Before the
FEDERAL COMMUNICATIONS
COMMISSION
Washington, DC 20554
|
In the Matter of Revision of
Parts 2 and 15 of the Commission’s Rules to Permit Unlicensed
National Information Infrastructure (U‑NII) Devices in the 5 GHz Band |
) ) ) ) ) ) ) |
ET Docket No. 03-122 RM - 10371 |
COMMENTS OF THE NATIONAL
TELECOMMUNICATIONS
AND INFORMATION
ADMINISTRATION
Michael D. Gallagher Kathy
D. Smith
Acting Assistant
Secretary for Chief
Counsel
Communications and
Information
Fredrick R. Wentland
Associate
Administrator
Office of Spectrum
Management
Charles T. Glass
Telecommunications
Specialist
Office of Spectrum
Management
Edward F. Drocella
Robert L. Sole
Electronics
Engineers
Office of Spectrum
Management National
Telecommunications and
Information
Administration
U.S.
Department of Commerce
Room
4713
1401
Constitution Avenue, N.W.
Washington,
DC 20230
(202)
482-1816
October 1, 2003
TABLE OF CONTENTS
Section
EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . .
I. INTRODUCTION . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . .
II. NTIA SUPPORTS THE COMMISSION’S PROPOSAL TO
CHANGE
THE U.S. TABLE OF FREQUENCY
ALLOCATIONS TO
ACCOMMODATE
THE NEEDS OF FEDERAL AND NON-FEDERAL
GOVERNMENT RADIO
SERVICES OPERATNG IN THE 5 GHZ
FREQUENCY RANGE. .
. . . . . . . . . . . .
III. NTIA SUPPORTS THE COMMISSION’S PROPOSAL TO
MODIFY
THE
PART 15 RULES TO ACCOMMODATE EXPANDED USE OF
U-NII
DEVICES. . . . . . . . . . . . . . . . . .
IV. NTIA SUPPORTS THE COMMISSION’S PROPOSAL TO
REQUIRE
U-NII
DEVICES OPERATING IN THE 5.25-5.35 GHZ AND
5.47-5.725
GHZ FREQUENCY BANDS TO EMPLOY DFS TO AVOID
INTERFERING WITH
CRITICAL FEDERAL RADAR OPERATIONS .
V. NTIA IS LEADING A PROJECT TEAM WITH GOVERNMENT
AND
INDUSTRY REPRESENTATIVES TO DEVELOP COMPLIANCE
MEASUREMENT PROCEDURES
FOR DFS ENABLED U-NII
DEVICES.
. . . . . . . . . . . . . .
VI. NTIA SUPPORTS IMPLEMENTING TPC IN BOTH THE
5.25-5.35 GHZ
AND 5.47-5.725 GHZ
FREQUENCY BANDS .
VII. NTIA RECOMMENDS THAT U-NII DEVICES OPERATING
IN
THE 5.25-5.35 GHZ
FREQUENCY BAND THAT ARE
IMPORTED
SHOULD ADHERE TO THE COMMISSION’S
PROPOSED
TRANSITION SCHEDULE FOR DOMESTIC DEVICES
VIII. IN ORDER TO AVOID CONFUSION, NTIA RECOMMENDS
THAT ADDITIONAL
DEFINITIONS BE INCLUDED IN THE
COMMISSION’S
RULES FOR U-NII DEVICES .
IX. CONCLUSION
. . . .
DESCRIPTION OF RADAR USAGE IN THE 5 GHZ
FREQUENCY
RANGE . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . .
. . . . . . . APPENDIX A
DRAFT MEASUREMENT PROCEDURES FOR DFS EQUIPPED
U-NII DEVICES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . APPENDIX B
SCHEDULE OF PROJECTED MILESTONES FOR 5 GHZ
PROJECT
TEAM . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APPENDIX C
The National Telecommunications and
Information Administration (NTIA) commends the Federal Communications
Commission (Commission) for initiating this proceeding to expand the
options for unlicensed device use, and particularly, linking such
expanded use to adoption of new technologies for active
interference-avoidance. NTIA agrees with
the Commission regarding the significant benefits to the economy,
businesses, consumers, and government agencies that could be gained by
allowing unlicensed devices to operate in the 5.47-5.725 GHz frequency
range, provided that such operation is tied to effective implementation
of active interference-avoidance techniques. NTIA
would also like to commend the Commission for its careful consideration
and review of existing Part 15 Rules in the 5.25-5.35 GHz band as well
as consideration of the federal government and private sector spectrum
requirements in the 5 GHz frequency range. NTIA
provides the following comments to specific issues raised in the
Unlicensed-National Information Infrastructure (U-NII) Notice of
Proposed Rulemaking (NPRM) that may have an impact on critical federal
systems used for scientific research, aviation, and national defense.
NTIA
supports the Commission’s proposals to upgrade the frequency
allocations of federal government Radiolocation Service, and federal
and non-federal government Space Research Service (active) and the
Earth Exploration-Satellite Service (active) in the 5 GHz frequency
range. Upgrading these allocations is
consistent with the allocations adopted internationally, and will
provide the necessary protection to federal systems supporting national
defense as well as federal and non-federal commercial and scientific
operations. In addition to the allocation
upgrades in the 5 GHz frequency range, several footnotes were adopted
at the World Radiocommunication Conference 2003 (WRC-2003). There were also modifications made to several
existing footnotes in the 5 GHz frequency range. The
Commission’s proposal to modify the U.S. Table of Frequency Allocations
did not include the new footnotes or the modifications to existing
footnotes that were adopted at WRC-2003. NTIA
believes that the modifications to the U.S. Table of Frequency
Allocations should include the appropriate new footnotes and
modifications to existing footnotes adopted at WRC-2003. NTIA
believes that the inclusion of these new footnotes and the
modifications to existing footnotes are necessary because of the
complex sharing arrangements that exist between the diverse federal and
non-federal government radio services operating in the 5 GHz frequency
range.
NTIA
supports the Commission’s proposal to modify the Part 15 Rules to allow
U-NII devices to operate in the 5.47-5.725 GHz band on a
non-interference basis. Utilization of the
mitigation measures proposed in the NPRM along with the additional 255
MHz of spectrum for U-NII devices to spread across will provide
protection to vital government systems. The
Commission’s proposal will also meet current industry needs as well as
future growth in the radio local area network radio local area network
(RLAN) industry which has proven to be one of the few technology
success stories in the current economy.
NTIA concurs with the Commission’s proposal that Dynamic Frequency Selection (DFS) should be required in the existing 5.25-5.35 GHz U-N