january 2005 abbie mathew, newlans slide 1 ieee 802.15-05/054r0 submission project: ieee p802.15...

January 2005January 2005

Abbie Mathew, NewLANSAbbie Mathew, NewLANSSlide Slide 11

IEEE 802.15-05/054r0IEEE 802.15-05/054r0

SubmissioSubmissionn

Project: IEEE P802.15 Working Group for Wireless Personal Area NetworksProject: IEEE P802.15 Working Group for Wireless Personal Area Networks

Submission Title: [WCA’s petition to the FCC for amendment to part 15.255]Date Submitted: [January 17, 2005]Source: [Abbie Mathew] Company [NewLANS, Inc.]Address [238 Littleton Road, Westford, MA 01886-3531, U.S.A.]Voice: [(617) 283-1363], E-Mail: [[email protected]]

Re: []

Abstract: [Update on WCA’s petition to the FCC for amendment to Part 15.255]

Purpose: [Contribution to 802.15 SG3c at January 2005 plenary in Monterey, CA]

Notice: This document has been prepared to assist the IEEE P802.15. It is offered as a basis for discussion and is not binding on the contributing individual(s) or organization(s). The material in this document is subject to change in form and content after further study. The contributor(s) reserve(s) the right to add, amend or withdraw material contained herein.Release: The contributor acknowledges and accepts that this contribution becomes the property of IEEE and may be made publicly available by P802.15.



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


Existing Rules in Part 15.255Existing Rules in Part 15.255

InterferenceInterference

Average power density ≤ 9 Average power density ≤ 9 W/cmW/cm22 at 3 m at 3 m• Translates to EIRP of 40 dBm in the far fieldTranslates to EIRP of 40 dBm in the far field

Peak power density ≤ 18 Peak power density ≤ 18 W/cmW/cm22 at 3 m at 3 m• Translates to an EIRP of 43 dBm in the far fieldTranslates to an EIRP of 43 dBm in the far field

Total peak transmitter power ≤ 500 mWTotal peak transmitter power ≤ 500 mW

RF RadiationRF Radiation

Power density ≤ 1 mW/cmPower density ≤ 1 mW/cm22 on antenna surface on antenna surface

Transmitter IdentificationTransmitter Identification

Within any 1 second interval of signal transmission, each transmitter Within any 1 second interval of signal transmission, each transmitter

must transmit a transmitter identification at least onemust transmit a transmitter identification at least one



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


Near Field & Far FieldNear Field & Far Field

Aperture Aperture , cm, cm ~ Gain, dBi~ Gain, dBi ~ ~ ӨӨ3dB3dB Near Field, cmNear Field, cm Far Field, cmFar Field, cm

22 19.019.0 18.3º18.3º 2.02.0 4.84.8

77 29.929.9 5.2º5.2º 24.724.7 59.359.3

88 31.131.1 4.6º4.6º 32.332.3 77.477.4

1515 36.536.5 2.4º2.4º 113.4113.4 272.3272.3

1616 37.137.1 2.3º2.3º 129.1129.1 309.8309.8

2424 40.640.6 1.5º1.5º 290.4290.4 697.0697.0

2525 41.041.0 1.5º1.5º 315.1315.1 756.3756.3

6161 48.748.7 0.6º0.6º 1,876.01,876.0 4,502.44,502.4

RNF = D2/4 RFF = 0.6 D2/

Transition Region

Frequency = 60.5 GHz, Aperture Efficiency = 50%



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


EIRP Based on Part 15.255EIRP Based on Part 15.255

Aperture Aperture ~ Gain~ Gain Average Average EIRPEIRP

Input Input Power Power

SSSS S at 3mS at 3m Location Location of 3mof 3m

cmcm dBidBi dBmdBm dBmdBm mW/cmmW/cm22 W/cmW/cm22

22 19.019.0 18.018.0 -1.0-1.0 1.01.0 0.070.07 FFFF

77 29.929.9 39.839.8 9.89.8 1.01.0 8.378.37 FFFF

88 31.131.1 40.040.0 8.98.9 0.60.6 9.009.00 FFFF

1515 36.536.5 40.040.0 3.53.5 0.10.1 9.009.00 FFFF

1616 37.137.1 40.340.3 3.23.2 00 9.009.00 TRTR

2424 40.640.6 43.943.9 3.23.2 00 9.009.00 TRTR

2525 41.041.0 44.444.4 3.43.4 00 9.009.00 NFNF

6161 48.748.7 59.959.9 11.211.2 00 9.009.00 NFNF

Frequency = 60.5 GHz Aperture Efficiency = 50%



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


WCA’s Case # 1WCA’s Case # 1

“measurements taken within an antenna near-field can vary significantly based on very small changes in the sampling location. ”

“..the near field for a high gain antenna typically extends beyond the 3-meter point, so there is little correlation between 3-meter PD measurements and the level of RF exposure near the antenna..”

“The sum of the above is that transmitters using high gain antennas in the 57-64 GHz band are forced to operate at PD levels far below those permitted under the Commission’s current RF safety limits. This, in turn, forces vendors to reduce transmit power levels well below the maximum peak power permitted in Section 15.255(e) (27 dBm), thereby reducing link distance substantially.“



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


Alternative Suggested By WCA

• Limit average EIRP to 82 dBm at antenna gain Limit average EIRP to 82 dBm at antenna gain of 51 dBiof 51 dBi

• Limit average EIRP to 82 dBm minus 2 dB/dBi, Limit average EIRP to 82 dBm minus 2 dB/dBi, below 51 dBi gainbelow 51 dBi gain

• Power density will be at or below 1 mW/cmPower density will be at or below 1 mW/cm22 on on the antenna surfacethe antenna surface

EIRP = 82 dBm for Gain > 51 dBi

EIRP = [(2 * Gain) – 20] dBm for Gain ≤ 51 dBi



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


WCA’s Case # 2WCA’s Case # 2

“…which imposes a transmitter identification (ID) requirement on indoor

antennas used at 57-64 GHz. The purpose of the rule is to permit users

experiencing interference from indoor wireless LAN transmitters to

more accurately identify where the interference is coming from. The

rule thus applies to the transmitter ID requirement to transmission that

emanate from inside a building. Unfortunately, there remains some

confusion over whether the rule’s exclusion of outdoor antennas also

excludes antennas located indoors but directed outside a window,

commonly referred to as ‘window links.’ WCA believes it is reasonable

to assume that the Commission did not intend to apply the rule to

window links, since they effectively pose no greater interference risk

than outdoor links.”



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


Alternative Suggested By WCA

“…WCA therefore asks that the Commission

eliminate any lingering uncertainty about this issue

by modifying Section 15.255(i) to clarify that the

rule’s transmitter ID requirement does not apply to

indoor antennas that direct point-to-point

transmissions outside through a window.”



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


Summary Of The PetitionSummary Of The Petition

-10

0

10

20

30

40

50

60

70

80

0 10 20 30 40 50 60

Antenna Aperture, cm

~ Gain, dBi

Average EIRP, dBm

Average Pin, dBm

Average EIRP, dBm

Average Pin, dBm

Frequency: 60.5 GHz Aperture efficiency: 50%

WCA

15.255



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


Proposed Rule Change # 1Proposed Rule Change # 1

Replace 15.255(b)(1) with the following text (new matter in red font)

(1) For products other than fixed field disturbance sensors, at least one of the following limits must be met:

(i) The average power density of any emission, measured during the transmit interval, shall not exceed 9W/cm2, as measured 3 m from the radiating structure, and the peak power density of any emission shall not exceed 18W/cm2, as measured 3 m from the radiating structure.

(ii) The average EIRP of any transmitter, measured during the transmit interval, shall be limited to the value of 82 dBm reduced by a factor of 2 dB for every dB that the transmit antenna far field gain is less than 51 dBi.



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


Proposed Rule Change # 2Proposed Rule Change # 2

Insert language into the first sentence of 15.225(i) as follows.

(i) For all transmissions that emanate from inside a building, except for point-to-point transmissions that are directed outside through a window, within any one second interval of signal transmissions,…



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


ConcernsConcerns

• Two guidelinesTwo guidelines• Reflections from window links with WCA’s Reflections from window links with WCA’s

petition petition



IEEE 802.15-05/054r0IEEE 802.15-05/054r0


Proposed ActionProposed Action

• Review the petitionReview the petition• Determine if WCA’s petition affects 802.15.3cDetermine if WCA’s petition affects 802.15.3c• If it affects 802.15.3c, write our opinion to the If it affects 802.15.3c, write our opinion to the

FCCFCC

• FCC is expected to make a ruling this quarterFCC is expected to make a ruling this quarter• Discuss this issue at Monterey and not postpone Discuss this issue at Monterey and not postpone

itit

january 2005 abbie mathew, newlans slide 1 ieee 802.15-05/054r0 submission project: ieee p802.15...

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