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Why the FCC’s safety guidelines for Wi-Fi need to be re-evaluated

Wi-Fi has become the fourth utility we need – after water, gas, and electricity. Everything is being “wifized.” My watch, my phone, my TV, my iPad, my DVD player, my coffee maker, my refrigerator, my weighing machine! Schools, hospitals, businesses, coffee shops… it’s everywhere. We can’t live without it, but hopefully it is not killing us slowly. I say this because FCC guidelines for maximum allowed transmit power of Wi-Fi Access Points are based on the assumption that Wi-Fi signals are received by a human body from a distance for one transmitting Wi-Fi antenna. However, we are not exposed to just one transmitting Wi-Fi antenna anymore.

From the FCC.gov site:

“Since 1996, the FCC has required that all wireless communications devices sold in the United States meet its minimum guidelines for safe human exposure to radio frequency (RF) energy. The FCC’s guidelines and rules regarding RF exposure are based upon standards developed by IEEE and NCRP and input from other federal agencies. These guidelines specify exposure limits for hand-held wireless devices in terms of the Specific Absorption Rate (SAR). The SAR is a measure of the rate that RF energy is absorbed by the body. For exposure to RF energy from wireless devices, the allowable FCC SAR limit is 1.6 watts per kilogram (W/kg), as averaged over one gram of tissue. All wireless devices sold in the U.S. go through a formal FCC approval process to ensure that they do not exceed the maximum allowable SAR level when operating at the device’s highest possible power level.”

This is where the problem is. The amount of radiation exposure today is over 100 times higher as we live in proximity to a very large number of actively transmitting Wi-Fi Devices and Wi-Fi Access Points/Routers. Consider the reality today:

  • Each person today carries three to five Wi-Fi devices (phone, laptop, watch, tablet, to name a few). And, the last time I looked for a Wi-Fi network at my home, I could see over 10 Wi-Fi Access Points (neighbors!).
  • When I am at the coffee shop, not only do I see multiple SSIDs, there are over 15 to 20 people working on their iPads and laptops (each device actively transmitting Wi-Fi).
  • Today’s SCHOOLS initiative for online classrooms is a scenario that will involve about 20 to 25 iPads actively transmitting per classroom and in multiple adjacent classrooms. Schools also have one to three Wi-Fi Access Points per classroom and additional Access Points in hallways, etc. Whether you are a student or teacher, you may see over 40 Wi-Fi Antenna and 200 clients in Wi-Fi proximity.
  • Enterprises deploy a large number of access points for better experience for roaming and other applications. For example, a typical 100-employee office might have over 30 Wi-Fi Antenna and over 300 Wi-Fi devices.
  • When I am in hospital, the phones carried by nurses, the code red buttons, the IV pumps are all Wi-Fi-connected. Whether a new-born baby, child, or a senior citizen, they are all getting exposed to Wi-Fi even if they are not using it.
  • At a retail store, they have a large number of Access Points and Wi-Fi devices. A typical Walmart-type store might have around 50 Access Points and 600 Wi-Fi devices, such as bar-code scanners, price verifiers, phones etc., carried by visitors and employees.
  • Each Access Points contains 1 to 12 Radios, and each radio has multiple transmitting antennas.

And the exposure to RF energy from one wireless device itself is close to the allowable FCC SAR limit already. For example: 

  • iPhone’s published SAR (specific absorption rate): 1.18 W/kg Body and 1.25 W/Kg Head.
  • iPad’s published SAR (specific absorption rate): 1.19 W/kg Body.

This is why I am concerned. All focus has been only on SAR and safety, with respect to cellular. However, in real-life measurement, the signals sent from Wi-Fi are more continual than on 3G transmission, and the effect is aggregate. The peak Wi-Fi radiation for iPads, Laptops, and Wi-Fi Antenna in aggregate is much higher.

About 300 of every 100,000 people develop cancer in top-10 countries with populations around 5 million or more (Denmark, France, Australia, Belgium, Norway, United States of America, Ireland, South Korea, Netherlands, and Canada), and these countries also have very high internet/Wi-Fi penetration (Denmark: 96%, France: 86%, Australia: 89%, Belgium: 85%, Norway: 96%, U.S.: 87%, Ireland: 82%, South Korea: 92%, Netherlands: 96%, Canada: 93%). The correlation is very hard to establish, as multiple factors are involved. However, with the increase of Wi-Fi/Radiation exposure today, the limits established before the “wifization” of society may not be good enough.  

I strongly believe that the time has come to re-evaluate the FCC guidelines, as well as how Wi-Fi transmit power is handled by Wi-Fi device/Access Point vendors. Here are some suggestions on how to do so:

  • FCC regulations need to be updated based on the maximum power of each transmitting device based on number of Wi-Fi Transmitting antenna in proximity.
  • Schools and businesses should require all Wi-Fi devices (client devices and Wi-Fi Access Point/Routers) to do automatic maximum power selection/reduction based on the number of Wi-Fi Transmitting antennas in proximity.
  • Access Point deployments and power settings should be done with consideration around aggregate SAR value exposure.

Let’s build our future using Wi-Fi, and protect our future at the same time.

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It’s on: LTE-U vs. Wi-Fi

To maximize innovation and competition in wireless space, the FCC and other international regulatory organizations have always allowed a part of the spectrum as unlicensed, along with the licensed spectrum. Unlike licensed spectrum, which is available for exclusive use via auction (to the highest bidder), the unlicensed spectrum is available for people to share. People can use unlicensed spectrum just by following technical rules. They do not need government authorities telling them what to do. This model has worked exceptionally well, as consumers ultimately have been able to choose what best serves their needs. Cellphone connectivity is one of the top innovations in licensed space, and Wi-Fi in the unlicensed space. Can’t live without either!

And, recently, a new carrier technology called LTE-U (LTE Unlicensed) has started being tested, and it has the potential to offer a substantially better cellphone experience. LTE-U isn’t meant to replace LTE, but add to LTE’s speed and services in areas that have high congestion. A device would connect using a typical LTE connection as well as connect with nearby LTE-U signals at the same time to get more bandwidth and better service. With LTE-U, your mobile phone will experience better throughput, better coverage, and increased capacity. However, LTE-U connects in unlicensed 5GHz Spectrum (same as Wi-Fi), and that is the reason for the big debate. The telecom or cable operators, Internet service providers, managed service providers, and Wi-Fi infrastructure vendors are all involved. Some of them want to preserve the status quo for Wi-Fi, some of them want to push forward without considering impact on Wi-Fi, and some of them even want to regulate the unlicensed space.

If you have used a cell phone for data, I am sure you have experienced slowness even in 4G networks. And at times we haev connected to Wi-Fi for as much as $14.95 per hour. Make no mistake – the debate is not about what is better for the consumer. The debate is about who will keep that $14.95.

A few facts about LTE-U:

  • LTE-U devices will meet the same power regulations as the Wi-Fi devices that exist today.
  • Unlike LTE, LTE-U will not be broadcast from macro cell towers. It’s strictly a small cell technology. LTE-U is good for healthcare, shopping malls, universities, hotels, stadiums and all the areas where “guest” cellphone users expect a better data experience.
  • LTE has better spectral efficiency than Wi-Fi. Compared to Wi-Fi, LTE can go up to twice the distance at the same power output.
  • LTE back-off algorithms are different from Wi-Fi, and ASIS coexistence may be challenging.

Will LTE-U impact Wi-Fi performance?

Yes, there is no doubt. However, I don’t agree with the fact that we should stop innovation in the unlicensed spectrum, as Wi-Fi is good enough. Wi-Fi itself was invented because we were allowed to innovate in unlicensed spectrum. No standards body for one technology should be given the right to impose limitations on another. Innovators have delivered millions of offerings, such as baby monitors, cordless phones, industrial/logistics/inventory systems, remote car door openers, and many more. Let the innovation continue.

Should you be worried as a consumer?

No, not at all. This debate between Wi-Fi and LTE-U is a nice problem to have. The conflict reflects the fundamental dynamism of the wireless industry. Technologies rise and fall based on their usefulness and subsequent adoption. We have witnessed many wireless technologies: AMPS, 2G, GSM, HSPA+, LTE, WiMax, Bluetooth, ZigBee, Active RFID (433MHz, 900MHz, etc.). Each with their set of advantages and success rate. The whole point of competition is that the companies try. Sometimes you win and sometimes you lose. Bring it on and we (consumers) can decide what works best for us.

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Why Wi-Fi will be the technology of choice for the Internet of Things

With projections of more than 5 billion connected devices by the end of this year and growth to 50 billion by 2020, the challenges facing the Internet of Things (IoT) include a lack of standardization, security, integration, battery life, and rapid evolution. Wi-Fi, in its 16th year, is getting ready for IoT and will perhaps make the most suitable network for the technology.

IoT may be a recent buzzword, but the quest for connected things is old. Very old. Caller ID, connected Coca-Cola vending machines, M2M, smart meters, RFID, AutoID, etc. The whole appeal of connected things has been efficiency and experience. And the desire for experience and efficiency is even greater today. We live in an experience era and have no patience. We expect ‘great experience’ and ‘efficiency’ around us. Only IoT can enable that. IoT is nothing but an intelligent and invisible network of things that communicate directly or indirectly with each other or the internet to enable experience and efficiency.

Here are some of the challenges facing the IoT, and how Wi-Fi can help address them.

IoT needs a standardized technology for connecting devices to each other or the cloud

The things (as in Internet of things) typically employ some kind of embedded technology that allows them to sense conditions such as pressure, humidity, temperature, motion, number of people in an area, etc. And then a technology allows them to connect to other things or the cloud so that they can send the information as well as be programmed. There are many standards and proprietary solutions used for connecting things to each other or to the cloud: Wi-Fi, Bluetooth, ZigBee, Active RFID, loWPAN, EtherCAT, NFC, RFID to name a few. The choice of technology is usually dictated by the physical characteristics of the environment, such as the presence of wood, concrete, metal etc., the density of sensors, desired range, and data rates. Among these technologies, Wi-Fi has been the most successful. It has become a ubiquitous standard of connectivity and is used in the home, enterprise, schools, hospitals, airports etc.

However, as the number of devices connected to a Wi-Fi Access Point or the distance of device to Access Point is limited, many Active RFID technologies that operate in sub 1-GHz bands are used for things too. Active RFID technologies allow a large number of devices as well as larger ranges.

To overcome these challenges, a new IEEE Wi-Fi standard 802.11ah using the 900MHz band has been in works and will solve the need of connectivity for a large number of things over long distances. A typical 802.11ah access point could associate more than 8,000 devices within a range of 1 km, making it ideal for areas with a high concentration of things. The Wi-Fi Alliance is committed to getting this standard ratified soon. With this, Wi-Fi has the potential to become a ubiquitous standard for IoT.

And, not to mention, the growth of the IoT has just started. We are rapidly evolving, but there is a lot of unknown. Unknown applications, unknown devices, and unknown use cases. The best way to proceed is using one common worldwide standard for technology and application programming interfaces that can get these devices to talk to each other and to the cloud without networking infrastructure upgrades. Standardization and implied interoperability is one of the main reasons Wi-Fi is very popular, and that’s another big reason that it is suitable for the IoT.

Needs of security and protecting privacy in the borderless world created by IoT are real

IoT creates a borderless world where things talk to the cloud. Network or device administrators may not even realize the firmware or operating systems of these things or the cloud applications that these things talk to. In other words, protecting privacy and preventing malicious activity will be a challenge.

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One may not even know what other information these things will send or how that information is used. Too many cloud apps, too many APIs, too many hackers out there. For security and policy enforcement, SDN is the most natural solution, and in the last couple of years, a good effort has happened in the industry around SDN (software-defined networking) enablement of Wi-Fi. With SDN, Wi-Fi enables unified policy management as IoT device traffic can be scanned and secured at the network entry point.

Without energy efficiency, maintenance overhead of things will be too substantial

As most of these things need to be portable or self-sustaining, stretching battery power or harvesting energy is almost a must. The battery change cannot be required every few days or weeks. And batteries should be preferably using solar, wind, thermal, and other energy mechanisms. Significant efforts in the industry have been going on for many years to make Wi-Fi low power, and many vendors now specialize in low-power Wi-Fi chipsets. Additionally, 802.11ah helps with lower-power consumptions and most recent innovations around backscatter Wi-Fi can enable a no-power or battery-assisted low-power Wi-Fi.

At this point, Wi-Fi appears to be the most suitable choice for the IoT as it has the potential to address all the challenges. I would love to hear your feedback about this.

This article is published as part of the IDG Contributor Network. 

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