Subject: [NEXTEL-1] Aviation groups argue again for UWB equipment authorization withdrawal

From: Marcel <[email-masked]>
Date: Tue, 19 Nov 2002 23:51:05 -0500

http://www.rcrnews.com/cgi-bin/news.pl?newsId=5989

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Aviation groups argue again for UWB equipment authorization withdrawal

Nov. 19, 2002 6:28 PM EST

WASHINGTON-A coalition of airlines, aviation and communications vendors urged the Federal Communications Commission late Tuesday to withdraw the ultra-wideband equipment authorization for Time Domain Corp.

"Nowhere in the opposition does [Time Domain] deny that emissions data on out-of-band must be submitted as part of the equipment authorization application. ... TDC states that its equipment authorization application demonstrates without question that there are no unauthorized emissions emanating from the device. However, TDC's bald assertions are unsupported by actual test data to demonstrate compliance with the rules. ... It is far from clear what the level of emissions actually are between 0.96 and 3.1 GHz because TDC never reports this data, even though such reporting is required by the [FCC's] rules," said the group.

The groups also object to the testing that Time Domain claims the FCC's Office of Engineering and Technology conducted on TDC's device.

"No actual data were placed in the record. OET indicates that it observed out-of-band emissions in the 1227-1536 MHz band, but the emissions were 'relatively narrow-band' and that it only 'intuitively anticipated' that the emissions were due to digital circuitry contained within the device; however, OET cannot know with certainty unless the device is tested. ... Petitioners cannot adequately respond unless the commission shares its 'intuition' with us," said the group.

One of the main disagreements appears to be whether the emissions must come from the antenna to be considered under the UWB rules. Time Domain believes that emissions emanating from the device but not from the antenna should not be considered.

"Any emissions emanating from components of the device intended to generate the UWB emissions are obviously associated with the intentional emissions and, consequently, should not be categorized as unintentional for purposes of the digital circuitry exception," said the groups.

In another UWB development, RCR Wireless News has obtained a letter of objection from the National Aeronautics and Space Administration regarding the ambient noise testing OET conducted over the summer.

"NASA believes that the material presented in the FCC test measurements is not relevant to the questions being posed by the commission in this proceeding. The FCC is attempting to make an illogical, scientifically unsound linkage between incidental, unwanted noise (what the current report addresses) and intentional transmissions filtered to achieve required out of band emission levels (what the UWB first Report & Order addressed). Until such time as 'real world' UWB devices and networks can be laboratory and field tested with respect to potential interference to other authorized services, no changes in current rules regarding UWB should be considered," said David Struba, of the NASA Office of Space Flight.

Comments on the OET tests are due on Friday.

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