VIA ELECTRONIC FILING December 18, 2020 Ms. Marlene H. Dortch, Secretary Federal Communications Commission 445 Twelfth Street, SW Washington, DC 20554

Re: Ex Parte Presentation GN Docket No. 17-183, Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz ET Docket No. 18-295, Unlicensed Use of the 6 GHz Band

Dear Ms. Dortch: On December 16, 2020, representatives from the Ultra Wide Band Alliance (“UWB Alliance”) Tim Harrington, Kelli Emerick, Ben Rolfe, Jackie Green, and Marc-Anthony Signorino spoke with staff from the FCC's Wireless Office of Engineering and Technology (OET) to discuss the above-referenced proceeding. Identified representatives from OET included Acting Chief Ron Repasi, Michael Ha, Monisha Ghosh, Jamison Prime, and Paul Murray. During the meeting, UWB Alliance discussed UWB coexistence initiatives, the significant increase of UWB devices in the high-volume consumer market, and a request for an update to the UWB rules. Attached, please find the slide deck presented on the call.

Respectfully Submitted, Timothy Harrington Executive Director UWB Alliance

Collectively Creating the Future

Agenda1. UWB Alliance Coexistence Initiatives

2. UWB Joins the High-Volume Consumer Market

3. Request for Update to UWB Rules

• UWB Alliance is an active member of the 6 GHz MSG

• Monitoring WS1, and Initiative with NAB for 4th Workstream for Contention Based Protocol

• UWB Alliance joined the WinnForum at our own expense to further the discussion and work toward solutions

• UWB Alliance is working constructively with other incumbents, (i.e., licensed and unlicensed)

• Working with RLAN companies that are incorporating UWB technologies into mainstream consumer products

• UWB Alliance Members are members of IEEE 802.19 to contribute to standardized coexistence initiatives

• UWB Alliance is leading efforts to bring everyone together in SDOs’ (e.g., IEEE, ETSI, CEPT) to foster co-existence and drive the industry forward

UWB Alliance Initiatives for Coexistence

UWB and Wi-Fi Evolution into Consumer Electronics

4

1985FCC opens

unlicensed

bands

1997IEEE802.11

released

2008Smartphones

iPhone 3G

Launched

with Wi-Fi

UWB Rulesets

created in USA

& ETSI

mandated by

EU

2002-3

2010Tablets

Wi-Fi only

Tablets

introduced

2018Wi-Fi Creates

$500 Billion

in economic

value in USA

IEEE

802.15.4a

Standard

Released

2006

Thriving

Industrial

UWB market

established

2010

1990Wireless

Payments

introduced

(WaveLAN)

UWB

incorporated

in all models

of iPhone 11

2019

Car

Manufacturers

recognize

value of UWB

2016

IEEE

802.15.4z

Standard

starts

2018

IEEE 802.15.4z Standard

released

Big Technology

companies start

to adopt UWB

technology

2015

23 Years

16 Years

Wi-Fi source: WifiForward

UWB

Wi-Fi

iPhone 12

4 models

Apple

Watch 6

Samsung

Note 20U

Xiaomi

Mi 10

3 models

Apple

HomePod

Mini

Lenovo

ThinkPad

X1 Nano

2020

UWB Releases in 2020

Selection of Emerging UWB Use Cases

5

High-Resolution Contact Tracing

Find “My Stuff” Applications

Secure Payment Solutions

Next Generation Passive KeylessEntry

AR & VR Positional Awareness and Communication

RTLS for Healthcare

• Samsung Note 20 Ultra

• Apple Watch 6

• Apple iPhone 12 Series

• Apple HomePod

• Xiaomi Mi 10 Series

• Lenovo ThinkPad X1 Nano

Short-Range Radio Connectivity Summary 2020

6

UWB Wi-Fi BlueTooth

✓ ✓ ✓

✓ ✓ ✓

✓ ✓ ✓

✓ ✓ ✓

✓ ✓ ✓

✓ ✓ ✓

UWB Alliance Estimated Adoption 2020 - 2025

7

0.0

500.0

1,000.0

1,500.0

2,000.0

2,500.0

0.0

200.0

400.0

600.0

800.0

1,000.0

1,200.0

2018 2019 2020 2021 2022 2023 2024 2025

Mil.

USD

Mil.

Units

Total UWB Device Shipment & Total Chip Revenue 2018-2025

Industrial RTLS Smartphone (ASP) Consumer Tag Consumer Wearable Automotive Access Others Including Smartphone Accessories Total UWB Chip Revenue

• Based on TSR 2020 UWB Market Report. UWB Smartphone Accessories for Smartphones will drive a 1:1 chip ratio with Smartphones by 2025, producing an estimated total $2.3B of Chip Revenue Annually

• Generic UWB Rules have had no significant changes for many years (2005 for any significant change)

• There have been some small updates and clarifications (e.g., 15.515, 15.252)

• Many other changes have happened since then

• Many UWB Waivers justifiably granted for a wide variety of requests

• Unlicensed RLAN @ 6 GHz

• UWB has proven to be non-interfering in all frequency bands

• Follow up to Bosch petition, including incorporating waivers into rules

Justification for UWB Rules Update

• Two Waivers requests granted for Railway tracking applications:

• Piper Networks, Inc. (Piper) waiver to:• Sections 15.519(a) and 15.519(a)(2) about handheld and fixed outdoor use

• Permit UWB train positioning system in the 4243-4743 MHz frequency band in the greater New York City area and in Harris County, Texas

• https://www.fcc.gov/document/piper-networks-inc-request-waiver-order

• Metrom Rail, LLC (Metrom) to waiver to:• Sections 15.519(a) and 15.519(c) regarding handheld and fixed outdoor use as well as increased output power

• Permit operations limited to 3.248-4.990Hz to enhance the safety and reliability of transit rail operations

• Allow directional antenna to achieve additional 6dB of gain for EIRP of up to -35.3dBm/MHz.

• https://www.fcc.gov/document/metrom-rail-llc-waiver-request-order

• These waivers are in line with goals we have for proposed changes to rules to increase power and update rules for outdoor use

• Cisco Systems and Hewlett Packard Enterprise argue in support of comprehensive UWB rule changes

• They encourage evaluating UWB rules comprehensively rather than through ad-hoc adjudication

Examples of Recent Waivers

9

• Increase freedom of use outdoor

• Allow fixed mount outdoor devices

• Allow surveillance UWB radars

• Increase permissible power

• Example: Power levels could vary with Bands specified in IEEE 802.15.4 + 4z

• Revisit rules for vehicular use

• FCC currently allows vehicular use if the device is “declared” as mobile

• Expand to allow mounting of external antennas (e.g., bumpers)

• Revisit the “at any point in time “ rule

• Allow modulation innovation beyond pulsed or OFDM

• Revise Technical requirements categories to enable more flexible use

• Ex: currently the “material” and surveillance applications are limited to professional/governmental use

• Update the UWB rules to allow alternative mitigation techniques

• Ex: Duty cycle as alternative to 10 second rule to allow similar use-cases as EU/ECC

Examples of UWB Changes: (May Be Frequency Dependent)

10

• Low duty cycle (LDC)/activity factor

• Detect And Avoid (DAA)/listen before talk

• Exterior limit (vehicular use: 12 dB extra attenuation required above horizontal plane)

• Power control/Total radiated power (used mainly in BMA/ODC)

• Emission directivity (also used in ETSI Location Tracking Type 2)

• Shielding mitigation (in (T)LPR, GPR mainly)

Alternatives to 10 Second Rule (Examples from EU/ECC)

11

Thank You