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15 of theR)  X -Commission's Rules Regarding SpreadR)hET Docket No. 968  X-Spectrum TransmittersR)hRM8435, RM8608, RM8609  X-  REPORT AND ORDER  X-(Proceeding Terminated) TP  XQ -X` hp x (#%'0*,.8135@8:Para. (# '(# `  Xk-J'bI.xINTRODUCTIONZ"(#R1 '(# `'(#  X=-Jo'^II.xBACKGROUNDZ"(#H26  X-J,'ZIII.xDISCUSSIONZ!(#B769  X-'(#'` (#`J''iA.` ` HIGH GAIN DIRECTIONAL ANTENNASZ!(#B721  X-'` (#`' (#J''iJ` 1. Directional antenna gain limitsZ!(#B715  X-J''iJ` 2. Output power reduction in the 2400 MHz bandZU!(#<1617  X-J''iJ` 3. Ratio of horizontal and vertical antenna beamwidthsZ`"(#L18  X-J''iJ` 4. Limitations on the operation of high gain antenna systemsZU!(#<1921 ' (#'` (# `  XW-J''iB.` ` MINIMUM NUMBER OF HOPPING CHANNELSZU!(#<2230  X)!-J''iC.` ` ADDITIONAL ISSUESZU!(#<3163  X"-J''i` ` J` 1. Spectral power densityZU!(#<3235  X"-J''i` ` J` 2. Definition of direct sequenceZU!(#<3637  X#-J''i` ` J` 3. Definition of pseudorandom sequence and frequency hopping systemsZ`"(#L38  X$-J''i` ` J` 4. Short duration transmissionsZU!(#<3943  X%-J''i` ` J` 5. Measurement of processing gainZU!(#<4445  X&-J''i` ` J` 6. Limits on unwanted emissionsZU!(#<4647  X'-J''i` ` J` 7. Frequency hopping coordinationZU!(#<4851  Xq(-J''i` ` J` 8. External radio frequency power amplifiersZU!(#<5255"q(,))ZZ3'"Ԍ X-J''i` ` J` 9. RF exposure hazardsZU!(#<5658  X-J''i` ` J 10. Cross border operationZU!(#<5961  X-J''i` ` J 11. Potential interference to LMS servicesZ`"(#L62  X-J''i` ` J 12. Reduction in the number of hopping channels at 2450 MHz  X-J''i` ` J  and 5800 MHzZ`"(#L63  Xv-'` (# `'` (#`J''iD.` ` TRANSITION PROVISIONSZU!(#<6465 '` (#`'` (#  XH-J"'ZIV.xPROCEDURAL MATTERSZU!(#<6675  X -Je'^V.xORDERING CLAUSESZU!(#<7677 Commenting PartiesZz(# APPENDIX A '` (#'(#`Final RulesZ(#APPENDIX B Laboratory Measurement ProcedureZ(#APPENDIX C '(#`X` hp x (#%'0*,.8135@8:- xwcomments on eliminating the directional antenna gain for that band. See Notice at para. 11. Cylink Corp. (Cylink),  xMetricom, Inc. (Metricom), and Tetherless Access Ltd. also requested that the limit on maximum directional antenna  {O- xgain also be deleted for systems in the 915 MHz band. The Commission rejected this latter request. See Notice at para. 9. This proposal was in response to a Petition for Rule Making and  X - xRequest for Immediate Waiver submitted by Western Multiplex Corporation (WMC).  l {O-  ԍxSee RM8435. In addition, waivers were granted to WMC on October 3, 1994, and February 14, 1995, to  xCylink on December 16, 1994, and to Atlantic Communications Sciences (ACS) on February 15, 1995, to operate  xspread spectrum transmission systems employing high directional antenna gains in the 2450MHz and 5800MHz  xbands. These waivers were due to expire on June 23, 1996, but were extended on June 18, 1996, for a two year  xperiod or until the effective date of the Report and Order in this proceeding, whichever is earlier. Spread spectrum  x<systems operating under this waiver are required to meet all other standards contained in the current regulations.  xFurther, the waivers are limited to equipment used for fixed pointtopoint operations; pointtomultipoint and  x,omnidirectional operations are prohibited. On November 5, 1996, similar waivers were granted to Microwave Data Systems (MDS) and Larus Corporation; on February 2, 1997, a similar waiver was granted to WiLAN Inc. In the  X - xjNotice, the Commission also proposed to reduce the minimum number of channels required for  xLfrequency hopping systems operating in the 915MHz band from 50 to 25 channels, along with  X- x\a corresponding reduction in the maximum allowable transmitter output power.Q rl {O!-ԍxSee Notice at para. 2634.Q This latter  x.proposal was in response to a Petition for Rule Making submitted by SpectraLink Corporation  x-(SpectraLink). On its own motion, the Commission also proposed several additional amendments  xNto Part 15 of the rules regarding the maximum permitted spectral power density for direct  xKsequence spread spectrum systems; the definitions of direct sequence, pseudorandom sequence,  xkand frequency hopping systems; the acceptability of transmitters employing short duration  x transmissions; the measurement of processing gain; clarification of the limits on unwanted" ,N(N(ZZ"  xemissions; the coordination of frequency hopping transmitters; and the use of external radio  X- xfrequency power amplifiers.Q l {Ob-ԍxSee Notice at para. 3544.Q It further proposed that the changes to the regulations adopted in  X- xresponse to the Notice become effective upon the date of publication in the Federal Register in  X- xorder to make the benefits resulting from the changes available as soon as possible.N Zl {O-ԍxSee Notice at para. 45.N Finally,  X- xthe Commission denied a Petition for Rule Making from Symbol Technologies, Inc. (Symbol)C l {OC -ԍxSee RM8608.C  xwhich requested that the minimum number of channels required for frequency hopping systems  Xx-operating in the 2450MHz or 5800MHz bands be reduced from 75 to 20.ax~l {O -ԍxSee Notice at para. 1825 and at para. 49.a  XJ-  x6. Comments responding to the proposed changes to the rules were submitted by a  xjnumber of parties. Generally, these comments were supportive of the Commission's proposals.  xThe commenters also submitted numerous suggestions for improving or modifying the proposed rules. A list of the parties submitting comments is contained in Appendix A.  X - III. DISCUSSION  X -  X- A. High gain directional antennas  Xd-X` hp x (#%'0*,.8135@8:ԍxWhen the spread spectrum rules were originally adopted, there was no limit on the amount of directional  xantenna gain that could be employed with the transmitters. At that time, there were few other radio communication  xsystems operating in these bands and little potential that interference would be caused to other users. The  xCommission did, however, express its concern in permitting high powered, unlicensed operation in these bands.  xJEventually, because of this concern that interference would be caused to the licensed radio services, the Commission amended its regulations to limit the maximum peak EIRP to 4 watts. While the Commission stated that it was not inclined to provide a similar  xrelaxation for the 2450 MHz band, comments were requested on whether the directional antenna  xgain limit could also be eliminated for that band. The Commission declined to propose a similar",N(N(ZZo"  xchange to the antenna directional limit for spread spectrum systems operating in the 915 MHz band.  X-  x8. In general, the commenting parties support the proposal to eliminate the limit on  X- xdirectional antenna gain in the 5800 MHz band. Cellular companies and utilities, including  xAT&T Wireless Services (AT&T), Columbia Gas Transmission, Oneonta Telephone Company,  xInc. (Oneonta Telephone), Rural Cellular Corporation (Rural Cellular) and others, also support  xthe use of high gain directional antennas. Apple Computer, Inc. (Apple) states that longerreach  x unlicensed communications are an important step for the expansion of the Internet and the  X1- xjNational Information Infrastructure (NII).1l {O -  \ԍxIn particular, the 5800 MHz band frequencies were also adopted for the NII/SUPERNet band. See Report  {Ot -and Order in ET Docket 96102, adopted January 9, 1997, FCC 975. Apple adds that unlicensed transmitters employing  xdirectional, narrowbeam antennas support the goals of the NII band by enabling rapid setup,  xKlower costs, greater frequency reuse and a higher information capacity. The Telecommunications  xIndustry Association, Fixed PointtoPoint Communications Section (TIA Fixed) was the only  xparty strongly to oppose the Commission's proposal to eliminate the limit on directional antenna  xygain at 5800MHz. Specifically, it opposes unlicensed, uncoordinated longrange operations in  xthe 5800 MHz band, arguing that longer path lengths, providing costeffective, highspeed, large  xcapacity capabilities, are already available in the 18, 23 and 38 GHz band to support the NII on  Xy-a licensed basis.Yy$l {ON-ԍxSee TIA Fixed Reply Comments at 2.Y  XK-  x9. Many of the commenting parties support permitting the use of high gain directional  X4- xantennas in the 2450MHz band.[Z4l {O-  ԍxSee, for example, comments from Apple , AT&T, Columbia Gas Transmission, Cylink, Gabriel Electronics,  xInc. (Gabriel Electronics), Metricom, Microwave Communications Technology Inc. (MCT), OCOM Corporation (OCOM), Part 15 Coalition, and US West, Inc. (US West).[ Cylink Corp. (Cylink) and WMC state that, under waivers  xissued by the Commission, they have been operating systems in the 2450 MHz band with  X- xdirectional antenna gains greater than the 6 dBi limit with no reports of interference.cl {O-ԍxSee Cylink Comments at 8; WMC Comments at 5.c Cylink,  xiMulcay Consulting Associates (MCA) and WMC argue that limiting the EIRP of spread spectrum  xdevices in the 2450 MHz band may adversely impact the ability of Part 15 devices to share the  X- xband with Part18 ISM devices.xj l {O!-ԍxSee Cylink Comments at 56; MCA Comments at 2; WMC Comments at 4.x WMC states that limiting the EIRP to 6 dBW will cause the  xkreceived signal level from Part 15 communications transmitters to fall below the background  xzradiation from industrial, scientific and medical (ISM) devices operating under Part 18 of the  X|- xrules, making these applications unusable.M| l {O)&-ԍxSee WMC Comments at 2.M Similarly, Metricom, Inc. (Metricom) states that the  xkgreatest potential for interference in the 2450 MHz and 5800MHz bands is from Part 18 ISM"e ,N(N(ZZ1"  X-transmissions rather than from Part 15 transmitters.Rl {Oy-ԍxSee Metricom Comments at 4.R  X-  x 10. Several parties opposed eliminating the limit on directional antenna gain for the  X- x\2450MHz band.eZZl {O-  ԍxSee comments from Adtran, Cushcraft Corporation (Cushcraft), Digital Wireless Corporation (Digital  xWireless), Rockwell International Corporation (Rockwell), Telecommunications Industry Association, Wireless Consumer Communications Section (TIA Wireless), and TIA Fixed. e The commenters' primary objections are that the 2450MHz band is more  xMheavily used than the 5800MHz band and contains both mobile and fixed users. Cushcraft  xCorporation (Cushcraft) is concerned that highgain, fixed pointtopoint operations may cause  xtoo much interference to systems employing lower gain antennas, such as wireless local area  X_- xnetwork systems (LANs).S_|l {O -ԍxSee Cushcraft Comments at 3.S Cushcraft adds that the increasing proliferation of mobile and  xLportable users in the 2450 MHz is not compatible with high gain, fixed, pointtopoint systems.  xFusion Systems Corporation (Fusion) points out that compatibility problems may exist between  X - xthe primary ISM users and the fixed or mobile communications users in the 2450MHz band.R l {O-ԍxSee Fusion Comments at 15.R  xFusion recommends adopting rules that caution manufacturers and users operating in any of the  xjISM bands that inband interference may be intolerable unless susceptibility standards, similar  xto those currently employed in Europe, are applied to their systems. Fusion Lighting, Inc.  X -(Fusion Lighting) raised identical concerns.[ l {O-ԍxSee Fusion Lighting Comments at 13.[  X-  1x 11. Based on the comments received, the Commission is amending its regulations to  x\eliminate the existing transmitter output power penalty for Part 15 spread spectrum systems  Xb- xkoperating with high gain directional antennas in the 2450 MHz and 5800MHz bands.Zb2 l yOE-  ԍxThe Commission is also adopting a more relaxed restriction on output power for the 2450 MHz band in  {O - xorder to decrease the potential for interference to other services. See discussion on reduction in output power for the 2450 MHz band contained in paragraphs 1617 of this Report and Order. The  xjCommission recognizes the advantages of being able readily to establish radio links capable of  xtransmission distances of 10 km, or greater, without the delays and costs associated with formal  X- xfrequency coordination and licensing.NT l {O""-ԍxSee Notice at para. 10.N The ability to establish quickly such transmission links  xMcould be critical in emergency situations. Directional antennas can significantly reduce the  xpotential for harmful interference to other radio operations in cases where the location of the",N(N(ZZ "  X- xdirectional systems is coordinated and there is a low preponderance of mobile systems.l yOy-  LԍxA directional antenna operates by taking radio frequency power from the transmitter and concentrating that  x;power in a specific direction, similar to the action of a reflector in a search light. While the signal strength is much  xystronger in the desired direction, the signal level in other directions is considerably reduced. The reference to  x"mobile systems" also, for the purpose of this Report and Order, includes temporary fixed systems since the location  x<of the temporary fixed system may not be known or coordinated prior to operation. For many temporary fixed systems, it is the receiving site that remains in a fixed location. When  x<dealing with fixed radio applications, the use of directional antennas can be particularly important  xin allowing nearby fixed radio systems to co-exist within the same frequency band. Radio  xsystems located outside the directional beam of the antenna pattern have a low probability of  x!receiving interference. However, radio systems that are located in the main beam of the  xkdirectional antenna will have a much higher potential for receiving interference, in particular  xbecause of the higher signal levels caused by the antenna gain. Thus, mobile systems are  xparticularly susceptible to interference from fixed stations since they can move into the main beam of the fixed station.  X -  x 12. There are a significant number of mobile operations in the 915MHz band.  @l yO -  ԍxThe 915 MHz band is allocated for ISM devices under Part 18 of the rules, U.S. Government radiolocation,  xU.S. Government fixed and mobile operations, land mobile operations under Part 90, and amateur operations under  xiPart 97. In addition, there are a significant number of Part 15 devices operating in the 915MHz band, including wireless computer local area network systems and cordless telephones. It was  x for this reason that the Commission decided not to eliminate the antenna gain limits for the  x915MHz band. Similarly, the number of mobile applications has continued to increase in the  x2450 MHz band. The 2450 MHz band is allocated for ISM devices under Part 18 of the rules,  xU.S. Government stations, the Private Land Mobile Radio Services under Part 90, the Private  xOperationalFixed Microwave Services under Part 94, Television Broadcast Auxiliary Stations  x]under Part 74, and the Amateur Radio Service under Part 97. The primary increase in the  xnumber of number of licensed mobile units is from surveillance and other systems operating  x/under the Public Safety Radio Services under Part 90. Further, as in the 915 MHz band, the  xnumber of Part 15 systems appearing in the 2450 MHz band is continuing to increase, especially  xfor devices such as wireless local area network systems. Accordingly, the Commission was not  X- xjinclined in the Notice to eliminate the limit on directional antenna gain for this band. However,  xas indicated by WMC, the 2450MHz band has a significant background noise level, primarily  X- xfrom the operation of microwave ovens and other ISM devices.M ( l {O -ԍxSee WMC Comments at 4.M Further, while the background  xnoise level for the 5800 MHz band is not as high as the 2450MHz band, this noise level is  xexpected to increase as the cost of equipment in the 5800MHz band continues to decline due  X- xto improvements in technology and the number of users in this band increase.! l yO%-  ԍxThe 5800MHz band is allocated for operation by ISM devices under Part 18 of the rules, U.S. Government stations, and the Amateur Radio Service under Part 97. The use of  xxdirectional antennas will help transmission systems to overcome these noise levels in both bands,"!,N(N(ZZ3"  xipermitting their use by important communication services. Accordingly, the Commission believes  xthat the limit on directional antenna gain could be relaxed for both the 2450 MHz and 5800 MHz  x-bands without substantially increasing the potential for harmful interference to the licensed radio  X- xservices." l yO4-  [ԍxWhile the number of Part 15 operations within these bands has continued to increase, the Commission notes  xthat Part 15 devices are not allocated spectrum within these bands but are permitted to operate on a sufferance basis.  xwThus, the potential for interference between Part 15 devices is not normally considered when implementing changes to the standards. However, as discussed in the next section, the Commission also believes that some  xcorresponding reduction in the transmitter output power is necessary for transmitters operating in the 2450 MHz band.  X_-  x 13. The Commission does not agree with Fusion that additional regulations should be  xadopted cautioning manufacturers and users that inband interference may be intolerable unless  xsusceptibility standards are applied to their systems. A note at the end of the spread spectrum  xrule section already advises that potential interference may occur from other operations in these  xfrequency bands. In addition, the transmitters must already be labelled with a statement that  X - xoperation under Part 15 is not protected against harmful interference.M# l {OM-ԍxSee 47 CFR  15.19.M Further, the Commission  xhas chosen not to establish susceptibility standards under its regulations for other Part 15  X - xproducts, but has allowed industry to develop these standards as necessary.$  Bl yO-  ԍx"Susceptibility standards" address the ability of a product, such as a digital device, to reject interference that  xcould be caused by other nearby sources of radio frequency noise. Such standards generally are not applicable to  xtransmitter/receiver systems. Any RF noise appearing in the passband of a receiver will be received by that system irrespective of the establishment of susceptibility standards. Further, the  xCommission's authority to establish susceptibility standards is limited to home electronic  X- xequipment and systems.I%* l {Ok-ԍxSee 47 USC 302(a).I The majority of the spread spectrum systems, especially those systems employing directional antennas, are not classified as home electronic equipment.  XK-  0x 14. The manufacturers and operators of spread spectrum transmitters are reminded that  x the operation of Part 15 devices is subject to the conditions that any received interference,  xincluding interference from ISM operations, must be accepted and that harmful interference may  xnot be caused to other radio services. Should the operation of these systems cause harmful  xinterference, the operator of the Part 15 system is required to correct the interference problem,  xeven if such correction requires the cessation of operation of the Part 15 transmitter. The  xCommission will not exempt Part 15 devices from this latter requirement because of the  xapplication for which the Part 15 transmitter is employed. Thus, the Commission strongly  xrecommends that utilities, cellular stations, public safety services, government agencies and others  xthat employ Part 15 transmission systems to provide critical communication services should  xexercise due caution to determine if there are any nearby radio services that could be affected by their communications."N %,N(N(ZZ"Ԍ X-  ԙx15. Finally, American Petroleum Institute (API) requests the Commission to clarify that  xusers are permitted to increase the transmitter power or antenna gain to account for transmission  X- xline loss.M&l {OK-ԍxSee API Comments at 2.M The Commission already permits manufacturers of systems that must use long  xtransmission lines to measure transmitter output at the connection between the transmission line  X- xkand the antenna.'Zl {O-ԍxSee also, the discussion on external radio frequency power amplifiers later in this Report and Order. This permission, however, is done on a casebycase basis and must be  x!justified during the certification procedure. Generally, the manufacturer must be able to  xdemonstrate that the system will be professionally installed and that the design or placement of  xthe equipment requires the use of long transmission lines. In certain cases, external radio  xifrequency power amplifiers, as discussed below, can be incorporated as part of the system design  xand authorized under the certification procedure in order to offset the effect of long transmission  xlines. Manufacturers should note that increases to the output power of a transmitter beyond what  x!was authorized under certification normally requires a new application for, and grant of,  X - x>certification.Q( l {O-ԍxSee 47 CFR  2.1043(a).Q Further, the antennas employed with a spread spectrum transmitter must be  X -certified as part of the system.) ~l {O-  ԍxSee 47 CFR  2.143(b) and 15.203. Manufacturers should also note that the use of an antenna other than  xthe type with which the transmitter was certified could cause the levels of the spurious emissions, especially those  xemissions appearing within the restricted frequency bands described in 47 CFR  15.205, to exceed the established  xlimits. Additional information regarding the authorization of systems with multiple antenna configurations can be found later in this Report and Order under the discussion regarding external radio frequency power amplifiers.  X-X` hp x (#%'0*,.8135@8:spectrum systems employing high gain directional antennas.Q3Fl {O-ԍxSee Notice at para. 1213.Q First, the operation of these  x/systems would be limited to fixed, pointtopoint applications. Second, pointtomultipoint  xsystems, omnidirectional applications and multiple colocated transmitters transmitting the same  xinformation would be prohibited. Third, the operator of a spread spectrum system would be  Xe- xresponsible for ensuring that the system is operated in this manner.4el yO#-  ԍxNormally the holder of a license from the Commission is responsible for ensuring that transmitting equipment is properly used. However, under Part 15 there are no station licenses. Fourth, the manual supplied  x with the spread spectrum transmitter must contain language in the installation instructions  xnotifying the operator of this responsibility. Fifth, the marketing of spread spectrum systems  xemploying high gain directional antennas would be limited to commercial or industrial operators,"  0 4,N(N(ZZ" and sales to the general public would be prohibited.  X-  Nx20. Comments supporting these proposals were received from several parties, including  xApple, AT&T, Columbia Gas, OCOM Corporation (OCOM), and Rockwell. Multipoint  xNetworks, in late filed comments, requests that 5800MHz spread spectrum transmitters be  X- xpermitted for pointtomultipoint applications as long as directional antennas are employed.5l {O-  ԍxSee Multipoint Network Comments at 2. Multipoint Network's comments are being accepted as latefiled comments. It  x<states that the combination of sectored antennas at a central site, along with directional antennas  xjat remote sites, can limit the total interference potential caused by a pointtomultipoint system  xto levels well below the interference potential caused by the larger number of pointtopoint links  xthat would otherwise be required. Rockwell, while opposed to the use of high gain antennas in  xthe 2450 MHz band, recommends that the installation of high gain antennas in the 5800MHz  xband could be limited to the equipment authorization grantee or entities contracted by the  X - x-grantee.R6 "l {O-ԍxSee Rockwell Comments at 4.R Apple asks for clarification that the restriction to commercial and industrial users does  X -not exclude municipalities, health care and educational institutions.O7 l {O:-ԍxSee Apple Comments at 7.O  X -  x21. The Commission is adopting its proposals from the Notice. It does not agree with  x/Multipoint Networks that pointtomultipoint applications should be permitted for systems  xLemploying high gain directional antennas with EIRPs greater than 4 watts. The use of multiple  x\or sectored antennas to provide pointtomultipoint coverage can significantly increase the  xjpotential for harmful interference to other radio service by providing what appears, in effect, to  xbe omnidirectional coverage but with a significant increase in EIRP. The potential for harmful  X- xinterference is reduced by restricting these systems, as proposed in the Notice, to pointtopoint  xxapplications and prohibiting pointtomultipoint systems, omnidirectional antennas or multiple co xylocated transmitters transmitting the same information. As proposed by the Commission in the  X- xNotice, the operator of the spread spectrum system or, if the equipment is professionally installed,  xthe installer will be responsible for ensuring that the system is operated in this manner; however,  xthe manual supplied with the spread spectrum transmitter must contain language in the  xinstallation instructions notifying the operator and the installer of this responsibility. These  xKprovisions will lower the potential for high signal level spread spectrum systems to cause harmful  xinterference by limiting the proliferation of these systems and by strongly encouraging  x=professional installations. The Commission no longer agrees that the regulations need to limit  xthe marketing of 2450 MHz or 5800 MHz systems employing high gain directional antennas and  xhigh EIRPs to commercial or industrial applications or that sales to the general public need to  x<be specifically prohibited. The use of these systems are already restricted to fixed, pointtopoint  xapplications, and the type of antennas employed generally require professional installation. These  xfeatures should be sufficient to reduce the potential for harmful interference to other radio services without additional restrictions being placed on the marketing of the equipment." F7,N(N(ZZ"Ԍ  X- B. Minimum number of hopping channels  X-  x22. In the Notice, the Commission proposed to reduce the minimum number of non xcontiguous channels that must be employed by a frequency hopping spread spectrum system in  X- xthe 915MHz band from 50 channels to 25 channels.8l {O-  ԍxSee Notice at para. 3034. The use of noncontiguous frequency hopping channels is already required under  x;the rules. This requirement is contained in the Commission's definition of a frequency hopping system which states  {O- xhthat the frequency of the carrier changes at fixed intervals under the direction of a pseudorandom code. See 47 CFR  x 2.1. While the Commission also proposed to amend the definition of frequency hopping systems and pseudorandom sequence, the revised definitions would still require the use of non-contiguous channels. This reduction in the number of hopping  xchannels would enable frequency hopping spread spectrum systems to avoid operations on  xfrequencies used by wideband, multilateration LMS systems, reducing mutual interference  xproblems. In order to keep the interference potential from increasing due to the reduced number  xLof hopping channels, the Commission also proposed that frequency hopping spread spectrum  xxtransmission systems operating with less than 50 channels employ channel bandwidths of at least  X - x250 kHz and operate at a reduced power level.y9 |l yO2-ԍxThe maximum 20 dB bandwidth of the hopping channel would remain 500 kHz.y Further, the maximum average time of  xoccupancy on any hopping frequency for transmitters using less than 50 hopping channels would  X -be increased to 0.4 seconds in any 10 second period.: l yO-  kԍxCurrently, the maximum average time of occupancy on any hopping channel in the 915 MHz band is 0.4 seconds in any 20 second period.  X -  x23. The Commission requested comments as to whether the rules should specify a  xformula for the minimum number of hopping channels based on the amount by which the  X{- x/bandwidth of the hopping channel exceeds 250 kHz.; {d l yO-  ]ԍxUnder this approach, the minimum number of hopping frequencies would be equal to 25 x (500/20 dB  xbandwidth of a single hopping channel in kHz) or 50 hopping frequencies, whichever results in the lowest number  xjof hopping frequencies. Adopting this formula would also require that the average time of occupancy on any hopping frequency not exceed 0.4 seconds within a 20 x (number of hopping channels/50) second period. It stated that the use of this formula  x=would result in an even distribution of the hopping channels over that portion of the 915 MHz  xband that is not employed by wideband multilateration LMS systems. This would prevent  xfrequency hopping systems employing between 250 kHz and 500 kHz bandwidth hopping channels from being concentrated in any single portion of the 915MHz band.  X-  x24. Because the smaller number of hopping channels would increase the potential for  x>interference, the Commission proposed to require that frequency hopping spread spectrum  xsystems in the 915 MHz band that use fewer than 50 hopping channels operate with a maximum  x.peak transmitter output power of 500 mW. However, the Commission indicated that, while the  xpotential for harmful interference can be offset by a reduction in operating power, a linear"L ;,N(N(ZZ3"  X- xreduction may not be sufficient to provide this offset.0<$l yOy-  >ԍxThe reference to a linear power reduction means that the maximum output power is reduced by the same  xpercentage as the reduction in the number of hopping channels. For example, if the number of hopping channels  {O - xZis reduced by 50 percent, i.e., to 25 hopping channels, the maximum output power is also reduced by 50 percent,  {O-i.e., to 500 mW. This is the amount of reduction requested by SpectraLink in its petition.0 It recognized that the chance of collisions  xywith other transmissions, and resulting interference, would be increased since there are a fewer  xnumber of hopping channels resulting in a change to the average time of occupancy on any  xfrequency and the crowding of transmissions into less spectrum. Accordingly, comments were  X- x!requested as to whether or not a greater reduction in output power should be applied.= l yO -  ԍxThe Commission also requested comments on whether a power reduction based on the actual number of  x<hopping channels should be employed. If a linear reduction was to be employed, this would result in a maximum  xpeak transmitter output power of no greater than (number of hopping channels/50) watts or one watt, whichever is the lesser power.  x/Comments were also requested on whether a limit on spectral power density, similar to that  xcurrently applied to direct sequence systems, should be applied to frequency hopping systems operating with fewer than 50 hopping channels.  X1-  x25. Most of the commenting parties support the proposal to reduce the minimum number  xof required channels employed by frequency hopping spread spectrum systems in the 915MHz  xband from 50 to 25 channels. The commenters agree that reducing the minimum number of  xZhopping channels will help Part 15 devices to avoid frequencies used by wideband multilateration  xLMS systems. Ericsson Corporation (Ericsson) and Teletrac License, Inc. (Teletrac) request  xjfurther restrictions to require frequency hopping systems using less than 50 channels to avoid  X - xusing LMS spectrum.j> l {O-ԍxSee Ericsson Comments at 3; Teletrac Comments at 5.j Teletrac proposes that frequency hopping systems using fewer than 50  x.channels be restricted from using the LMS subbands to occupy more than 50 percent of their  Xy- xneeded bandwidth.R?y. l {OX-ԍxSee Teletrac Comments at 6.R Teletrac adds that frequency hopping spread spectrum systems that employ  xMat least 50 hopping channels should continue to be presumed not to be a source of harmful  x/interference to multilateration LMS systems, but that this presumption should not apply to  xsystems that employ less than 50 hopping channels and use any channels in the multilateration  X- xLMS bands.Q@ l {O -ԍxSee 47 CFR  90.357(a).Q Digital Wireless strongly opposes Teletrac's proposal, stating that frequency  xhopping systems should not be restricted from using spectrum in areas where there are no LMS  X- x<users or only partial use of the spectrum by LMS systems.`AR l {O#-ԍxSee Digital Wireless Reply Comments at 1.` The International Microwave Power  xyInstitute (IMPI) is the only party to oppose a reduction in the number of channels because it is  xconcerned that frequency hopping systems operating in a narrower band may be more susceptible"A,N(N(ZZ"  X-to interference from ISM devices.NBl {Oy-ԍxSee IMPI Comments at 2.N  X-   x26. Apple, Digital Wireless and SpectraLink support the adoption of simple, unambiguous  X- x-rules rather than limits based on a complex formula.CZl {O-ԍxSee Apple Comments at 4; Digital Wireless Reply Comments at 3; SpectraLink Comments at 5. While the commenting parties also support  xa reduction in power for systems using fewer than 50 channels, the comments vary on the  x[appropriate method and level of reduction. Adtran, Itron, Inc. (Itron), the Part 15 Coalition and  Xv- xSpectraLink support adoption of the proposed 500 mW limit.Dvl {O -  ԍxSee Adtran Comments at 4; Itron Comments at 2; Part 15 Coalition Comments at 6; SpectraLink Comments at 3. Ericsson believes that the power  X_- xlimit should be reduced to 100 mW rather than 500 mW.E"_Fl {OV-  LԍxSee Ericsson Comments at 3. Additionally, Ericsson is concerned that frequency hopping systems operating  xZin a narrower bandwidth will adversely impact other Part 15 devices operating under Section 15.249 and requests  xan increase in power for these devices. This request is outside the scope of this proceeding and will not be considered herein. Metricom recommends adopting a  XH- x250mW output limit.XFH0 l {O)-ԍxSee Metricom Reply Comments at 3.X Rockwell and Telecommunications Industry Association, Wireless  xConsumer Communications Section (TIA Wireless) recommend using formulas that relate the  X - x\power limit to the number of hopping channels.pG l {O-ԍxSee Rockwell Comments at 7; TIA Wireless Comments at 25.p TIA Wireless submitted the only detailed  xxtechnical analysis relating the interference potential of a frequency hopping system to the number  xof hopping channels and the transmitter output power. The formula developed by TIA Wireless  xindicates that a frequency hopping system using 25 hopping channels should have a transmitter  xoutput limit of 250 mW in order for the interference potential to be no greater than that of a 50  X - xchannel system operating with a transmitter output power of 1 W. H T l {O-  ԍxSee TIA Wireless Comments, Attachment at 1. The formula developed by TIA Wireless states "[f]or  x;frequency hopping systems operating in the 902928 MHz band: 1 watt for systems employing at least 50 hopping  yO>- xchannels. For systems employing less than 50 hopping channels, the lesser of: (1) (n"f/26)2 watts, and (2) (m/50)2  xwatts; where n is the total number of systemdefined channels from which the actual hopping channels are randomly xselected, f is the minimum center frequency separation between any two of the systemdefined channels, in MHz, and m is the number of hopping channels employed."  RAMAR Technology, Ltd.  X-(RAMAR) believes a power density limit should be applied to frequency hopping transmitters.OIl {O#-ԍxSee RAMAR Comments at 4.O  Xb-  ^x27. The Commission agrees with the comments that the minimum number of hopping  xLchannels for spread spectrum systems operating in the 915 MHz band should be reduced from  x50 to 25 channels for frequency hopping systems employing hopping channels bandwidths of at"4`I,N(N(ZZ"  X- xleast 250 kHz.Jl yOy-  ԍxFrequency hopping spread spectrum systems employing channel bandwidths less than 250 kHz can already avoid using the spectrum allocated for wideband multilateration LMS systems. A corresponding change to the average time of occupancy on any hopping  X- xfrequency, as proposed in the Notice, is also being adopted to accommodate the smaller number  xLof hopping channels. Adoption of these proposals will allow a reduction, from 25MHz to 12.5  xMHz, in the spectral occupancy of frequency hopping spread spectrum systems operating at the  X- xymaximum channel bandwidth.K l yOw-ԍxA total of 26 MHz of spectrum is available for spread spectrum systems operating in the 915 MHz band. By decreasing the number of frequency hops, the users of Part  x15 spread spectrum systems can avoid operating in the frequency bands employed by wideband  Xx- xmultilateration LMS systems and, thereby, reduce mutual interference problems.zLzxl yO -  ԍxWideband multilateration LMS systems operate, on a primary basis to nonmultilateration systems, in the  x904909.75 MHz and 921.75927.25 MHz bands with associated forward links in the bands 927.75928 MHz and  x927.25927.5 MHz, respectively. This leaves only 14.25 MHz in the 915 MHz band in which frequency hopping  xspread spectrum systems can avoid wideband multilateration LMS systems. However, multilateration LMS systems  xmay also operate on a coequal basis with nonmultilateration LMS systems in the band 919.75921.75 MHz with  xa forward link at 927.5927.75 MHz, or aggregate operation to include the 921.75927.25 MHz band, leaving only  {O-12 MHz of available spectrum. See 47 CFR  90.357(a).z Part 15 spread  xspectrum transmitters operating in the 915 MHz band under certain, specified conditions already  xare presumed not to be a source of harmful interference to wideband multilateration LMS  X3- xMsystemsNM3 l {O-ԍxSee 47 CFR  90.361.N; however, it is to the benefit of the spread spectrum operators to avoid using the  xwideband multilateration LMS channels in order to reduce the potential for received interference.  xThe resulting reduction in the spectral occupancy of the wideband multilateration LMS channels  x.by spread spectrum systems will maximize spectral efficiency by increasing the number of Part  x?15 devices and LMS users that can coexist in the band. This should facilitate the future deployment of frequency hopping systems in the 915MHz band.  X-  x28. The Commission does not agree with Teletrac that limitations should be placed on  x<spread spectrum signals occupying the LMS subbands. As stated by Digital Wireless, there are  xareas within the U.S. where the wideband multilateration LMS channels are not being used or  xare only partially used. Further, as indicated above, Part 15 spread spectrum transmitters  xcomplying with the conditions in Section 90.361 of the rules are already presumed not to be a  xsource of harmful interference to wideband multilateration LMS systems. Accordingly, there is  xZno basis for prohibiting the operation of spread spectrum systems in the wideband multilateration  xLMS channels. It is, however, to the benefit of the spread spectrum operator to avoid operating on these LMS channels, as indicated above.  X-  x29. The Commission agrees with the comments that simple, unambiguous rules, rather  xthan several different limits based on formulas, are appropriate, and is so amending its  xregulations. The Commission also agrees with the technical analysis presented by TIA Wireless  xthat the peak output power of a spread spectrum transmitter operating with less than 50 hopping"g M,N(N(ZZ"  xchannels should be reduced to 250mW with a maximum directional antenna gain of 6 dBi. As  xshown by TIA Wireless, this change is necessary to avoid increasing the interference potential  xof frequency hopping spread spectrum systems operating with a reduced number of hopping  xchannels. Accordingly, the regulations are being amended to adopt a peak transmitter output  xlimit of 250 mW for frequency hopping spread spectrum systems operating with less than 50 hopping channels.  X_-  Ox30. Finally, the Commission noted that a number of petitions for reconsideration had  XH- xbeen received in response to the recent Report and Order implementing the LMS systems.{NHl {O -ԍxSee Report and Order in PR Docket No. 9361, 10 FCC Rcd 4695 (1995).{ It  xindicated that any changes to the LMS rules in response to those petitions could result in  X - xjmodifications to the amendments that were proposed in the Notice for Part 15 spread spectrum  xoperation in the 915 MHz band. Adtran, Lucent Technologies Inc. (Lucent), Metricom, the Part  x15 Coalition and TIA Wireless oppose any changes to Part 15 rules in this proceeding based on  X - xchanges made to the LMS regulations.O Zl {O-  ԍxSee Adtran Reply Comments at 2; Lucent Comments at 3; Metricom Comments at 78; Part 15 Coalition Comments at 7; TIA Wireless Comments at 5. Lucent states that there is no need to link Part 15 rules  xwith LMS rules. Metricom and the Part 15 Coalition state that parties must be given an  xopportunity to make comments under the Administrative Procedure Act and that no changes to  xythe spread spectrum rules based on changes to the LMS regulations should be made without a  xnew rule making. The Commission concurs with the comments that these changes to the  x<regulations should not be linked to future possible changes to the LMS regulations under Part 90 of the rules.  X - C. Additional issues   X-  |x31. The Notice contained several additional proposals to clarify, codify or amend the regulations concerning Part 15 spread spectrum transmission systems. These are discussed below.  X-X` hp x (#%'0*,.8135@8:were received from Adtran and Apple.f[# l {OX!-ԍxSee Adtran Comments at 5; Apple Comments at 10.f The Commission agrees with the comments and is  X -adopting this change to the rules, as proposed in the Notice. X` hp x (#%'0*,.8135@8:Microwave Data Systems (MDS), and the Part 15 Coalition.g8 l {O-  zԍxSee Adtran Comments at 6; Apple Comments at 10; Digital Wireless Comments at 2; MDS Comments at 3; Part 15 Coalition Comments at 6. Adtran and Digital Wireless  X!- xbelieve the two alternative procedures contained in the Notice are nearly equivalent and will  xpreclude the approval of noncompliant systems. The Commission agrees with these comments and is amending the rules, as proposed.  X-X` hp x (#%'0*,.8135@8:apply to spread spectrum transmitters.Nhl {O4-ԍxSee 47 CFR  15.205.N Thus, in the Notice the Commission proposed to  xsimplify the existing standards by stating that all emissions outside of the frequency band  xjemployed by the spread spectrum transmitter, except for emissions within the restricted bands,  Xx- xzmust be attenuated by at least 20 dB.NixZl {O -ԍxSee Notice at para. 41.N It further proposed to clarify these requirements by  xstating that demonstration of compliance with this 20 dB emission standard can be based on RF  xantenna conducted or radiated measurements. Finally, it proposed to reference in the spread  xspectrum rules the requirements for the attenuation of radiated emissions in the restricted bands.  xSince the limits for emissions appearing in the restricted bands are expressed in terms of the field  xstrength of the signals, emission levels in these bands must always be determined based on radiated emission measurements.  X -  ]x.47. The comments from Adtran, Apple, Digital Wireless, MDS, and the Part 15 Coalition  X - xsupported the proposal in the Notice.j l {OF-  zԍxSee Adtran Comments at 6; Apple Comments at 10; Digital Wireless Comments at 3; MDS Comments at 3; Part 15 Coalition Comments at 6. The Commission received no opposition to this proposal.  xIt agrees with the comments and believes that this change to the regulations will provide needed  xsimplification and clarification to the rules. Accordingly, the Commission is adopting the changes to the regulations, as proposed.  X!-X` hp x (#%'0*,.8135@8:equivalent antennas from different manufacturers.Pu{$l {OP-ԍxSee Adtran Comments at 7.P Similarly, Digital Wireless requests an  x=exclusion for highgain antennas since these systems cannot practically be sold with attached  XM- xKantennas.ZvMl {O-ԍxSee Digital Wireless Comments at 3.Z Adtran and Cushcraft request that the use of alternate antennas be allowed as either  X6- xzClass I or Class II permissive changes.qw6Hl {O/-ԍxSee Adtran Reply Comments at 2; Cushcraft Comments at 34.q MDS and WMC specifically oppose the language  X- xproposed in the Notice for in the proposed Section 15.204(d). MDS is concerned because it  X - xproduces a software controlled radio that would have to be approved with each antenna.Ox l {O-ԍxSee MDS Comments at 34.O WMC  xrequests that the proposed Section 15.204(d) be deleted so that high gain antennas may be used  X-with professional installation.Myl l {O -ԍxSee WMC Comments at 2.M  X-  x554. The Commission is adopting its proposal as detailed in the Notice. In accordance  xwith 47 USC 302, radio frequency devices must comply with the Commission's standards as a  x[condition of manufacture, marketing and use. These requirements include obtaining a grant of  xcertification for the transmitter and meeting the emission limits specified in the rules. The  xCommission will not certify an external radio frequency power amplifier under Part 15 of its  xrules as a standalone device. However, it will certify such an amplifier as part of a system since"= y,N(N(ZZ"  xit is the specific combination of transmitter, amplifier and antenna that determines whether or not  xthe resulting system will comply with the standards. If an external amplifier has not been  xcertified as part of the system but is employed with a Part 15 transmitter, the certification on the  X-transmitter is no longer valid.[zl {O4-ԍxSee 47 CFR  2.1043(a) and (b)(3)[  X-  x655. With regard to the antenna employed with the system, changes to the antenna  xcertified with the system often will change the amplitude levels of both the fundamental and the  xunwanted emissions. The Commission is particularly concerned about possible increases to  x<emissions appearing in frequency bands allocated to sensitive radio services or services used for  xsafetyoflife applications. Thus, changes to the antenna can be made only if the equipment  xcontinues to comply with the standards. Further, changes to the antenna may be made only by  x\the holder of grant of certification following the procedures for ClassII permissive changes  X - xspecified in Part 2 of the regulations.r{ Zl {O-ԍxSee 47 CFR  2.1043(b) and especially  2.1043(b)(3).r In order to simplify the measurement requirements when  xa manufacturer wishes to produce a transmitter that can be used with several different antennas,  xthe Commission has permitted tests of representative antennas instead of requiring the transmitter  xxto be tested with each possible antenna; however, this testing criteria is established on a caseby x.case basis and is dependent on the specific type of transmitter and antennas being employed.  xAdditional information on how to simplify the test requirements when multiple antenna choices  x=are being made available should be obtained from the Commission's Laboratory staff just prior to the equipment being tested in preparation for submission for a grant of certification.  X-X` hp x (#%'0*,.8135@8:63. In the Notice, the Commission denied the petition from Symbol Technologies, Inc.  X- xto reduce the number of hopping channels in the 2450 MHz and 5800 MHz bands.Xl {O6-ԍxSee Notice at para. 1825 and 49.X Several  X- xof the comments indicated agreement with this decision.WZZl {O-  /ԍxSee, for example, Adtran Comments at 4; Digital Wireless Corporation Comments at 2; Fusion Lighting  xxComments at 2; International Microwave Power Institute Comments at 1; Lucent Technologies Comments at 2; Rockwell Comments at 5; TIA Wireless Comments at 4.W However, GEC Plessey  xkSemiconductors (GPS) requests that the Commission reconsider its decision to permit wider  xbandwidth channels to support wireless LAN systems. Tadiran also requests that the Commission  xreduce the minimum number of frequency hopping channels to permit wider bandwidths to be  XJ- xemployed.J|l yOw-  ԍxTadiran, in late filed comments, also requests that a linear reduction in power be applied with the decrease in the number of hopping channels. Neither of these parties offer new or novel arguments that were not previously  x\considered by the Commission in its denial of the Symbol petition. Tadiran indicates that it  xwould be desirable to avoid operating in the frequency range of 24502483.5MHz due to the  xjallocation to broadcasters and private microwave licensees. However, Tadiran fails to account  xfor similar problems that would occur in the 2400-2450MHz band due to operations in the  xAmateur Radio Service or to other radio frequency noise produced throughout the 2450 MHz  x>band by ISM equipment. Accordingly, the Commission is reaffirming its previous decision  xdenying a reduction of the minimum number of frequency hopping channels for spread spectrum systems operating in the 2450 MHz and 5800MHz bands.  XM- D. Transition provisions  X-  x?64. The amendments being adopted in this proceeding clarify permissible methods of  xoperation. With the exception of limits on directional antenna gain versus transmitter output  xpower for systems in the 2450 MHz band, these amendments should not impact any existing  x\equipment designs. As mentioned above, waivers were issued previously to WMC, Cylink  xCorporation, Atlantic Communications Sciences, MDS, Larus Corporation and WiLAN to  x/manufacture fixed, pointtopoint spread spectrum systems in the 2450 MHz and 5800MHz  xLbands without a limit on directional antenna gain. These manufacturers would be impacted by  xMa decision to reduce the output power of a 2450 MHz transmitter by 1dB for every 3dB the  xdirectional antenna gain exceeds 6 dBi. Under the terms of the waivers, this equipment can only be manufactured until final action in this proceeding.  X"-  x@65. Cylink requests that any restrictive regulations to limit antenna gain in the 2450 MHz  xband be phased in over a twelve month period to permit the completion of any existing"  ,N(N(ZZ["  X- xcontractual obligations.Ql {Oy-ԍxSee Cylink Comments at 15.Q However, Cylink, along with the other manufacturers that were issued  xwaivers, was aware of the possibility that its waiver may not continue subsequent to finalization  xof this rule making proceeding. Any contractual obligations based on a temporary, and possibly  xLnoncontinuing, waiver must be considered to have been taken at the manufacturer's own risk.  xAccordingly, the Commission sees no reason to delay the effective date of these amendments to  xthe regulations. While the Commission originally proposed to make these amendments effective  Xv- xupon the date of publication of the final rules in the Federal Register,NvZl {O -ԍxSee Notice at para. 45.N the Contract With  X_- xAmerica Advancement Act of 1996[_l yO -ԍxPub. L. No. 104121, 110 Stat. 847 (1996).[ requires that these amendments not become effective prior to 30 days from publication in the Federal Register.  X -R IV. PROCEDURAL MATTERS ĐTP  X - Final Regulatory Flexibility Analysis  X -  xA66. As required by Section 603 of the Regulatory Flexibility Act, 5 U.S.C.  603 (RFA),  X- xLInitial Regulatory Flexibility Analysis (IRFA) was incorporated in the Notice of Proposed Rule  X{- xMaking ("Notice") in ET Docket No. 968.{|l yO-  >ԍxAmendment of Parts 2 and 15 of the Commission's Rules Regarding Spectrum Transmitters, 11 FCC Rcd 3068 (1996). The Commission sought written public comments  Xf- xon the proposals in the Notice including the IRFA. The Commission's Regulatory Flexibility  xAnalysis (FRFA) in this Report and Order conforms to the RFA, as amended by the Contract  xwith America Advancement Act of 1996 (CWAAA), Public Law No. 104121, 110 Stat. 847  X#-(1996).#l yO-  OԍxSubtitle II of the CWAAA is "The Small Business Regulatory Enforcement Fairness Act of 1996" (SBREFA), codified at 5 U.S.C.  601 et seq.  X-X` hp x (#%'0*,.8135@8:backbone connections; and T1 common carrier links in rural areas. The new rules will also  xzpermit frequency hopping spread spectrum systems and wideband, multilateration Location  xLMonitoring Service (LMS) systems to operate within the same frequency band with decreased potential for mutual interference problems.  XH-  l X` hp x (#%'0*,.8135@8:the conditions of a temporary waiver that permits them to manufacture fixed, pointtopoint"#'",N(N(ZZ%"  xspread spectrum systems in the 2450 MHz band without a limit on directional antenna gain. All  xof these companies were notified at the time the waivers were granted that the waivers would expire upon the date of final action in this proceeding.  X-  xE70. The rules adopted in this R&O will apply to any entities manufacturing equipment  x/for unlicensed Part 15 spread spectrum transmitters. The Commission has not developed a  xdefinition of small entities applicable to manufacturers of spread spectrum transmitters.  xTherefore, the applicable definition of small entity is the definition under the Small Business  xKAdministration ("SBA") rules applicable to manufacturers of "Radio and Television Broadcasting  x]and Communications Equipment". According to the SBA's regulations, radio frequency  X - x manufacturers must have 750 or fewer employees in order to qualify as a small business. l {O -ԍxSee 13 C.F.R.  121.201, Standard Industrial Classification (SIC) Code 3663.  xCensus Bureau data indicates that there are 858 companies in the United States that manufacture  xradio and television broadcasting and communications equipment, and that 778 of these firms  X -have fewer than 750 employees and would be classified as small entities. Zl {O-  ԍxSee U.S. Department of Commerce, 1992 Census of Transportation, Communications and Utilities (issued May 1995), SIC category 3663.  X -X` hp x (#%'0*,.8135@8:point operations may employ transmitting antennas with directional gain greater than 6 dBi  x provided the maximum peak output power of the intentional radiator is reduced by 1 dB for every 3 dB that the directional gain of the antenna exceeds 6 dBi.  x=(ii) Systems operating in the 57255850 MHz band that are used exclusively for fixed, pointto x>point operations may employ transmitting antennas with directional gain greater than 6 dBi without any corresponding reduction in transmitter peak output power.  xy(iii) Fixed, pointtopoint operation, as used in paragraphs (b)(3)(i) and (b)(3)(ii) of this section,  xLexcludes the use of pointtomultipoint systems, omnidirectional applications, and multiple co x/located intentional radiators transmitting the same information. The operator of the spread  xspectrum intentional radiator or, if the equipment is professionally installed, the installer is  xresponsible for ensuring that the system is used exclusively for fixed, pointtopoint operations.  xMThe instruction manual furnished with the intentional radiator shall contain language in the installation instructions informing the operator and the installer of this responsibility."#'),N(N(ZZ%"Ԍ xԙ(4) Systems operating under the provisions of this section shall be operated in a manner that  xensures that the public is not exposed to radio frequency energy levels in excess of the  X-Commission's guidelines. See  1.1307(b)(1) of this Chapter.  x](c) In any 100 kHz bandwidth outside the frequency band in which the spread spectrum  xLintentional radiator is operating, the radio frequency power that is produced by the intentional  x?radiator shall be at least 20 dB below that in the 100 kHz bandwidth within the band that  xLcontains the highest level of the desired power, based on either an RF conducted or a radiated  xmeasurement. Attenuation below the general limits specified in Section 15.209(a) is not required.  xIn addition, radiated emissions which fall in the restricted bands, as defined in Section 15.205(a),  xmust also comply with the radiated emission limits specified in Section 15.209(a) (see Section 15.205(c)).  x-(d) For direct sequence systems, the peak power spectral density conducted from the intentional  xradiator to the antenna shall not be greater than 8 dBm in any 3 kHz band during any time interval of continuous transmission.  x<(e) The processing gain of a direct sequence system shall be at least 10 dB. The processing gain  xrepresents the improvement to the received signaltonoise ratio, after filtering to the information  xjbandwidth, from the spreading/despreading function. The processing gain may be determined using one of the following methods:  x(1) As measured at the demodulated output of the receiver: the ratio in dB of the signaltonoise  xMratio with the system spreading code turned off to the signaltonoise ratio with the system spreading code turned on.  xz(2) As measured using the CW jamming margin method: a signal generator is stepped in 50  xLkHz increments across the passband of the system, recording at each point the generator level  x[required to produce the recommended Bit Error Rate (BER). This level is the jammer level. The  xoutput power of the intentional radiator is measured at the same point. The jammer to signal  xratio (J/S) is then calculated, discarding the worst 20% of the J/S data points. The lowest  x/remaining J/S ratio is used to calculate the processing gain, as follows: Gp = (S/N)o + Mj +  x=Lsys, where Gp = processing gain of the system, (S/N)o = signal to noise ratio required for the  xchosen BER, Mj = J/S ratio, and Lsys = system losses. Note that total losses in a system, including intentional radiator and receiver, should be assumed to be no more than 2 dB. * * * * *  xx(g) Frequency hopping spread spectrum systems are not required to employ all available hopping  xchannels during each transmission. However, the system, consisting of both the transmitter and  xthe receiver, must be designed to comply with all of the regulations in this section should the  x.transmitter be presented with a continuous data (or information) stream. In addition, a system  xemploying short transmission bursts must comply with the definition of a frequency hopping  xsystem and must distribute its transmissions over the minimum number of hopping channels specified in this section."%'*,N(N(ZZ%"Ԍ x[ԙ(h) The incorporation of intelligence within a frequency hopping spread spectrum system that  xpermits the system to recognize other users within the spectrum band so that it individually and  x,independently chooses and adapts its hopsets to avoid hopping on occupied channels is permitted.  xThe coordination of frequency hopping systems in any other manner for the express purpose of  xavoiding the simultaneous occupancy of individual hopping frequencies by multiple transmitters is not permitted. * * * * * "H+,N(N(ZZ"  S-#&J\  P6Q&P#+ APPENDIX C ă  ]- XX   XXX w  FEDERAL COMMUNICATIONS COMMISSION Equipment Authorization Division 7435 Oakland Mills Road Columbia, MD 21046 Telephone: (301) 7251585  Facsimile: (301) 3442050 T  S-TGuidance on Measurements for Direct Sequence Spread Spectrum Systems T(X Part 15 of the FCC Rules provides for operation of direct sequence spread spectrum transmitters. Examples of devices that operate under these rules include radio local area networks, cordless telephones, wireless cash registers, and wireless inventory tracking systems. The Commission frequently receives requests for guidance as to how to perform measurements to demonstrate compliance with the technical standards for such systems. No formal measurement procedure has been established for determining compliance with the technical standards. Such tests are to be performed following the general guidance in Section 15.31 of the FCC Rules and using good engineering practice. The following provides information on the measurement techniques the Commission has accepted in the past for equipment authorization purposes. Alternative techniques may be acceptable upon consultation and approval by the Commission staff. The information is organized according to the pertinent FCC rule sections. Section 15.31(m): This rule specifies the number of operating frequencies to be examined for tunable equipment. Section 15.207: Power line conducted emissions. If the unit is AC powered, an AC power line conducted test is also required per this rule. Section 15.247(a)(2): Bandwidth. Make the measurement with the spectrum analyzer's resolution bandwidth (RBW)=100kHz. In order to make an accurate measurement, set the span>>RBW. Section 15.247(b): Power output. This is an RF conducted test. Use a direct connection between the antenna port of the transmitter and the spectrum analyzer, through suitable attenuation. Set the RBW > 6 dB bandwidth of the emission or use a peak power meter. Section 15.247(c): Spurious emissions. The following tests are required : (1) RF antenna conducted test: Set RBW=100 kHz, Video bandwidth (VBW)>RBW, scan up through 10th harmonic. All harmonics/spurs must be at least 20dB down from the highest emission level within the authorized  S !-band as measured with a 100 kHz RBW.  S!-  (2) Radiated emission test: Applies to harmonics/spurs that fall in the restricted bands listed in Section 15.205. The maximum permitted average field strength is listed in Section 15.209. A preamp (and possibly a highpass filter) is necessary for this measurement. For measurements above 1GHz, set RBW=1MHz, VBW=10Hz, Sweep: Auto. If the emission is pulsed, modify the unit for continuous operation, use the settings shown above, then correct the reading by subtracting the peakaverage correction factor, derived from the appropriate duty cycle calculation. See Section 15.35(b) and (c)."&,,N(N(ZZ("ԌSection 15.247(d): Power spectral density. Locate and zoom in on emission peak(s) within the passband. Set RBW=3kHz, VBW>RBW, sweep=(SPAN/3kHz) e.g., for a span of 1.5MHz, the sweep should be  S-1.5x106Ġ3x103Ġ=500 seconds. The peak level measured must be no greater than +8dBm. If external attenuation is used, don't forget to add this value to the reading. Use the following guidelines for modifying the power spectral density measurement procedure when necessary.  S-MBullet ListXPXxFor devices with spectrum line spacing greater than 3kHz no change is required."0Bullet List"ƀ%  S-MBullet ListXPXxFor devices with spectrum line spacing equal to or less than 3kHz, the resolution bandwidth must be reduced below 3kHz until the individual lines in the spectrum are resolved. The measurement data must then be normalized to 3kHz by summing the power of all the individual spectral lines within a 3kHz band (in linear power units) to determine compliance."n0Bullet List"ƀ%  SH -MBullet ListXPXxIf the spectrum line spacing cannot be resolved on the available spectrum analyzer, the noise density function on most modern conventional spectrum analyzers will directly measure the noise power density normalized to a 1Hz noise power bandwidth. Add 34.8dB for correction to 3kHz."b0Bullet List"ƀ%  S -MBullet ListXPXxShould all the above fail or any controversy develop regarding accuracy of measurement, the Laboratory will use the HP89440A Vector Signal Analyzer for final measurement unless a clear showing can be made for a further alternate." 0Bullet List"ƀ%  Section 15.247(e): Processing Gain. The Processing Gain may be measured using the CW jamming margin method. Figure1 shows the test configuration. The test consists of stepping a signal generator in 50kHz increments across the passband of the system. At each point, the generator level required to produce the recommended Bit Error Rate (BER) is recorded. This level is the jammer level. The output power of the transmitting unit is measured at the same point. The Jammer to Signal (J/S) ratio is then calculated. Discard the worst 20% of the J/S data points. The lowest remaining J/S ratio is used when calculating the Processing Gain. In a practical system, there are always implementation losses which degrade the performance below that of an optimal  S-theoretical system of the same type. Losses occur due to nonoptimal filtering, lack of equalization, LO phase noise, "corner cutting in digital processing", etc. Total losses in a system, including transmitter and receiver, should be assumed to be no more than 2dB.  SP-The signal to noise ratio for an ideal noncoherent receiver is calculated from:  S-(1)PxPe = e((S/N)o)  S-where :xPe = probability of error (BER)  S-P x(S/N)o = the required signal to noise ratio at the receiver output for a given Pxreceived signal quality This is an example. You should use the equation (or curve) dictated by your demodulation scheme.  S!-Ref.: Viterbi, A. J. Principles of Coherent Communications, (New York: McGrawHill 1966), Pg. 207  Figure 1  Figure 1 Using equation (1) shown above, calculate the signal to noise ratio required for your chosen BER. This value and the measured J/S ratio are used in the following equation to calculate the Processing Gain (Gp) of the system.  Q&%-PxGp=(S/N)o+Mj+Lsys  S&-where:Px(S/N)o = Signal to noise ratio  S'-PxMj =  J/S ratio  S(-PxLsys = System losses.  Sd)-Ref.: Dixon, R., Spread Spectrum Systems (New York: Wiley, 1984), Chapter 1."d)-.**/+" y!? Fx0*xddspread4.bmp .? y$XX%%XX!$$  ]<!$.  ]<$XXXX%%!$$ ALTERNATIVE TEST PROCEDURES T(X If antenna conducted tests cannot be performed on this device, radiated tests to show compliance with the various conducted requirements of Section 15.247 are acceptable. As stated previously, a preamp must be used in making the following measurements. 1) Calculate the transmitter's peak power using the following equation: 1dddddddd (1) 1dddddddd (1)   S-!xXdddddddO ddh.x#E = { SQRT 30 OVERLINE PG } over d &J\  P6Q&P&J\  P6Q&P&J\  P6Q&PE:4PG@d   O:430ߕ$XX%%3!3!%%!!3!$ "!3! "!3! $!3!  S-3!3!%%XX%%PWhere:xE is the measured maximum field strength in V/m utilizing the widest available RBW. PxG is the numeric gain of the transmitting antenna over an isotropic radiator. Pxd is the distance in meters from which the field strength was measured.  S-PxP is the power in watts for which you are solving:AxX$dddddddddd.xP = { (Ed) SUP 2 } OVER {30G } &J\  P6Q&P&J\  P6Q&P&J\  P6Q&PPY4Ed@G 4(%4)zzb|2?@30ߎ $XX%%o3!3!%%"A3!$ "A3! "A3! $A3! 3!3!%%"XX%%2) Measure the power spectral density as follows: XPA. Tune the analyzer to the highest point of the maximized fundamental emission. Reset the analyzer to a RBW=3kHz, VBW>RBW, span=300kHz, sweep=100 sec.ƀ% XPB. From the peak level obtained in (A), derive the field strength, E, by applying the appropriate antenna factor, cable loss, preamp gain, etc. Using the equation listed in (1), calculate a power level for comparison to the +8dBm limit.