Before the
DEPARTMENT OF COMMERCE
National Telecommunications and Information Administration
Washington, DC 20230
In the Matter of )
)
Request for Comments )
On Ultra-wideband )
Systems Testing Plan )
)
Comments of Motorola, Inc.
Motorola is in full support of the plan which has been developed by the National Telecommunications and Information Agency (NTIA) to characterize ultra-wideband signals and estimate their impact on existing systems. It is our opinion that the Institute of Telecommunications Sciences (ITS) ultra-wideband measurement plan as described is sound and will achieve its stated goals. There is one element, however, which we feel has been overlooked, and that is the focus of these comments. That element is the measurement of the effect of ultra-wideband emissions on standard terrestrial land mobile communications equipment.
One of the objectives of the ultra-wideband test plan is to "perform a limited set of measurements to validate the one-on-one interference analysis between UWB signals and selected Federal radio receivers, particularly radio navigation and safety-of-life systems." (1)
In Table 2 of Section 4.4 of this document, eleven candidate systems are listed of which three to four will be measured to determine what level of emissions is necessary for protection. The majority of these systems are aviation or satellite systems. None of them are terrestrial mobile communications systems.
Land mobile communications systems used by Federal agencies are of critical importance in fulfilling their safety-of-life missions. It is increasingly common for state, local, and Federal agencies to make use of commercial off-the-shelf (COTS) communications technologies. Many of the current technologies which Federal agencies may find themselves using within a few years (GSM, CDMA, Bluetooth, etc.) have wideband receivers of the kind expected to be most affected by ultra-wideband emissions. Motorola believes that at least one of the receiver protection measurements performed should examine a land mobile communications system of this type.
Motorola's review of the NTIA test plan has been, in general, very favorable. This plan could be improved by the addition of at least one land mobile communications technology to the list of receiver protection measurements that is being planned. Motorola stands ready to offer any assistance necessary to include these measurements into the NTIA test plan.
Respectfully Submitted,
Motorola, Inc.
/S/_______
Leigh M. Chinitz
Assistant Director
Telecommunications Strategy and Spectrum
Motorola, Inc.
1350 I Street, N.W.
Washington, D.C. 20005
(202) 371-6900
July 17, 2000
1 Ultra-Wideband Signals for Sensing and Communication: A Master Plan for Developing Measurement Methods, Characterizing the Signals and Estimating Their Effects on Existing Systems, ITS Ultra-Wideband Measurement Plan (Master Plan Task 1.2), June 14, 2000, section 2.