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NTIA expressed concerns last week to FCC that without appropriate...

NTIA expressed concerns last week to FCC that without appropriate safeguards in proposal for use of software defined radio (SDR), “this flexibility may lead to unauthorized spectrum usage.” NTIA submitted comments on notice of proposed rulemaking (NPRM) adopted by…

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FCC (CD Dec 8 p1) that would streamline equipment approval processes. SDR technology allows wireless phones to receive intelligence from software rather than hardware, meaning radios can be changed quickly to transmit on different frequencies and in different formats. NPRM proposes SDR definition as transmitter for which operating parameters, including frequency range and modulation type, could be altered in software without making hardware changes. Proposal would streamline equipment certification procedures so that new operating parameters could be set via software without relabeling equipment already in field. NTIA said FCC had proposed that changes in frequency, power and modulation type of SDR could be authorized as new class of permissive change, called Class 3. FCC proposed that Class 3 permissive changes be made only to equipment in which no hardware changes have been made in original device. “NTIA does believe that, in order to verify that after the modifications authorized under a Class III permissive change, the SDR still remains compliant with the Commission’s operating and service rules… the combination of the hardware and the software modification must be reauthorized.” NTIA said proposal wasn’t clear on whether all possible combinations of installed software must be tested or whether it was sufficient to test each waveform separately. NTIA recommended that, in coordination with SDR industry, FCC examine security features that could be used to prevent unauthorized modifications that could change SDR compliance. SDR Forum said it backed NPRM and sought quick adoption of rules. As for tentative conclusion that radio software and hardware should be approved in combination, forum said that as technology advances, it might make sense to test them separately, Forum said. “Testing numerous versions of software with many versions of the underlying radio equipment could become burdensome,” Forum said, and combined testing would make sense until manufacturers and FCC had acquired more experience with technology. Among recommendations in its comments are that FCC: (1) Revise SDR definition to recognize software changes that affect both desired and undesired emissions and to permit hardware changes that don’t affect emissions of either type. (2) Not require declaration that radio is SDR at time of original equipment authorization. (3) State clearly that Class II permissive change is required only when undesired emission are degraded.