1. doc.: IEEE 802.11-01/254 Submission May 2001 Chris Heegard, TISlide 1 Great News from the FCC for IEEE 802.11 Task Group G Chris Heegard, Ph.D. Home and Wireless Networking Texas Instruments 141 Stony Circle, Suite 130 Santa Rosa California 95401 (707) 521-3060, heegard@ti.com

2. doc.: IEEE 802.11-01/254 Submission May 2001 Chris Heegard, TISlide 2 Action by the Commission May 10, 2001 Further Notice of Proposed Rule Making and Order –FCC 01-158 –Chairman Powell, Commissioners Ness, Furchtgott-Roth and Tristani FCC Documents –http://www.fcc.gov/Daily_Releases/Daily_Business/2001/db0510/nret0104.html –http://www.fcc.gov/Daily_Releases/Daily_Business/2001/db0511/fcc01158.doc The FCC will not be the “long pole” in Task Group G –NPRM --> Blanket interim waiver –Levels the playing field: no technology preference given

3. doc.: IEEE 802.11-01/254 Submission May 2001 Chris Heegard, TISlide 3 Background In 2000, Wi-LAN applied for certification of an OFDM system in the 2.4 GHz ISM band under the existing rules –The application was denied –An appeal with also denied –The May 10 meeting confirmed the denial It is intended that the May 10 NPRM will allow OFDM –A “blanket interim waiver” will allow such systems before the rules are in place

4. doc.: IEEE 802.11-01/254 Submission May 2001 Chris Heegard, TISlide 4 Background (cont) In 2000, Texas Instruments claimed that PBCC-22 technology would satisfy the existing rules –Up to today's date, PBCC-22 has not been submitted to the FCC –This claim remains “unchallenged” The only “controversy” involves the “Processing Gain” requirement of the existing rules –Is Coding Gain a component of Processing Gain? –CCK, which is the mandatory part of 802.11b, requires a YES answer to meet the rules The May 10 NPRM will allow PBCC-22 –The blanket interim waiver will dispense with Processing Gain requirement

5. doc.: IEEE 802.11-01/254 Submission May 2001 Chris Heegard, TISlide 5 The FCC May 10 th action NPRM: Propose to amend Part 15 of the Commission’s rules to improve spectrum sharing by unlicensed devices operating in the 2.4 GHz band –Provide for introduction of new digital transmission technologies Examples: PBCC and OFDM No specific technology favored –Eliminate unnecessary regulations for spread spectrum systems Processing gain –Frequency hopping spread spectrum systems Reduce the amount of spectrum that must be used Allows Bluetooth to support adaptive FH with as few as 15 frequencies (all 79 required now)

6. doc.: IEEE 802.11-01/254 Submission May 2001 Chris Heegard, TISlide 6 FCC Statement Allowing authorization of digital modulation systems now will avoid the delays otherwise imposed by our rulemaking process and thereby substantially speed the process for implementation of these new system designs. In this regard, our decision to waive the restrictions which prevent authorization of such systems reflects our view that it is appropriate and desirable to take steps wherever possible to facilitate the timely and efficient introduction of new technologies and equipment, and particularly those that will support the development and deployment of broadband infrastructure without threat to incumbent operations and devices.

7. doc.: IEEE 802.11-01/254 Submission May 2001 Chris Heegard, TISlide 7 The Blanket Interim Waiver Allows new digital technologies that meet the existing rules for direct sequence spread spectrum systems to obtain FCC equipment certification prior to the adoption of final rules – a maximum peak power limit of 100 mW The commission affirmed a staff decision denying the application for equipment certification for a Wideband Orthogonal Frequency Division Multiplexing system filed by Wi-LAN, Inc. –but directed the staff to consider the application pursuant to the provisions of the interim waiver

8. doc.: IEEE 802.11-01/254 Submission May 2001 Chris Heegard, TISlide 8 What Peak Power limit means W-OFDM, as a multi-carrier technology, will not be able to operate with the same average power –Higher peak-to-average ratio compared to PBCC, Barker and CCK and other single carrier technologies –Other things being equal, it causes more interference, so the FCC will requires that its average power level be throttled back by limiting peak power –This means that a OFDM transmitter will have a smaller range compared with PBCC, CCK and other single carrier technologies –It was partly for this reason that the FCC recently rejected a version of OFDM for digital television broadcasting and instead endorsed a single carrier technology

9. doc.: IEEE 802.11-01/254 Submission May 2001 Chris Heegard, TISlide 9 PBCC-22 The FCC clearly anticipates a PBCC-22 submission –Paragraph 6 of FCC document Texas Instruments intends to submit a reference design system for certification under the waiver –ASAP One or more others intend to submit soon One or more PBCC-22 systems will likely be certified before the next IEEE 802.11 meeting