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February 14, 2002


Re: Revision of Part 15 of the Commission’s Rules Regarding Ultra-Wideband Transmission Systems (ET Docket No. 98-153)

I believe that ultra-wideband (“UWB”) technologies are destined to play a significant role across America’s communications landscape. UWB devices will save firefighters’ and policemen’s lives, prevent automobile accidents, assist search-and-rescue crews in seeing through the rubble of disaster sites, enable broadband connections between our home electronics, and allow exciting new forms of communications in the years ahead. Indeed, the U.S. Government already uses UWB extensively to make our soldiers, airport runways, and highway bridges safer, and so much more is on the horizon.

But opinion differs greatly on the interference effect of the widespread use of UWB technologies by the public. If interference does occur, it could conceivably affect critical government and non-government spectrum users. Our national defense and several safety-of-life systems depend on bands that have the potential to be impacted by UWB devices.

Because the effects of widespread use of UWB are not yet fully known, and interference could impact critical spectrum users, I will support, albeit somewhat reluctantly, the ultra-conservative ultra-wideband step we take today. The limits we place on UWB are designed to reduce the interference risks associated with the technology to levels far, far below those placed on technologies that place energy into narrower portions of the spectrum. These limits are intentionally at the extreme end of what FCC engineers – the best spectrum engineers in the country – believe necessary. They were agreed to because of the unique and novel impact of this technology, and should not be taken as precedent for any other interference dispute – involving other Part 15 devices, government bands, or other new technologies.

I strongly support the Commission’s decision to initiate a further NPRM within 6 to 12 months. My hope is that we can phase in this exciting new technology with some sense of urgency, proceeding through the conduct of expeditious step-by-step authorizations from the Commission for applications that are waiting in line. We owe it to our citizens and our businesses to determine, just as quickly as we prudently can, whether we can loosen the ultra-conservative restrictions we put in place today. So I urge all parties, especially our government colleagues, to start collecting data immediately so we can have as much data as possible, including information about their own use of UWB and how UWB effects their other uses of the spectrum, in a timely manner.

Delay, even when advisable, still has costs. If we find that our rules are too restrictive and we fail to correct them promptly, the price may be that the United States loses its leadership role in ultra-wideband. The technology could easily move overseas, where, I wager, would-be competitors are only too eager to get a step ahead of the USA. Let’s be cognizant, too, of the need to proceed so as to inflict minimal harm on U.S. commercial interests. Some companies may be seriously inhibited by the limitations being announced. We should not expect that they can afford to stand patiently by while testing and approval proceeds at glacial pace. I hope that all of us, whether in government or the private sector, will approach our nation’s deployment of ultra-wideband with the sense of urgency that it so clearly merits.

Finally, I want to welcome Ed Thomas to the FCC. He started with ultra-wideband – a trial by fire! I look forward to working with you. I also want to thank Julie Knapp and the whole OET team for their dedication and hard work on this item. Lots of weekends and late nights went into this Order.