[Federal Register Volume 65, Number 63 (Friday, March 31, 2000)]
[Proposed Rules]
[Pages 17246-17248]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 00-7967]


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FEDERAL COMMUNICATIONS COMMISSION

47 CFR Part 2

[ET Docket No. 00-47, FCC 00-103]


Inquiry Regarding Software Defined Radios

AGENCY: Federal Communications Commission.

ACTION: Notice of inquiry.

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SUMMARY: This document requests comments on ``software defined radio'', 
which the Commission believes could have wide range implications for 
radio technology and our regulatory policies. Software defined radios 
have the potential to change the way users can communicate across 
traditional services and to promote efficient use of spectrum. The 
Commission believe's that software defined radios could significantly 
affect a number of Commission functions, including spectrum allocation, 
spectrum assignment, and equipment approval. The purpose of this 
inquiry is to gather information on the state of software defined radio 
technology, interoperability issues, spectrum efficiency issues, 
equipment authorization processes, and other relevant issues.

DATES: Comments June 14, 2000; and reply comments July 14, 2000.

ADDRESSES: All filings must be sent to the Commission's Secretary, 
Magalie Roman Salas, Office of the Secretary, Federal Communications 
Commission, 415 12th Street, SW, TW-A325, Washington, DC 20554.

FOR FURTHER INFORMATION CONTACT: Hugh Van Tuyl, Office of Engineering 
and Technology, (202) 418-7506.

SUPPLEMENTARY INFORMATION: This is a summary of the Commission's Notice 
of Inquiry, ET Docket 00-47, FCC 00-103, adopted March 17, 2000, and 
released March 22, 2000. The full text of this Commission decision is 
available for inspection and copying during normal business hours in 
the FCC Reference Information Center, Room Cy-A257, 445 12th Street, 
SW, Washington, DC, and also may be purchased from the Commission's 
duplication contractor, International Transcription Services, Inc. 
(202) 857-3800, 1231 20th Street, NW, Washington, DC 20036.

Summary of Notice of Inquiry

    1. The Commission initiated this Notice of Inquiry (``NOI'') to 
obtain comments from the public on a variety of issues related to 
software defined radios. Software defined radios could offer tremendous 
advantages to consumers over currently available wireless equipment. 
These benefits include lower cost, a greater variety of features, and 
the ability to adapt to multiple communication standards. They could 
also offer advantages to manufacturers, such as increased economies of 
scale in production, increased worldwide market opportunities, and a 
decrease in the number of devices that must be maintained in inventory. 
Software defined radios could expand access to broadband communications 
for all persons and increase competition among telecommunication 
service providers. Through this inquiry, we seek input to help us 
evaluate the current state of software defined radio technology, and to 
determine whether changes to the Commission's rules are necessary to 
facilitate the deployment of this technology. Upon review of the 
responses to this inquiry, we will determine whether to propose any 
changes to the rules.
    2. Software defined radio technology was originally developed for 
the United States military. The ``SPEAKeasy'' project was undertaken by 
the Department of Defense with the goal of developing a multi-band, 
multi-mode software. The SPEAKeasy project showed that a software 
defined radio is feasible. Nevertheless, there are many technological 
hurdles that must be overcome before software defined radios can be 
widely deployable. For example, there are limitations on the speed and 
dynamic range of current analog to digital converters, physical 
limitations on the frequency range over which an antenna can operate, 
and speed and cost constraints on digital signal processing circuitry. 
In addition, standards that would allow interoperability between 
hardware and software produced by different manufacturers are still 
under development. Therefore, in order to assist us in understanding 
the current state of software defined radio technology, we seek comment 
in the following areas.

     What features in a radio are apt to be controlled by 
software? For example, could the operating frequency, output power, 
and modulation format be software controlled?
     What are the specific limitations of current software 
defined radio technology? What are the cost implications?
     What capabilities could software defined radios have 
that are not found in current radio technology?
     When could software defined radios be deployed 
commercially, and for what services or purposes?
     What work is being done on software defined radios 
internationally, and are there any steps the Commission should take 
to encourage this work?

    3. Interoperability. The Commission's rules are divided up into a 
number of parts that contain the requirements for various licensed 
radio services. The rules for each service specify the operating 
frequencies and other technical requirements for radio equipment in 
that particular service. In some cases there is overlap between these 
frequencies and other requirements, so equipment can be developed to 
operate in more than one service. However, in most cases, equipment 
designed to operate in one service can not communicate with equipment 
designed to operate in another service, and in some cases can not even 
communicate with other equipment in the same service due to

[[Page 17247]]

lack of common transmission standards or operating frequencies.
    4. The inability of users to communicate due to non-uniform 
standards within services or between services can be a serious problem. 
The ability of software defined radios to change frequency and 
transmission standards would appear to be a way to overcome the lack of 
interoperability between different wireless systems. We are therefore 
asking for comment on the following questions.

     To what extent can software defined radios improve 
interoperability between different public safety agencies?
     To what extent can software defined radios improve 
interoperability between equipment and services using differing 
transmission standards?
     To what extent would software defined radios move 
toward uniformity in standards within or across bands?
     To what extent can software defined radios be used to 
facilitate transitions from one technical standard to another, such 
as the transition mandated by the land mobile ``refarming'' 
proceeding?
     What particular means could be employed by software 
defined radios to facilitate interoperability?

    5. Improving spectrum efficiency and spectrum sharing. The 
Commission allocates bands of spectrum to the various radio services in 
the rules, and maintains a table of these frequency allocations. In 
order to operate within a service, a license issued by the Commission 
is required. The rules for each service specify eligibility 
requirements for obtaining a license, and the technical requirements 
for operation, including location, power and frequency. Licenses may be 
issued through an application process, or through a competitive bidding 
process.
    6. Because of the ability to be easily reprogrammed, a software 
defined radio would not be limited to operation within a single fixed 
frequency band or on a limited set of pre-programmed channels. It could 
have the capability of operating on any frequency within the limits of 
its design, and could operate on channels of varying widths with 
varying modulation formats. Further, it should be possible to design 
the equipment with some ``intelligence,'' which would let it monitor 
the spectrum to detect usage by other parties and transmit on open 
frequencies. These capabilities could open up new possibilities in the 
area of spectrum allocation and licensing.
    7. The use of software defined radios may also enable new types of 
spectrum sharing that are currently precluded by today's conventional 
equipment. For example, our PCS rules permit wide flexibility in terms 
of the services offered and technology employed in the PCS spectrum. In 
the event that a PCS licensee has spectrum available in excess of its 
immediate needs, it could lease that spectrum on a short-term basis to 
a third party. Software defined radio could facilitate such sharing. A 
third party could, for example, acquire from a manufacturer software 
defined radio equipment capable of being configured to offer different 
services in the various frequency ranges. Having negotiated for 
spectrum use, it would be in a position to rent a package of equipment 
and ``airtime'' to end users needing communications capacity on a 
short-term basis. It would load the appropriate software to properly 
configure the equipment at the time the end user enters into the rental 
agreement. Another alternative would be for the end user to contract 
directly with the licensee for the necessary spectrum and then rent the 
properly configured software defined radio equipment. With today's 
technology, such short-term sharing is difficult or impossible to 
accomplish due to the difficulties associated with quickly configuring 
radios for different applications in novel spectrum configurations. As 
a result, we believe that significant public benefits might flow from 
software defined radio technology. The public benefits include 
increased communications capacity for end users and better utilization 
of the spectrum resource. We seek comments regarding these potential 
benefits and what regulatory steps we might take to
    8. Functions described in the NOI have the potential to allow 
spectrum to be utilized more efficiently. We are therefore seeking 
comment on the following areas related to frequency allocation and 
licensing.

     To what extent could software defined radios improve 
the efficiency of spectrum usage?
     What particular functions related to spectrum usage 
could a software defined radio perform? Could it locate free 
spectrum, dynamically allocate bandwidth, and enable better sharing 
of the spectrum?
     How specifically could it carry out these functions?
     What are the benefits of the spectrum sharing 
arrangements described above, and what steps might we take to permit 
the use of software defined radios to enable such sharing 
arrangements?
     What changes may be appropriate for the way the 
Commission currently allocates spectrum?
     If changes are warranted, how could we make the 
transition from the current allocation and licensing model to a new 
model?

    9. Equipment approval process. Section 302 of the Communications 
Act of 1934, as amended, authorizes the Commission to make reasonable 
regulations, consistent with the public interest, governing the 
interference potential of equipment that emits radio frequency energy. 
The Commission carries out its responsibilities under this section by 
establishing technical regulations for transmitters and other equipment 
to minimize their potential for causing interference to radio services, 
and by administering an authorization program to ensure that equipment 
reaching the market complies with the technical requirements. The 
authorization program requires that equipment be tested either by the 
manufacturer or at a private test laboratory to ensure that it complies 
with the technical requirements. The majority of radio transmitters 
require the submission of an application that must be reviewed and 
approved before the equipment can be marketed, although certain 
transmitters may be authorized through a manufacturer's self-approval 
process.
    10. A transmitter is approved to a specific set of technical 
parameters, including the operating frequencies, output power, and 
types of radio frequency emissions. If a manufacturer changes these 
parameters after a piece of equipment has been authorized, the FCC 
issues a new approval before the unit may be marketed with the changes. 
By design, the operating parameters of a software defined radio can be 
readily changed in the field by altering its software. Such a change 
could violate the terms of the transmitter's equipment authorization by 
causing it to operate in modes for which it has not been approved. 
Also, our rules do not allow parties other than the grantee of the 
equipment authorization to make modifications to approved equipment 
without obtaining a new approval. Even if a new approval were obtained 
by the original grantee, the rules require the modified transmitter to 
be labeled with a new FCC identification number, which would be 
impractical for software modification of equipment that is already in 
the field. We therefore seek comments on the following issues related 
to the authorization of software defined radio transmitters.

     Should we approve the radio hardware, the software or 
the combination of them?
     Are the currently required measurements in Part 2 of 
the rules appropriate for software defined radios?
     How should software defined radio equipment be tested 
for compliance, including compliance with SAR requirements? What 
type of approval process and labeling would be appropriate?

[[Page 17248]]

     Should we regulate who changes the software and the 
manner in which it is done? If so, should the Commission maintain 
records of such modifications?
     What are the various means that may be used to download 
new software? We anticipate, for example, that software could be 
downloaded by methods such as direct connection to a programming 
device or over the airwaves. To what extent will the software 
interfaces be standardized?
     Should we require anti-tampering or other security 
features? How would such security features work? Could equipment be 
designed to prevent it from transmitting in certain designated 
frequency bands, such as those allocated exclusively for government 
use, as a safeguard against causing interference?
     Do we need to adopt additional requirements for 
software defined radios to ensure the privacy of users' 
communications?

    11. One possible scenario for an approval process for software 
defined radios could be as follows. The software could be tested and 
approved to ensure that the transmitter meets the applicable technical 
requirements under all operating conditions. In order to ensure that 
untested and unapproved software could not be loaded, such transmitters 
would have an authentication system that checks the software for an 
authentication code added to it by the FCC or a Telecommunications 
Certification Body (TCB). The software itself would be submitted for 
approval in a process similar to today's application process except 
that a copy of the object code would be supplied in machine-readable 
form. Upon approving the software application, which would involve a 
test of the hardware and software together similar to today's tests, 
the FCC or TCB would compute the authentication code for the submitted 
source code and send it to the applicant. The authentication system 
would be a two key system in which the key needed to compute the 
authentication code would be known to only the FCC or TCB, and the key 
needed to check in a transmitter object code which is being loaded 
would be publicly available.
    12. In an analogy to the current requirement for labeling a 
transmitter, there may be a need for a method to allow users to 
determine whether the desired operating software is currently loaded in 
a transmitter, and to allow Commission enforcement personnel to verify 
that the software has been approved. To meet this need, the transmitter 
could display information about the software installed by a means such 
as a liquid crystal display (LCD) screen in response to an input from a 
keypad. The identification information about the software installed in 
the radio could include such information as the technical operating 
parameters, the source of the software, and the name of the body that 
approved it. The user manual and the authorization application would 
describe how to access this information. Since such radios are expected 
to have displays for user information and input mechanisms for the user 
in normal use, we do not think this requirement would be burdensome. We 
seek comments on the following questions about this possible approval 
method.

     Is there a need for such an approval system, and is it 
feasible and practical?
     What type of authentication system should be used? 
Should there be one system or alternative systems? Who should have 
responsibility for generating the authentication codes: the FCC, 
TCBs, equipment manufacturers, or some other party?
     In the case of transmitters subject to verification how 
should authentication of software be handled? For example, could an 
``authentication only'' service be offered in which the FCC or TCB 
computes the authentication code for the software after all elements 
of compliance with the FCC rules are verified by the manufacturer?
     How should simple changes to software be handled that 
do not affect the operating parameters of the equipment but require 
the computation of a new authentication code? Could an 
``authentication only'' service be offered for them?
     Is there a need for a method to display information 
about the software loaded in a transmitter? If so, what method 
should be used and what information should be displayed?

    13. Other matters. The questions raised in this notice are intended 
to solicit information to assist the Commission in deciding whether to 
propose rule changes as a result of the developing software defined 
radio technology. We realize that these questions do not necessarily 
encompass all of the issues raised by this technology. Commenters may 
want to address whether software defined radio technology could help 
parties comply with Sections 255 and 251(a) of the Communications Act. 
These sections require manufacturers of telecommunications equipment 
and providers of telecommunications services to ensure that such 
equipment and services are accessible to persons with disabilities, if 
readily achievable. Commenters may also wish to address how we would 
enforce any new rules for software defined radios. Accordingly, 
comments are invited on any other matters or issues that may be 
pertinent to software defined radios.

Federal Communications Commission.
Magalie Roman Salas,
Secretary.
[FR Doc. 00-7967 Filed 3-30-00; 8:45 am]
BILLING CODE 6712-01-U