FCC UWB TEST REPORT DUE OUT SHORTLY

Current lack of commercial quantities of UWB communications devices for testing has led to expectation by some in industry that FCC may not be able to revisit more flexible standards for that technology as quickly as originally envisioned. When Commission adopted UWB order in Feb. (CD Feb 15 p3), officials said they planned in next 6-12 months to review UWB standards and set further rulemaking to examine possibility of more flexible standards and address operation of additional types of UWB technology. FCC official said last week at meeting of U.S. Task Group on UWB, formed to provide input to ITU policy in that area, that Commission expected to act on petitions for reconsideration pending on UWB rules in Feb. Agency also could act on further notice that would examine stringency of existing standards, but whether it would act in that period wasn’t yet clear.

FCC, at time it approved order, said it erred on side of conservatism in setting power limits, trying to strike balance between allowing technology to move forward and satisfying interference concerns raised by cellular operators, GPS representatives, others. Thomas declined to say whether he would recommend that FCC wait on making changes in rules until test data were available on real-world devices, but he said: “Common sense says there aren’t a lot of real devices out there. So to assume that a definitive order is made and is never revisited to me is a risky proposition, so what I would suggest to the Commission is that it watch how the space evolves and revisits this thing in the future to assess whether they did the right thing.”

Current FCC test program is examining ambient noise levels and receiver susceptibility to interference, Thomas said. In letter last month to Sen. Burns (R-Mont.), FCC Chmn. Powell said Commission currently wasn’t testing UWB devices, since only commercial ones available were ground- penetrating radar. While FCC still plans to test UWB devices when enough are available to form representative sample, Powell said FCC was testing common electronic devices such as computers, electric drills and others that were sources of incidental electromagnetic radiation that could cause interference with some radio signals. Agency also is examining radio noise levels in environments such as airports and factories.

Most restrictive emission mask adopted in UWB order was designed to protect GPS receivers from interference, with power limit that constrains UWB devices to levels that are 6 dB below thermal noise floor. Testing/measurement program for which FCC will soon issue description and results to date is examining questions such as whether ambient noise floor will prevent GPS receiver from achieving performance inherent in its thermal noise floor, Commission said. Testing also is analyzing level of emissions generated in GPS band from existing personal or commercial devices. FCC said measurements of existing consumer devices were examining emissions from both intentional and unintentional radiators and comparing data with UWB limits.

Currently there are no data that characterize noise floor in all environments, Thomas said. “It’s a fairly difficult problem,” he said. “There is no such thing as a ‘noise floor.’ There are noise floors and they vary from environment to environment.” What FCC lab in Columbia, Md., has been doing is “a beginning,” he said. Now lab primarily has been examining ambient noise levels in Baltimore- Washington area, he said. Asked whether those data could be used in other FCC rulemakings where reading of noise floor levels would be helpful, he said: “In order to do it right, it’s got to be done in a lot more locations.”

Testing has generated criticism by companies and groups that have raised interference concerns about UWB. Thirty- four companies and trade groups told Powell earlier this month that they were concerned that FCC test plans involved hair dryers but not UWB devices. Airline, wireless and GPS interests said they were particularly concerned that Commission wasn’t testing “intentional and aggregated emissions from UWB devices but instead was testing incidental noise levels from “unintentional” emitters such as laptops. Coalition also said agency didn’t intend to furnish test plan for public review and comment ahead of tests’ actually being conducted.

Asked about general questions on disclosure of test plans, Thomas said: “The FCC feels no obligation for bringing out to public notice and comment how we are going to do our measurements before we do them. We know how to make measurements. We are professionals in this field.” One concern is timing, with unwieldy long lead times built into process under scenario in which test plans are released for comment before testing begins, he said. “Otherwise, it would delay us forever.”

NTIA spokesman said that agency had been studying its own test program and was collecting data that other federal govt. agencies could provide. NTIA testing has been apart from FCC plans, Thomas said. “My presumption is that when we put our report out that they will have data that will support or countermand what we're doing and submit it,” he said. Thomas said he hadn’t been apprized by NTIA as to whether it planned to submit separate data.

Separately, Thomas said he was exploring ways to get some experts from FCC lab more involved in formative part of technical rulemakings. “I'm very anxious to get the lab more involved in the day-to-day rulemaking of the Commission on a proactive basis rather than a retroactive basis,” he said. In past, lab has done certain kinds of enforcement work that Enforcement Bureau could have handled, Thomas said. Still, in some cases, such enforcement work is of technical nature that lab, rather than Enforcement Bureau, should address, he said. “What we are trying to put together is a partitioning that makes sense and the reasoning for that is to free up certain people so that the lab could be more active in the empirical part of rulemaking,” he said.