1. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 1 Project: IEEE P802.15 Working Group for Wireless Personal Area Networks (WPANs) Submission Title: Draft Proposal for correction to IEEE 802.15.6 MICS/MedRadio band to support world-wide regulatory changes in this band (to be formally submitted during sponsor ballot) Date Submitted: 16 - Sep, 2010 Source: Peter Bradley, Zarlink Semiconductor Re: Future sponsor ballot comment – support for complete MedRadio to align with current world- wide regulations Abstract:This document proposes corrections for the Narrowband PHY section due to worldwide regulatory changes that support expansion of the core MICS band (402-405 MHz) to a new band termed MedRadio Band from (401-406) MHz. Purpose:For discussion by IEEE 802.15 TG6 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. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 2 MICS/MedRadio Issue Regulatory inconsistency issue: –The FCC established in Mar-2009 the MedRadio Service as documented in FCC Report and Order FCC-09-23. –“By this Report and Order, we establish a new Medical Device Radiocommunication Service (MedRadio Service) under Part 95 of the Commission’s rules.1 This new service incorporates the existing Medical Implant Communications Service (MICS) “core” band at 402-405 MHz, and also includes two megahertz of newly designated spectrum in the adjacent “wing” bands at 401-402 MHz and 405-406 MHz. Altogether, the MedRadio Service will provide a total of five megahertz of contiguous spectrum on a secondary basis and non-interference basis for advanced wireless medical radiocommunication devices used for diagnostic and therapeutic purposes in humans. The MedRadio Service will accommodate the operation of body-worn as well as implanted medical devices, including those using either listen-before-talk (“LBT”) frequency monitoring or non- LBT spectrum access methods, in designated portions of the 401-406 MHz band” –Similar approval of the MedRadio Service has occurred in Europe and internationally –IEEE 802.15.6 band definitions and channel requirements reference the original core MICS band only and should be updated to conform fully to current regulations –This is a significant oversight that should be corrected to enable successful implementation of 802.15.6 in medical implant and external sensor applications. –The use of 802.15.6 compliant third-party external sensors or therapeutic devices networked to medical implants using MedRadio may be considered one of the stronger cases for implementing an interoperable system within a medical implant system. Proposed Resolution to Issue: –Modifications as documented in attached slides.

3. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 3

4. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 4 About MedRadio Expansion of core MICS band (402-405 MHz) by adding 1 MHz “wing” bands 401-402 MHz and 405-406 MHz –May be used by implanted or medical body worn device –20 x 100 KHz channels Industry saw a need for additional spectrum for medical devices (both implant and body-worn) and filed a petition for rulemaking with the FCC in July 2005 requesting additional spectrum Granted in March 2009 by FCC report and order FCC-09-23 with significant industry support Follows earlier standardization in Europe (ETSI) and elsewhere so that MedRadio is now essentially internationally harmonized.

5. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 5 MedRadio Benefits MedRadio provides 2 key additional benefits over the core MICS 1) More channels for Implants systems –An additional 20x100 kHz channels may be used for implants –Similar LBT rules as for the core MICS 300 kHz channels –Future implant systems will want access to this additional spectrum 2) Supports medical body-worn systems –Simplified external node that can communicate using a single band to both implants and external devices –Useful for external sensors, control systems, therapy devices (e.g. implantable blood glucose sensor with external pump system, –Future medical body-worn systems will want access to this additional spectrum Successful uptake of 802.15.6 within implant and body-worn systems operating in the region 401-406 MHz will require that 802.15.6 fully support the spectrum available with MedRadio.

6. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 6 MedRadio Benefits From FCC report and order: –“ This additional spectrum is urgently needed due to the increasing numbers and types of devices used for an ever-increasing array of diagnostic and therapeutic purposes. Indeed, no commenter opposed designating this additional spectrum in the wing bands for these purposes.” –“ we believe that the additional spectrum and enhanced flexibility afforded in the new rules will promote the accelerated development of newer generations of advanced medical device technologies. These advances, in turn, will herald dramatic improvements in therapeutic/diagnostic patient care and quality of life for countless individuals ”

7. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 7 MedRadio Permissible Communications Similar requirements as MICS – –under direction of health care professional –Non-voice data FCC§ 95.1209 Permissible communications. (a) Except for the purposes of testing and for demonstrations to health care professionals, MedRadio programmer/control transmitters may transmit only non-voice data containing operational, diagnostic and therapeutic information associated with a medical implant device or medical body-worn device that has been implanted or placed on the person by or under the direction of a duly authorized health care professional. “The term “duly authorized health care professional” means a physician or other individual authorized under state or federal law to provide health care services. Operations that comply with the requirements of this part may be conducted under manual or automatic control.” Medical body-worn device. Apparatus that is placed on or in close proximity to the human body (e.g.,within a few centimeters) for the purpose of performing diagnostic or therapeutic functions.

8. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 8 MICS/MedRadio Change Discussion Most of the changes to IEEE 802.15.6 are based on a simple scaling from 300 kHz MICS core channels to 100 kHz wing channels. Use identical methods as previously employed to derive sensitivity, ACPR etc

9. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 9 Proposed Channelization Additional 18 channels x 100 kHz channels Guardbanding for tx emission regulatory requirements –ETSI - MICS into MEDS –FCC - mobile satellite 406-406.1 MHz

10. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 10 Band and Channel Modifications Proposed Modification –Add (401-402 and 405-406) to introduction section 9 “A compliant device shall be able to support transmission and reception in one of the following frequency bands: (401-402 and 405-406) MHz, 402 – 405 MHz, 420 – 450 MHz, 863 – 870 MHz, 902 – 928 MHz, 950 – 956 MHz, 2360 – 2400 5 MHz and 2400 – 2483.5 MHz.” –Add (401-402 and 405-406) MHz to beginning of list in section 9.5.1 –Add row to Table 42, to define channel numbering 401-402,405-406 f c =401.075+0.05 x g 1 (n c )(MHz), n c =0,…,19 Discussion –The band and channel plan supports devices falling into several categories –(a) Implant systems with support for core MICS band (402-405) MHz –(b) Implant systems with support for wing bands (401-402 and 405-406) MHz –(c) Implant systems with support for both core MICS and wing bands –(d) Body-worn devices with support for wing bands

11. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 11 Data Rate Considerations Data Rate Selection considerations –Ideally scale MICS data rate by factor of 3 corresponding to BW ratio = 187.5/3= 62.5 kbps –Low data rate limits Frequency offset should not be very much greater than 25% of symbol rate Too low a data rate increases packet length which is undesirable –High data rate limits Maximum for reasonable spectrum usage is 62.5 kbps consistent with other bands –Clock generation 62.5 ksps is simple translation by a factor of 3from the 187500 kbps used for MICS Same available clocks for sampling (2,4,8,16 samples/symbol) Other alternatives are 50 ksps and 46.875 ksps but these may be problematic for large frequency offsets

12. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 12 Data Rate Modifications Packet ComponentModulation Symbol Rate (ksps) Code Rate (k,n) Spreading FactorPulse Shape Information Data Rate (kbps)Support PLCP Headerπ/2-DBPSK62.519/31*2SRRC19.2Mandatory PSDUπ/2-DBPSK62.551/632SRRC25.3Mandatory PSDU π/2-DBPSK62.551/631SRRC50.6Mandatory PSDU π/4-DQPSK62.551/631SRRC101.2Mandatory PSDU π/8-D8PSK62.551/631SRRC151.8Optional Proposed Modification: –Add new section 9.1.1 401-402 and 405-406 MHz Add new table in this section which is a copy of table 26 except for –Symbol rate changed from 187.5 to 62.5 –All information data rates reduced by a factor of 3 –Add column to Table 36 with first 4 rows filled by 25.3, 50.6, 101.2 and 151.8 and next 4 rows are “Reserved”, Column header is “ (401-402 and 405-406) MHz” –Consideration for dropping the spreading factor of 2 is under review

13. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 13 Transmit BW, Power and ACPR Modifications (THIS SECTION IS STILL UNDER REVIEW) Proposed Modification –‘Add row to table 46 for channel bandwidth specification “401-402 and 405-406-20100 kHz” –Modify first sentence of section 9.7.2 Transmit Power “A transmitter shall be capable of transmitting at least –10 dBm EIRP in all frequency bands, except for 401 – 406 MHz, where a transmitter shall be capable of transmitting at most –16 dBm EIRP” –Add row to table 48, “401-402,405-406” with -26 dB for node and -32 dB for hub Discussion –Since implants may use the wing-bands we apply the same ACPR requirements as per the core MICS.

14. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 14 Proposed Modification –Add rows to table 49 as follows: Discussion: –Expected improvement in sensitivity by going from 300 kHz for MICS to 100 kHz channel is 4.7 dB, Round down to 4 dB delta from the 402-405 MHz Receiver Sensitivity Modifications Frequency Band (MHz) Information Data Rate (kbps) Minimum Sensitivity (dB) 401-402 and25.3-102 405-40650.6-99 101.2-96 151.8-90

15. doc.: IEEE 802.15-10-0802-00-0006. Submission Sept 2010 Peter Bradley, Zarlink SemiconductorSlide 15 Proposed Modification –Add 401-402 and 405-406 to first row of table 50 (cell currently containing 402-405) Discussion –ACR calculated as per previous calculations: ACR was previously determined by combination of (i) phase noise limited reciprocal mixing assuming a phase noise of -85 dBc/Hz at fc+fbw and (ii) a fixed term for ACPR, other noise sources When compared with core MICS, the phase noise for 100 kHz wing band channels may increase; assuming a 20dB/decade phase noise profile the phase noise could potentially increase from -85 dBc/Hz to -75 dBc/Hz from 300 kHz to 100 kHz. This does appear like a lax phase noise specification. If we assume -80 dBc/Hz then the calculated ACR is identical to the core MICS. So recommend this approach Adjacent Channel Rejection Modifications