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 ii 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. iv 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 v 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)