1. January 2005 Abbie Mathew, NewLANS Slide 1 IEEE 802.15-05/054r0 Submission Project: IEEE P802.15 Working Group for Wireless Personal Area Networks Submission Title: [WCA’s petition to the FCC for amendment to part 15.255] Date Submitted: [January 17, 2005] Source: [Abbie Mathew] Company [NewLANS, Inc.] Address [238 Littleton Road, Westford, MA 01886-3531, U.S.A.] Voice: [(617) 283-1363], E-Mail: [amathew@newlans.com] Re: [] Abstract: [Update on WCA’s petition to the FCC for amendment to Part 15.255] Purpose:[Contribution to 802.15 SG3c at January 2005 plenary in Monterey, CA] 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. January 2005 Abbie Mathew, NewLANS Slide 2 IEEE 802.15-05/054r0 Submission Existing Rules in Part 15.255 Interference  Average power density ≤ 9  W/cm 2 at 3 m Translates to EIRP of 40 dBm in the far fieldTranslates to EIRP of 40 dBm in the far field  Peak power density ≤ 18  W/cm 2 at 3 m Translates to an EIRP of 43 dBm in the far fieldTranslates to an EIRP of 43 dBm in the far field  Total peak transmitter power ≤ 500 mW RF Radiation  Power density ≤ 1 mW/cm 2 on antenna surface Transmitter Identification  Within any 1 second interval of signal transmission, each transmitter must transmit a transmitter identification at least one

3. January 2005 Abbie Mathew, NewLANS Slide 3 IEEE 802.15-05/054r0 Submission Near Field & Far Field Aperture , cm ~ Gain, dBi ~ Ө 3dB Near Field, cm Far Field, cm 219.018.3º2.04.8 729.95.2º24.759.3 831.14.6º32.377.4 1536.52.4º113.4272.3 1637.12.3º129.1309.8 2440.61.5º290.4697.0 2541.01.5º315.1756.3 6148.70.6º1,876.04,502.4 R NF = D 2 /4 R FF = 0.6 D 2 / Transition Region Frequency = 60.5 GHz, Aperture Efficiency = 50%

4. January 2005 Abbie Mathew, NewLANS Slide 4 IEEE 802.15-05/054r0 Submission EIRP Based on Part 15.255 Aperture  ~ Gain Average EIRP Input Power SSSSSSSS S at 3m Location of 3m cmdBidBmdBm mW/cm 2  W/cm 2 219.018.01.00.07FF 729.939.89.81.08.37FF 831.140.08.90.69.00FF 1536.540.03.50.19.00FF 1637.140.33.209.00TR 2440.643.93.209.00TR 2541.044.43.409.00NF 6148.759.911.209.00NF  Frequency = 60.5 GHz  Aperture Efficiency = 50%

5. January 2005 Abbie Mathew, NewLANS Slide 5 IEEE 802.15-05/054r0 Submission WCA’s Case # 1  “measurements taken within an antenna near-field can vary significantly based on very small changes in the sampling location. ”  “..the near field for a high gain antenna typically extends beyond the 3-meter point, so there is little correlation between 3-meter PD measurements and the level of RF exposure near the antenna..”  “The sum of the above is that transmitters using high gain antennas in the 57-64 GHz band are forced to operate at PD levels far below those permitted under the Commission’s current RF safety limits. This, in turn, forces vendors to reduce transmit power levels well below the maximum peak power permitted in Section 15.255(e) (27 dBm), thereby reducing link distance substantially.“

6. January 2005 Abbie Mathew, NewLANS Slide 6 IEEE 802.15-05/054r0 Submission Alternative Suggested By WCA Limit average EIRP to 82 dBm at antenna gain of 51 dBiLimit average EIRP to 82 dBm at antenna gain of 51 dBi Limit average EIRP to 82 dBm minus 2 dB/dBi, below 51 dBi gainLimit average EIRP to 82 dBm minus 2 dB/dBi, below 51 dBi gain Power density will be at or below 1 mW/cm 2 on the antenna surfacePower density will be at or below 1 mW/cm 2 on the antenna surface EIRP = 82 dBm for Gain > 51 dBi EIRP = [(2 * Gain) – 20] dBm for Gain ≤ 51 dBi

7. January 2005 Abbie Mathew, NewLANS Slide 7 IEEE 802.15-05/054r0 Submission WCA’s Case # 2 “…which imposes a transmitter identification (ID) requirement on indoor antennas used at 57-64 GHz. The purpose of the rule is to permit users experiencing interference from indoor wireless LAN transmitters to more accurately identify where the interference is coming from. The rule thus applies to the transmitter ID requirement to transmission that emanate from inside a building. Unfortunately, there remains some confusion over whether the rule’s exclusion of outdoor antennas also excludes antennas located indoors but directed outside a window, commonly referred to as ‘window links.’ WCA believes it is reasonable to assume that the Commission did not intend to apply the rule to window links, since they effectively pose no greater interference risk than outdoor links.”

8. January 2005 Abbie Mathew, NewLANS Slide 8 IEEE 802.15-05/054r0 Submission Alternative Suggested By WCA “…WCA therefore asks that the Commission eliminate any lingering uncertainty about this issue by modifying Section 15.255(i) to clarify that the rule’s transmitter ID requirement does not apply to indoor antennas that direct point-to-point transmissions outside through a window.”

9. January 2005 Abbie Mathew, NewLANS Slide 9 IEEE 802.15-05/054r0 Submission Summary Of The Petition  Frequency: 60.5 GHz  Aperture efficiency: 50% WCA 15.255

10. January 2005 Abbie Mathew, NewLANS Slide 10 IEEE 802.15-05/054r0 Submission Proposed Rule Change # 1 Replace 15.255(b)(1) with the following text (new matter in red font) (1) For products other than fixed field disturbance sensors, at least one of the following limits must be met: (i)The average power density of any emission, measured during the transmit interval, shall not exceed 9  W/cm 2, as measured 3 m from the radiating structure, and the peak power density of any emission shall not exceed 18  W/cm 2, as measured 3 m from the radiating structure. (ii)The average EIRP of any transmitter, measured during the transmit interval, shall be limited to the value of 82 dBm reduced by a factor of 2 dB for every dB that the transmit antenna far field gain is less than 51 dBi.

11. January 2005 Abbie Mathew, NewLANS Slide 11 IEEE 802.15-05/054r0 Submission Proposed Rule Change # 2 Insert language into the first sentence of 15.225(i) as follows. (i)For all transmissions that emanate from inside a building, except for point-to-point transmissions that are directed outside through a window, within any one second interval of signal transmissions,…

12. January 2005 Abbie Mathew, NewLANS Slide 12 IEEE 802.15-05/054r0 Submission Concerns Two guidelinesTwo guidelines Reflections from window links with WCA’s petitionReflections from window links with WCA’s petition

13. January 2005 Abbie Mathew, NewLANS Slide 13 IEEE 802.15-05/054r0 Submission Proposed Action Review the petitionReview the petition Determine if WCA’s petition affects 802.15.3cDetermine if WCA’s petition affects 802.15.3c If it affects 802.15.3c, write our opinion to the FCCIf it affects 802.15.3c, write our opinion to the FCC FCC is expected to make a ruling this quarterFCC is expected to make a ruling this quarter Discuss this issue at Monterey and not postpone itDiscuss this issue at Monterey and not postpone it