UltraVision Security Systems Inc. requested a waiver of Part 15 of the FCC rules to allow the marketing and operation of an ultra-wideband (UWB) surveillance system that would operate in the VHF and UHF bands below 700 MHz. UltraVision said its UltraSensor system has a typical -10 dB bandwidth between 80 and 600 MHz. While the system complies with Section 15.209 and Section 15.511 emission limits, it does not operate within the 1,990-10,600 MHz band required under Section 15.511(a).
Although users of the 80-600 MHz spectrum are likely to be concerned about UltraVision using this band for its UltraSensor security system, both the company and FCC point out that emissions from the UltraSensor in the VHF and UHF spectrum are no greater than those allowed for UWB systems using spectrum authorized under Section 15.511(a). UltraVision explained that its system, as far as emissions are concerned, is no different than systems authorized for operation in the 1,990-10,600 MHz band. The only difference is the UltraSensor system produces fewer emissions on frequencies above 960 MHz.
"UltraSensors" are installed 15 to 20 cm underground, below pavement or turf, at about 20-meter intervals around the site to be protected. A co-located receiver analyzes the return signal to determine the presence, location, velocity and mass of an intruder. The UWB pulses are 2 nanoseconds wide at 20-80 kHz. The pulses are dithered, "all but eliminating the possibility of nearby units emitting simultaneously," according to UltraVision. Power levels are, UltraVision states, "...trivial, just a few nanowatts. The energy into the passband of an actual receiver at any realistic distance will be completely undetectable."
UltraVision also proposes to maintain a complete database of exact locations of devices authorized under the waiver and make this data available to the FCC and to NTIA on request. The company said it "will honor its obligation to promptly correct any reported harmful interference, by shutting off the unit if necessary." UltraVision added, "indeed, because UltraSensor is less interfering than compliant UWB surveillance systems, the combination of rule interpretation and waiver will yield installations that are both less interfering and more broadly in the public interest than compliant systems."
UltraVision said its UltraSensor is invisible to an intruder, and is hidden where an intruder cannot disable it. The system operates in all weather conditions and requires little or no maintenance. In addition, unlike other security systems it can provide real-time distance to a moving target, such as a pedestrian or vehicle, the real-time velocity of the target and the target mass. This allows automatic classification of the target, i.e., if the target is a vehicle, person, small animal, or an object blown by the wind.
Comments on the waiver request are due Nov. 24, with reply comments due Dec. 8. The FCC has declared this a "permit-but-disclose" proceeding for ex-parte purposes. For additional information, see FCC Public Notice DA 06-2102 as well as UltraVision's request and other comments on the FCC's Electronic Comment Filing System. Enter "06-195" in box number 1, "Proceeding."
