RADAR MANUFACTURERS CONCERNED ABOUT LIMITS IN UWB ORDER

In March 8 letter, Kerry said companies that were expressing concerns about impact of order provided geophysical services that aided in location of underground storage tanks and utilities and located structural deficiencies in infrastructure such as highways and bridges. Dennis Johnson, pres. of GPR manufacturer Geophysical Survey Systems Inc. (GSSI), said most of GSSI’s U.S. customers were small companies that provided services to larger corporate customers and govt. agencies. In some cases, hotels are using GPR as they upgrade with fiber cable for Internet access, Johnson said. GPR is used before holes are drilled in walls to ensure that tension cables aren’t broken, he said.

Johnson said he and other GPR manufacturers would like to have GPR emissions measured as spurious rather than intentional under FCC rules. “The unusual thing about us or other GPRs is that we're the only transmitters that I'm aware of where the intention is to transmit into the ground and not the air,” he said. Johnson said he would like to see rules tailored to GPR that would characterize devices as spurious transmitters that would be covered by existing Part 15 Class B rules. GSSI, which in past has conducted UWB project for Denver International Airport, has told FCC that it had sold UWB-based GPR without federal govt. waiver for years. Johnson told us company’s GPR transmitters, “with few exceptions,” had fallen within requirements of Part 15 Class B restrictions. He said 20% of GSSI sales were to govt. agencies and that company had been GSA supplier since 1984, with customers that included “every branch of the military.” Johnson said one concern was that differences between GPR and other types of UWB systems be taken into account.

FCC has said it plans, after collecting data on UWB deployment, to reassess restrictions in 6-12 months to ascertain areas whether they may be too restrictive or may need to be strengthened. One source said pending rule didn’t appear to have precluded any particular applications for GPR devices, which can operate in number of different frequencies and by their nature operate across wide swathe of bands. Most uses that FCC was made aware of during period leading up to UWB vote operated below 1 GHz. Only handful of types identified in docket had unique applications that would put them above that line, source said.

Several GPR industry officials said that although they were awaiting final text of order, they were concerned that, based on tight limits described in summary documents released by Commission, many of their applications would be precluded. Kutrubes said that while GPR industry itself was composed largely of small companies, they often served larger client bases such as law enforcement offices or federal agencies. “For us, [rule] eliminates useful applications like detecting voice beneath concrete structures, holes under runways and deteriorated concrete bridge decks,” Kutrubes said. She said she had heard concerns from customers such as Mass. State Police and state medical examiner’s office that frequencies used to find things such as broken patches embedded in concrete couldn’t be used under new rules. Realistically, Kutrubes said, her company’s GPR systems couldn’t be used successfully above 1.5 GHz.

“Looking back at the discussions that we had as we were going through this process we always wanted to enable as many ultra-wideband applications as we safely could and that included the ground penetrating radars,” NTIA Deputy Dir. Michael Gallagher said. He said he could speak about press release on FCC’s UWB decision but not on UWB order itself, which hasn’t been released yet. He said that between 960 MHz and 3.1 GHz, spurious emissions from GPR devices had to meet same emissions mask as other UWB devices. “In between there are critical aviation and radar functions as well as GPS that needed to be protected,” Gallagher said. “We are all going to continue to learn as we go forward with the testing and deployment of ultra-wideband technology. The FCC’s order, as expressed in the press release, clearly is forward-looking. There will be ample opportunities for parties to clarify the technical issues.” He said one issue that emerged in discussions between govt. and industry was that there were shielding and improved ground coupling techniques that could be used to reduce spurious emissions between 960 MHz and 3.1 GHz. “It’s a bit premature for people to be saying that the order is flawed when it’s not public yet -- that process is moving along,” he told us.

Infrasense’s Maser cited recent cancellation of request for proposals by Federal Highway Administration (FHWA) as signal that in some cases FCC order was having early impact. In Jan., FHWA solicited contract proposals for 20-year study of pavement performance using GPR technology. It said goal of study was to “provide the data necessary to explain how pavements perform and why they perform as they do.” Several sources said that because of specialized nature of work, small number of companies were in running to carry out study, which called for use of antennas in pavement that operated at or around 1 GHz. Day after FCC approved UWB order Feb. 14, FHWA cancelled RFP, citing pending changes under Part 15. “Under the changes, GPR will be restricted to operating below 960 MHz or between 3.1-10.6 GHz,” FHWA said. “Should these forthcoming FCC regulations be revised, FHWA anticipates re- issuing the subject RFP,” cancellation notice said.

One problem with ban on GPR operation between 960 MHz and 3.1 GHz is that “we can’t use frequencies above 3.1 GHz because we are dealing with earth materials,” Kutrubes said. “It eliminates useful applications like detecting voices beneath concrete structures,” she said. Below 960 MHz, “we would not have sufficient resolution.” Radar Solutions International and Infrasense are among companies that are considering filing petition for reconsideration once FCC order is released, but organizers said they wouldn’t make any final decisions until seeing text of order.