Response to Active RFID PAR and 5C Comments November 2008 Session

The RFID PAR & 5C are incomplete and should not be approved because: The 5C & PAR incorrectly claim there is no existing international standard The 5C & PAR need to include evidence that there is user demand for yet another RFID standard The 5C & PAR need explain what technical deficiencies of existing systems the proposed standard will address The 5C & PAR needs to provide a better justification of technical feasibility for a unified standard that addresses the requirements of all market segments The 5C & PAR need to acknowledge the use of in this space today and explain why a based solution will be significantly better

The 5C & PAR incorrectly claim there is no existing international standard It is asserted in the 5C that there is a need for an international standard for active RFID, and it is asserted in the PAR that is there in no international standard. However, it appears that this is not true, with the 5C even quoting the number of an ISO standard. There are also other quasi international standards in this space that need to be acknowledged The 5C and PAR need to be modified to correct this error. I suspect what is meant is that there no suitable international standard, but such a statement needs justification.

Draft Response If the commenter is referring to the following international standards; 1) ISO/IEC :2008 Information technology -- Radio frequency identification for item management -- Part 7: Parameters for active air interface communications at 433 MHz. 2) ISO/IEC :2006 Information technology -- Real-time locating systems (RTLS) -- Part 2: 2,4 GHz air interface protocol. 3) ISO/IEC CD (in development) Information technology -- real time locating systems (RTLS) -- Part 5: Chirp Spread Spectrum (CSS) at 2.4 GHz. 4) ISO/IEC Information technology -- Telecommunications and information exchange between systems -- Local and metropolitan area networks -- Specific requirements -- Part 11: Wireless LAN Medium Access Control (MAC) and Physical Layer (PHY) specifications There are several problems with the ISO/IEC standards indicated above : ISO/IEC has high license fees and relatively little adoption (DOD only and they are looking for alternatives) ISO/IEC active RF tags are interrogated by RFID readers, active RF tags do not transmit autonomously. ISO/IEC has limited distance between RFID readers and tags. ISO/IEC MHz band is not globally available. ISO does not meet IEEE Active RFID PAR scope and 5C criteria requirements as stated below.

Draft Response continued " The PHY and MAC scheme parameters must be flexible and configurable to provide optimized use in a variety of active RFID tag operations including simplex and duplex transmission (reader-to- tags and tag-to-readers), multicast (reader to a select group of tags) uni-cast (reader to a single tag), tag-to-tag communication, and multi-hop capability. " The ISO/IEC series of standards are 'simplex' tag beaconing-to-reader Real Time Location Systems (RTLS) and do not meet the IEEE Active RFID PAR scope and 5C criteria requirements as stated above. The ISO/IEC (IEEE ) series of standards do not meet the IEEE Active RFID PAR Scope and 5C criteria requirements for low energy consumption (low-duty-cycle) and multi- hop (tag-to-tag-to-tag) communications. "This project will define the PHY and MAC for Active RFID (readers and tags) in a way that allows for efficient communications with active RFID tags and sensor applications in an autonomous manner in a promiscuous network, using very low energy consumption (low-duty-cycle)..." "The PHY and MAC scheme parameters must be flexible and configurable to provide optimized use in a variety of active RFID tag operations including simplex and duplex transmission (reader-to-tags and tag-to-readers), multicast (reader to a select group of tags) uni-cast (reader to a single tag), tag-to-tag communication, and multi-hop capability."

The 5C & PAR need to include evidence that there is user demand for yet another RFID standard The 5C and PAR asserts that active RFID tags have not been successful so far because there are too many options available, which has reduced interoperability and economies of scale. This may be true However, it is not explained how the development of yet another standard will actually assist solve this problem, particularly in a context where does not have much scale today, certainly in comparison with, say, The 5C and PAR need to be modified to include evidence that there is user demand for yet another standard. Draft Response: There are a few things I would mention here. First, EPCglobal is looking for existing standards which may be ammended to meet EPCglobal Active Tag requirments rather than reinventing the wheel. IEEE 15.4 is the only AIP that meets the requirements of all active tags defined by the EPCglobal Active Tag Joint Requirements Group. Also, what is critical to active tags is power independence. It’s critical to remember that active tags must act as autonomous units that cannot be recharged for ‘years’ is most suitable for this type of tag

The 5C & PAR need explain what technical deficiencies of existing systems the proposed standard will address One reason that would justify a new standard is that all the existing mechanisms are missing functionality from a technical perspective If this is not the case, why not just submit one of the existing mechanisms to EPCGlobal, IEEE or ISO. However, the PAR & 5C does not even address the issue of whether existing systems are technically deficient The PAR & 5C need to be modified to explain what technical deficiencies of existing systems the proposed standard will address Draft Response: The current IEEE standard cannot provide for communications between tags and between tags and readers in an autonoumous manner, meaning without becoming a member of a PAN. " This project will define the PHY and MAC for Active RFID (readers and tags) in a way that allows for efficient communications with active RFID tags and sensor applications in an autonomous manner in a promiscuous network

The 5C & PAR needs to provide a better justification of feasibility for a unified standard that addresses the requirements of all market segments One reason that the active RFID market is segmented today is that each market segment has different requirements However, the 5C and PAR assume that a unified standard can achieve the goals of every market segment Even worse, it bases technical feasibility for the unified standard on an argument that the existing standards are technically feasible The 5C and PAR need to demonstrate technical feasibility for the unified standard, not just a subset Draft Response: The emphasis needs to be changed to show that active tags would take off if there was a single AIP that in essence acts as ‘device neutral’. What is critical is that an AIP be established globally that meets requirements for multiple commercial uses. Examples: sensor integration includes security devices, chemical (environmental) sensors, operational management, location. Companies are looking for one AIP that can be used for multiple purposes without draining the tag power

The 5C & PAR need to acknowledge the use of in this space today and explain why a based solution will be significantly better It is asserted in the 5C that the proposed active RFID functionality is not addressed in any existing 802 standard. However, there is a growing opinion among many in the industry that based systems could dominate this space There are already several start-ups that are showing WiFi based sensor chips with very low power and cost and of course with WiFi you dont require a separate infrastructure. The PAR & 5C need to be modified to recognise the existing use of in the active tag space, and explain why offers significant benefits over The answer should account for the fact that based solutions exist today, whereas based solutions will not exist for some years (5 years?) Draft Response: IEEE does not meet the requirements of an Active RFID tag for tag-to-tag and tag-to reader communications without switching between explicit ad-hoc station-to-station and station-to-AP modes, and low energy consumption which are features of the IEEE and.4a standards. Current Wi-Fi RTLS tags on the market from AeroScout, Ekahau, G2 Microsystems, Pango Networks, WhereNet, etc. do not provide for tag-to-tag communications (beacon only from tag-to-AP) and commonly utilize the IEEE b 1 Mb/s standard which interferes with more recent standard releases such as g (lowest g OFDM bit rate is 6 Mb/s), and n. If Wi-Fi RTLS tags were to utilize the lowest g OFDM bitrate of 6 Mb/s the energy level of the tag would decrease greatly when compared to b and the g RTLS RSSI range would be shorter than b. Lastly, there are no vendors offering any type of tag for global standardization or acceptance in either ISO or EPCglobal.

I'm aware of P1902.1, an RFID project nearing Sponsor ballot. It isn't addressed in PAR 7.1, and it seems to me to have significant overlap in multiple functional areas: low data rate, high density of RFID tags, etc. it would be appropriate to address the differences (which I'm sure there are) when requesting another RFID project. The IEEE P standard, commonly known as RuBee, is in the sponsor ballot stage and expectation is that it will become an IEEE standard in March of IEEE P utilizes the frequency band below 450 KHz, commonly 131 Khz. One of the things not specifically listed in the RFID Study Group's PAR and 5C, but required as part of the EPCglobal active tag specification, is the ability to provide active RTLS which I assume this P standard cannot do due to the frequency in which it is operating. From the P PAR 5.4 Purpose: The purpose of this project is to produce a protocol standard for use in applications where bandwidth is not an issue; but low cost, high tag (client) count, long battery life and use in harsh environments (near steel and water) are key performance criteria.