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www.marcus-spectrum.com




             Michael J. Marcus, Sc.D., F-IEEE

                     Former Associate Chief for Technology
                   FCC Office of Engineering and Technology

                    Director, Marcus Spectrum Solutions, LLC
                                       Cabin John, MD, USA
                                  www.marcus-spectrum.com

                                           Adjunct Professor
             Department of Electrical & Computer Engineering
                                                Virginia Tech

                                                                N3JMM/
                                                                 7J1AKO


Technology                 Regulation
Overview
 Will review interaction of regulation and technology in wireless
  technology
 How a bipartisan political movement for deregulation
  unexpectedly removed roadblocks that kept a promising
  wireless technology & underutilized bands locked in “Pandora’s
  box”
   Serendipity and (generally good) unexpected consequences
   Today’s ubiquitous Wi-Fi and Bluetooth and other useful
     niche applications




                Technology               Regulation
Why Is Wireless Different than Other
Technologies?

 Basic spectrum policy concepts were formed in
  aftermath of Titanic sinking 100 years ago
 Many regulators resemble Soviet economic planners,
  projecting demands and allocating resources
 Classically, entrepreneurs, “disruptive innovation” and
  niche applications get little attention
   Wi-Fi started as a niche application!


             Technology            Regulation
4


Birth of Unlicensed in US
            US legislation does not provide
             explicitly for unlicensed use

            1st system was a Philco remote control
             system for radio receivers in late 30s

            FCC ruled that since it was unlikely to
             cause interference license was not
             needed

            Subsequent legislation has noted
             unlicensed but never explicitly
             authorized it
              ARRL claims FCC has no legal basis for
               unlicensed
    Technology              Regulation
The Strange Case of iTrip:                       5



      T
      The Classic Problem for Unlicensed in Some Countries

                                     Prescriptive nature of spectrum
                                      regulation in many countries held
                                      back unlicensed innovation, e.g.
                                     iTrip is a low power FM transmitter
                                      user to connect iPod music to
                                      nearby FM broadcast receivers
                                     In US, FCC has allowed such low
                                      power systems for decades
http://www.ofcom.org.uk/
media/news/2006/11/nr_2
0061123b
                                     But were banned in Europe for
                                      several years because of lack of
                                      rules in this area

                               Technology           Regulation
Traditional Spectrum Policy

      Prioritize uses of spectrum
      Controls interference and market entry
      Pick technological winners and losers
      GSM was extremely successful and came from
       such a policy environment
        Only GSM equipment can be sold in Europe and
         some other countries (prior to 3G)


         Technology             Regulation
But Wi-Fi and Bluetooth can from a Very
      Different Background than GSM!
         Rest of presentation will explore technical and regulatory
          roots of of Wi-Fi
        If traditional spectrum management is similar to Soviet
         economic policy, the origins here are              based
Госплан on Field of Dreams concepts




                    “If you believe the impossible,
                    the incredible can come true.”

                Technology                            Regulation
Roots of Wi-Fi (and Bluetooth)
 Wi-Fi came about as a result of spectrum deregulation
  creating a “blank slate” for innovators
 Spread spectrum (SS) was the basis for creation of
  spectrum that became the home of Wi-Fi and Bluetooth
   Prior to FCC 1981-1985 action, SS was implicitly banned in
    general
   Carter-era FCC sought to remove barriers from technology to
    stimulate economy
     SS was selected as initial area
   SS was the core technology of Wi-Fi until 802.11(g)
    and continues as Bluetooth core
               Technology              Regulation
Hedy Lamarr:
Legendary Inventor of Spread Spectrum
       As is often reported in popular press, Hedy Lamarr
        was awarded an early frequency hopping spread
        spectrum* patent during WWII
         But invention was not reduced to practice

       Like with the computer, it is probably impossible to
        identify a single inventor of spread spectrum

      • Spread spectrum comes in 2 “flavors”: direct
         sequence/pseudonoise and frequency hopping.
         Wi-Fi started as DS/PN, Bluetooth is FH


     Technology              Regulation
1953 MIT Lincoln Lab System
 Developed by Paul Green
  (later of IBM) as a thesis
  project
 One of earliest SS/PN
  systems
   More related to early Wi-Fi
    and Qualcomm CDMA than
    Lamarr concept

 Technology of the day
  required large size
             Technology           Regulation
Early Literature
 In the 1950-1970’s spread spectrum generally remained a
  classified technology with only occasional references in the
  open literature.
 My first exposure was at a classified 1972 conference
 Only textbook-like discussion was a classified Sylvania
  report for NSA




              Technology           Regulation
Dixon’s Book 1975
 First comprehensive, though
  mathematically inelegant, unclassified
  treatment of spread spectrum

 Introduced a generation of designers to the
  technology




                      Technology                Regulation
Commercial Spread Spectrum
c. 1979
                     Magnavox produces a
                      “civil” version of
                      AN/ARC-50/90
                       Unit shown is modem,
                        separate transceiver
                        needed

                     Japan MPT purchases
                      and tests for possible civil
                      applications
                       Concludes no practical
                        value for civil use!
       Technology      Regulation
Setting the Stage for Wi-Fi:
   Prophets of Deregulation




 Pres. Carter                Alfred Kahn                       Pres. Reagan
                             Cornell University Professor
                             Former Chairman of
                              New York PUC
                              US Civil Aeronautics Board




                Technology                        Regulation
FCC Chairman Ferris (1977-81)
Makes Deregulation FCC Focus

 Translates Kahn’s concepts and Carter’s mandate into more
  specific program:
   Identify technologies that are being held back by anachronistic
    regulations and “liberate” them - so they can sink or swim
    under their own merits
   Hires former (D)ARPA Director Steve Lukasik to implement
    program
   Spread spectrum identified as a candidate technology




              Technology               Regulation
FCC Chairman Fowler (1981-87)
Makes Spread Spectrum Deregulation Part of “Reagan Agenda”


  Chmn. Fowler replaces Chmn. Ferris after the Reagan election

  While disagreeing with predecessor on many issues, he
   embraces the spread spectrum initiative seeing its connection to
   Reagan’s deregulatory agenda – despite mainstream industry
   opposition
     “Looking back, it is clear that adoption of these rules was one of the
      significant achievements of the Reagan FCC —though I doubt if anyone
      thought so at the time.” 4/08




                     Technology                   Regulation
Early FCC Action
 1980 MITRE Corp. report to
  study options for civil use of
  spread spectrum
 Best 70K FCC ever spent!!


 Raises unlicensed option


 Available from NTIS as PB81-165284
  and on MITRE site



                Technology             Regulation
Early FCC Action
 1981 2 initiative begun:
   Docket 81-413 – General use
   Docket 81-414 – Amateur radio use
 While H-P (now Agilent) was supportive, most industry
  opposed
 IEEE IT Society filed support



            Technology            Regulation
1985
              May 9, 1985 FCC adopts spread spectrum
               rules in ISM bands
                  1 W limit
                  PN or FH
                  Almost any application
                    But no explicit mention of Wi-Fi-like RLANs


              Same basic rules until 2002
                              incorporated July 1985
                  CDMA becomes major cellular player
                  Key part of most 3G mobile systems


Technology                Regulation
“First Light”
                        In 1988 the first real commercial
                         spread spectrum product
                         appeared – a LAN
                        “Spontaneous generation” –
                         developer was a Canadian
                         startup aiming at using new
                         FCC rules!




          Technology     Regulation
Creation of IEEE 802.11

 5 years after 81-413 decision - after several
  proprietary products tested the market and
  explored technologies - 3 pioneering firms joined
  in IEEE 802.11 to explore 2 niche applications:
   Wireless cash registers
   Warehouse mobile bar codescanners
    (building on supermarket scanners)

 Vic Hayes of NCR’s lab in Holland
  leads standardization discussions
1991 Snapshot

                      Many key players went to Quebec
                       woods to discuss the future of
                       spread spectrum



                      “Myth or Reality”
                        Future was still not clear




        Technology     Regulation
Wi-Fi Growth

                            Niche applications

                             worldwide demand!
Early Growth




               Technology           Regulation
Unexpected Uses of Wi-Fi
        & Related Systems




        Municipal Wi-Fi

                                                                       Supermarket
                                       Public system at marina       customer product
                                                                      scanning while
                                                                         shopping




Bathtub with Wi-Fi iPod music link     §15.249 Equipment – Cousin of ISM Band rules

                          Technology        Regulation
The FCC Team That Lead ISM Band
   Policy 1979-1985




From left: Robert Powers, Stephen Lukasik, Elliot Maxwell, MM, Marjorie "Peggy" Reed Greene
                                          May 2010
Are “Unlicensed” or “802” Magic
Elixirs of Success?
 “.com” once seen as magic elixir

 Some other unlicensed initiatives, some with broad
  industry support, have had little success:
   U-PCS, U-NII, UWB, HiperLan

 Unlicensed with detailed regulations may not be able
  to adapt to meet demand

 802 efforts to standardize UWB were unsuccessful
   802.16 (WiMax) has had mixed success

 Today’s 802 is very different than 1990
Conclusions                               “If you believe the impossible,
                                              the incredible can come true.”




 Wi-Fi and Bluetooth had their roots in White House-directed deregulation to stimulate
  economic growth

 A major break from previous “Soviet style” planning of radio spectrum where bureaucrats
  tried to predict markets, technologies, and demands years in advance

 Deregulatory concepts grew into a new worldwide market serving unanticipated needs
  for mobility

 Synergy of unlicensed and regulatory flexibility is powerful approach to facilitate wireless
  innovation and economic growth



                         Technology                      Regulation
ns ?
    s tio
  ue
Q
                    More details and other sources at:
                    http://www.marcus-spectrum.com/SSHistory.htm




       Technology      Regulation

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F2C 2012: Mike Marcus

  • 1. www.marcus-spectrum.com Michael J. Marcus, Sc.D., F-IEEE Former Associate Chief for Technology FCC Office of Engineering and Technology Director, Marcus Spectrum Solutions, LLC Cabin John, MD, USA www.marcus-spectrum.com Adjunct Professor Department of Electrical & Computer Engineering Virginia Tech N3JMM/ 7J1AKO Technology Regulation
  • 2. Overview  Will review interaction of regulation and technology in wireless technology  How a bipartisan political movement for deregulation unexpectedly removed roadblocks that kept a promising wireless technology & underutilized bands locked in “Pandora’s box”  Serendipity and (generally good) unexpected consequences  Today’s ubiquitous Wi-Fi and Bluetooth and other useful niche applications Technology Regulation
  • 3. Why Is Wireless Different than Other Technologies?  Basic spectrum policy concepts were formed in aftermath of Titanic sinking 100 years ago  Many regulators resemble Soviet economic planners, projecting demands and allocating resources  Classically, entrepreneurs, “disruptive innovation” and niche applications get little attention  Wi-Fi started as a niche application! Technology Regulation
  • 4. 4 Birth of Unlicensed in US  US legislation does not provide explicitly for unlicensed use  1st system was a Philco remote control system for radio receivers in late 30s  FCC ruled that since it was unlikely to cause interference license was not needed  Subsequent legislation has noted unlicensed but never explicitly authorized it  ARRL claims FCC has no legal basis for unlicensed Technology Regulation
  • 5. The Strange Case of iTrip: 5 T The Classic Problem for Unlicensed in Some Countries  Prescriptive nature of spectrum regulation in many countries held back unlicensed innovation, e.g.  iTrip is a low power FM transmitter user to connect iPod music to nearby FM broadcast receivers  In US, FCC has allowed such low power systems for decades http://www.ofcom.org.uk/ media/news/2006/11/nr_2 0061123b  But were banned in Europe for several years because of lack of rules in this area Technology Regulation
  • 6. Traditional Spectrum Policy  Prioritize uses of spectrum  Controls interference and market entry  Pick technological winners and losers  GSM was extremely successful and came from such a policy environment  Only GSM equipment can be sold in Europe and some other countries (prior to 3G) Technology Regulation
  • 7. But Wi-Fi and Bluetooth can from a Very Different Background than GSM!  Rest of presentation will explore technical and regulatory roots of of Wi-Fi  If traditional spectrum management is similar to Soviet economic policy, the origins here are based Госплан on Field of Dreams concepts “If you believe the impossible, the incredible can come true.” Technology Regulation
  • 8. Roots of Wi-Fi (and Bluetooth)  Wi-Fi came about as a result of spectrum deregulation creating a “blank slate” for innovators  Spread spectrum (SS) was the basis for creation of spectrum that became the home of Wi-Fi and Bluetooth  Prior to FCC 1981-1985 action, SS was implicitly banned in general  Carter-era FCC sought to remove barriers from technology to stimulate economy  SS was selected as initial area  SS was the core technology of Wi-Fi until 802.11(g) and continues as Bluetooth core Technology Regulation
  • 9. Hedy Lamarr: Legendary Inventor of Spread Spectrum  As is often reported in popular press, Hedy Lamarr was awarded an early frequency hopping spread spectrum* patent during WWII  But invention was not reduced to practice  Like with the computer, it is probably impossible to identify a single inventor of spread spectrum • Spread spectrum comes in 2 “flavors”: direct sequence/pseudonoise and frequency hopping. Wi-Fi started as DS/PN, Bluetooth is FH Technology Regulation
  • 10. 1953 MIT Lincoln Lab System  Developed by Paul Green (later of IBM) as a thesis project  One of earliest SS/PN systems  More related to early Wi-Fi and Qualcomm CDMA than Lamarr concept  Technology of the day required large size Technology Regulation
  • 11. Early Literature  In the 1950-1970’s spread spectrum generally remained a classified technology with only occasional references in the open literature.  My first exposure was at a classified 1972 conference  Only textbook-like discussion was a classified Sylvania report for NSA Technology Regulation
  • 12. Dixon’s Book 1975  First comprehensive, though mathematically inelegant, unclassified treatment of spread spectrum  Introduced a generation of designers to the technology Technology Regulation
  • 13. Commercial Spread Spectrum c. 1979  Magnavox produces a “civil” version of AN/ARC-50/90  Unit shown is modem, separate transceiver needed  Japan MPT purchases and tests for possible civil applications  Concludes no practical value for civil use! Technology Regulation
  • 14. Setting the Stage for Wi-Fi: Prophets of Deregulation Pres. Carter Alfred Kahn Pres. Reagan Cornell University Professor Former Chairman of New York PUC US Civil Aeronautics Board Technology Regulation
  • 15. FCC Chairman Ferris (1977-81) Makes Deregulation FCC Focus  Translates Kahn’s concepts and Carter’s mandate into more specific program:  Identify technologies that are being held back by anachronistic regulations and “liberate” them - so they can sink or swim under their own merits  Hires former (D)ARPA Director Steve Lukasik to implement program  Spread spectrum identified as a candidate technology Technology Regulation
  • 16. FCC Chairman Fowler (1981-87) Makes Spread Spectrum Deregulation Part of “Reagan Agenda”  Chmn. Fowler replaces Chmn. Ferris after the Reagan election  While disagreeing with predecessor on many issues, he embraces the spread spectrum initiative seeing its connection to Reagan’s deregulatory agenda – despite mainstream industry opposition  “Looking back, it is clear that adoption of these rules was one of the significant achievements of the Reagan FCC —though I doubt if anyone thought so at the time.” 4/08 Technology Regulation
  • 17. Early FCC Action  1980 MITRE Corp. report to study options for civil use of spread spectrum  Best 70K FCC ever spent!!  Raises unlicensed option  Available from NTIS as PB81-165284 and on MITRE site Technology Regulation
  • 18. Early FCC Action  1981 2 initiative begun:  Docket 81-413 – General use  Docket 81-414 – Amateur radio use  While H-P (now Agilent) was supportive, most industry opposed  IEEE IT Society filed support Technology Regulation
  • 19. 1985  May 9, 1985 FCC adopts spread spectrum rules in ISM bands  1 W limit  PN or FH  Almost any application  But no explicit mention of Wi-Fi-like RLANs  Same basic rules until 2002  incorporated July 1985  CDMA becomes major cellular player  Key part of most 3G mobile systems Technology Regulation
  • 20. “First Light”  In 1988 the first real commercial spread spectrum product appeared – a LAN  “Spontaneous generation” – developer was a Canadian startup aiming at using new FCC rules! Technology Regulation
  • 21. Creation of IEEE 802.11  5 years after 81-413 decision - after several proprietary products tested the market and explored technologies - 3 pioneering firms joined in IEEE 802.11 to explore 2 niche applications:  Wireless cash registers  Warehouse mobile bar codescanners (building on supermarket scanners)  Vic Hayes of NCR’s lab in Holland leads standardization discussions
  • 22. 1991 Snapshot  Many key players went to Quebec woods to discuss the future of spread spectrum  “Myth or Reality”  Future was still not clear Technology Regulation
  • 23. Wi-Fi Growth Niche applications  worldwide demand! Early Growth Technology Regulation
  • 24. Unexpected Uses of Wi-Fi & Related Systems Municipal Wi-Fi Supermarket Public system at marina customer product scanning while shopping Bathtub with Wi-Fi iPod music link §15.249 Equipment – Cousin of ISM Band rules Technology Regulation
  • 25. The FCC Team That Lead ISM Band Policy 1979-1985 From left: Robert Powers, Stephen Lukasik, Elliot Maxwell, MM, Marjorie "Peggy" Reed Greene May 2010
  • 26. Are “Unlicensed” or “802” Magic Elixirs of Success?  “.com” once seen as magic elixir  Some other unlicensed initiatives, some with broad industry support, have had little success:  U-PCS, U-NII, UWB, HiperLan  Unlicensed with detailed regulations may not be able to adapt to meet demand  802 efforts to standardize UWB were unsuccessful  802.16 (WiMax) has had mixed success  Today’s 802 is very different than 1990
  • 27. Conclusions “If you believe the impossible, the incredible can come true.”  Wi-Fi and Bluetooth had their roots in White House-directed deregulation to stimulate economic growth  A major break from previous “Soviet style” planning of radio spectrum where bureaucrats tried to predict markets, technologies, and demands years in advance  Deregulatory concepts grew into a new worldwide market serving unanticipated needs for mobility  Synergy of unlicensed and regulatory flexibility is powerful approach to facilitate wireless innovation and economic growth Technology Regulation
  • 28. ns ? s tio ue Q More details and other sources at: http://www.marcus-spectrum.com/SSHistory.htm Technology Regulation