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Unlicensed to KillA Brief History of the Part
15 Rules

• Kenneth R. CarterSenior Consultantwik-Consult
  GmbH
• THE GENESIS OF UNLICENSED WIRELESS POLICY
• An Information Economy Project Conference
  George Mason University School of Law
• April 4, 2008

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Agenda

• Unlicensed Rules Generally
• The History of the Part 15 Rules
• Origins of the Rules Governing Unlicensed Devices
• The Evolution of the Part 15 Rules
• More Room for Unlicensed Operation Into the
  Future
• Spectrum Policy Lessons from Its History

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Unlicensed OperationNo such thing as Unlicensed
Spectrum

• Low Power Operation without a User License
• No Vested Right to Continued Operation
• May Not Cause Harmful Interference
• Must Accept Any Interference
• Must Cease Operation if Notified by FCC that
  Device is Causing Harmful Interference
• Must Receive Equipment Authorization before
  Marketing/Importation

No, Mister Bond, I expect you to accept all
harmful interference.
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Types of Part 15 Devices

• Unintentional Radiators devices that generate RF
  energy internally, or sends RF signals to
  associated equipment via connecting wiring, but
  which are not intended to radiate RF energy
  through the air. Examples include computer CPU
  boards and power supplies. The components and
  enclosures of these devices must be shielded
  sufficiently to limit the amount of RF energy
  that escapes.
• Incidental Radiators devices, like electric
  motors, that generate radio frequency energy
  during the course of operation although the
  devices are not intentionally designed to
  generate or emit RF energy.
• Intentional Radiators devices that intentionally
  generate and emit RF energy by radiation or
  induction.

Now Ive got to get all these certificated.
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Charting Unlicensed Devices
RF Devices Part 15
Intentional Radiators Subpart C
U-NII Subpart E
UWB Subpart F
Low Power Transmitters
U-PCS Subpart D
Garage Door
RFIDs
Spread Spectrum
Motorola Canopy
Cordless Phones
802.11b 802.11g
802.11a
Blue- Tooth
Wi-Fi
ISM Part 18
HomePlug
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History

• Everything leaks RF energy
• FCC Chief Engineer, Ewell Jett in 1938 No
  interference no engineering reason for
  suppressing their use.
• No such thing as unlicensed spectrum
• Creation of field strength in 1955
• Westward migration new bands opened.
• Bands congested
• Higher frequencies available
• Each new technology required rulemaking

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Part 15 Timeline
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Coordinated vs. Uncoordinated Spectrum Access
Regimes
Coordinated Spectrum Access Uncoordinated Spectrum Access
Features Centralized base stations and terminals time slots higher power Distributed radio devices only collision avoidance lower power
Advantages Handles congestion well Low overhead cost at high utilization rates Low overhead cost at low utilization rates No coordination across standards
Disadvantages High overhead and opportunity costs at low utilization Requires coordination across standards Higher barriers to entry High congestion costs No ability to exclude

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FCC Enforcement Case Load 2000 -2003
Unlicensed operators are well behaved spectrum
users.
Total Case Load 39,771
0.16 of Total Case Load
Source Enforcement Bureau, FCC
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Summary

• Not spectrum, just policy
• Address engineering concerns
• Regulate emissions characteristics
• Manufacturers have wide latitude and flexibility
  in devices and services
• One size does not fit all - there are a variety
  of approaches.
• Markets are good servants, but poor masters
• Balance among stability, flexibility, and
  development

Comes complete with sidewinders, smokescreen,
ejection seat, and Bluetooth.
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Thank you
I ? Pussy Galore
Alpha is a Greek letter ALFA is an Italian car
Id rather be spying
My other car is a jetpack.
Its not a midlife crisisIts a childhood
fantasy.
I break for supervillains.
When rayguns are outlawed, only outlaws will have
rayguns
Ernst Stavro Blofeld 08
wik-Consult GmbH Tel [phone]
k.carter_at_wik-consult.comFax 49 (0)
2224-9225-2224 www. wik-consult.com
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