SPECTRUM WARS 2002 The FCCs RF Lighting Proceeding

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SPECTRUM WARS 2002 The FCC’s RF Lighting Proceeding (ET Docket 98 -42) Robert D.

SPECTRUM WARS 2002 The FCC’s RF Lighting Proceeding (ET Docket 98 -42) Robert D. Primosch, Esq. Wilkinson Barker Knauer, LLP Washington, D. C. robert. [email protected] com

What is RF Lighting? • Devices that produce light by using RF energy to

What is RF Lighting? • Devices that produce light by using RF energy to stimulate gases contained inside a lamp • Utilized to light large commercial areas (warehouses, parking lots, shopping malls, etc. ) • Regulated under Part 18 of the FCC’s Rules. • Fusion Lighting: high-power RF lamp for commercial use that operates in the 2400 -2500 MHz band (the “ISM” band). • Affected Parties: SDARS (2320 -2345 GHz) and Part 15 License Exempt (2. 4 GHz)

Why Is It Important? • High-Power, Ubiquitous, Outdoor Device • Reflects growing regulatory tension

Why Is It Important? • High-Power, Ubiquitous, Outdoor Device • Reflects growing regulatory tension between licensed and license-exempt services • Raises fundamental issues of what levels of interference are unacceptable, and who pays for it

Timeline • 1985: FCC classifies RF lighting devices as Part 18 ISM equipment •

Timeline • 1985: FCC classifies RF lighting devices as Part 18 ISM equipment • 4/9/98: FCC releases NPRM in ET Docket No. 98 -42: • Two types of devices: GE Lamp (2. 2 and 2. 8 MHz) and Fusion Lighting (2. 4 GHz) • FCC proposes to relax line-conducted emission limits and adopt radiated emission limits above 1 GHz • 1/21/99: Fusion Lighting and Part 15 interests ask for delay re: rules for non-consumer RF lighting devices • 6/16/99: First Report and Order – FCC defers action on nonconsumer RF lighting devices • 2/29/00: Fusion Lighting files Petition for Further Rulemaking

What’s On the Table • Issue: Appropriate out-of-band emission limits for Fusion Lighting devices

What’s On the Table • Issue: Appropriate out-of-band emission limits for Fusion Lighting devices • Current Limit: 71 d. Bu V/m @ 3 M • FCC Proposal: 54 d. Bu V/m @3 M (85% reduction from current limit) • Fusion Lighting: 44 d. Bu V/m @ 3 M (95% reduction), plus “safe harbor” • SDARS: 18. 7 d. Bu V/M @ 3 M

What’s On The Table (cont’d) • Issue: In-Band Limits to Protect Part 15 Operations

What’s On The Table (cont’d) • Issue: In-Band Limits to Protect Part 15 Operations • Bluetooth: Limit RF Lighting “pollution” to top one-third of 2. 4 GHz band • Part 15 Interests: • 2400 -2460 MHz: 10 m. V/m @ 3 M • 2460 -2480 MHz: 330 m. V/m @ 3 M • 2480 -2500 MHz: 10 m. V/m @ 3 M

Going Forward. . . • 5/14/02: Fusion Lighting Proposes “Real World” Testing Procedures •

Going Forward. . . • 5/14/02: Fusion Lighting Proposes “Real World” Testing Procedures • SDARS Has Committed to Renewed Joint Testing

What to Look For • Post-UWB Approach to Interference: less reliance on “worst case”

What to Look For • Post-UWB Approach to Interference: less reliance on “worst case” analysis • Who pays? Is it the responsibility of the party receiving the interference to design better receivers? • Treatment of “safe harbor” issue • Relationship to other licensed vs. licenseexempt proceedings