Motorola urged FCC to not delay decision on ultra- wideband, sayi...
Motorola urged FCC to not delay decision on ultra- wideband, saying in ex parte filing that it was “unlikely that the Commission will gain any significant new insight into the potential of UWB to interfere by further delaying a…
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decision.” Commission is expected to include UWB item on agenda for Feb. 14 meeting after postponing it at Dec. meeting in deference to request by Commerce Secy. Donald Evans for more time to evaluate issue. Motorola also proposed compromise for UWB limitations, saying it agreed that allowing UWB to operate at Part 15 limits above 5 GHz “while limiting UWB emissions below 5 GHz to levels that are in line with industry-developed standards for protection of services” would strike balance of interests. Motorola said Defense Dept. had backed limiting UWB operation to above 4.2 GHz and coalition of companies, including some wireless carriers, sought limitations on UWB operations to above 6 GHz. Motorola said FCC had to ensure that existing services were protected from potential interference by UWB. “This protection can only be adequately afforded by setting appropriate technical limits rather than trying to construct a complex and unenforceable regulatory structure that severely limits the operational abilities of UWB while still not ensuring adequate protection to existing services,” company said. Equipment manufacturer cited “considerable debate” in UWB docket on correct way to interpret various interference studies submitted to Commission. “One thing should be clear, however: the rights of a Part 15 user should not exceed the rights of the licensed primary user of the spectrum, nor should Part 15 operations be permitted to disrupt a carefully managed radio environment,” Motorola said. Company cited industry standards for protecting PCS services in relation to Part 15 emission limits. It said industry “finds it necessary to protect itself to a level significantly greater than what is required under the Commission’s rules.” That means FCC shouldn’t allow UWB emissions above levels that wireless industry had imposed on itself -- 16-24 dB below Part 15 levels, Motorola said. It said FCC should err on side of protecting GPS and limit emissions in GPS band to 27-35 dB below Part 15 levels, depending on type of UWB emission. Company urged Commission not to rely on “artificial regulatory constraints” such as barring peer-to-peer communications or limiting UWB use to indoors.