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[ba-unrev-talk] Intel et. al. regarding Ultra-wideband for license exempt use by revising Part 15 of FCC Rules

The Honorable Michael Powell
Federal Communications Commission
445 12th Street, S.W.
Washington, DC 20554

Re: ET Docket No. 98-153 -- Revision of Part 15 of the Commission's Rules Regarding Ultra-Wideband Transmission Systems
https://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6512975933 >

Ex Parte Communication

Dear Chairman Powell:
As technology companies that share an interest in using ultra-wideband (UWB) technology in our products, we are writing you regarding the Commission's removal of the ultra-wideband (UWB) item from its December 12, 2001, open meeting agenda. We appreciate your commitment to resolve the process in February. We are concerned that a short delay could be extended, which in turn would be a substantial setback to the timely development and deployment of UWB services. This could have a negative impact on current industry momentum focused on building UWB technology and products.

This proceeding is more than three years old with almost 800 comments, notices, and technical studies on the docket. UWB proponents have filed detailed technical analyses showing that operation of their devices will not cause harmful interference to other users of the spectrum, both government and non-government. These analyses also explain why studies that purport to show harmful interference gave incorrect results. It is time to issue a decision.

The prompt adoption of rules is necessary not only to bring the benefits of this technology to consumers, but also to respond constructively to increasing interest from the military in UWB technology as reflected by the recent DARPA NETEX BAA. We urge you to issue the UWB report and order at the earliest possible date, and no later than the date indicated at your open meeting.

Respectfully submitted,

Kevin C. Kahn, Intel Fellow, Director, Communications & Interconnect Technology Lab, Intel Corp.
Steven W. Stewart, Director, Public Affairs, IBM Corporation
John K. Boidock, Vice President, Government Relations, Texas Instruments
Dr. Ken Gray, Director, Multimedia Communications Dept., Sharp Labs of America
Gregg Ward, Vice President, Government Relations, Siemens Corporation

cc: Commissioner Kathleen Q. Abernathy
Commissioner Michael J. Copps
Commissioner Kevin J. Martin

December 14, 2001
Ms. Magalie Roman Salas
Federal Communications Commission
445 12th St., S.W.
Washington, DC 20554

Re: Summary of Oral Ex Parte Presentation Concerning Ultra-Wide Band Deployment (ET Docket No. 98-153, filed electronically)

Dear Ms. Salas:
On December 13, 2001, Mr. Joel Wiginton (Vice President, Government Affairs) and Mr. John Godfrey (Senior Manager, Government Affairs) held an ex parte meeting with Mr. Paul Margie of the Office of Commissioner Michael Copps to discuss Sony Electronics, Inc.'s support for regulatory approval for commercial deployment of Ultra-Wide Band technology. The attached statement accurately summarizes the detailed substance of the meeting.

With sincere regards,
John Godfrey
Senior Manager, Government Affairs
Sony Electronics, Inc.

Sony Electronics, Inc.'s Support for Regulatory Approval of Ultra-Wide Band (UWB) Radio Commercial Deployment
Ex Parte Presentation Regarding ET Docket No. 98-153

December 13, 2001

As a leader in the field of consumer and professional electronic devices, Sony Electronics has been studying the advantages offered by UWB. We have determined that UWB technology has the potential for creating innovative and beneficial new applications involving wireless communications which could greatly enhance the flexibility and satisfaction enjoyed by consumers and professionals when using multimedia devices in business, home, and personal networks.

We are enthusiastic about exploring UWB for use in our products.
We are particularly interested in wireless data technologies with these features:
• high data rates for audio and video communications
• low power and sizes for portable applications
• low costs for mass market products

When UWB comes to the commercial market, we have every intention of exploring it to confirm it has these features and is appropriate for our products. What we have seen so far is very encouraging. However, it is not possible to explore the technology fully and realistically until commercial deployment is permitted.

The FCC can make a reasonable decision with the currently available data.
We believe there is sufficient information in the record to make an immediate decision permitting commercial deployment under rules that provide for both protection of incumbents and a valuable opportunity for new technology deployment. The potential value for data communications is much higher if peer-to-peer and outdoor uses are permitted.
• Banning peer-to-peer use would preclude many potentially valuable consumer and professional applications (e.g., handheld to laptop PC; mobile phone to laptop; camcorder to laptop; digital camera to mobile phone).
• Banning outdoor data communications would preclude many professional applications (e.g., news and sports coverage, video surveillance).

Permitting deployment of UWB is good public policy.
Deployment could enable a new, entrepreneurial U.S. industry to form and grow. Moreover, it could stimulate the electronics sector in general as new applications are enabled. Finally, it could enable more efficient use of spectrum, a long-standing goal of U.S. policy-makers.

NASA's Entomopters Project
What is an Entomopter?
• An Entomopter is a flying vehicle that generates lift in a fashion similar to that of an insect.
• It is based on a present DARPA program to develop micro- aircraft (on Earth) with flight characteristics like those of insects (flapping wings).
• Mars flight would be in the same flight Reynolds number regime experienced by large insects on Earth.
• Extremely high potential lift generation capability (C L ~ 5.0)
• Context, particularly location, is an important source of information for human-computer interaction.
• The communications scheme is based on ultra- wideband (UWB) technology.
– UWB emits rapid sequencing of extremely short (< 1ns) wideband (> 1 GHz) low power bursts of radio frequency energy.
• UWB system will reduce power, mass and volume over conventional communications systems.
– Analysis has predicted that data can be transferred over a 10 mile range at a T1 rate on 56 mW of average power.
• UWB system is software controlled and reconfigurable in real time to perform different functions as needed.

UWB can be simultaneously used for a number of tasks:
• High rate digital communications between one or more of the Entomopters and the lander or rover.
• Precise position control between the Entomopters and surface or obstacles.
• In- flight collision avoidance radar imaging.
• Timing synchronization between Entomopters.

More info ......
A communications scheme based on Ultra-Wideband (UWB) technology appears to be the best choice for the entomopter vehicle. The information in this section was provided through a written report supplied by Marc Seibert of NASA Glenn Research Center. [26]
Communications are integral to successful space missions. It is imperative that communications be reliable, robust, and ensure that science is returned from the mission. For high rate communications, UWB impulse trains can be modulated many different ways with information, possibly even adaptively throughout the mission as terrain and other signal propagation factors surface. No UWB modulation techniques are yet approved for terrestrial use (except under certain DoD/NTIA agreements), but several companies including Multispectral Solutions, Inc., Anro Engineering, Aetherwire, Inc. and Time Domain, Incorporated have already developed and are testing UWB-based systems, anticipating limited approval for public use by the Federal Communications Commission [27]. In the future, such systems may be used for wireless computer and voice networks, voice communications, geolocation of “anything” on Earth, and asset tracking (via RF tags) and inter-object positioning. If UWB is approved for public use in quantities, the benefits of the technology will become readily apparent. Future 4 th or 5 th generation cellular systems may be developed with this technology, enabling low-power “watch phones.” One UWB wireless network implementation already on the bench has been called “Bluetooth on Steroids.”

UWB technology is based on the process of emitting rapid sequences of extremely short (<1ns), wideband (>1GHz), and extremely low power impulses or “bursts” of radio frequency (RF) energy for a host of desired purposes. UWB waveforms have been used for a variety of classified and unclassified military applications, including independent applications for high-rate communications, intercraft and geo-positioning and/or proximity fuzes, collision avoidance for aerial vehicles, and a variety of imaging, radar, and even electromagnetic pulse warfare systems. UWB impulses are the fundamental element at the core of each of these implementations, and we believe that amultifunctional subsystem could be fabricated and used by one or more manner to perform many functions with the single subsystem with accompanying antennae [28].

UWB is an attractive technology for potentially providing Entomopter missions. The benefits of this technology are listed below and shown in the diagram in Figure 30.

1. High-rate digital communications between one or more Entomopters and a lander vehicle
2. Precise positioning information between Entomopters,
3. In-flight collision avoidance radar imaging, and precise intercraft timing synchronization

Among all the applications for which UWB has been a core technology, none of the systems appear to combine more than two functions into a single UWB subsystem. The only space mission known to make use of UWB technology was the Apollo 17 mission in
1967 to the moon, which included a “Ground Penetrating UWB Radar,” used to characterize the lunar regolith. More recently, newer dual-use UWB subsystems have emerged for terrestrial applications, which are strongly convincing, that a single software controlled

UWB micro-impulse system could be developed that can:
1. perform all four of the functions listed above concurrently using the same hardware
2. require significantly less power, mass and physical space than conventional systems in use, and
3. be reconfigured in real-time to perform these functions, even autonomously, by the vehicles carrying the system.

Unique space flight vehicles such as the Mars entomopter require flexible and hybrid technologies such as a multifunction UWB subsystem to achieve the tight mission architecture goals driving the mission, and effectively make use of precious power and
mass budget resources.

The UWB hardware onboard the entomopter will be capable of producing a variety of impulse shapes and frames, and will be software controlled. A master communications and navigation controller onboard the entomopter would continuously reconfigure UWB
hardware autonomously and “on the fly” as shown in Figure 18. Upon command or at predefined times, the communications and navigation (COMM/NAV) subsystem will issue periodic impulses that could be coded to simultaneously monitor the location of the ground, and inform the lander of it’s current geo/space-physical position (in three dimensions). The COMM/NAV subsystem will also process returns from collision-avoidance impulses, and additional impulses will be issued to improve the system’s understanding of the size of an obstacle, and so on. Also throughout the mission, specific impulse frames will be filled with communications information back to the lander (or other entomopters) such as buffered images, meteorological data, entomopter health status, and other types of mission and flight coordination data.

Groups of entomopters may need to hover in formation (depending on the mission), in which case the multifunction UWB subsystem would be used to coordinate the formation flight and synchronize measurement timings. Most importantly, the entomopter itself
would autonomously request the use of the impulse energy in whatever ways necessary – imaging, communications, positioning or radar. Intelligent and autonomous flight dynamics must be considered and integrated into the control algorithms for the
COMM/NAV subsystem as well.

To illustrate the low power benefits of the technology, consider the UWB data transmission system example in Figure 32. This high-quality channel analysis was performed by MSSI, Inc. and represents a “reverse-link” in a mobile communications system and is an “uncoded” channel. The link would communicate up to 10 miles, and operate on only 56mW of average power (14.5W peak). Because of the duty cycle requirements of this link, the example above is 14 times more power efficient (11.5dB) than a typical current commercial device and the UWB system can transmit 10 miles at T1 data rates. In most communications circles these power figures are especially small, considering the range and quality of the channel. Error correction coding used extensively in space and other critical communications can further improve the performance of this channel (potentially to 10 -7 or better). Note that this scenario only illustrates the “reverse” link from the entomopter. The reason for this is because this portion of the link is considered the most power-critical, and has the highest bandwidth requirement, therefore it is most advantageous to illustrate the benefits of UWB in this portion of the link. The same antennae would be used at the lander and entomopter for a “forward” communications link (to the entomopter), potentially at even higher data rates if mission parameters require. [27]

Figure 32 shows very conservative numbers for antenna gains and expected bit errors (without forward-error correction coding), yet provides for a very high bandwidth link from the entomopter to the lander. The true bandwidth requirements for the reverse link
must be defined by the actual mission parameters and the number of science data collection modules being carried onboard. For example, an entomopter carrying four active digital video cameras would require a higher bandwidth reverse communications link than would be required for an entomopter carrying only meteorological sensors. On the specific aerial system developed by MSSI, Inc. for communications and collision avoidance, a UWB transmitter was fitted to an RC Helicopter. In the flight configuration, the UWB system measured 3" x 4" x 5" with a weight of 27.9 oz. The company notes that this was about twice the volume necessary for the circuit boards used, the chassis was much heavier than needed, and that the UWB boards alone weigh only a few ounces. In terms of performance, the system operated between 5.4 and 6.0 GHz, only required 0.2 Watts peak power (which can be increased significantly if necessary). A 0.025” wire was detected in flight at 300’. The example shown constitutes typical UWB performance characteristics for existing UWB communications systems. For an entomopter mission to Mars such specifications would be revisited, potentially resulting in increased link performance. In short, mission mass and power budget restrictions directly affect the bandwidth capability of UWB communications, and especially for communications, so UWB technology would greatly benefit a Mars mission.

Location Determination
For precise positioning applications, impulse trains can provide extremely precise positioning accuracies (<cm) at appreciable distances [28]. All mission vehicles could be programmed to regularly issue generic “I am here” type messages (even while solar charging on the ground), or, every impulse transmission from each vehicle could be processed by the lander and analyzed in time to compute the physical position of the “talker” at the instant it is “talking.” Using the first technique may constitute a more reliable means for locating vehicles, however, the second technique is the most bandwidth efficient since no extra impulses would be issued strictly for one purpose. Communications impulse energy could be analyzed for both information content and spatial origination. Figure 33 illustrates from a plan (top view) perspective how the antennae on one entomopter and the lander could locate each other in 3-dimensions.

Radar Collision Avoidance
To suit radar, collision avoidance, and potentially “synthetic vision,” requirements in flight, the same types of impulses can be used to accurately measure scattered components in an environment better than conventional radar. UWB technology has been used for decades for ground-penetrating radar, and one company is even able to locate striations of gold 20 feet into rock. Dolphins naturally emit echolocation impulses similar to UWB waveforms to navigate in unclear waters, and have even located a meal buried a several feet under a sandy sea bottom. UWB radar also has the capability to “range gate” impulse returns, enabling them to ignore returns from close objects (like a wall, boulder, etc) and effectively “see through” these objects to image the environment on the other side.

UWB collision avoidance systems have already been employed in support of DARPA’s Micro Air Vehicle (MAV) program, at least one company demonstrating a capability for an autonomous flying vehicle to detect and avoid objects as small as a 0.25” wire in the
flight path. This technology could be enhanced to provide an autonomous flight vehicle with this capability, as well as a real-time synthetic view of the environment in any direction, and avoidance of other vehicles in flight. With additional special processing,
such a system could be used in conjunction with the intercraft positioning processing to synchronize formation or cluster flight arrangements, and so on. Distributed Timing, Intercraft Synchronization and Marking Experiment Events in Flight For precise intercraft timing, a multifunction UWB subsystem can provide the means for intercraft synchronization and for experiment marking events. Similar to the techniques discussed above for communications and positioning, special impulse protocols could be used to announce an impending mark event, trigger entomopter flight coordination events, and broadcast distributed event measurement timing. For example, imagine four entomopters used to measure upper atmosphere oxygen content in four different physical locations simultaneously. The lander master controller would designate one of the entomopters as lead timing vehicle, and distribute mission parameters to the vehicles in one broadcast or independently. The lead entomopter would autonomously synchronize timing between the vehicles (in a manner yet to be determined), then coordinate assembly of the proper formation for the experiment and initiate the measurement gathering activity.

This type of experiment autonomy obviously relies on other navigational control capabilities in the entomopter as well, but a multifunction UWB subsystem may enable such complicated autonomy that these systems require. A basic messaging scheme an
entomopter master controller and the COMM/NAV subsystem would also be required to facilitate such autonomy.