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

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

3. 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 v1.8.1
Rich Kennedy, Research In Motion

4. 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

5. Regulatory Summary – European Union
September 2009
Regulatory Summary – European Union
ERM TG11 - EN 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

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

7. September 2009
Proposal for TG11
For operation under EN 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 still allowed
Rich Kennedy, Research In Motion

8. 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 RLAN system.
In order for 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

9. Shortcomings of the Proposal
September 2009
Shortcomings of the Proposal
While the proposed elements of duty cycle may facilitate sharing with 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

10. 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 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

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

12. ERM TG11 Response Timeline
September 2009
ERM TG11 Response Timeline
Milestone
Date
Finalize /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

13. September 2009
References
FCC Notice of Inquiry (
FCC Second Report and Order and Memorandum and Order (
ofcom-update-on-the-digital-dividend-cognitive
ofcom-update-on-ddr-cleared-award
"Transforming the digital dividend opportunity into social benefits and economic growth in Europe“ ( )
Rich Kennedy, Research In Motion