We have, until know, always worked on the assumption that the device would be 
certified, or not, to comply with any out of band emissions. The FCC for 
instance specifically tests the more stringent rule around channel 37, as well 
as the more general case. The Database is not, and cannot be, the enforcement 
agency. So simply providing a list of channels that it can use is sufficient.
It should be of no consequence to a device why it cannot use a channel other 
than to behave with its compliant emissions.
I agree with Gabor, why are we overly complicating this?

From: "[email protected]<mailto:[email protected]>" 
<[email protected]<mailto:[email protected]>>
Date: Friday, September 20, 2013 4:54 PM
To: "[email protected]<mailto:[email protected]>" 
<[email protected]<mailto:[email protected]>>, 
"[email protected]<mailto:[email protected]>" 
<[email protected]<mailto:[email protected]>>
Cc: "[email protected]<mailto:[email protected]>" <[email protected]<mailto:[email protected]>>
Subject: Re: [paws] Spectrum encoding discussion

Aren’t we talking past each other in this thread?
If the rules are supposed to specify what is the max intended power level a 
device can put into a channel (available or not), then I also think this is 
what the DB should communicate to the device.
If Ofcom specifies that the max leakage into an unavailable channel is -33dbm, 
I assume the device will not be certified if it leaks more. If the device 
supports multiple modulation types and one of them leaks more than what is 
permitted in that regulatory domain, then the device will need to know it, and 
in that regulatory domain avoid using that particular modulation type. How does 
the device come to know it? Andy proposes the DB to indicate that level for the 
unavailable channels. Others folks seem to suggest a device built to operate 
under a certain ruleset has to implicitly know it.
Another way of looking at it might be to say that the max level of permitted 
unintentional leakage into an adjacent channel is part of the rulesetInfo, and 
the spectrum response only lists the available channels. Could this be a way 
forward?

-          gabor

From: [email protected]<mailto:[email protected]> 
[mailto:[email protected]] On Behalf Of ext Andy Lee
Sent: Friday, September 20, 2013 1:00 PM
To: Benjamin A. Rolfe
Cc: Protocol to Access White Space database
Subject: Re: [paws] Spectrum encoding discussion

Hi Ben,

And that means NO intentional radiation in the channel.

If you are reading this as "transmitted emissions in band should be lower than 
-33dBm" then, no, this is not the same as "no emissions" per FCC rules. If one 
were to intentionally transmit at -33dBm where no intentional emissions are 
allowed, that would not be the same as "no" under the rules.

There is certainly no intention to encourage any malicious behavior.  In 
general, we expect devices to be trying to do the right thing and just need 
some information to understand where the boundaries are.  These boundaries 
include both intentional and unintentional emissions.

Various modulation types have known spectral profiles, including both in-band 
and out-of-band emissions.  Knowing where the "shelf" is on the adjacent 
channel makes it possible to match that with the "skirt" of the intended 
modulation pattern.  The "skirt" is not part of the intended emission, but is 
important in trying to avoid causing interference on adjacent channels.

A crude example of this is shown in the following image:

[cid:[email protected]]

Best regards,


Andy Lee |

 Google Inc. |

 [email protected]<mailto:[email protected]> |

 408-230-0522


On Fri, Sep 20, 2013 at 3:07 AM, Benjamin A. Rolfe 
<[email protected]<mailto:[email protected]>> wrote:

On 9/19/2013 9:09 AM, Andy Lee wrote:
The math bears that out, but nonetheless OFCOM are still effectively proposing 
that *no* in-block transmissions are allowed in that channel.

Same is true for the FCC.  The FCC also assumes that "off" channels are not 
used by WSDs.
And that means NO intentional radiation in the channel.

Specifying a low power level like -33 dBm is effectively the same thing as 
specifying no in-band emissions there.

If you are reading this as "transmitted emissions in band should be lower than 
-33dBm" then, no, this is not the same as "no emissions" per FCC rules. If one 
were to intentionally transmit at -33dBm where no intentional emissions are 
allowed, that would not be the same as "no" under the rules.




Even if someone did try to put an in-band emission there (regardless of how 
impractical that actually is), it would be too low to cause interference to 
anyone and no harm has been done to the "RF environment".
Should be a little careful here for a couple reasons.  I've designed and 
shipped communication systems that operate quite well with transmit power 
levels intentionally below -33dBm and do very useful things. It's pretty easy 
to design a receive with sensitivity better than -96dBm, so an intentional 
radiator at -33dBm near by will be noticed - at 900 MHz your 10dB above 
sensitivity at 10m and at 54MHz you'd be 10 dB above sensitivity at 100m, 
possibly. And when it comes to protecting their spectrum, people always use the 
best propagation model to calculate interfence impact on them :-).  I've 
probably misunderstood something badly, but -33dBm is certainly enough power to 
be noticed.

I have tried the "too low to be noticed" argument a few times in the past  in 
regulatory discussions, and incumbent and/or protected users usually set the 
threshold closer to -120dBm and usually argue that even at really low TX power, 
the "aggregate impact" of multiple devices in the "RF Environment" is an 
unacceptable impact.   We had trouble with this argument when the intentional 
radiator TX limit was below the maximum unintentional emission limits for most 
non-transmitting devices (-41.3dBm).

So it would be fairly important to ensure a device does not interpret -33dBm as 
it's ok to use that channel so long as it's TX power is below -33dBm.

I may be off base here because of  how y'all see the DB providing and what I am 
expecting to support future needs. "protected users" includes more than TV 
stations in the US.

Not sure that helps, but hope so.




The advantage of having an "well behaved" spectrum profile (contiguous and 
without special values like -inf) is that the channel selection algorithm on 
the WSDs becomes much simpler and logical.  There's no need to have lots of 
special boundary condition checks and code paths that only get triggered under 
special circumstances.  I'd like to avoid ambiguous interpretations on the 
device side as much as possible.
Certainly ambiguous interpretations on the device side are a bad thing.

Some apps are aggregating multiple TV channels to get a logical channel that 
that can carry a 'wide'  data pipe. Other uses can fit many useful channels in 
one TV channel. In 802.15.4m we divide the TV channel up into multiple physical 
channels carrying low data rate signals.  Right now we assume a peak power 
level for the TV channel, and we get that value with the start frequency and 
width (or end frequency) from the database. However, I've heard it proposed to 
the FCC that we may get different power limits different parts of the TV 
channel, changing over time, as a protection mechanism for deal with narrow 
band protected users while allowing effective use of the rest of the TV 
channel.  For what we do, this is a good thing - our physical channel may be 
less than 200kHz wide. There are a LOT of applications  in IoT that need < 
200kHz channels,  and blocking an entire TV channel to protect a wireless 
microphone using < 200kHz of it means there are 28 other usable channels  not 
being used - not efficient use of the spectrum.

Hope this helps.

-Ben




Andy Lee |

 Google Inc. |

 [email protected]<mailto:[email protected]> |

 408-230-0522<tel:408-230-0522>


On Thu, Sep 19, 2013 at 8:30 AM, Ray Bellis 
<[email protected]<mailto:[email protected]>> wrote:

On 19 Sep 2013, at 16:21, Andy Lee <[email protected]<mailto:[email protected]>>
 wrote:

> This actually shows that Ofcom has picked a power threshold on channel 38 of 
> -33 dBm.  If you look at the ACLR numbers for class 3, 4, and 5 devices, 
> you'll see they are 10 dB apart from each other and that they all work out to 
> be -33 dBm on channel 38.
>
> The reason there are no limits for class 1 and 2 devices is because the 
> in-band power on channels 37 and 39 cannot exceed +36 dBm/8MHz, and therefore 
> the power on channel 38 will naturally be less than -33 dBm.
The math bears that out, but nonetheless OFCOM are still effectively proposing 
that *no* in-block transmissions are allowed in that channel.

Per OFCOM / ETSI device interface requirements it would be incorrect for us to 
actually send that value of -33 dBm to a device.

Ray




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