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US GPS Industry Council Comments on FCC First Report on Ultra-wideband Technology
The US GPS Industry Council issued a statement in response to the release of the FCC's First Report and Order to allow for the introduction of Ultra-wideband Transmission Systems.
The council is pleased the FCC responded to the desire for equipment compatibility and interoperability expressed by GPS users. In comments to the FCC, a broad range of GPS user industries expressed deep concern about UWB interference to GPS receivers resulting from the incompatible overlay of UWB devices on the entire GPS frequency band. This First Report and Order identifies spectrum for UWB operations and provides limits on out of band emissions which allow many UWB applications to be implemented, while ensuring that millions of GPS users can continue to depend on the vital safety of life services made possible through the use of the global positioning system.
The council applauds the Commission's frankness that "based on the limited information on the record and our lack of operation experience with UWB devices, we believe it best to proceed with an abundance of caution in establishing emission limits." The Commission recognizes, in fact, that the rules announced in the First Report and Order are conservative precisely because so little is known or understood about how UWB networks will impact existing services. Many of the services UWB will overlay include safety of life services in heretofore "restrictive bands." It is vital for the nation that this experimental sharing is proven to work and is well understood before putting at risk the vast majority of existing radio communications services which operate below the 3.1 GHz limit specified in the First Report and Order.
The council is disturbed, however, that the FCC is not allowing sufficient time to gain operational experience with the UWB devices. If, in the three years of this proceeding, the FCC was not able to amass sufficient information and understanding of the nature of UWB transmissions to propose actual rules of operation before it issued the Report and Order, how much more will it know in six months to a year to allow a complete review of the impact of these new rules on existing services? Especially since the Report and Order already contemplates UWB high speed transmissions suitable for broadband access to networks-operating as an overlay on existing services. Six months or even one year is not sufficient time for UWB devices and communications networks to be fully deployed and ubiquitously available to enable a true measurement of their impact on existing services. The council instead urges the Commission to allow sufficient time to pass for UWB devices to build to a critical mass that would allow for meaningful testing and measurements of the impact of UWB on existing services.