application needs and use cases (throughput, coverage, QoS). • These requirements include generic mitigation techniques that require radio technology dependant solutions and could impact the MAC and physical layers. The most viable (based on complexity and cost estimation) are: • Transmission Power Control (TPC): Limit transmitted power to the minimum required to meet the requirements of the associated application. • Coordinated and uncoordinated quiet periods: Periods of no UWB transmissions are provided on a regular basis to allow other services to have full access to the spectrum. • Definition of application specific requirements such as compression rates (video streaming, multimedia content transfer, etc…) in order to reduce the air traffic rate. Dr. John R. Barr, Motorola

  36. Approach Summary • Additionally, dedicated mitigation techniques could be proposed when no other solution has proven to be suitable, and eventually, the investigation of techniques such as static frequency shaping should be carried on, mainly in the case of coexistence with future indoor fixed and mobile services. • Due to the increased system complexity required to support these features, a viable technical approach could be to support these measures only by capable devices (defined as masters), and not supported by all UWB devices. This would imply that these devices should coordinate the activities of slave devices to comply with these requirements. • The definition of such requirements should be mandated by regulatory rules, but the technical feasibility studies should be conducted within standardization (or “harmonized standardization”) bodies. Dr. John R. Barr, Motorola

  37. Revise Compatibility Studies • Path loss models: The work in TG3 employed path loss models which emphasized conservatism and do not necessarily reflect restrictions on devices to primarily operate indoor. It is possible to select alternative path loss models which accurately reflect the interference environment. • Activity factors: TG3 reached conclusion on activity factor estimates after the close of Report 64. These estimates should be incorporated into existing simulations. Simulations could then use common assumptions. • Mitigation factors: The effects of UWB upon victim services were calculated without incorporation of potential mitigation techniques. Existing simulations for the 4 victim services would be recomputed with a base set of mitigation techniques as a starting point. These would include elimination of fixed outdoor infrastructure, a 10 second rule on beaconing without association, radio access schemes (TDMA), coordinated and uncoordinated quiet periods, and activity based on device classifications. • Single Entry Assumptions: A 100% activity is assumed in all Single Entry calculations. These assumptions could be revisited with a recognition that devices will not be operational 100% of the time. Dr. John R. Barr, Motorola

  38. Challenge to TG3a • Consider what will be required to satisfy EU and ITU regulatory requirements: • Needs to be available in all UWB solutions • Scalable implementation that can adapt to domain conditions • TPC, TDMA, rate/power trade offs, limit activity • Support UWB proponents (PULSERS) to complete suggested regulatory framework and update compatibility studies: • Provide resources to complete definition of proposed regulatory framework • Provide resources to update compatibility studies • Demonstrate compelling applications if EC holds UWB Public Hearing in Brussels. Dr. John R. Barr, Motorola

  39. References • ERO Documents: • Report 64: • http://www.ero.dk/documentation/docs/docfiles.asp?docid=2051 • ECC TG3 meeting reports and documents: • http:///www.ero.dk Password required. Checking on whether this can be released to TG3a voting members. Dr. John R. Barr, Motorola

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