1. July 2005 Gary Baldwin, SiBEAM, Incorporated Slide 1 doc.: IEEE 802. 15-05-0442-00-003c Submission Project: IEEE P802.15 Working Group for Wireless Personal Area Networks Submission Title: [Comments on WCA Petition to Change FCC Regulations Governing the Unlicensed 57 – 64 GHz Band] Date Submitted: [July 2005] Source: [Gary Baldwin] Company [SiBEAM, Inc.] Address [39300 Civic Center Drive, Fremont, CA 94538] Voice: [(510) 745-7334], E-Mail: [gbaldwin@sibeam.com] Re: [WCA Petition RM-11104 Filed with FCC, September 2004; and a presentation by Gregg Levin to IEEE 802.15.3c, dated July 14, 2005] Abstract: [The WCA has proposed a change in the regulations that govern the use of the unlicensed 57 – 64 GHz band; the changes would dramatically increase the power injected into this band, thus increasing interference for low-power WPAN systems. There are good arguments to oppose the WCA proposal, and this presentation advances those arguments.] Purpose: [Contribution to 802.15 TG3c at July 2005 meeting in San Francisco, California] 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.

2. July 2005 Gary Baldwin, SiBEAM, Incorporated Slide 2 doc.: IEEE 802. 15-05-0442-00-003c Submission The WCA petition basically asks for three things:  A conversion to EIRP instead of Power Density for restrictions on radiated power  An increase in the combined antenna gain and radiated power (EIRP) allowed in the band  Exemption from call ID for point-to-point “window links” mounted indoors What are the issues raised by the WCA petition and presentation?

3. July 2005 Gary Baldwin, SiBEAM, Incorporated Slide 3 doc.: IEEE 802. 15-05-0442-00-003c Submission   Market for an IEEE standard-based consumer product (WPAN) will be considerably larger than that for outdoor point-to-point equipment. Efforts by IEEE to develop a standard attest to this market potential.   WCA objections to limited link distances at 60 GHz can be addressed with the FCC’s opening of the 70 GHz and 80 GHz bands.   Hence, WCA should consider moving to these bands to capitalize on more than 10 GHz of aggregated bandwidth and longer link distances than at 60 GHz.   WCA claims that the proposed rule change will not cause significant potential for interference are problematic.   On the contrary: at the power levels requested, links mounted indoors would exhibit significant interference, both by direct transmission and by reflected radiation from windows. Elements of Letter* in Circulation * IEEE P802.15-05/0308r0

4. July 2005 Gary Baldwin, SiBEAM, Incorporated Slide 4 doc.: IEEE 802. 15-05-0442-00-003c Submission Request for Support of P802.15-05/0308r0   Conversation has taken place off-line to seek compromise.   WCA seems to concur that Call-sign ID is acceptable. The main objection is a 15.255 requirement for field programmability. We should work together to change this; factory installation should be adequate.   WCA seems to join in the belief that power density, measured in the far field in all cases, for all antenna apertures, with extrapolation to other distances using a simple spherical calculation, is acceptable and maintains a level playing field. EIRP is not strictly necessary.   It is the proposal for dramatic increases in EIRP that still remains unresolved.

5. July 2005 Gary Baldwin, SiBEAM, Incorporated Slide 5 doc.: IEEE 802. 15-05-0442-00-003c Submission The issue is this:  Frequency: 60.5 GHz  Aperture efficiency: 50% WCA 15.255 dB Typical WPAN Typical for Point-to-Point Links EIRP “advantage” is really 35 – 45 dB in increased interference WCA claims there is “only” a 13 dB increase in EIRP requested; however... ＜ January. 2005> Doc. ： IEEE802.15-05/054r0,

6. July 2005 Gary Baldwin, SiBEAM, Incorporated Slide 6 doc.: IEEE 802. 15-05-0442-00-003c Submission Request for Support of P802.15-05/0308r0   Conversation has taken place off-line to seek compromise.   WCA seems to concur that Call-sign ID is acceptable. The main objection is a 15.255 requirement for field programmability. We should work together to change this; factory installation should be adequate.   WCA seems to join in the belief that power density, measured in the far field in all cases, for all antenna apertures, with extrapolation to other distances using a simple spherical calculation, is acceptable and maintains a level playing field. EIRP is not strictly necessary.   It is the proposal for dramatic increases in EIRP that still remains unresolved.   While this discussion continues, the WCA should withdraw its petition. WCA declines to do this.   Therefore, as long as this petition remains on the FCC docket, we urge 802.18 to send the letter forwarded from 802.15.3cTG to the FCC, opposing the petition as it now stands.   Thank you!