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Update: New and Changing Rules
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In
the past several months, regulatory changes worldwide have
affected wireless devices. These changes include new regulations
for new technologies, updates to current regulations, and
the postponed implementation of another. Several other regulatory
changes that will affect wireless are waiting in the wings
as well. This article examines global regulatory changes
that affect the design of wireless devices. Since it was
originally written, it has been updated to reflect changes
from the last three months.
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| Table I. New conducted-emissions limits for Part 15 and Part 18 devices. |
UWB. With the adoption of NPRM 99-231, FCC has created a new section F under Part 15. These new rules can be downloaded from the FCC Web site. They will appear in the next revision of CFR 47, which will be released sometime this year.
The UWB regulations divide devices into specific categories such as indoor operation, handheld operation, vehicle radar, imaging systems, etc. Looking at the requirements for a handheld UWB device, the FCC regulations specify the following requirements for a UWB:
• The UWB bandwidth of a device operating under the provisions of this section must be contained between 3100 and 10,600 MHz.
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| Table II. Under Part 15, section F, radiated emissions above 960 MHz must not exceed the limits as shown. |
• The radiated emissions at or below 960 MHz from a device operating under the provisions of this section shall not exceed the emission levels in Section 15.209 of this chapter. The radiated emissions above 960 MHz from a device operating under the provisions of this section shall not exceed the average limits shown in Table II when measured using a resolution bandwidth of 1 MHz.
• In addition to the radiated-emissions limits specified in Table II, UWB transmitters operating under the provisions of this section shall not exceed the average limits shown in Table III when measured using a resolution bandwidth of no less than 1 kHz.
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| Table III. UWB transmitters must not exceed average limits when measured using a resolution bandwidth of no less than 1 kHz. |
After releasing the order, FCC found itself in the hot seat with Congress. FCC expected questions for approving the changes despite concerns of the National Telecommunications and Information Administration (NTIA) and the Department of Defense (DoD). Rather, FCC had to explain why it approved the allowance only for a low power—a move that could stifle the technology. According to the Report and Order, FCC plans to revisit this rulemaking to address the power levels and other concerns.
On February 13, just about one year from the date when the commission established the original UWB rules, FCC denied the requests of the petitioners that sought further restrictions on UWB technology. FCC will conduct additional studies as this technology rolls out to determine whether further modifications are needed. It should be noted, however, that FCC did make slight modifications in the Part F rules addressing low pulse-repetition-frequency UWB systems and imaging systems used by law enforcement.
Spread Spectrum. In May 2002, FCC adopted the final rules for Part 15.247, specifically addressing digital transmission systems (DTS) and updates to frequency-hopping systems. Before the final release of this rule, systems operating as 2.4 GHz DTS were limited to 100 mW. The final rules require DTS to operate as direct-sequence spread-spectrum (DSSS) systems with conducted output power of 1 W. In addition, FCC removed the requirement for processing gain for DTS as well as DSSS.
Frequency-hopping systems operating at a 5 MHz bandwidth are limited to 125 mW conducted power. The use of adaptive hopping is not mandatory under these final regulations.
As part of this ruling, FCC decided that proposed limits for Part 15 devices was not part of the scope of the rule. The petition for these limits was filed by Sirius Satellite Radio (New York City) and XM Satellite Radio (Washington, DC). FCC further stated that before these proposed limits could be addressed, the petitioners must provide documentation of actual interference. The petitioners must also demonstrate that reducing out-of-band spurious emissions would be the only practical solution.
Biennial Part 15 Review. FCC should take some action on both NPRM 01-278 and 02-312 in future rulemakings. It appears that FCC will divide NPRM 01-278 into two parts.3 The first issue to be addressed will be the receiver emissions of radar detectors operating above 1 GHz. Although currently exempt from meeting emissions levels above 960 MHz, in some cases these receivers have caused interference to licensed services. The second part of the biennial review should be released around late summer or early fall 2003. This part will update requirements for labeling. New rules allow the manufacturers to provide manuals—including FCC information—on- line only. This part of the review may also allow Part 15.231(a) products to send or receive data. It is also expected that FCC will address tighter out-of-band emissions in response to a second Sirius petition.
Under NPRM 02-312, FCC also opened up the Part 15 rules yet again to remove outdated rule parts. Industry responded to this, specifically asking FCC to address the connector issue in Part 15.203 and the integral-antenna issue in Part 15.407(d). Industry also asked FCC to accept the use of the CISPR 22 test methodology, including the use of ferrite clamps. FCC plans to address these issues in future rulemakings.
Other FCC Issues. FCC has initiated proceedings to address unlicensed technology use in the 71–76, 81–86, and 92–95 GHz bands.4 FCC believes these bands could be used for both unlicensed and licensed services. The agency is seeking comments on its proposed rules for these bands.
FCC has moved the requirements for Part 100 (digital broadcast services) to Part 25 of the rules. Part 25 deals with satellite systems, and FCC believes that DBS is best served under that rule part. This change eliminates the Part 100 regulations that addressed DBS.
FCC has issued a Public Notice for comments on future spectrum issues. The notice asks a series of questions to start a dialogue with industry on spectrum issues going forward. FCC will hold a series of workshops later this summer to discuss the comments.
FCC released the long-awaited TCB exclusion list. The list is extremely simple to use, and it basically allows TCBs to certify most radio products, including those that deal with specific absorption rate (SAR) issues.
FCC also issued several interesting Technical Opinions. The first opinion allows the use of a biconical antenna to test transmitters whose fundamental frequency is operating at 27 MHz. FCC will allow use of a biconical antenna as long as it is calibrated down to 20 MHz. The second ruling of interest (although not surprising) is that FCC does allow a 0-dBm Bluetooth device to be approved under Part 15.249 of the rules, as well as under Part 15.247 of the rules.
China
Recently, the Chinese Ministry of Information Industry (MII) announced that it would delay implementation of its proposed SAR standard. This delay was due to industry pressure on the agency. The proposed standard included SAR levels tighter than those of other internationally or nationally recognized standards.
The MII proposal called for a SAR level of 1 W/kg, much stricter than that required by the International Electrotechnical Commission or the Federal Communications Commission (FCC). OET Bulletin 65C requires 1.6 W/kg, and the international standard allows a level of 2 W/kg. With input from industry recommending harmonized levels, MII announced that the standard would not be implemented until further studies are done.
China has recently proposed opening up the 5.8 GHz band for wireless local-area network (WLAN) operation. The operation parameters are to be more in line with international standards than the parameters that China adopted for the 2.4 GHz band.
France and UK Public Consultations
Both France and the UK have completed public inquiries into allowing 2.4 and 5 GHz WLAN to provide public connection to the Internet. After reviewing the comments from industry, it appears both countries are willing to adopt rules that allow this option to provide connection to the Internet. The agencies involved are France's Autorité de Régulation des Télécommunications (ART) and the UK Radio Communications Agency. Under the current rules, fee-for-connection broadband access could not be offered via the 2.4 or 5 GHz WLAN systems in those countries.
Japan
Japan is considering allocating part of the 4.9 GHz band for outdoor WLAN use. Under the proposal, the following bands may be allocated:5
• 4.90 to 5.0 GHz (2004).
• 5.03 to 5.091 GHz.
For outdoor use, transmitter power would be 250 mW. Only licensed operators would be able to set up access points. Japan has proposed the following three channel schemes:
• 20 MHz channels.
• 10 MHz channel spacing (proposed).
• 5 MHz channel spacing (proposed).
Future Issues
FCC has released its Spectrum Policy Task Force report and has issued several Notice of Inquiries (NOIs) based on the report. These notices include one on rural broadband access and one on opening up more unlicensed spectrum below 900 MHz and at 3650–3700 MHz. There may be an NOI on receiver specifications in the works as well. FCC is preparing an NPRM on opening up the 5470–5725 MHz band for WLAN operation. This change is in response to the recently reached U.S. position on dynamic frequency-selection thresholds developed by the U.S. working group addressing World Radio Conference (WRC) issues (see Table IV).
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| Table IV. New DFS thresholds and other parameters. |
Even as these issues are resolved for wireless devices, new ones are just over the horizon. The Italian government is in the early stages of considering a similar proposal to the one approved by France and the UK. Italy would be the third EU country to allow public connection to the Internet via WLAN as a subscriber service. In the United States, it is rumored that FCC is working on an NPRM that will address radio-frequency (RF) exposure, including issues for devices that operate under Part 15.247. One issue examines how to address RF exposure for radio modules classified as portable devices.
Obviously, the public notice on spectrum issues should facilitate changes or future NPRMs from FCC. A parallel study in Canada should also generate new proposals in the band.
Another hot issue is the preparation for World Radio Conference 2003 (WRC-03). This conference is scheduled for June 9–July 4 in Geneva, Switzerland. The agenda for WRC-03 addresses many critical wireless issues. Information on the WRC-03 preparation work group is available on the FCC International Bureau Web site (http://www.fcc.gov/ib/) or on the ITU-R Web site (http://www.itu.int/ITU-R/).
Conclusion
The changes or proposed changes for wireless technologies seem to be constant. Many changes are in store for wired devices too. For example, FCC has extended comments on issues such as broadband proceedings via cable access, E-911, and the Communications Assistance to Law Enforcement Act (CALEA). Regulations are constantly in a state of flux, giving designers new opportunities as well as solving old challenges.
References
1. FCC Report and Order, UWB, February 14, 2002.
2. FCC NPRM 99-231, Spread Spectrum, August 8, 2000.
3. FCC NPRM 01-278, Biennial Review, October 15, 2001.
4. FCC NPRM 02-142, Opening Up the 71 GHz Band, 2002.
5. Kazuhiro Okanoue, "5 GHz Band Usages in Japan," NEC Japan, May 2002.
David A. Case, NCE, NCT, is senior radio compliance engineer for Cisco Systems Corporate Compliance Operations and EMC Standards Group (Akron, OH). He can be reached via e-mail at davecase@cisco.com.