Project: IEEE P802.15 Working Group for Wireless Personal Area Networks (WPANs)

1. Project: IEEE P802.15 Working Group for Wireless Personal Area Networks (WPANs) Submission Title: [DS-UWB Responses to TG3aVoter NO Comments – FCC Compliance] Date Submitted: [September 2004] Source: [John McCorkle & Matt Welborn] Company [Freescale Semiconductor, Inc] Address [8133 Leesburg Pike] Voice:[703-269-3000], E-Mail:[matt.welborn @freescale.com] Re: [] Abstract: [Response to NO voter comments and feedback regarding the DS-UWB (Merger #2) Proposal] Purpose: [Provide technical information to the TG3a voters regarding DS-UWB (Merger #2) Proposal] Notice: This document has been prepared to assist the IEEE P802.15. 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 P802.15. McCorkle & Welborn, Freescale

2. Topic - FCC Certification • Typical comments • Proposal #2 needs to show FCC compliance approval • It hasn’t been shown how the proposal is compliant with current FCC regulations • I would like to know if it has been certified by the FCC and if not why, since this may seriously impact allowed transmit levels McCorkle & Welborn, Freescale

3. Response Fully Resolved • Freescale’s Implementation of DS-UWB has been certified by the FCC • FCC identifier: RUN-XSUWBWDK • FCC Rules Parts: 15F • Frequency Range (MHz): 3147.6 - 5163.6 McCorkle & Welborn, Freescale

4. Topic: OOB Emissions • Typical comments • I would like to see how the DS-UWB system can efficiently meet power spectral density limits well below the FCC mask at frequencies below 3.1 GHz, which are being considered by the ITU • Draft European spectral mask has a sloping out-of-band emissions mask. It has not been shown that that this mask can be met at reasonable cost. While some may view that meeting a draft European emissions mask is not necessary at this time. My view is that 802.15.3a is to be world wide standard and will require world wide acceptance. Thus the market place success of the 802.15.3a standard will depend on world wide acceptance. Thus, I assert that easy flexibility in meeting the draft European mask is very important for any candidate technology. • Out of band emissions appear to be a serious problem that is inherent in the proposal and has not been adequately addressed McCorkle & Welborn, Freescale

5. FCC Indoor Limit -51.3+87 log(f/3.1) ETSI Proposed Indoor Limit Example Mask Proposed by ETSI to ITU Note that the US is not supporting this indoor limit proposed by ETSI USA has proposed that ITU use the FCC’s mask McCorkle & Welborn, Freescale

6. Measurement FromFCC Certification Test Document • Notes: • This curve is directly on top of the measurement of the instrument noise floor! • The Freescale DS-UWB radio emissions are actually lower One Indoor Limit Proposed to ETSI McCorkle & Welborn, Freescale

7. Response Fully Resolved • There are no existing international regulations • The PAR and the Criteria Document do not specify that a proposal meet non-existent regulations • Freescale’s Implementation of the DS-UWB proposal is proven by measurements in the FCC compliance test report document to be compliant even with the proposed ETSI mask, even though USA has a counter proposal. McCorkle & Welborn, Freescale

8. Topic: Cognitive Radio • Typical comments (excerpts) • CID#43 Radio evolution - With the current movement to cognitive radio technology and sensing radios which will need to include UWB, the pulse-based approach creates a non-sequitor issue. The technology foundation for the IEEE UWB phy needs to be compatible with this evolution expectation, and DS-UWB does not fit the bill as currently defined. • CID#68 UWB will occupy chunks of a 7GHz space!! To me, the need for a well mannered and flexible 'cognitive radio' is compelling. In my view, the news from the ITU-R supports this. • CID#68 a 7 GHz bandwidth _needs_ a 'cognitive radio'. McCorkle & Welborn, Freescale

9. Topic: Cognitive Radio – Fully Resolved • The PAR and the Criteria document do not require any cognitive radio features • There are no UWB regulations anywhere that use cognitive radio • Getting even simple UWB regulations has proven to be the most contentious proceedings in history for regulatory agencies • This fact argues that attempting to get cognitive UWB regulations in place is highly unlikely McCorkle & Welborn, Freescale

10. BACKUP McCorkle & Welborn, Freescale

11. Achieving Dynamic SpectrumIn UWB Cognitive Radio • Requires sensing of other systems (active or passive) • Often requires knowledge of device location and apriori knowledge of the location and parameters of other devices • Cognitive radio concepts often rely on GPS and location data bases with locations of potential victim receivers and their characteristics • Could require additional protocols at the MAC layer or higher to ensure network coordination • The requirements are not consistent with low-cost requirements of CE devices • None have been proposed to TG3a • None have been proposed to FCC • None have been proposed internationally McCorkle & Welborn, Freescale