Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

In the Matter of ) ) Targeted Changes to the Commission’s ) ET Docket No. 19-226 Rules Regarding Human Exposure to ) Radiofrequency Electromagnetic Fields )

REPLY COMMENTS OF WITRICITY CORPORATION

Ky Sealy, Morris Kesler WiTricity Corporation 57 Water Street Watertown, MA 02472

July 20, 2020

SUMMARY

WiTricity Corporation (“WiTricity”) submits these reply comments primarily regarding the matter of Wireless Power Transfer (“WPT”). WiTricity previously filed comments1 on this topic and acknowledges and appreciates the comments submitted to the Commission related to

the subject matter of WPT, and WiTricity incorporates these comments by reference2 for reply.

WiTricity agrees and acknowledges that WPT should generally fall under the

Commission’s Part 18 rules for ISM equipment. WiTricity recognizes the Commission’s need to

define “local use” for WPT due to the definition of Industrial, Scientific, and Medical (ISM)

Equipment indicated in the ITU-R Radio Regulations for which the Unites States is a member

nation. WiTricity offers a very simple scientific explanation for determining the definition local

use in Subsection §B. Definitions for Types of WPT herein. The premise for consideration of

local use, as it pertains to WPT, is that ISM equipment does not radiate broadly into the

environment. The two ways to ensure that a WPT system meets the local use requirement is

either by 1) ensuring the WPT system utilizes evanescent (i.e., reactive near-field)

electromagnetic fields / coupling, which is “local” by definition, or by 2) ensuring a WPT system

1 WiTricity Comments - https://ecfsapi.fcc.gov/file/1042777110387/WiTricity%20WPT%20Responses%20FCC%2019-126%20Document.pdf 2 Dr. Bernd Sisolefsky - https://www.fcc.gov/ecfs/filing/104262609810533 WiTricity Corporation- https://www.fcc.gov/ecfs/filing/1042777110387 Ossia Inc. - https://www.fcc.gov/ecfs/filing/1052248419025 ASC C63 Subcommitee 4 - https://www.fcc.gov/ecfs/filing/1060338411833 Rober Kavet - https://www.fcc.gov/ecfs/filing/106120110803924 IEEE ICES - https://www.fcc.gov/ecfs/filing/10615409300413 Hammett & Edison, Inc. - https://www.fcc.gov/ecfs/filing/106160465024704 MetaPower, LLC - https://www.fcc.gov/ecfs/filing/106171364226583 Guru Wireless, Inc. - https://www.fcc.gov/ecfs/filing/10617201318669 ITIS Foundation - https://www.fcc.gov/ecfs/filing/106173024905066 Energous Corporation - https://www.fcc.gov/ecfs/filing/1061748818006 Momentum Dynamics Corp. - https://www.fcc.gov/ecfs/filing/106181802110698

operating in the far-field provides sufficient directivity to ensure the RF energy is used “locally”

by the receiving device. WiTricity recognizes and agrees that in addition to this local use requirement, ISM equipment must not cause harmful interference to other licensed radio devices and must be safe for humans by means of compliance with RF Exposure rules. In no way does the local use requirement specifically indicate a fixed distance nor does it preclude various types of WPT. Due to the fact that the mechanisms of power transfer are different (and hence the methods of testing) when considering specific types of WPT, WiTricity also offers definitions for types of WPT based on the intended distance of operation for the device and the highest frequency used for power transfer. These definitions allow the Commission to provide appropriate guidance based on the delineation of local wireless power transfer (LWPT) versus wireless power transfer at-a-distance (WPTAAD) while still maintaining the local use requirement for both under the definition of ISM Equipment.

WiTricity agrees and generally acknowledges that WPT systems must 1) adhere to Part

18 EMC rules to prevent harmful interference and 2) adhere to RF Exposure rules under Part 2 and for which the Commission is considering expanding its scope to include WPT at frequencies below 300 kHz. WiTricity acknowledges and thanks important working groups such as the

International Commission on Non-Ionizing Radiation Protection (ICNIRP) and IEEE’s

International Committee on Electromagnetic Safety (ICES). WiTricity is not opposed to the

Commission’s adoption of either the ICNIRP 2010 Guidelines limits or IEEE C95.1-2019 limits for frequencies below 300 kHz, but WiTricity urges manufacturers to consider field limits that do not cause interference with cardiac implantable electronic devices (CIEDs). WiTricity urges the Commission to consider adopting equivalent Maximum Permissible Exposure (MPE) levels below 300 kHz or provide specific guidance that indicates the proposed Basic Restriction Limits

iii

can be shown to be met by means of the (Exposure) Reference Levels in either the ICNIRP 2010

Guidelines or the IEEE C95.1-2019 Standard – based on whichever the Commission chooses to adopt.

Based on a significant maturity of standards (e.g., 10+ years of work in SAE J2954),

WiTricity urges the Commission to consider higher electromagnetic interference (EMI) limits in the range of 79 kHz to 90 kHz as indicated by the petition RM-11815 for wireless power transfer for electric vehicles (WPT-EV) referenced herein. In particular, WiTricity urges the

Commission to adopt limits based on recommendations from Standards Development

Organization (SDOs) such as SAE J2954. Adoption of increased limits in this range is in harmony with ITU-R Recommendation SM.2110 and will help the United States in improve its adoption of Electric Vehicles (EVs) and reduce carbon and greenhouse emissions, which have been shown to be harmful both to humans and the environment.

With the Commission’s adoption of new definitions and clarity for existing Part 18 rules as well as the expanded scope of RF exposure rules below 300 kHz, WiTricity encourages the

Commission to simplify the approval process for wireless power transfer devices and specifically local wireless power transfer devices (utilizing evanescent electromagnetic fields) by updating the Commission’s specific guidance in KDB 680106 to further allow more WPT devices to be approved by means of standard Telecommunication Certification Body (TCB) processes and modular approval. WiTricity acknowledges that the EMC approval process in particular should be simplified for WPT systems falling within the scope of the soon-to-be published ANSI

C63.30 Standard (as an update for WPT to the Commission’s outdated MP-5) which provides appropriate methods for testing the EMC of local wireless power transfer systems.

TABLE OF CONTENTS

REPLY COMMENTS OF WITRICITY CORPORATION ...... 1 DISCUSSION ...... 2 A. Applicable Title 47 Rule Parts for WPT ...... 2 B. Definitions for Types of WPT ...... 3 C. EMC Frequencies, Limits, and Methods for WPT ...... 6 D. EMF RF Exposure Limits for WPT ...... 8 E. WPT Certification Process ...... 10 CONCLUSION ...... 10

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

In the Matter of ) ) Targeted Changes to the Commission’s ) ET Docket No. 19-226 Rules Regarding Human Exposure to ) Radiofrequency Electromagnetic Fields )

REPLY COMMENTS OF WITRICITY CORPORATION

WiTricity Corporation (“WiTricity”) was founded in 2007 to commercialize a new technology for wireless electricity invented and patented two years earlier by a team of physicists from the Massachusetts Institute of Technology (MIT), led by Professor Marin Soljačić.

Professor Soljačić and team proved that magnetic fields of two properly designed resonators with closely matched resonant frequencies can couple to enable the transfer of power from one device to the other at high efficiency and over a distance range that is useful for real-world applications.

Dubbed “highly resonant wireless power transfer” or “magnetic resonance”, the initial technology was demonstrated by illuminating a 60-watt light bulb from a power source over 2 meters away (as published in the prestigious journal Science in July 2007). More important than simply proving a light bulb could be illuminated, the experiment validated their theoretical models of how electric power is wirelessly transferred as a function of the geometry, distance, and electrical properties of the devices used by means of magnetic resonance.

WiTricity is the exclusive licensor of the foundational MIT patents and also of the

University of Auckland3 WPT patents for electric vehicles. WiTricity licenses its intellectual

property across many industries and companies world-wide and continues to develop important

intellectual property. In 2019, WiTricity acquired Qualcomm Halo4 and its assets related to

WPT for electric vehicles. As of July 2020, WiTricity Corporation holds over 1000 patents worldwide with more than 400 patent applications pending. WiTricity is the global leader in magnetic resonance wireless power transfer.

DISCUSSION

The Commission’s Notice of Proposed Rulemaking (NPRM) ET Docket No. 19-226

addresses issues and raises questions related to WPT including the topic of applicable rule parts,

definitions, appropriate frequencies, certification process, electromagnetic compatibility (EMC),

and RF exposure consideration. WiTricity addresses these points with consideration of the

comments filed to date on the subject of WPT.

A. Applicable Title 47 Rule Parts for WPT

WiTricity agrees with the comments that indicate the WPT is generally considered an

Industrial, Scientific, and Medical (ISM) device in accordance with the Commission’s Title 47,

Part 18, Sub-part §18.107c definition of ISM equipment as well as in accordance with the latest

ITU Radio Regulations (2016 Publication as of this date) definition found in Volume I, Chapter

1, Article 1.15. In accordance with these definitions and the intended application of the

3 https://witricity.com/witricity-establishes-development-team-switzerland-extends-relationship-university- auckland/ 4 https://witricity.com/witricity-acquires-qualcomm-halo/ https://witricity.com/witricity-expands-wireless-charging-qualcomm-deal/

Commission’s Part 18 rules, WiTricity agrees that the Part 18 rules currently apply and should

continue to solely apply generally to the WPT portion of the device so long as any “in-band”

signaling (i.e., signaling occurring with the fundamental power transfer frequency) that may or

may not be present follows the Commission’s applicable requirements listed in KDB 680106

attachment to the extent that they are “…used only to the extent necessary to enable safe and

efficient operation…”. WiTricity disagrees with any commenter(s) that suggest that WPT should be classified under a newly created rule because existing Part 18 rules are sufficient to encompass wireless power transfer technologies and many such devices have already been tested and certified under these rules.

WiTricity acknowledges specifically that ISM equipment is defined in both the Part 18

definitions and the ITU Radio Regulations such that it encompasses devices that use the RF

energy “locally”. WiTricity agrees with commenters that suggest that the local use requirement

is met by near-field type WPT systems and can be met by far-field type WPT systems. All WPT systems must also adhere to 1) EMC compliance rules and 2) RF exposure rules. WiTricity also

agrees that an arbitrary definition of local use of RF energy by limitation of distance only has no

foundational nor scientific basis. WiTricity does, however, recognize and agree with

commenters that indicate that the types of WPT need to be clearly delineated since the

methodologies for testing EMC and RF exposure requirements can be very different. The

definition for the different types of WPT are related to distance and the frequency of operation as

indicated in WiTricity’s original comments and as discussed further below.

B. Definitions for Types of WPT

The ITU-R refers to “non-beam wireless power transmission” in its latest ITU-R

Recommendations SM.2110 and SM.2129 and specifically delineates between beam and non-

beam WPT. Per these ITU Recommendations, “near-field inductive, resonant and capacitive coupling” is considered non-beam WPT; whereas “transmission via radio frequency radiated transmission in the far-field” is considered beam wireless power transfer. In these same ITU-R

Recommendations, the broad characterization of WPT (including both beam and non-beam

WPT) is considered and defined “as the transmission of power from a power source to an electrical load wirelessly using the electromagnetic field”. The CISPR B committee is also considering delineation of types of WPT. For purposes of equivalency, the ITU-R’s beam WPT is what CISPR refers to as Wireless Power Transfer At A Distance (WPTAAD) whereas non- beam WPT is simply referred to as wireless power transfer (WPT). These variations in approach to define types of WPT can be confusing to readers and so a concise set of definitions is required.

Based on WiTricity’s review of comments to the Commission as well as consideration for on-going work in other Standards Development Organizations (SDOs), WiTricity amends its suggested definitions of wireless power to broadly cover wireless power and to delineate between the types of wireless power as follows:

a) Wireless Power Transfer (WPT): A category of ISM equipment which transmits

power from a power source to an electrical load wirelessly for local use by means

of an electromagnetic field.

b) Local Wireless Power Transfer (LWPT): A category of ISM equipment which

generates and emits RF energy for local use by means of inductive or capacitive

coupling, for transfer of electromagnetic energy between a power transfer unit

(TU) and receiving unit(s) (RU) of a Wireless Power Transfer (WPT) system.

c) Wireless Power Transfer at-a-distance (WPTAAD): A category of ISM equipment

which generates and emits RF energy for local use by means of radiative coupling

or RF Beam generation, for transfer of electromagnetic energy between a power

transfer unit (TU) and receiving unit(s) (RU) of a Wireless Power Transfer (WPT)

system.

It is important to note that local wireless power and wireless power at-a-distance can be distinguished by means of frequency of operation and distance of operation. This difference is based on the definition of “local” as follows (and as discussed and referenced in WiTricity’s original comments):

d) Local: A distance less than or equal to c/(20πf) in meters, where c is the speed of

light (and may be approximated as 300,000,000 m/s), and f is the highest

frequency of operation used by a device for the transmission of wireless energy.

By definition, local wireless power transfer (LWPT) automatically meets the requirement of local use for ISM equipment. In the case of wireless power transfer at-a-distance

(WPTAAD), the ISM local use requirement can be met by the additional requirement that the RF energy is formed in such a way that it does not broadly radiate into the environment but rather is focused and directed for the sole purpose of transferring energy locally to a device. Devices that broadly radiate electromagnetic energy into the environment without some means of beam generation would not meet the local use ISM requirement. For all WPT (LWPT and WPTAAD), the Commission already imposes necessary additional requirements to ensure EMC compliance and RF Exposure rules are met; WiTricity applauds the Commission on consideration for updates and clarifications to these rules. Given these important constraints, it would be prudent to also consider defining local use as follows:

e) Local use: Use of RF energy for the purpose of work or for the purpose of energy

transfer by means of local RF generation or by means of radiative beam forming

to ensure energy is directed and used in a non-harmful way.

WiTricity applauds the Commission’s efforts to provide definitions, rules, and guidance for all types of WPT and for consideration to update its current rules to reflect the current state- of-the-art in technology.

C. EMC Frequencies, Limits, and Methods for WPT

WiTricity recognizes and appreciates the comments of the former CISPR CIS/B Chair,

Dr. Bernd Sisolefsky, as they pertain generally to the status of the work for WPT in CISPR as well as specifically to the work on LWPT for electric vehicles (WPT-EV). WiTricity acknowledges that the current published edition 6.2 of CISPR 11 only defines electromagnetic interference (EMI) limits starting at 150 kHz. The Commission’s FCC current Part 18 rules, however, define EMI limits starting at 9 kHz. WiTricity believes it is prudent for the

Commission to consider the petition for rule making, RM-118155, filed by BMW of North

America, Ford Motor Company, Nissan North America, and Toyota Motor North America to

increase EMI limits in the range of 79 kHz to 90 kHz for the purpose of WPT-EV. In opposition

comments filed by ARRL6 on RM-11815, ARRL asserted that such a rule-making would be

“premature”. Since the date of ARRL’s comments additional studies have been performed. In particular, WiTricity would like to point to an additional impact study7 on amateur radio done by

the SAE J2954 Cooperative Research Program with participation from ARRL, which was

scrutinized by the United States delegation for ITU-R WP1A and which has been contributed by

5 https://www.fcc.gov/ecfs/filing/1090576720580 6 https://www.fcc.gov/ecfs/filing/102984871787 7 https://www.itu.int/md/R19-WP1A-C-0017/en

the U.S. delegation to ITU-R WP1A for the purpose of inclusion in ITU-R Report SM.2392.

WiTricity notifies the Commission that limits in this frequency range (for the fundamental

frequency of WPT-EV at 79 k Hz to 90 kHz) should be considered based on developed

Standards from SDOs. In particular, SAE J2954 has approved and will be releasing a Standard

shortly which suggests an appropriate limit in this frequency range measured at a distance of 10

meters is 82.8 dBµA/m, or a limit of 67.8 dBµA/m when a WPT-EV installation is within 10 m

of known sensitive equipment. WiTricity urges the Commission to consider the

recommendations of SAE J2954 on this matter and to consider future work in WPT-EV for

heavy duty and higher power applications. Furthermore, WiTricity applauds the work and the

comments of the ASC C63 Subcommittee 4 with respect to the ANSI C63.30 Standard that is

also planned to be published. The SAE J2954 soon-to-be-published Standard refers to the ANSI

C63.30 soon-to-be-published Standard for testing methodology of local wireless power systems

and utilizes the work done by the Commission’s Joseph McNulty to appropriately scale the

Commission’s Part 18 limits from 300 m to 10 m. WiTricity urges the Commission to consider the recommendations in both SAE J2954 and ANSI C63.30. As noted by the ASC C63

Subcommittee 4, the testing methodologies only apply to local wireless power transfer (LWPT)

(as defined above) and do not currently consider wireless power transfer at-a-distance

(WPTAAD).

With respect to general WPT frequencies, WiTricity recommends that the Commission

consider ITU-R’s Recommendations SM.2110 and SM.2129 for some fundamental frequency

options; however, WiTricity recognizes the potential use for WPT in any ISM band as well as

other frequencies that may be most suitable for particular applications. WiTricity reiterates that

many more frequencies could be suitable for wireless power depending on the application, size,

current level, proximity of local coupling, and other system-level considerations. The specific frequency used for a system should have more to do with a given application and the requirements for that application to allow for system optimization. While certain fundamental frequencies can and should be recommended, it is unnecessary to place restrictions on frequencies for wireless power unless specific frequencies used by WPT systems are known definitively to cause harmful interference.

D. EMF RF Exposure Limits for WPT

WiTricity recognizes and appreciates the significant amount of study and work over

multiple decades that has been done by various SDOs on the topic of RF Exposure – in particular

the work done by the International Commission on Non-Ionizing Radiation Protection (ICNIRP)

and the IEEE International Committee on Electromagnetic Safety (ICES). WiTricity recognizes

that the continued work of these two groups resulted in fairly recent publications – specifically

ICNIRP 2020 Guidelines8 (as an update to frequencies above 100 kHz of the ICNIRP 2010

Guidelines9 which include frequencies below 100 kHz) and the IEEE C95.1-2019 Standard10.

WiTricity recognizes the expertise of both ICNIRP and IEEE ICES on the matter of

human safety for RF Exposure. WiTricity agrees with commenters that assert that the IEEE

C95.1-2019 Standard may be most appropriate for the Commission’s consideration of Rule-

Making under NPRM 19-226 for consideration of human RF exposure safety generally.

However, WiTricity notifies the Commission that other Standards which are in various stages of

acceptance and publication such as SAE J2954, IEC 61980, and ISO 19363, all reference

ICNIRP 2010 Guidelines for WPT-EV specifically for at least two reasons. 1) For unknown

8 https://www.icnirp.org/cms/upload/publications/ICNIRPrfgdl2020.pdf 9 https://www.icnirp.org/cms/upload/publications/ICNIRPLFgdl.pdf 10 https://standards.ieee.org/standard/C95_1-2019.html

reasons, the ICNIRP Guidelines appear to be accepted more widely by other countries – perhaps because they are more stringent in some regards, and 2) Cardiac Implantable Electronic Devices

(CIEDs) which utilize Standards such as AAMI/ISO 14117 are tested to electromagnetic field

(EMF) levels (based on an assumed 225 cm2 loop area) which are more similar to those

Reference Levels (for frequencies between 79 kHz to 90 kHz) in the ICNIRP 2010 Guidelines.

WiTricity is not opposed to adoption of the IEEE C95.1-2019 RF exposure limits by the

Commission in any way; however, we admonish manufacturers of WPT-EV systems to also

consider the SAE, IEC, and ISO standards which provide procedures for testing both human exposure EMF limits and CIED exposure limits. WiTricity provides no comment on systems not related to WPT such as Electronic Anti-theft Systems (EAS) that could also be impacted when considering current CIED EMF immunity limitations.

On the matter of “Reference Levels” as defined by ICNIRP or “Exposure Reference

Levels (ERLs)” as defined by IEEE C95.1-2019 or “Maximum Permissible Exposure (MPE)”

Levels as defined by the Commission, WiTricity agrees with the commenters that indicate it would be prudent for the Commission to either adopt MPE levels below 300 kHz (in accordance with either IEEE C.95-1 ERLs or ICNIRP 2010 Reference Levels), or that the Commission simply indicate in the form of guidance that meeting these ERLs/Reference Levels would satisfy the considered Basic Restrictions (or Dosimetric Reference Limits as referenced in IEEE C95.1-

2019). It would be an egregious error to unnecessarily complicate compliance testing and validation for WPT systems that meet the ERLs/Reference Levels by forcing validation only of the Basic Restrictions. At this time, WiTricity is only aware of simulation modeling techniques that are used below 300 kHz to show compliance with Basic Restrictions. These modeling techniques for Basic Restriction predictions below 300 kHz require expertise and significant

validation of the models themselves. ERLs/Reference Levels; however, can be measured with

standardized field meters which are readily available.

E. WPT Certification Process

WiTricity agrees with commenters that suggest that the current pre-authorization guidance of the Commission as outlined in KDB 680106 is outdated and should be expanded to include, at very least, all local wireless power transfer (LWPT) as defined herein. The

Commission should consider expanding its guidance, instead of pre-authorization, on RF

Exposure testing and refer to appropriate standardized methodologies. Additionally, WiTricity agrees with the ASC C63 Subcommittee 4 comments that propose that the “FCC investigate

‘Type’ accreditation for vehicular WPT transmitting units, similar to the process currently used for modular devices under Part 15C.” The aforementioned WPT-EV Standards already conceive of this approach and provide detailed methodologies for such interoperability testing – inclusive of EMC and EMF restrictions.

CONCLUSION

WiTricity would like to thank the Commission for its work related to wireless power

transfer. WiTricity appreciates the Commission’s forward-thinking and consideration for adding

clarity to existing rules by appropriately defining wireless power transfer and expanding the

scope of RF Exposure rules to be inclusive of these rules. With the Commission’s release of

these clarifications and scope increase for RF Exposure below 300 kHz, WiTricity hopes the

Commission will simplify its guidance for local wireless power transfer (LWPT) and allow

typical Telecommunication Certification Body (TCB) modular and type approval processes.