Download - IEEE Mentor

May 14 2008
Project: IEEE P802.15 Working Group for Wireless Personal Area Networks
(WPANs)
Submission Title: [Potential Waiver and Rulemaking change to Part 15.247]
Date Submitted: [14 May 2008]
Source: [Jeff Solum] Company [Starkey Laboratories, Inc]
Address [6600 Washington Av S, Eden Prairie, MN, 55344]
Voice:[Add telephone number], FAX: [Add FAX number], E-Mail:[[email protected]]
Re: [in response to the call for presentations from WNG Chair]
Abstract: [Description of wireless hearing aid needs.]
Purpose: [Informative document on NPRM to FCC Part 15.247]
Notice: This document has been prepared to assist the IEEE P802.15. It is offered as a basis
for discussion and is not binding on the contributing individual(s) or organization(s). The material
in this document is subject to change in form and content after further study. The contributor(s)
reserve(s) the right to add, amend or withdraw material contained herein.
Release: The contributor acknowledges and accepts that this contribution becomes the property
of IEEE and may be made publicly available by P802.15.
Slide 1
<Jeff Solum >, <Starkey Laboratories>
Potential Waiver and Rulemaking
change to Part 15.247
Starkey Laboratories, Inc.
Jeff Solum
5/14/2008
<Jeff Solum >, <Starkey Laboratories>
Agenda
• Introduction of Starkey Laboratories,
Inc.
• What are we trying to accomplish
• Hearing aid styles
• Benefits for the hearing disabled
• Assistive Listening Devices
• Waiver/Rulemaking relative to hearing
aids operating within Part 15.247
Starkey Laboratories, Inc.
• Private company founded in 1967 by William F. Austin
• Headquarters in Eden Prairie, MN
• With 35 facilities in more than 24 countries around the globe,
Starkey is an industry leader in hearing instrument manufacturing.
We create top quality diagnostic equipment, hearing protection
products, wireless technology and unique hearing solutions for
every environment.
• Starkey is a world leader in the design, development and
distribution of comprehensive hearing solutions. We believe in
using superior hearing technology as a means to something even
greater—creating meaningful connections between people and
their worlds.
What we are trying to accomplish
• We care about our patients
– We care about the real life frustrations today’s hearing
disabled patients face on a daily basis.
– We are passionate about the quality of our patient’s life
experiences.
– We believe that the hearing disabled should be able to enjoy
the same quality of life as persons with normal hearing.
– We believe that the hearing disabled should be fully
connected to the world in which they live through digital
wireless technology.
– There are over 31 million Americans with hearing problems
that can be addressed through wireless technology.
• 16 million (and rising) are baby boomers
What we are trying to accomplish
• Current regulations do not enable us to provide next generation
patient benefits for the hearing disabled.
• We are seeking a waiver and subsequent rule making change to
help facilitate a high quality of life for the hearing disabled.
Hearing Aid Styles
Behind The Ear
(BTE)
On The Ear
(OTE)
Receiver-InCanal
(RIC)
In-The-Ear
(ITE)
In-The-Canal
(ITC)
Completely-InCanal
(CIC)
BTE instruments
With soft, flexible The receiver-in-the- Smaller, in-the-ear
In-the-canal
These devices fit
have a plastic casing earbuds and an
canal device is
instruments house
instruments are
completely in the
that rests behind the extra-small casing, small, discreet, and
their technology
smaller still,
canal. Only the head
ear and houses the on-the-ear models incredibly quick to fit; components in a featuring an earmold of a tiny plastic
device's technology.
are light and
perfect for many
custom-formed
that fits down into line—with which you
A clear plastic tube
comfortable.
first-time wearers.
earmold that fits the ear canal and a insert or remove the
then directs
within the outer smaller portion that instrument—shows
amplified sound into
portion of the ear. faces out into the
above the canal.
an earmold inside
outer ear.
the ear canal.
Benefits for the hearing disabled available through digital
wireless technology
• Social
– Interaction with others
• Social Events
– Large gatherings are often avoided by hearing aid wearers.
– Many venues do not have ALD systems or require stigmatizing
apparatus to be used.
– Intimacy
• Interpersonal warmth in relationships significantly declines as
hearing loss worsens.
• It can be exhausting to cope with the needs of a spouse with
a hearing disability.
– Independence
• There is a strong relationship between one’s ability to hear,
perceived safety, and independence.
• Education
– Classroom
– Online
– Other learning situations
http://www.betterhearing.org/hearing_solutions/qualityOfLifeDetail.cfm
Benefits for the hearing disabled available through digital
wireless technology
• Safety
– Alarms and announcements
• Doorbells
• Fire alarms
• Emergency announcements
• Information
– Audible indicators
– Public transportation
• Buses/Trains
• Bus/Train/Airport Terminals
• Entertainment
– Music
– TV
– Live Theater
http://www.betterhearing.org/hearing_solutions/qualityOfLifeDetail.cfm
Benefits for the hearing disabled available through
digital wireless technology
> Economic
> Household income is affected by hearing loss,
particularly for moderate to profound loss – $-13,000
Household
per
yearIncome Related to Severity of Hearing Loss
Household Income
40000
35000
> Wearing a hearing aid reduces this to $-7000
> Greater connectivity could reduce this even further
30000
25000
20000
15000
10000
5000
0
Mild
Mild to
Moderate
Moderate
Moderate to
Profound
Profound
Hearing Loss
http://www.betterhearing.org/hearing_solutions/qualityOfLifeDetail.cfm
Today’s Patient Limitations
• Custom hearing aid wearers are generally unable to take advantage of
many Assistive Listening Devices (ALD’s) because direct audio input
connectors are not physically available on custom hearing aids.
•
Speech Understanding in public places
– Poor signal to noise ratios make it difficult to understand public
announcements such as bus/train arrivals or next stops.
– Often, patients must remove their hearing aids in order to use
currently available public ALD systems.
– Using most widely available ALD systems causes patients to give up
their prescribed frequency response.
• Range on in-home ALD’s is often limited to line of sight (same-room
usage).
– Many are not compatible with hearing aids
• Dongles, cables, or headsets are required for most current
communication interfaces
•
Almost all current ALD systems highlight a patient’s disability.
Current Assistive Listening Devices
• Audio Inductive Loop Systems
–
–
–
–
Require high power magnetic loops
Audio frequencies direct to tele-coil input
Suffer from low range and polarization effects
Not widely installed in the US
• Analog FM Systems
– 200 and 70 MHz narrow band analog FM
– Require external receiver
– Require direct audio input connection to HA
• Infrared Systems
– Some public venues (Museums)
– Limited to line of sight
– Require direct audio input connection to HA
http://www.betterhearing.org/hearing_solutions/listeningDevices.cfm
May 14 2008
The Future of Personal Assistive Listening
Devices
Low Power 915 MHZ, One Way Voice Link
Slide 13
<Jeff Solum >, <Starkey
May 14 2008
Assistive listening device in an
auditorium setting
Slide 14
<Jeff Solum >, <Starkey
May 14 2008
Assistive listening device in a public
transportation setting
Slide 15
<Jeff Solum >, <Starkey
Starkey’s vision for personal connectivity
Tomorrow’s connectivity
Change the paradigm of wireless connectivity
from a clumsy, costly accessory to a ubiquitous
communication feature.
• Safety information/alarms can be transmitted directly to a
hearing instrument.
• Digital audio can be utilized in classrooms or theaters
without the need for expensive loop system installation.
• Allows connection to the public telephone network.
• Extend the range at which ALD’s are able to be effective,
including personal microphone systems.
Applications envisioned for new
hearing instruments
15.249
• Phase 1 (2008-2009) –possible under part 15.249
– Programming Hearing Instruments
– Patient Ear to Ear Communication
– Remote control
– Patient Data Logging
NOT 15.249
• Phase 2 (2010) – NOT possible under part 15.249
– Digital Streaming Audio
– Assistive Listening Device
• Phase 3 (2011) – also NOT possible under 15.249
– Bi-Directional Streaming Audio
Why we are using 902-928 MHz
• Unlicensed band in the US with similar bands available in
the EU and many other countries.
• 900 MHz is a good place to operate small body worn
ultra-low power devices
– Antennas are small and efficient for the size available in a
hearing aid.
– Small, custom hearing aids dominate the US market.
– Power consumption is low, with transmit and receive
consumption nearly equal at this frequency and antenna
efficiency.
– Losses due to body absorption are relatively low below 1
GHz.
Part 15.249 Technical Limitations
• 15.249 RF output level is limited to -1.5 dBm.
• Range is limited to < 3m for good quality links given the hearing
aid antenna size and limited sensitivity.
• This works well for the programming and ear to ear applications
for a programmer using adaptive frequency selection and relatively
large antennas.
• 15.249 will not work well for real time streaming audio
applications beyond 2 meters.
• Interference will be problematic at this low a power level
operating in this “unlicensed band”.
What about 15.247?
• 15.247(e) For digitally modulated systems, the power spectral
density conducted from the intentional radiator to the antenna shall
not be greater than 8 dBm in any 3 kHz band during any time interval
of continuous transmission.
• Allows a power spectral density of 8 dBm/ 3 kHz.
• This power level extends the range of communication to 30 m and
opens up streaming digital audio and other applications for
classrooms, households, and public venues.
• 15.247(a)(2) Systems using digital modulation techniques may
operate in the 902–928 MHz, 2400–2483.5 MHz, and 5725–5850
MHz bands. The minimum 6 dB bandwidth shall be at least 500 kHz.
• Constraint is the specification of a minimum bandwidth of 500 kHz
Design Crossroad Reached
• Starkey and other hearing aid manufacturers have three
design options to use 902-928 MHz
– Work within Part 15.249
• Limits the applications
• Poor reliability due to limited link margin
– Increase occupied bandwidth to meet Part 15.247
• Occupy more bandwidth than necessary for the
application (500 kHz)
• Power consumption increases (Battery life decreases)
– Work within Part 15.247 with requested waiver
• Allows operation of all applications without creating
unnecessary interference.
• Improves reliability
• Reduces overall power consumption
Waiver Request
• A waiver to 15.247 minimum bandwidth
requirements to allow the hearing disabled to use
the same power spectral density (8 dBm/3 kHz),
but with a lower bandwidth minimum (100 kHz vs.
500 kHz)
• Waiver is in the public interest
• Waiver request does not undermine the purpose
of the rule
100 to 300 kHz is sufficient for most digital streaming
audio signals
Rule Making
Change the rules to allow operation
under 15.247 at a lower minimum
bandwidth (100 kHz) while
maintaining the power spectral density
requirement of 8 dBm/ 3 kHz.
– Public interest
• Current rule has potentially unintended
consequences.
– Promotes inefficient use of the spectrum
• A rule change will allow efficient and
better utilization of the available
bandwidth.