FCC Approves Part 15 Waiver for Robotic Lawn Mower

The FCC’s Office of Engineering and Technology released an order today approving a waiver to permit the marketing of a robotic lawn mower by iRobot Corp.

“Specifically, we are waiving the prohibition on the use of fixed outdoor infrastructure to allow iRobot to obtain equipment certification for and market a robotic lawn mower (‘RLM’) that operates in the 6240-6740 MHz frequency range,” OET said in an order released in ET docket 15-30. “We find that granting this waiver is in the public interest because it will enable iRobot to market its robotic lawn mower without posing a significant risk of harmful interference to authorized users of the radio spectrum.”

The order noted that the National Radio Astronomy Observatory (NRAO) expressed concern that the waiver could lead to interference to radio astronomy operations (TRDaily, March 10), but it said that the concerns were overblown.

“As discussed above, grant of this waiver does not frustrate Section 15.250(c)’s purpose of preventing the establishment of fixed wireless communications networks over wide areas,” OET said. “We note that the interference concerns raised by NRAO do not address the Section 15.250(c) restriction on fixed outdoor infrastructure being considered in this waiver proceeding, or the Commission’s intent to prevent the establishment of wide area communications systems. However, we agree that iRobot’s system design – including the use of low-to-the-ground transmitters pointing horizontally – and its focus on marketing for non-commercial residential use – incorporates practical measures (i.e., consistent with US342) appropriate for protecting the non-allocated radio astronomy service from harmful interference.

“Furthermore, because the NRAO analysis looked at line-of-sight separation distances, it has greatly overestimated the interference potential of transmitters that are located less than two feet above the ground,” OET added. “We find that when taking into account the variability in propagation characteristics due to terrain, low antenna heights and other propagation factors, grant of this waiver is very unlikely to increase the potential for harmful interference. As a condition for granting this waiver, and to promote the protection of radio astronomy operations, we will require iRobot to comply with the representations and commitments it made in the Waiver Request.”

The order said that the lawn mowers will be limited to residential use and its beacons can’t communicate with other devices. The devices also must be no higher than 24 inches from the ground and must comply with part 15 emissions limits and 5925-7250 MHz band out-of-band emissions limits and other technical rules.- Paul Kirby, paul.kirby@wolterskluwer.com