1. doc.: IEEE 802.15-10-0962-03-004g Submission December 2010 Khurram Waheed (Freescale)Slide 1 Project: IEEE P802.15 Working Group for Wireless Personal Area Networks (WPANs) Submission Title: [Channel Assignment in 2.4GHz and 868MHz Band] Date Submitted: [December 13, 2010] Last Revision: [January 3, 2011] Source: [Khurram Waheed] Company [Freescale Semiconductor, Inc.] Address [USA] E-Mail:[khurram.waheed@freescale.com] Re: [Supporting IEEE 802.15.4g LB59 Comment Resolution CID’s 34, 569, 570, 649, 650, 651] Abstract:[This spreadsheet reviews the proposed channel assignment in Draft 2 of the IEEE 802.15.4g draft standard and proposes ways to differentiate the assignment in US and the rest of the world for the 2.4GHz Band. ] Purpose:[Supporting Draft 2 Comment Resolution. CID’s 34, 569, 570, 649, 650, 651] 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 802.15-10-0962-03-004g Submission GH requirement in 2.4 GHz Channel for US and the rest of the world December 2010 Khurram Waheed (Freescale)Slide 2

3. doc.: IEEE 802.15-10-0962-03-004g Submission Executive Summary This document studies the regulatory requirements pertaining to the 2.4 GHz (2400 – 2483.5 MHz) band and also looks carefully at how the channel assignment has been done in IEEE 802.11 and IEEE 802.15.4-2006 standards FCC 47 CFR §15.205 (in US) places a stringent requirement (i.e., -41.2 dBm/MHz) on the emission level in 2483.5 – 2500 MHz spectrum Channelization of the complete band in US places impractical phase noise requirements for the radio specification IEEE 802.11 (in US) takes care of this issue by not using (blacklisting) the highest two channels in the band. This restriction does not apply outside of USA and as such the whole band can be used without any restriction. This document proposes solutions regarding the allocation of 2.4GHz in US and rest of the world. Slide 3Khurram Waheed (Freescale) December 2010

4. doc.: IEEE 802.15-10-0962-03-004g Submission Background (Excerpt from d2P802-15-4g_Draft_Standard.pdf) Khurram Waheed (Freescale) December 2010 Slide 4

5. doc.: IEEE 802.15-10-0962-03-004g Submission 802.11 b/g Channel Assignment Channel frequency (MHz) North America Japan Most of world 12412Yes 22417Yes 32422Yes 42427Yes 52432Yes 62437Yes 72442Yes 82447Yes 92452Yes 102457Yes 112462Yes 122467No B B Yes 132472No B B Yes 142484No.11b.11b only C C No Reference: IEEE 802.11-2007 — Table 18-9 ^A^A Earlier, in Spain the only allowable channels were 10-11, and in France 10-13. These restrictions have been removed since, and these countries are currently following the common European policy (channels 1-13). ^B^B In the USA, 802.11 operation in the channels 12 and 13 is actually allowed under low powered conditions. The 2.4 GHz Part 15 band in the US allows spread-spectrum operation as long as the 50-dB bandwidth of the signal is within in the range of 2400-2483.5 MHz [8] which wholly encompasses both channels 12 and 13. A Federal Communications Commission (FCC) document clarifies that only channel 14 is forbidden and furthermore low-power transmitters with low-gain antennas may legally operate in channels 12 and 13. [9] However, channels 12 and 13 are not normally used in order to avoid any potential interference in the adjacent restricted frequency band, 2483.5-2500 MHz [10], which is subject to strict emission limits set out in 47 CFR §15.205 [11]. [8]Federal Communications Commission [9] [10] [11] In Canada, 12 channels are available for use, 11 of which at full power and channel 12's transmit power limited. However, few devices have a method to enable a lower powered channel 12. ^C^C Channel 14 is valid only for DSSS and CCK modes (Clause 18 a.k.a. 802.11b) in Japan. OFDM (i.e. 802.11g) may not be used. (IEEE 802.11-2007 §19.4.2)DSSSCCKa.k.a.802.11bOFDM802.11g Khurram Waheed (Freescale) December 2010 Slide 5

6. doc.: IEEE 802.15-10-0962-03-004g Submission Excerpt from FCC 47 CFR §15.205 Except as shown in paragraph (d) of this section, only spurious emissions are permitted in any of the frequency bands listed below: (b) Except as provided in paragraphs(d) and (e) of this section, the field strength of emissions appearing within these frequency bands shall not exceed the limits shown in § 15.209. Khurram Waheed (Freescale) December 2010 Slide 6

7. doc.: IEEE 802.15-10-0962-03-004g Submission Excerpt from FCC 47 CFR §15.209 § 15.209 Radiated emission limits; general requirements. (a) Except as provided elsewhere in this subpart, the emissions from an intentional radiator shall not exceed the field strength levels specified in the following table: Khurram Waheed (Freescale) This is equivalent to -41.2 dBm/MHz in 2483.5 – 2500 MHz band (see backup slides) December 2010 Slide 7

8. doc.: IEEE 802.15-10-0962-03-004g Submission Channel Assignment in IEEE 802.15.4-2006 5 MHz wide channels Using a formulas as specified in IEEE 802.15.4g/D2, this Implies –GL = 2.5MHz –GH = 1.0 MHz Note, the complete band is channelized irrespective of the FCC regulation. Channel #Center Frequency 112405 122410 132415 142420 152425 162430 172435 182440 192445 202450 212455 222460 232465 242470 252475 262480 Khurram Waheed (Freescale) December 2010 Slide 8

9. doc.: IEEE 802.15-10-0962-03-004g Submission Proposed Option 1: Location agnostic channelization (preferred) Remove the text “For 2.4GHz, GH is 5MHz”. Channelize the complete 2.4GHz band, resulting in a higher number of possible channels Define one set of GL, GH, parameters for each 2.4GHz PHY combination (for details, please refer to P1802.15.4g/D2 or 10/955r0) Blacklist the additional channels in US, by adding a statement in the standard and referring to FCC regulations, i.e., Khurram Waheed (Freescale)Slide 9 December 2010

10. doc.: IEEE 802.15-10-0962-03-004g Submission Table for Proposed Option 1 Khurram Waheed (Freescale)Slide 10 Current Proposed Proposed text (to be added) “Due to strict FCC regulations, no channel using spectrum within 5MHz of the 2483.5 MHz band edge will be used in the USA” OR “For the 2400-2483.5 ISM band, SUN implementations in the USA will not use a channel that encompasses spectral frequencies higher than 2478.5 MHz to avoid violation of FCC regulations” See Slide 18 for the agreed text to be added December 2010

11. doc.: IEEE 802.15-10-0962-03-004g Submission Proposed Option 2: Location aware channelization Remove the text “For 2.4GHz, GH is 5MHz”. Channelize the 2.4GHz band separately for US and the rest of the world This would result in a different number of allocateable channels in the 2.4GHz band for US and the rest of the world Define two separate sets of GL, GH, parameters for each 2.4GHz PHY combination (for details, please refer to P1802.15.4g/D2 or 10/955r0) Khurram Waheed (Freescale)Slide 11 December 2010

12. doc.: IEEE 802.15-10-0962-03-004g Submission Table for Proposed Option 2 Khurram Waheed (Freescale)Slide 12 USA Rest of the World * Need to discuss USA allocation for 2.4GHz OQPSK in USA, if applicable December 2010

13. doc.: IEEE 802.15-10-0962-03-004g Submission Exclusive sub-bands in 868-870 MHz Channel Khurram Waheed (Freescale)Slide 13 December 2010

14. doc.: IEEE 802.15-10-0962-03-004g Submission Background (Comment by Michael Schmidt) Just a few comments with regard to the following documents: * DCN 957 For 868-870 MHz (using SUN PHYs other than MR-O-QPSK), the regulation according to ERC/REC 70-03 and EN300200 seem to be ignored. Here is the list of alarm channels (ERC/REC 70-03 a Annex 7 Alarms) a) 868.6-868.7 MHz 10 mW e.r.p. < 1.0 % duty cycle 25 kHz b) 869.250-869.300 MHz 10 mW e.r.p. < 0.1 % duty cycle 25 kHz c) 869.650-869.700 MHz 25 mW e.r.p. < 10 % duty cycle 25 kHz d) 869.200-869.250 MHz 10 mW e.r.p. < 0.1 % duty cycle 25 kHz Social Alarms e) 869.300-869.400 MHz 10 mW e.r.p. < 1.0 % duty cycle 25 kHz I recommend a table based description for center frequency assignment within 868.0 MHz - 870.0 MHz, avoiding overlap with alarm channels. Khurram Waheed (Freescale)Slide 14 December 2010

15. doc.: IEEE 802.15-10-0962-03-004g Submission Executive Summary The commenter has pointed out the existence of alarm channels in the 868-870 MHz band and proposed a table based approach Steve Jillings pointed out that “ERC 70-03 is purely a recommendation, EN 300 220-1 is the instrument of law”. –However, EN 300-220-1 also defines these spectral exclusions in the band This presentation proposes a channel assignment scheme and the accompanying text, which avoids conflicts with regulatory requirements. Khurram Waheed (Freescale)Slide 15 December 2010

16. doc.: IEEE 802.15-10-0962-03-004g Submission Excerpt from EN 300-220-1 Khurram Waheed (Freescale)Slide 16 ** Refer to table 5 in EN 300- 220-1 for regulatory details on maximum radiated power, channel spacing and spectrum access. December 2010

17. doc.: IEEE 802.15-10-0962-03-004g Submission Excerpt from 10/957r0 The frequency band 868-870 MHz is already excluded from channel assignment using a formula Resolution: Reject; No change required. The section would continue to use a table with 3 entries (Table 3a in IEEE P802.15.4g/D2) for this band To cover the issue of overlapping alarm channels in 863-870 MHz band; see slide 18 for the agreed text to be added to the draft Khurram Waheed (Freescale)Slide 17 BandEdge Low (MHz) BandEdge High (MHz) Width of Band, W (MHz)PHY Mode ChanWidth (MHz) ChanSpacing (MHz) Guard Low, GL (MHz) Guard High, GH (MHz)TotalNumChan min ChanCenterFreq (MHz) Mid Channel mid ChanCenterFreq (MHz) max ChanCenterFreq (MHz) 8688702OQPSKRegulated Channel Center Frequencies from IEEE P802.15.4g/D2 December 2010

18. doc.: IEEE 802.15-10-0962-03-004g Submission Clarification for Other PHYs in 863-870 MHz Band As per the standard, 868-870 MHz is intended only for MR-OQPSK, for which Table 3a specifies the specific center frequencies while avoiding any alarm channels. Spectrally, this band overlaps with the 863-870 MHz band, which supports MR- FSK and MR-OFDM modes. As suggested for the ISM 2.4GHz band in document 10/962r0, my proposal remains to be “region agnostic” and do a contiguous assignment of channels. Blacklisting of channels is an implementation detail, which is region and implementation specific and it is best left for the network implementer to specify to a silicon/SW vendor, as needed. To cover all the exceptions, we can just include one sentence at the end of section stating: “Wherever applicable, SUN allocated channels conflicting with local regulatory requirements should not be used” Alternate Statement (adapted from James Gilb’ proposal): “The availability of SUN channels varies among different regulatory regions. A SUN implementer will need to reference the latest regulations applicable to a local region” Do we need to include any informative text? December 2010 Khurram Waheed (Freescale)Slide 18 Editor’s to use the proposed text with edits if needed.

19. doc.: IEEE 802.15-10-0962-03-004g Submission Backup Slides Khurram Waheed (Freescale)Slide 19 December 2010

20. doc.: IEEE 802.15-10-0962-03-004g SubmissionSlide 20 Channel Numbering Comments CID 34 –As written GL is not defined for the 2.4GHz band. –Proposed text: Add "and GL is ChanSpacing/2" after "5MHz" and before the period, CID 569 –For uniformity, it is best to use the same terminology and the parameters for defining channel numbering for all PHYs CID 570 –To avoid confusion, it is best to include a table of parameters such as BandEdge, GL, GH, Chan Spacing, etc. for all bands in this section CID 649 –Specifying the GL and GH parameters in text is clumsy. –Proposed: Use a table for the GL and GH values for each band. CID 650 –GL and GH need to be specified for the dedicated use bands to arrive at the proper first channel center frequency. CID 651 –The numbering scheme assumes channel width and channel spacing are the same, but they need not be; this might complicate future standard amendments if the numbering scheme has to change again. It would be better if the scheme were more flexible from the outset. The original 15.4 case of 2MHz channel with 5MHz spacing is one example. Khurram Waheed (Freescale) December 2010

21. doc.: IEEE 802.15-10-0962-03-004g Submission Spurious Emission Limit (ITU-R Specification) Frequency band containing the assignment (lower limit exclusive, upper limit inclusive) For any spurious component, the attenuation (mean power within the necessary bandwidth relative to the mean power of the spurious component concerned) shall be at least that specified below and the absolute mean power levels given shall not be exceeded 1 9 kHz to 30 MHz40 dB, 50 mW 2, 3, 4 30 MHz to 235 MHz – mean power above 25 W60 dB, 1 mW 5 – mean power 25 W or less 40 dB, 25  W 235 MHz to 960 MHz – mean power above 25 W60 dB, 20 mW 6, 7 – mean power 25 W or less 40 dB, 25  W 6, 7 960 MHz to 17.7 GHz – mean power above 10 W50 dB, 100 mW 6, 7, 8, 9 – mean power 10 W or less 100  W 6, 7, 8, 9 Above 17.7 GHzThe lowest possible values achievable shall be employed (see Recommendation 66 (Rev.WRC- 2000)*). 1 When checking compliance with the provisions of the Table, it shall be verified that the bandwidth of the measuring equipment is sufficiently wide to accept all significant components of the spurious emission concerned. 2 For mobile transmitters which operate below 30 MHz, any spurious component shall have an attenuation of at least 40 dB without exceeding the value of 200 mW, but every effort should be made to comply with the level of 50 mW wherever practicable. 3 For transmitters of a mean power exceeding 50 kW which can operate on two or more frequencies covering a frequency range approaching an octave or more, while a reduction below 50 mW is not mandatory, a minimum attenuation of 60 dB shall be provided. 4 For hand-portable equipment of mean power less than 5 W, the attenuation shall be 30 dB, but every practicable effort should be made to attain 40 dB attenuation. 5 Administrations may adopt a level of 10 mW provided that harmful interference is not caused. 6 Where several transmitters feed a common antenna or closely spaced antennas on neigh­bouring frequencies, every practicable effort should be made to comply with the levels specified. 7 Since these levels may not provide adequate protection for receiving stations in the radio astronomy and space services, more stringent levels might be considered in each individual case in the light of the geographical position of the stations concerned. 8 These levels are not applicable to systems using digital modulation techniques, but may be used as a guide. Values for these systems may be provided by the relevant ITU ‑ R Recommendations, when available (see Recommendation 66 (Rev.WRC-2000)*). 9 These levels are not applicable to stations in the space services, but the levels of their spurious emissions should be reduced to the lowest possible values compatible with the technical and economic constraints to which the equipment is subject. Values for these systems may be provided by the relevant ITU-R Recommendations, when available (see Recommendation 66 Rev.WRC-2000)*). * Note by the Secretariat: This Recommendation was abrogated by WRC-03. Khurram Waheed (Freescale) December 2010 Slide 21

22. doc.: IEEE 802.15-10-0962-03-004g Submission FCC Regulation Overview (1/2) Ref: ZigBee wireless networks and transceivers; by Shahin Farahani Khurram Waheed (Freescale) December 2010 Slide 22

23. doc.: IEEE 802.15-10-0962-03-004g Submission FCC Regulation Overview (2/2) Ref: ZigBee wireless networks and transceivers; by Shahin Farahani Khurram Waheed (Freescale) December 2010 Slide 23