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Unlicensed to Kill: A Brief History of the Part 15 Rules. Kenneth R. Carter Senior Consultant THE GENESIS OF UNLICENSED WIRELESS POLICY An Information Economy Project Conference George Mason University School of Law April 4, 2008. Agenda. Unlicensed Rules Generally - PowerPoint PPT Presentation
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Unlicensed to Kill:A Brief History of the Part 15 Rules
Kenneth R. CarterSenior Consultant
THE GENESIS OF UNLICENSED WIRELESS POLICY
An Information Economy Project Conference George Mason University School of Law
April 4, 2008
2
Agenda
• Unlicensed Rules Generally• The History of the Part 15 Rules
- Origins of the Rules Governing Unlicensed Devices
- The Evolution of the Part 15 Rules- More Room for Unlicensed Operation – Into
the Future
• Spectrum Policy Lessons from Its History
3
Unlicensed OperationNo such thing as “Unlicensed Spectrum”
• Low Power Operation without a User License
• No Vested Right to Continued Operation
• May Not Cause Harmful Interference
• Must Accept Any Interference
• Must Cease Operation if Notified by FCC that Device is Causing Harmful Interference
• Must Receive Equipment Authorization before Marketing/Importation
“No, Mister Bond, I expect you to accept all harmful interference.”
4
Certification
• Unintentional Radiators: devices that generate RF energy internally, or sends RF signals to associated equipment via connecting wiring, but which are not intended to radiate RF energy through the air. Examples include computer CPU boards and power supplies. The components and enclosures of these devices must be shielded sufficiently to limit the amount of RF energy that escapes.
• Incidental Radiators: devices, like electric motors, that generate radio frequency energy during the course of operation although the devices are not intentionally designed to generate or emit RF energy.
• Intentional Radiators: devices that intentionally generate and emit RF energy by radiation or induction.
“Now I’ve got to get all these certificated.”
5
Charting Unlicensed Devices
RF DevicesPart 15
U-NII Subpart E
U-PCSSubpart D
UWBSubpart F
IntentionalRadiators Subpart C Low Power
Transmitters
Spread Spectrum
Wi-Fi802.11b802.11g
802.11a
Motorola Canopy
RFIDs
Cordless Phones
GarageDoor
ISMPart 18
Blue-Tooth
HomePlug
6
History
• Everything leaks spectrum
• FCC Chief Engineer, Ewell Jett in 1938: No: interference no engineering reason for suppressing their use.
• No such think as “unlicensed spectrum”
• Westward migration new bands opened.
• Bands congested
• Higher frequencies available
7
Part 15 Timeline
1920 2003
1920 - 1934“Wild West Days”
1934The Communications Act
1960 - 1979Expanding Applications Base.
1938Unlicensed Precedent Set
Part 15 0.3-3
3-30 MHz.
wireless microphones, telemetry systems,garage door openers, video cassette recorder,
anti-pilferage systems, auditory assistance devices, control and security alarm apparatus, and cordless telephones.
U-PCS 1910-19201920-19302390-2400 MHz
Low Power &Spread Spectrum900 - 9282400 - 2483.55725 - 5850 MHz
Millimeter Wave Technology. 59-64 GHz later widened to 57-64 GHz.
Part 15 Revision Limits on peak emissions. Unintentional Radiators Incidental Radiators Intentional Radiators
Introduction of U-NII5.15-5.355.725-5.825 GHz
Making Way for Ultra-Wideband.several gigahertz wide.
70-80-90 GHz NOI.71-7681-8692-95 GHz
SPTFUnlicensed NOI
5.8 NOI
Carter, Lahjouji, & McNeilPublish OSP WP #39
Unlicensed & Unshackled
1955Restricted Radiation Devices
27- 3070 - 890 MHz
8
Coordinated vs. Uncoordinated Spectrum Access Regimes
Coordinated Spectrum Access Uncoordinated Spectrum Access
Features
Centralized
-base stations and terminals
-time slots
~higher power
Distributed
-radio devices only
-collision avoidance
~lower power
Advantages
Handles congestion well
Low overhead cost at high utilization rates
Low overhead cost at low utilization rates
No coordination across standards
Disadvantages
High overhead and opportunity costs at low utilization
Requires coordination across standards
Higher barriers to entry
High congestion costs
No ability to exclude
9
FCC Enforcement Case Load 2000 -2003
35,93390.3%
3,8389.7%
Other Case Load i/x Cases
Unlicensed operators are well behaved spectrum users.
3,77398.3%
651.7%
Part 15 Cases Other i/x Cases
0.16% of Total Case Load
Total Case Load = 39,771
Source: Enforcement Bureau, FCC
10
Summary
• Not spectrum policy
• Address engineering concerns
• Regulate emissions characteristics
• Manufacturers have wide latitude and flexibility in devices and services
• One size does not fit all - there are a variety of approaches.
• Markets are good servants, but poor masters. “Comes complete with sidewinders,
smokescreen, ejection seat, and Bluetooth.”
wik-Consult GmbH
Tel +49 (0) 2224-9225-24 [email protected] +49 (0) 2224-9225-2224 www. wik-consult.com
Thank you
I Pussy GaloreAlpha is a Greek letter; ALFA is an Italian car
I’d rather be spyingMy other car is a jetpack.It’s not a midlife crisisIt’s a childhood fantasy.I break for supervillains.When rayguns are outlawed,
only outlaws will have raygunsErnst Stavro Blofeld ‘08