Docstoc

900 MHz Band - Submission by Nuuon Australia

Document Sample
900 MHz Band - Submission by Nuuon Australia Powered By Docstoc
					                                    Australia
Date: 23 June 2011                                                Ref: 2011-ACMA 900MHz review-v01


Miss Bridget Lally
Spectrum Engineering Section
Australian Communications and Media Authority
PO Box 78
Belconnen ACT 2616


Subject: Submission, 900 MHz Review



We, Nuuon Australia, are solution providers for sustainable smart buildings and represent EnOcean
Alliance in Australia / New Zealand region.

The EnOcean Alliance (http://www.enocean-alliance.org/en/) is a consortium of more than 200
companies working to further develop and promote self-powered wireless monitoring and control
systems for sustainable buildings. The EnOcean Alliance has the largest installed base of field-proven
wireless building automation networks in the world.

Self-powered sensors and switches are powered by tiny energy harvesters which convert e.g.
mechanical actuation, light, or temperature differentials into electricity.

No wires, no batteries, no limits – energy harvesting wireless technology and Alliance Members’
interoperable products offer a simple, proven and maintenance-free solution to meet today’s
requirements of sustainable buildings.

Australia is a technology importing country rather than manufacturing. Gaps in standards and
regulations as compared to the other developed world create huge marketing barriers between
Australia and the rest of the developed world (mainly Europe and the USA). This results in lack of
opportunity for new technologies to find market in Australia, which brings the country way behind
from many other developed nations in benefiting from new technological developments.

This discussion about the 900 MHz band review is an opportunity for us to make a submission and put
forward our point of views. We hope this gets your attention towards few more technical aspects
related to the allocation of this spectrum for better use of technologies in the future in this country.

It will be our pleasure if you need to contact us for any further information.

We look forward to making a contribution to this review process and get accepted.

With kind regards




Puneet Dhiman | Director Business Development | Nuuon Australia
T +61 (0)3 8819 1285 | M +61 (0)422 178 274
puneet.dhiman@nuuon.com.au | www.nuuon.com.au
P.O. Box 765, Brentford Square VIC 3131, Australia




Nuuon Australia                       Phone +61 422 178274, +61 3 88191285
ABN: 93 371 594 525                         australia@nuuon.com.au
VIC Security License: 781-241-60S             www.nuuon.com.au
                                     Australia
Our Comments on the spectrum allocation:
ACMA’s document reference.
     1. The figure Annex 1- Comparison of international arrangements in the 900
        MHz band
     2. Section 2.3.2 Europe

     3. Section 2.4 Emerging technologies and spectrum management issues,
        Question 4

     4. Section 3.4.4 Other services, questions 21 & 22




                                        Use of SRD with
                                      different duty cycle
                                    regulations in Europe in
                                    accordance to ERC 70-30




The figure in Annex 1 and also the text in 2.3.2 do not show that in Europe the bands
around from 863-870MHz can be used for short range devices with different duty
cycle regulations.

The EnOcean Alliance uses the band 868.0-868.6 MHz which allows 1% duty cycle in
accordance to ERC recommendation 70-03, relating to the use of Short Range
Devices (SRD).




P a g e |2                                                Ref: c253e84c-1930-4546-aaaf-f646db4fffbd.doc, 16 February 2013
Nuuon Australia                            Phone +61 422 178274, +61 3 88191285
ABN: 93 371 594 525                              australia@nuuon.com.au
VIC Security License: 781-241-60S                  www.nuuon.com.au
                                      Australia

“Short Range Device” (SRD) are the radio transmitters which provide either unidirectional or bi-
directional communication and have low capability of causing interference to other radio equipment.

ERC 70-30 describes the spectrum management requirements for SRDs relating to allocated
frequency bands, maximum power levels, channel spacing and duty cycle; extract of which is listed
below for reference purposes.

 Frequency Band       Transmission Power           Spectrum access and mitigation requirement             Channel spacing
863-870 MHz          ≤ 25 mW e.r.p.        ≤ 0.1% or LBT                                                  ≤ 100 kHz
                                           Duty cycle may be increased to 1% if the band is limited to    for 47 or more
                                           865-868 MHz                                                    channels
868.000-868.600      ≤ 25 mW e.r.p.        ≤ 1% or LBT+AFA                                                25 kHz
MHz                                        When a duty cycle, Listen Before Talk (LBT) or equivalent      (for 1 or more
                                           technique applies then it shall not be user                    channels)
                                           dependent/adjustable and shall be guaranteed by
                                           appropriate technical means.
                                           For LBT devices without Adaptive Frequency Agility (AFA), or
                                           equivalent techniques, the duty cycle limit applies.
                                           For any type of frequency agile device the duty cycle limit
                                           applies to the total transmission unless LBT or equivalent
                                           technique is used.
869.400-869.650      ≤ 500 mW e.r.p.       ≤ 10% or LBT+AFA                                               25 kHz
MHz                                        Narrow / wide-band modulation The whole stated frequency       (for 1 or more
                                           band may be used as 1 channel for high speed data              channels)
                                           transmission




EnOcean’s self-powered sensors and switches use tiny energy harvesters which
convert e.g. mechanical actuation, light, or temperature differentials into electricity.

The actuation of a light switch, for example, is sufficient to transmit the state of the
switch via radio signal.

For such energy harvester driven devices a well regulated band with duty cycle
restrictions is very important, because it is usually not possible to switch on a
receiver for listen before talk due to the tiny amounts of energy. In addition it is
necessary that only low transmit powers of a few mW are allowed.




P a g e |3                                                 Ref: c253e84c-1930-4546-aaaf-f646db4fffbd.doc, 16 February 2013
Nuuon Australia                            Phone +61 422 178274, +61 3 88191285
ABN: 93 371 594 525                              australia@nuuon.com.au
VIC Security License: 781-241-60S                  www.nuuon.com.au
                                    Australia
Reasons – self-powered, energy harvesting modules
cannot operate in LIPD Class License spectrum:
ACMA’s document reference.

     1. Section 2.2.10, Low interference potential devices
     2. Section 5.3.1, Smart Infrastructure


The bands shown in Table 2.12 cannot be used for such self-powered sensors and
switches because allowed power is too high and there is no duty cycle limitation.




                                                                 Too high EIRP with no
                                                                  duty cycle limitation




The band planned for smart infrastructure (Section 5.3.1) cannot be used to operate
energy harvester driven devices due to very high risk of interference created by such
mesh network devices.




P a g e |4                                           Ref: c253e84c-1930-4546-aaaf-f646db4fffbd.doc, 16 February 2013
Nuuon Australia                       Phone +61 422 178274, +61 3 88191285
ABN: 93 371 594 525                         australia@nuuon.com.au
VIC Security License: 781-241-60S             www.nuuon.com.au
                                    Australia
International approvals and conformity to regional
regulations for EnOcean devices:
EnOcean devices are currently approved according to

         EN300220 in Europe

         FCC 15.231 in the USA

         RSS-210 in Canada

         Approval in China is currently in progress. Regulation in China similar to as in
          Europe for 868MHz.




P a g e |5                                           Ref: c253e84c-1930-4546-aaaf-f646db4fffbd.doc, 16 February 2013
Nuuon Australia                       Phone +61 422 178274, +61 3 88191285
ABN: 93 371 594 525                         australia@nuuon.com.au
VIC Security License: 781-241-60S             www.nuuon.com.au

				
DOCUMENT INFO
Shared By:
Categories:
Tags:
Stats:
views:0
posted:2/16/2013
language:Latin
pages:5