IEEE 802.11 Regulatory Updates April 2009 doc.: IEEE 802.19-09/xxxxr0 September 2009 IEEE 802.11 Regulatory Updates Date: 2009-09-21 Authors: Rich Kennedy, Research In Motion Rich Kennedy, Research In Motion

April 2009 doc.: IEEE 802.19-09/xxxxr0 September 2009 Abstract This presentation is to provide updates on some of the IEE 802.11 regulatory issues. Rich Kennedy, Research In Motion Rich Kennedy, Research In Motion

Agenda Regulatory summaries Input to ERM TG11 on EN 300 328 v1.8.1 September 2009 Agenda Regulatory summaries North America European Union Asia Input to ERM TG11 on EN 300 328 v1.8.1 Rich Kennedy, Research In Motion

Regulatory Summary – North America September 2009 Regulatory Summary – North America US – Meeting with Julius Knapp Nationwide Broadband Plan Primary focus of OET Multiple NOIs active Defining “Broadband” SmartGrid Technology Fostering Innovation and Investment in the Wireless Communications Market The TV White Spaces Next phase of database definition will open end of September, start of October Response to reconsideration petitions – early 2010 DFS certification – waiting for new test profile from NTIA Canada Mexico Rich Kennedy, Research In Motion

Regulatory Summary – European Union September 2009 Regulatory Summary – European Union ERM TG11 - EN 300 328 revision EU Digital Dividend Consultation (Closed September 4th) WG SE21 - Radar Spurious Emissions EUMETNET asking for relaxation of -100dBc requirement to -60dBc Edgard presented WFA position that EUMETNET request be rejected SE21Chair accepted the input; indicated that the project closes in Sept 2010 WG SE24 - 5GHz RLANs OBA RLAN community has offered to block 5600 – 5650MHz band OBA Final report indicates 5600 – 5650MHz OBA only should be blocked No position taken on terrestrial WLANs in this band Rich Kennedy, Research In Motion

Regulatory Summary - Asia September 2009 Regulatory Summary - Asia No updates at this time Rich Kennedy, Research In Motion

September 2009 Proposal for TG11 For operation under EN 300 328 rules: A technology neutral limit, based on the maximum average transmitted energy during a busy second, and assuming that peak transmit power limits are unchanged 10m W operation under EN 300 440 still allowed Rich Kennedy, Research In Motion

September 2009 Existing Proposal RLAN manufacturers present during the last TG11 meeting clearly stated that the MU approach only works if duty cycle is further restricted in terms of maximum Tx-on time, minimum Tx-off time, max averaging period, etc… as otherwise a single Duty Cycled system can cause continuous interference into an 802.11 RLAN system. In order for 802.11 devices to benefit from duty cycled systems, the following should be respected: Max. Tx-on time: 0.4 mSec Min. Tx-off time: 0.1 mSec Averaging time: 4.0 mSec Maximum duty cycle: 10% Rich Kennedy, Research In Motion

Shortcomings of the Proposal September 2009 Shortcomings of the Proposal While the proposed elements of duty cycle may facilitate sharing with 802.11 devices, it may still be incompatible with other technologies, especially those with modulations that do not use constant transmit power, e.g., W-CDMA systems. Current applications in 2.4 GHz use a wide range of different technologies, each having their own needs w.r.t. maximum Tx-on time and minimum Tx-off time making it impossible to agree on a single set of values that could be beneficial for all technologies. Rich Kennedy, Research In Motion

Alternate Approach September 2009 We should offer a variation of the current formula that we believe will suit not only the short range devices, but also protect devices, like 802.11 devices, that have optimized active sharing mechanism Medium Utilization = Energy in millijoules measured over any 1 second of the complete duty cycle; the limit is MU < 4 millijoules Examples 100 mW for 100 milliseconds (out of 1 second) = 10 millijoules 10 mW for 1 second (DC – 100%) = 10 millijoules Compared to the current agreement, the 4 Millijoules represents a lower threshold, but on the other hand, apart from the measuring period of 1 second, no further restrictions are applied on modulation e.g. the Tx-on time and Tx-off time Joules preferred over ‘Power x Time’ to allow non-constant envelope modulations, or technologies that operate at variable power to benefit from those transmissions where they do not operate at full power. Rich Kennedy, Research In Motion

September 2009 Conclusions We believe that this alternative will enable the provisions of Paragraph 4.3.5 Spectrum Sharing Mechanisms to allow SRDs to operate at higher power limits than the current limits of EN 300 440 without causing unacceptable interference into Wideband Transmission Systems that have depended on EN 300 328 for market access for many years. Rich Kennedy, Research In Motion

ERM TG11 Response Timeline September 2009 ERM TG11 Response Timeline Milestone Date Finalize 802.11/15 position September 14, 2009 Complete REG AHC discussion September 17, 2009 (on REG AHC call) Submit to RR-TAG (802.18) September 21, 2009 Approval by RR-TAG September 22, 2009 (in Hawaii) Submit to ExCom September 24, 2009 ExCom approval 5 day review Submit to ERM TG11 October 5, 2009 Present to ERM TG11 October 12 – 14, 2009 Rich Kennedy, Research In Motion

September 2009 References FCC 09-31 Notice of Inquiry (http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-09-31A1.pdf) http://www.broadband.gov/ FCC 08-260 Second Report and Order and Memorandum and Order (http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-01-260A1.pdf) 18-09-0091-00-0000-ofcom-update-on-the-digital-dividend-cognitive 18-09-0089-00-0000-ofcom-update-on-ddr-cleared-award "Transforming the digital dividend opportunity into social benefits and economic growth in Europe“ (http://ec.europa.eu/information_society/policy/ecomm/radio_spectrum/_document_storage/consultations/2009_digitaldividend/2009_0710_0904_digitaldividendconsultation.pdf ) Rich Kennedy, Research In Motion