Comments and Filings

Filings

March 27th 2024, The UWB Alliance submitted a response to the Federal Communications Commission (FCC) regarding the the Second Further Notice of Proposed Rulemaking (FNPRM) for unlicensed use of the 6 GHz Band. Our response supported the operation of VLP U-NII devices in U-NII-6 and U-NII-8, and allowing client-to-client operation. But we opposed increasing VLP power above the current levels.

UWBA Response to Second Further Notice of Proposed Rulemaking for unlicensed use of the 6 GHz Band

March 21st 2024, The UWB Alliance submitted a response to Networking and Information Technology Research and Development (NITRD) regarding the National Spectrum Research and Development Plan (R&D Plan) Request for Information. Our response included recommendations that will help shape the R&D Plan in a way that enables optimized sharing of the spectrum. We also presented diversity of use as an important metric for evaluating spectrum efficiency, and strongly endorsed a national testbed that would allow researchers and spectrum stakeholders to collaboratively test a mix of technologies and share results.

UWBA Response to National Spectrum Research and Development Plan RFI

January 2nd 2024, The UWB Alliance submitted a response to the National Telecommunications and Information Administration (NTIA) regarding the National Spectrum Strategy Implementation Plan Request for Input. Our response emphasized the importance of coexistence for spectrum sustainability, that UWB is an excellent example of spectrum sharing, and that policies supporting near-exclusive use of spectrum are not sustainable in the long term.

UWBA Response to National Spectrum Strategy Implementation Plan Request for Input

October 5th 2023, The UWB Alliance submitted a letter to the European Commission regarding the People’s Republic of China MIIT’s proposed regulations on European industry and the potential trade barriers they present. The UWB Alliance voiced concerns that the MIIT’s proposed regulations finding a new maximum value of 650 MHz for the 10 dB bandwidth would foreclose several European UWB manufacturers from trading in the Chinese market.

UWBA Letter to the European Commission Regarding MIIT’s Proposed Regulations that Include 650 MHz Upper Limit on the 10 dB Bandwidths

 

August 30th 2023, The UWB Alliance responded a consultation from the Czech Telecommunications Office pertaining to its Radio Spectrum Management Strategy, which was last updated in 2015. Our response provided updated information on the UWB industry, market size, growth and trends.

UWBA Response to Consultation from the Czech Telecommunications Office

 

August 16th 2023, The UWB Alliance responded to a Public consultation by the Malaysian Communications and Multimedia Commission on proposed positions for WRC-23 agenda items. The proposed positions from the MCMC excluded RLAN and mobile from using 6425-7125 MHz. The current allocations within 6425-7125 MHz are compatible with UWB underlay. Thus, the UWBA responded to the MCMC consultation by recommending no changes to their current allocations in their WRC-23 positions.

UWBA Response to Consultation by the MCMC on Proposed Positions for WRC-23 Agenda Items

 

July 7th 2023, The UWB Alliance contributed to 802.18 comments in response to a Public Consultation on UAE TDRA Regulations for Ultra Wide Band and Short Range Devices. The consultation sought comments on proposed updates to the UWB and SRD regulations in UAE. The UWBA recommended alignment with the latest EU harmonized standards and regulatory updates. Our response included recommendations for updating references and some elimination of redundancy in the regulations. The response also provided basic background on 802.15.4 UWB for context.

802.18 Response to Consultation on UAE TDRA Regulations for Ultra Wide Band and Short Range Devices

 

April 21st 2023, The UWB Alliance responded to an RFC from the FCC Office of International Affairs (OIA) regarding recommendations approved by the World Radiocommunication Conference Advisory Committee. Our comments emphasize the importance of diversity of uses when determining the overall value obtained from spectrum. We emphasized the value UWB provides and the fact it provides great diversity of use without disrupting other services.

UWBA Comments on OIA Recommendations Approved by the World Radiocommunication Conference Advisory Committee

 

April 18th 2023, The UWB Alliance submitted Comments on the ECC deliverable “Draft CEPT Report 084.” In its response, the UWB Alliance endorsed the measures included in the updated ECC Decision (06)04 and fully supports their inclusion in an updated EC Decision on ultra-wideband. The ECC Decision would make fixed outdoor, higher power indoor, and vehicular without exterior limits mandatory in EU single market member states.

UWBA Comments to CEPT Report 084 Consultation

 

April 17th 2023, The UWB Alliance responded to the National Telecommunications and Information Administration’s Request for Comments on the Development of a National Spectrum Strategy. In its response, the UWB Alliance emphasized how UWB technology plays an important role in achieving spectrum policy objectives related to increased spectrum sharing, spectrum efficiency, and diversity of spectrum use. Click the link below to read the entire response submitted to the FCC.

UWBA Response to NTIA RFC on National Spectrum Strategy

 

March 1st 2023, The UWB Alliance applauded the FCC on Recognizing UWB Applications’ Use in Providing Relief in Türkiye and Syria. In her remarks to the Mobile World Congress on February 27, 2023, FCC Chairwoman Jessica Rosenworcel praised the next-generation wireless technologies that are being used to assist rescuers searching for survivors of the tragic earthquakes that devastated Turkey and Syria.

UWBA Applauds FCC Chairwoman Jessica Rosenworcel

 

February 6th 2023, The UWB Alliance responded to the Ministry of Industry & Information Technology (MIIT) consultation concerning a proposed rule change that would restrict the frequencies available for the use of UWB in China. The UWB Alliance recommends against this reduction, noting that UWB does not cause harmful interference to other services. UWB Alliance recommends that where specific concerns are identified, the alliance believes collaborative solutions can be found. UWB Alliance further suggests harmonization with international rules and standards such as those recently adopted in the EU.

UWBA Response to MIIT Concerning the Use of UWB in China

 

July 27th 2020, The UWB Alliance takes positions at the FCC on submissions from other Corporations and Organisations on the subject of Wi-Fi at 6 GHz. Click the link below to discover now how we are working with the FCC to advocate strategies for UWB coexistence:

UWBA FCC 6 GHz FNPRM-ReplyComments

 

June 29th 2020, The UWB Alliance outlines how Ultra-wideband has evolved to become a mainstream technology and responds to the questions asked by the FCC in the 6 GHz FNPRM:

UWBA Comments FCC 6GHz FNPRM June 29 2020 final Updated

 

April 13th 2020, The UWB Alliance predicts estimated market size for ultra-wideband devices will exceed 240 Billion Dollars by 2022:

UWBA Comments on FCC 6 GHz RO April 14 2020 FINAL

 

March 5th 2020, the UWB Alliance submits a 6 GHz sharing proposal to the FCC with suggestions on how co-existence in the band could be achieved for Wi-Fi, UWB and Licensed Incumbents:

UWBA FCC Ex Parte March 5 2020

 

Click the link below to see a selection of the Ultra Wide Band (UWB) Alliance Filings at the FCC:

Ultra Wide Band (UWB) Alliance Filings at the FCC

 

May 2, 2019, Ultra Wide Band Alliance (“UWB Alliance”) Executive Director Tim Harrington and Ira Renfrew (iRobot), met with Aaron Goldberger, Acting Wireless and International Advisor for Chairman Pai, to discuss the NPRM proceeding:

UWB Alliance FCC 6 GHz Ex Parte May 2019 (FINAL)

 

April 8, 2019 As part of the NPRM Coexistence Action Process, Our Executive Director, Tim Harrington visited the FCC in Washington DC to present to Commissioners Staff, they Presented to William Davenport, Umair Javed, and Erin McGrath:

UWB Alliance FCC ExParte Letter Apr08 2019 (FINAL)

Bosch Petition

In an interesting turn, on the 18th June 2019 Bosch filed a petition with the FCC for a new rulemaking that proposed a comprehensive review of the FCC rules governing UWB devices (Part 15, Subpart F). The Rulemaking would normalize current waivers and encourage the utilization of existing standards to promote coexistence in the 6 GHz band. The UWB Alliance filed its own comments in support of the Bosch petition, and those can be found on the links below:

UWBAlliance_Supports_Bosch_Petition_RM-11844_08152019

and our reply comments:

UWB Alliance Reply Comments Bosch Petition 09032019

Click below to see all of the filings for the Bosch Petition to update the UWB Rules in the USA.

Filings for the Bosch Petition to update the UWB Rules in the USA