4. Analysis

4.1 Issue 2.a - Adequacy of Definitions

4.2 Issue 2.b - Benefits and Risks

4.3 Issue 3.a - Demand and Sharing

4.4 Issue 4.a - International Standards

4.5 Issue 5.a and 5.b - Preferences for NZ

4.6 Issue 6.a - Interim Licensing

4.7 Summary of Outcomes

The Ministry released Engineering Discussion paper on UWB devices raised a range of issues for comment. This section discusses these issues in relation to the submissions and other inputs received.

4.1 Issue 2.a - Adequacy of Definitions

The Ministry invites comments on the adequacy of the above definitions and any proposals for alternative definitions for UWB technology.
Of the 30 submitters, 15 generally agreed with the proposed definitions, one saw limitations and proposed an alternative, while the rest had no comments.

BCL suggested that the definition could unintentionally include some systems which were not regarded as UWB such as broadband services at low frequencies. They proposed an alternative which was summarised as:

(BW > 500 MHz) AND (FBW > 20%) AND (PSDeirp < -50 dBW/MHz)

Communications & Control and Freescale suggested there could be problems in measuring the out of band emissions especially when the UWB device is part of other digital equipment which would have comparable emc emissions.

NZDF suggested the power definition should be qualified with the statement (measured at the 10 dB point).

W & A suggested a slightly modified definition:

A UWB radio system or device is one which utilises radiofrequency emissions with bandwidths greater than or equal to 500 MHz or with a fractional bandwidth greater than or equal to 20% of the nominal centre frequency of the defined occupied bandwidth.

The RBA expressed caution over the adequacy of the RC Act to manage interference issues when it is the result of accumulated power from many devices.

NZART considered the reference to UWB operating below the noise floor was misleading considering the true noise floor is -108 dBm/MHz while the UWB permitted e.i.r.p. is -41.3 dBm/MHz.

Conclusions

There was general agreement with the adequacy of definitions for UWB technology with a small number of submitters suggesting slight modifications or alternatives. The Ministry intends to discuss these suggestions at the ITU-R TG 1/8 - international standards meeting of UWB.

4.2 Issue 2.b - Benefits and Risks

The Ministry invites comments on the potential benefits and risks associated with the introduction of applications using UWB technology.

4.2.1 Benefits

Almost all submitters commented on the risks involved in permitting UWB devices but only a few made specific comments on the benefits.

There was general acknowledgement that the intermittent use of UWB imaging devices for safety of life purposes was an acceptable compromise. Several suggested that their use be restricted to certified operators. CPL also suggested a notification system to avoid unnecessary fault finding effort by those who may experience interference. In general however, the public safety benefits of UWB imaging devices were recognised by many submitters.

The use of vehicle collision avoidance radar also has a safety of life component which was promoted by those in the industry.

Economic gains in the supply chain, IT infrastructure and the recreational and entertainment value experienced by the end user were seen to be the primary benefits from the use of communication devices using UWB technology. In addition, UWB was seen to provide opportunities for the creation of new applications due to its higher data rate capability. The net economic benefits of using UWB communication devices compared with other solutions, as reported in the Ofcom report, were acknowledged in a few of the submissions.

Intel also identified the benefit of higher spectrum utilisation which is provided by UWB technology.

W & A suggested that the benefits have been overstated compared with the capabilities of other emerging technologies such as WiMax, WiBro and Bluetooth.

4.2.2 Risks

The most frequently quoted risk was the insidious deterioration of the noise floor due to the ubiquitous use of UWB devices for communications and vehicular radar. Submissions from many operators of radio systems operating under both radio licences and spectrum licences expect to have access down to signal levels approaching the natural noise floor. This includes an expectation that the spectrum would be managed to ensure it was shared amongst legitimate users in such a way that there was minimal increase to this noise floor.

This expectation was expressed by many of the holders of Management Rights even though it was acknowledged that the Management Right Power Floor was specified as -50 dBW. BCL noted that any certification of a GURL must take into account technical compatibility with existing licences under clause 12 of the Radio regulations, which provides some protection to management right holders.

This concern was expressed specifically by operators in spectrum bands below the 3.1 to 10.6 GHz UWB band such as cellular and VHF maritime radio operators. The effect on these services is very dependent on the emission mask used in the analysis with a strong preference expressed for the Ofcom mask which has the most stringent roll off across these bands. MSA estimated that the PFD from UWB in a nearby suburb could increase the noise floor at a base receive site to a level 24 dB above the planned receive level, assuming the FCC emission mask is adopted. It is noted that this is a safety of life service which may not be able to fulfil its role with this level of interference.

Operators in bands within the 3.1 to 10.6 UWB band such as C band FSS, FWA, MBWA and WiFi are particularly exposed to interference. Chip suppliers such as Intel and Freescale noted how interference mitigation methods such as dynamic notching and dynamic frequency selection could be used to avoid services operating in the vicinity. Until these techniques are proven, there is general concern backed up by a number of models which identify potential interference levels.

Satellite services operating within the 22 to 29 GHz UWB band are also shown to be vulnerable to interference from UWB vehicular radar. Particularly sensitive are Earth Exploration Satellite Services (EESS) that operate at the lowest possible signal levels, which cannot overcome interference by way of increasing its transmitter power. EESS depend on the unique atmospheric properties at 23.6 to 24 GHz to provide essential data for weather forecasting which is not available from any other monitoring systems. The emissions from many UWB devices have the potential to cause serious interference to such a sensitive service.

Radio Astronomy (RA) is also vulnerable to interference from nearby UWB devices. To some degree this may be mitigated by RA sites generally being located remote from the main centres of UWB use.

Another risk identified was that UWB devices could become established in New Zealand before a suitable regulatory framework was established. This is particularly likely in the case of importation of used motor vehicles that include UWB devices, which the importer may be unaware of.

Mitigation of Risks

A number of submitters suggested that any interference issues could be managed and minimised using a variety of mitigation methods. One submitter, Freescale, suggested that the potential interference from UWB had been overstated.

Proposed mitigation techniques include:

• Introducing the most stringent emission mask which is technically possible below 3.1 GHz to protect services operating in this spectrum. There was general support for the Ofcom mask with many investigations showing that this provided acceptable protection to the vulnerable services while the FCC mask did not.
• Ensuring the maximum attenuation of emissions above the horizon from UWB vehicular radar. The FCC rules have a staged introduction of vertical radiation pattern limits which culminate in a limit of -35 dB at 30° above the horizon from the year 2014.
• Limiting the market penetration of vehicle radar to 7% as recommended for Europe and accommodating further growth in the 79 GHz band.
• Implementing fixed notching to ensure the UWB device avoids the known sensitive bands such as that used for EESS. Although Intel provided a spectrum display of an applied notch, it is unclear from the information provided how effective this technique would be in avoiding interference and the effect it would have on the cost and performance of the UWB device.
• Implementing dynamic notching to ensure the UWB device does not transmit power in a band where it detects other transmitters operating.
• Confining UWB communication devices to operations above 6 GHz. The current standards for the two major UWB technologies, Multi-band OFDM and Direct Sequence UWB, both require transmissions below 6 GHz with optional operation above 6 GHz. Since it has been shown in interference studies that the most vulnerable services operate below 6 GHz, the W & A submission proposed that UWB transmissions should only operate within the 6 to 10.6 GHz band. This is also one of the options considered in the Ofcom report.

Conclusions

Many submitters commented on risks associated with the introduction of UWB devices and only a few made specific comments on benefits, which include; public safety benefits of UWB imaging devices, safety of life aspects of vehicular radar and the economic gains in the supply chain, IT infrastructure and the recreational value experienced by the end user in relation to UWB communication applications. Some of the risks raised by the submissions include; the deterioration of the noise floor, the sensitive nature of passive services such as EESS, RA and the risks associated with not having a suitable regulatory framework for UWB. A number of submitters also proposed several risk mitigation techniques. The Ministry intends to address these issues by way of studies it plans to carry out, which are discussed in Section 5 of this document.

4.3 Issue 3.a - Demand and Sharing

The Ministry invites comments on the future demand for UWB imaging, vehicular radar and wireless communication system applications in New Zealand, along with comments on any sharing issues. The Ministry also invites views on the existing and planned receive-only Radio Astronomy use in the 23.6 - 24.0 GHz band in New Zealand.

Many of the submitters considered that they had already commented on sharing issues and future demand under 2b. The following additional issues were raised under 3a:

• C & C recommended that priority be given to emergency, military and anti-terrorist devices over consumer devices when framing UWB regulations.
• The MTA reiterated the inevitability of vehicle equipment arriving in NZ irrespective of the absence of any legislation. They also noted the necessity for information on any regulations to be written in a non-technical form to facilitate compliance by the motor industry.
• Vodafone recommended that the risk to future 4G mobile services be accounted for in any UWB regulation.
• A number of submissions suggested that protection of the EESS and RA band 23.6 to 24 GHz is best provided by limiting vehicle radar to the alternative 79 GHz band.

4.4 Issue 4.a - International Standards

The Ministry invites comments on the FCC proposals for different UWB applications and their applicability to New Zealand.
Comments are also invited on the UK proposal for UWB indoor communication devices in comparison to the FCC limits and the ETSI limits.
Further, comments are invited on the EU proposal on vehicular radar and the applicability of the proposed parameters to New Zealand.

There was a wide range of opinions on the action that should be taken by New Zealand to accommodate the current and proposed standards. These can be summarised as:

These opinions were often supported by detailed interference analysis and accompanying papers. In addition, several suggested additional control methods, including:

• Reducing the power of UWB communication devices from -41.3 dBm to -55 dBm, in line with current studies being undertaken by CEPT. This was specifically rejected by another submission as a change which would hamper harmonisation.
• Limiting UWB communication devices to greater than 6 GHz on the grounds that the most vulnerable services such as MBWA and FSS operate below 6 GHz.
  Limiting operation of UWB communication devices to indoor use to minimise the impact on the outdoor noise floor.
• Registering the approved UWB products rather than issuing a radio or spectrum licence to ease compliance monitoring.
• Permitting vehicular radar which meets both the European (79 GHz) and FCC (24 GHz) rules to minimise compliance and border management issues.
• Limiting vehicular radar to FM-CW technologies for better spectrum utilisation and minimal interference issues.

The Ministry's participation at the ITU-R TG1/8 meeting in May 2005 also highlighted that for UWB communications:

• only the FCC emission mask is current
• the ETSI slope mask was only used as a starting point for impact studies and is not an agreed European emission mask
• the Ofcom mask was only a proposal to raise debate and is not an agreed emission mask within the UK, let alone Europe
• there is a proposed Scandinavian mask (which effectively only considers the 6-10 GHz band for UWB communications)
• Europe was aiming to work together to bring a new proposed mask to the TG 1/8 meeting in October 2005

Conclusions

There was a wide range of opinions on the current and proposed standards. The Ministry's participation at the ITU-R TG1/8 meeting in May 2005 also confirmed that for UWB communications only the FCC emission mask has been implemented. The Ministry plans to continue its participation at international standards bodies to monitor the evolving standards for UWB technology.

4.5 Issue 5.a and 5.b - Preferences for NZ

The Ministry invites comments from industry on the extent to which UWB should be allowed in New Zealand and preferred timings.
The Ministry invites comments on industry's preferred options for licensing UWB and timings.

Many submissions combined their comments on Issues 5a and 5b. The majority supported the use of UWB imaging devices under some sort of controlled licensing regime. Options suggested included the granting of individual radio licences, limiting the use to certified operators and the approval of equipment.

There is a wide variety of opinions on the action that NZ should take on UWB communication devices. Most submitters accepted the inevitable introduction of such devices once international standards and regulation guidelines have been developed. Three submitters, EMC, Freescale and Intel, promoted the immediate permitting of these devices to gain the maximum benefits and minimise the negative impact of compliance costs. However many used the terms "phased approach", "progressive licensing", "no urgency", "cautious approach", "trial licenses" and "limited licensing" suggesting a desire for the Ministry to ensure existing systems were sufficiently protected from interference before introducing general licensing for these devices.

UWB vehicular radar at 22 to 29 GHz was seen as an immediate issue. Those in the motor trade saw an immediate need for allowing open access for FCC approved equipment because of the inevitable importation of these devices with used cars. There was opposition from Northrop and SIA who have an interest in satellite services. They considered that these devices represented an unacceptable risk to EESS and RA services and noted that it would be impossible to reverse their release if the outcome was unacceptable interference. It was acknowledged by many submitters that New Zealand would have to accept the outcome of any international resolution to these issues.

Conclusions

The majority of the submitters supported the use of UWB imaging devices under a controlled licensing regime with suggested options including individual radio licences and limiting the use to certified operators. A variety of views were expressed re: licensing options for UWB communication devices, with only a small number of submitters proposing immediate licensing. Those in the motor trade saw an immediate need for allowing UWB vehicular radar at 24 GHz in NZ whilst international satellite service organisations opposed that view.

4.6 Issue 6.a - Interim Licensing

The Ministry invites comments on the strategy of creating interim licences for UWB applications with low potential to cause interference on a case-by-case basis, until international standards and compatibility studies are more mature.

Many of the submissions chose not to comment on the issue of interim licensing. Of those who did, 14 were in favour of interim licensing of devices with low interference potential. Some placed conditions on their support, especially those wishing to protect the EESS and RA bands. In addition, MSA, Siemens, and Woosh did not support any licensing of communication devices at this time. W & A did not support the licensing of any devices below 6 GHz.

Of those who did not support interim licensing, MTA and SARA wished to see long term licensing of vehicular radar now. WiQuest supported full licensing of devices now as the best pragmatic approach although they did suggest a restriction to indoor use.

TNZ did not support the licensing of any UWB devices at this stage.

C & C, TVNZ and Woosh also supported the concept of experimental licenses for ongoing research and trials.

BCL supported individual licensing of imaging devices, an interim GURL for vehicular radar and if a GURL was to be issued for communications devices then the most stringent emission mask possible should be a condition of the licence. \

Conclusions

There were varying degrees of support for interim licensing from many submitters. Whilst a small number of submitters did not support licensing of any UWB devices at present, another group of submitters proposed going ahead with full licensing.

4.7 Summary of Outcomes

4.7.1 Imaging Systems

In the submissions received, there is general acknowledgement of the safety of life and security benefits from the use of imaging devices using UWB technology. There is also acknowledgement that the potential for interference is low as the expected number of these devices is low and their usage intermittent.

Imaging devices may operate over a wide range of frequency bands below 10.6 GHz depending on their specific application. The services which are considered most vulnerable to interference from these devices are:

• TV and FM broadcasting
• Maritime VHF services including the maritime distress channel
• 2G, 3G and 4G cellular mobile operators
• Mobile Broadband Wireless Access (MBWA) services at 2 and 3.5 GHz

Limiting access to UWB imaging devices to certified operators was seen as an appropriate method of controlling the interference risk and managing potential misuse.

Conclusions

There was general consensus that provided the devices can be shown to have a low potential for interference, suitable licences should be immediately made available for UWB imaging devices.

4.7.2 Vehicular Radar Using UWB

The most pressing UWB application for New Zealand is collision avoidance vehicular radar. Vehicular radar devices are seen to have two major benefits. One is improved safety on the roads and the other is the economic benefits it brings to the electronics and motor vehicle industries. This equipment is already available from vehicle manufacturers and the automotive industry is anxious to have the regulations in place to facilitate importation. The Ministry has received several enquiries from automotive distributors in NZ, the Motor Industry Association of NZ and the Motor Trade Association of NZ concerning licensing options so that 24 GHz UWB vehicular radar enabled automobiles can be imported into New Zealand. They are aware that a failure to have appropriate approval, licensing and border controls in place will expose the market to a wide variety of products, much of it imported unwittingly with second hand cars.

The intentional emissions of the UWB vehicular radar spans the 21.625-26.625 GHz range and the services most vulnerable to interference from vehicular radar are seen to be satellite services. The Radio astronomy service, which operates within 23.6 to 24 GHz, uses very sensitive receivers, and is usually located in radio quiet areas remote from areas of high population. It is generally considered that their location will afford them protection from UWB communication devices.

The Earth Exploration Satellite Service (EESS), which includes Meteorological services, operates in the 23.6 to 24 GHz band. This service cannot be relocated to a different band because it utilises the unique physical properties of the current band. Also it cannot increase its operating power levels because it is a passive service with very sensitive receivers at the satellite. Suppliers and operators using the EESS services such as the New Zealand Meteorological Service have expressed concern that the unique benefits of this band could be lost if UWB devices were permitted to operate in this band. This band is already protected by current ITU rules and there is a strong international group who are promoting its continued protection.

Protection of the 23.6 to 24 GHz band is an international issue and the consensus of the submissions was for New Zealand to follow the ITU guidelines when they become available. However the urgency for definite regulation promoted by the vehicle industry conflicts with the longer time scale required to conclude the ITU studies.

To preserve the unique properties of the 24 GHz band and to award protection to EESS services, European countries have established conditions such as limiting the number of vehicles enabled with UWB collision avoidance radar at 24 GHz to 7% of the total vehicles in operation in each of these countries and limiting the sale of UWB vehicular radar devices using this band to no later than 30 June 2013. After this date, vehicular radar devices can only be deployed in the 79 GHz band.

Options for the way forward in order of the submitters' preference include:

1. Issuing licences for UWB vehicle radar at 79 GHz only. Note the current GURL already permits vehicular radar at 24 and 79 GHz using narrow band technology.
2. Issuing interim licensing for 24 GHz vehicular radar on the understanding that licences could be withdrawn if interference is shown to be a problem.
3. Issuing licences for 24 GHz vehicular radar with the condition that equipment must be installed and maintained by certified operators.
4. Limiting market penetration at 24 GHz to 7% as proposed for Europe.
5. Requiring equipment to avoid any radiation in the EESS band by using the sub-band 24 to 29 GHz or by providing a notch in the output at the EESS band.

Conclusions

The most pressing UWB application for New Zealand was recognised as collision avoidance vehicular radar and the automotive industry is anxious to have the regulations in place to facilitate importation. The services most vulnerable to interference from vehicular radar are seen to be passive satellite services and to award protection to these services European countries have established conditions for the introduction of 24 GHz vehicular radar in Europe. The Ministry plans to adopt the majority of these conditions for NZ.

4.7.3 Wireless Communications Systems

Wireless communications systems are seen to be the most significant use and "killer application" of UWB technology. A number of submissions noted that the economic benefits of licensing UWB communications devices could be significant within the consumer and business markets, referring to the Ofcom report which reported a net value in the UK of ₤2000m over the next 10 years. An additional benefit is the improved utilisation of the radio spectrum allocated to individual licensed services by sharing it with UWB devices. Submitters representing component and equipment suppliers promoted the need for immediate licensing being made available based on the FCC rules (as these had been well researched and provided a sound balance between existing and new technologies).

Other submitters saw ubiquitous UWB communication devices as a significant threat to existing individually licensed radio services operating within the same vicinity. Some submitters noted that a number of the services operating in the 3.1 to 10.6 GHz band such as mobile, fixed, MBWA and satellite space to earth systems are designed to operate down to a receive level approaching the natural noise level of -108 dBm/MHz. These were considered under threat from ubiquitous UWB devices operating at a radiated power level of -41.3 dBm in the same vicinity. Many submitters also saw services operating below 3.1 GHz threatened by the out of band FCC emission mask for UWB devices. These include TV and FM broadcasting, mobile radio and VHF maritime safety services.

Those services operating under a private management right considered their rights would be breached if UWB devices were permitted to operate across the spectrum specified in the management right. It was acknowledged that the power floor of the management right was -50 dBW but they noted that the nature of their systems meant that UWB devices may not be technically compatible and the systems could suffer from harmful interference if UWB were introduced.

A number of submissions noted the significant differences between the UK, Europe and USA emission masks. This added to the caution concerning the FCC rules and encouraged many to promote the most stringent mask (from Ofcom, UK). These concerns illustrated the need for greater confidence in the standards which should be possible once clearer guidance is available from the ITU.

As outlined under section 4.4 of this report, the Ministry's participation at the ITU-R TG1/8 meeting in May 2005 also highlighted that for UWB communications:

• only the FCC emission mask is current
• the ETSI slope mask was only used as a starting point for impact studies and is not an agreed European emission mask
• the Ofcom mask was only a proposal to raise debate and is not an agreed emission mask within the UK let alone Europe
• there is a proposed Scandinavian mask (which effectively only considers the band 6-10 GHz)
• Europe was aiming to work together to bring a new proposed mask to the meeting of TG 1/8 in October 2005

Options for the way forward in order of the submitters' preference include:

1. Not issuing any long term licences until there is greater international consensus. This however, has the associated risk of some devices entering the country and operating outside of any regulation
2. Providing licences for apparatus which has shown to meet the most stringent emission mask. Such equipment will be available once markets open up in the major trading blocks
3. Requiring dynamic notching to ensure the UWB device avoids spectrum in use in the geographic vicinity - this feature will only be available if it is required by some major markets
4. Limiting the radiated power level to -55 dBm/MHz, as was under study in Europe
5. Confining operation to spectrum above 6 GHz
6. Issuing a GURL now for equipment meeting FCC standards and creating an environment for greater economic benefit and innovation while minimising compliance costs

Conclusions

A number of submissions noted significant economic benefits of licensing UWB communications devices over the next 10 years. Submitters representing component and equipment suppliers promoted the need for immediate licensing. Other submitters saw ubiquitous UWB communication devices as a significant threat to their existing services. A number of submissions noted the significant differences between existing and proposed standards for UWB and the Ministry's participation at the ITU-R TG1/8 meeting in May 2005 also highlighted that only the FCC emission mask is current for UWB communication devices. The Ministry considers that at this stage a cautious approach is appropriate for licensing of UWB communication devices and any consideration of general licensing will be deferred until international standards are more mature.