1. Michael J. Marcus, Sc.D., F-IEEE
Wi-Fi and Bluetooth: The Path from Carter and Reagan-era Faith in Deregulation to Widespread Products Impacting Our World  
Michael J. Marcus, Sc.D., F-IEEE
Federal Communications Commission (Retired) Director, Marcus Spectrum Solutions LLC

2. Origins of Wi-Fi/Bluetooth
Roots are twofold:
Technological
Spectrum Policy
Convergence of the two at FCC in the 1980s enabled a unique blossoming of technologies in a field normally subject to “command and control” policies
Was not focused on either petitions or WLANs
Subsequent more focused proceedings (u-PCS and U-NII were less sucessful

3. Origins of Wi-Fi/Bluetooth
FCC action was a self initiative
Was not focused on either external petitions or WLANs
Subsequent more focused proceedings (U-PCS and U-NII [and HIPERLAN in Europe]) were less successful

4. Traditional FCC Spectrum Policy
Has its roots in the 1930s
When frequencies were limited
Technological options few
Faith in government high
Rules could be easily changed
But these all changed with
Post-WWII technological explosion
1946 Administrative Procedures Act
Just as new technology became available, regulations slowed down!

5. Traditional FCC Spectrum Policy
FCC (and other spectrum regulators) traditionally depended on petitioners spelling out “requirements” and then specifying band and technology to meet such “requirements”
Hard to impossible to keep up with technological change and needs of a changing society and economy

6. Deregulation Comes to FCC (and Stays)
Carter Administration brought a focus on deregulation as a means to stimulate economic growth
CAB Chairman Alfred Kahn was a leader within administration on the effectiveness of deregulation
FCC Chairman Ferris embraces concepts
For Both Titles II and III

7. Chmn. Ferris & Spectrum
Chmn. Ferris challenges his spectrum team to identify promising technologies that are blocked by anachronistic regulations
Recognizes the delay and transactions costs associated with waiting for petitions in all cases
Goal was not to force new technology but get out of its way

8. Searching for Candidate Technologies
Ferris recruits former ARPA chief S. J. Lukasik to head Office of Science & Technology starting in Summer of 1979
Challenges him to identify candidate technologies to remove barriers from
New emphasis on market forces not “command & control”

9. Serendipity in Action
I encounter Lukasik in May 1979 at a classified Army Science Board electronics warfare panel meeting in Chicago
Had previously met while I administered ARPA R&D projects in nuclear test detection during military service
Due to Army efficiency, “MA” certain to sit next to “LU”
Electronic warfare similar to spectrum management except for intent

10. Serendipity in Action Chicago encounter leads to question:
What radio technologies might bloom if dated regulations were removed?
Within a few days reply with list:
Spread spectrum
Adaptive antennas
Millimeter wave bands (>30 GHz)
Lukasik replies with job offer at FCC
My ticket out of military-industrial complex

11. Spread Spectrum Background
Like the computer, the basic technology, spread spectrum, has no single specific inventor
As is often reported in popular press, Hedy Lamarr was awarded an early frequency hopping spread spectrum patent during WWII
But invention was not reduced to practice

12. 1953 MIT Lincoln Lab System
Developed by Paul Green as a thesis project
One of earliest PN systems
Technology of the day limited size

13. Early Literature
In the ’s spread spectrum generally remained a classified technology with only occasional references in the open literature.
My first exposure was at a classified 1972 conference
Only “text book”-like discussion was a classified Sylvania report

14. My First Real Contact
Joining the Institute for Defense Analyses in 1975, I was assigned to studying options for communications ECCM
1973 Mid East War showed an unexpected amount of communications EW
DoD had minimized EW threat to communications up to that point and was concerned about options to increase preparedness against “new” threat

15. Dixon’s Book 1975
First comprehensive, though mathematically inelegant, treatment of spread spectrum
Introduced a generation of designers to the technology

16. Commercial Spread Spectrum c. 1979
Magnavox produces a “civil” version of AN/ARC-50/90
Japan MPT purchases and tests for possible civil applications
Concludes no practical value for civil use

17. Circa 1980 Publications became more common
But most publications still focused on military applications
Possibly to justify DoD funding

18. Early FCC Action - Phase I
FCC had encountered MITRE Corp. in connection with deliberations of JTIDS use of L band
First FCC step in 12/79 was commission MITRE for a report on options for civil use of spread spectrum
Since then FCC has never commissioned such a report unless ordered by Congress
Available from NTIS as PB

19. MITRE Report
Not very useful in hindsight Very useful and significant

20. 6/30/81 - The Regulatory Struggle Begins
2 initiatives begun:
Chmn. Fowler supports action
Docket – General use
Docket – Amateur radio use
No specific proposals
“designed to serve two purposes. We hope to gather information to: 1) assist us in identifying specific radio services presently authorized by the Commission, as well as ideas for new services, where the authorization of wideband modulation techniques would serve the public interest; and 2) identify the technical parameters which characterize a wideband emission, including procedures used to measure these parameters, and identify technical standards necessary to insure operation on a minimum interference basis.”
Do not mention unlicensed or RLANs but does mention ISM bands

21. Reaction to Phase II
“It was felt that there are many useful communications applications which could be achieved with spread spectrum techniques that could not be satisfactorily developed with any other technology.
“However, many had reservations about the particular implementation of spread spectrum systems and expressed concern over the potential for interference with existing communications systems. Because the technology is so new, many urged the Commission to proceed slowly with its implementation until we have had successful operating experience with these systems, including the identification and measurement of spread spectrum signals and their interference potential.
“There was particular concern among some parties that regular communications might be interrupted and the Commission might not be able to detect the source of the interference.”

22. Reaction to Phase II
Discussion of “overlays” lead to a preview what what would happen in later UWB rulemaking: NIMBY
“Both GE and RCA objected to authorizing spread spectrum systems in the Industrial, Scientific and Medical (ISM) bands because many Part 15, low power consumer devices, such as home security devices and video disc systems, have already been authorized to operate in some of the bands.”
The major mobile manufacturer saw any civil spread spectrum use as a prelude to CDMA which would threaten their market hegemony

23. 1983
Focus of technical publications on spread spectrum continues to be military applications

24. 1984
While interest in the US was minimal, others were interested

25. 6/16/84 NPRM Phase III
“It appears that most low power communication devices, currently authorized under Part 15 of our Rules and Regulations, could be considered as potential candidates for spread spectrum.”
“ At the same time, the Commission might be spared the immediate need to allocate additional spectrum space for these services and for other requested services such as cordless telephones.”

26. 6/16/84 NPRM Phase III
“The authorization of spread spectrum systems under Part 15 of the Rules and Regulations would be unrestrictive and unregulatory in nature, since devices operating under Part 15 do not have to be licensed and users do not face eligibility requirements, content regulation, or coordination requirements. This would allow the forces of the marketplace to drive the implementation of this new technology, unhampered by regulations other than those needed to prevent harmful interference to licensed systems.”

27. Response to NPRM NIMBY and fear of overlays is major concern
“Of the parties submitting comments that opposed the proposed authorization of spread spectrum systems, RCA was the only one that supported its position with analysis. RCA's analysis dealt with possible interference to FM and television broadcasting from spread spectrum systems operating in the broadcast bands.”
NIMBY and fear of overlays is major concern
2 IEEE groups file supportive comments
Chairman Fowler supportive of deregulatory concepts

28. 1985 May 9, 1985 FCC adopts spread spectrum rules in ISM bands
Same basic rules until 2002
1 W limit
PN or FH
Almost any application
incorporated July 1985

29. Original Rules: WYSIWYG
Ҥ Operation of spread spectrum systems.
Spread spectrum systems may be operated in the MHz, MHz and MHz frequency bands subject to the following conditions:
They may transmit within these bands with a maximum peak output power of 1 watt.
(b) RF output power outside these bands over any 100 kHz bandwidth must be 20 dB below that in any 100 kHz bandwidth within the band which contains the highest level of the desired power. The range of frequency measurements shall extend from the lowest frequency generated in the device (or 100 MHz whichever is lower) up to a frequency which is 5 times the center frequency of the band in which the device is operating.
(c) They will be operated on a noninterference basis to any other operations which are authorized the use of these bands under other Parts of the Rules. They must not cause harmful interference to these operations and must accept any interference which these systems may cause to their own operations.
(d) For frequency hopping systems, at least 75 hopping frequencies, separated by at least 25 kHz, shall be used, and the average time of occupancy on any frequency shall not be greater than four-tenths of one second within a 30- second period. The maximum bandwidth of the hopping channel is 25 kHz. For direct sequence systems, the 6 dB bandwidth must be at least 500 kHz.
(e) If the device is to be operated from public utility lines, the potential of the RF signal fed back into the power lines shall not exceed 250 microvolts at any frequency between 450 kHz and 30 MHz.

30. Immediate Results No near term career benefits for this action:
Had not been sensitive enough to concerns of other FCC staffers
OST subject to major reorganization with abolishment of 3 top positions including mine
Received lowest senior performance appraisal in 6 years of SES system at FCC
Probably intended to guarantee demotion or dismissal
Transferred to vague job in Enforcement Bureau predecessor
Returned from “internal exile” in 1994

31. 7/87 IEEE Communications Magazine Article
Gave a paper on new rules at GLOBECOM ‘85
FCC management tried to prevent such discussion
7/87 update of paper raised possibility of RLANS in ISM bands

32. “First Light”
In 1988 the first real commercial spread spectrum product appeared – an RLAN

33. “Second Light” Gambatte MIDI LAN
Limited production but very popular with top rock musicians!
Derivative system still used in nuclear power plants

34. Equipment Trends
After slow start, equipment authorizations has had exponential growth

35. Equipment Trends II
Is growth inversely proportional to rule complexity?

36. 1991
“Myth or Reality”
Many key players went to Quebec woods to discuss the future of spread spectrum

37. 1992
LANs discussed
Available products focused on cordless phones and PDA-like systems

38. Non-LAN Systems
Unlicensed point-to-point was unexpected but permitted by liberal rules
Undersold traditional Part 101 systems
Popular in cellular industry for quick installation without paperwork

39. Lessons Learned
Since technology moves faster than regulations, there are often anachronistic regulations that block new technologies
Transactions costs of changing regulations decreases interests in technologies adversely affected
Removing barriers to new technology while maintaining a level playing field can stimulate innovation

40. Lessons Learned
Studying promising technologies that do not have petitioners can lower investment barriers
While consensus decision making has benefits, it is not always the right model for spectrum policy decisions
The public interest is not always the interest of the immediately affected parties in an FCC proceeding

41. Lessons Learned
While FCC has internal resources for most decisions, some innovative areas need outside support not now available:
“Think tank” studies
Technical advisory committee
NAS/NRC study committees
Often used by other agencies

42. Thanks for Listening Questions? More info on website