Unlicensed Spectrum and Its Future&

M-LMS and Possible Interference Issues in the 902-928 MHz Band

Mark Jarman, President of InovonicsAnd a member of The Part 15 Coalition

June 6, 2013

25+ Years of Unlicensed Use

• 902-928 MHz unlicensed band has enormous societal and economic benefits

• Hundreds of millions of devices, billions of revenue and tax dollars, and many, many jobs

• Applications:– Duress Alarms– Security Systems– Energy Infrastructure management– Telecommunications– ISPs providing broadband access to millions of people

The Installed Base – Hundreds of Millions of Unlicensed Devices on 902-928 MHz

• 100’s of millions of smart grid devices, with 20-year life-spans.

• 10’s of millions of oil and gas monitoring devices.

• Over 10 million emergency duress and alarm devices.

• 100’s of millions of other industrial and consumer devices.

• Hundreds of new equipment authorization grants each year.

Indoor Location – The Next FrontierCisco Systems Eka HauQualcomm AeroscoutMeridan CentrakInovonics Status SolutionsWifarer MeridianMicello CSRPoint Inside MapEverywhereBytelight NokiaAisle411 BuildingLayerPolaris TruePositionMeru Networks

“But accuracy remains a glaring problem for mapping technologies. … A group of indoor mappers is working to fine-tune indoor positioning, although the results are still preliminary and far from ready for a commercial market roll out.”

Over Two-Thirds of These Companies Use Unlicensed Spectrum

Cisco Systems Eka HauQualcomm AeroscoutMeridan CentrakInovonics Status SolutionsWifarer MeridianMicello CSRPoint Inside MapEverywhereBytelight NokiaAisle411 BuildingLayerPolaris TruePositionMeru Networks

M-LMS and Possible Interference Due To Progeny’s FCC Waiver

• FCC waived Section 90.353(g) so Progeny can track the location of both vehicular and non-vehicular mobile devices. Allows for a 5 X increase in allowable power of transmissions.

• Progeny’s mission, as represented thus far, is to augment the indoor location of e911 calls. That’s 911 calls from cellular handsets in urban canyons and urban indoor building spaces. Watch for broader application announcements, and subsequent installations expansions intentions.

902 MHz 928 MHz

The Unlicensed 902-928 MHz Band, FCC Part 15 & Progeny LMS LLC [NextNav]

M-LMSNon M-

LMS

M-LMS

904 909.75 919.75 921.75

Beacon

927.25902 928

Non M-

LMS

Progeny’s licenses

7

4 MHz out of 26 MHz allocated are effectively being “removed” from available spectrum where NextNav gets deployed. That’s greater than 15% reduction, without further consideration for the possible effects on nearby frequencies.

Best available information is that current Progeny technology transmits at 30 watts ERP. Higher density will certainly be needed, and/or possible higher power – maybe even higher duty cycles.

Beacon

Itron/Progeny Test Results 50’ Antenna Ht.

Progeny Test Results

• Testing shows that there will be interference from Progeny operations because of duty cycle, power, & density of transmitters.

• For some Part 15 users, Progeny will preclude co-frequency operation on Progeny’s 4 MHz of spectrum (15% of the band).

• For other wideband Part 15 users, Progeny will preclude operation on much more of the 902-928 MHz band (about 2/3 of the band).

“…about a third of the [location] fixes [using NextNav/Progeny technology] fell inside the

target building,…”

Indoor location requires a minimum density of either receiver or transmitters: For Progeny, sensors receiving signals indoors from at least 3 beacons, and 8 of 10 time slots used outdoors in urban areas, which means an 80-100% duty cycle at each cellular handset / receiver.

CSRIC Excerpts

CSRIC Excerpts

FCC Created Special Protections:1. M-LMS (Progeny’s) License Condition: “the

licensee’s ability to demonstrate through actual field tests that their systems do not cause unacceptable levels of interference to Part 15 devices.” 47 C.F.R. § 90.353(d).

2. Safe harbor: Unlicensed users conforming to specified technical conditions are insulated from claims that such devices cause harmful interference to M-LMS systems. 47 C.F.R. § 90.361.

Part 15 Coalition Members• Landi+Gyr Company• MJ Lynch & Associates LLC• Notor Research• Plantronics• Qualcomm Incorporated• Silver Spring Networks• Starkey Laboratories, Inc.• Utilities Telecom Council• Wireless Internet Service Providers

Association

• Alarm Industry Communications Committee

• American Petroleum Institute• Association of American Railroads• Elster Solutions• FreeWave Technologies, Inc.• GE Digital Energy• Inovonics Wireless Corporation• Intelleflex Corporation• Itron, Inc.

Part 15 Coalition Supporters

• Cisco• E-Z Pass Group• Google Inc.• IEEE 802.11• Kapsch TrafficCom IVHS, Inc.• Microsoft Corporation• New America Foundation• Public Knowledge• Texas Instruments