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Re: [802SEC] +++EC Email Ballot+++Urgent motion to approve 802.18 doc+++



Given that Steve is satisfied, I am happy to vote to approve.

mike

Carl R. Stevenson wrote:
> Steve, and EC colleagues,
>
> Again, comments in context below with a .pdf for those whose mail
> clients may not handle HTML.
>
>
>     ------------------------------------------------------------------------
>     *From:* Shellhammer, Stephen J [mailto:stephen.j.shellhammer@intel.com]
>     *Sent:* Tuesday, November 23, 2004 9:14 PM
>     *To:* wk3c@wk3c.com; paul.nikolich@att.net;
>     STDS-802-SEC@listserv.ieee.org
>     *Subject:* RE: [802SEC] +++EC Email Ballot+++Urgent motion to
>     approve 802.18 doc+++
>
>     Carl,
>
>
>
>                 Thank you for your detailed response. Let me try to
>     summarize my concerns in this response. They relate to wireless
>     microphones and professional installation.
>
>
>
>     *Wireless Microphones*
>
>                 I am not trying to question the accuracy of the
>     technical work within 802.18.  My concern is that the IEEE is
>     recommending to the FCC that they regulate how industry ensures that
>     Part 15 devices do not interfere with Part 74 devices. Typically the
>     FCC limits power and power spectral density (PSD) of Part 15 devices
>     but does not specify rules for spectrum sharing. They typically
>     leave any spectrum sharing designs to the industry.
>
>
>
>     That has been their practice in unlicensed vs. unlicensed sharing
>     situations (the ISM bands), but again, unlicensed under licensed is
>     a very different situation, as you note before.
>
>
>
>                 You mention my position as chair of 802.19 Coexistence
>     TAG which is a very good point.  By analogy, 802.19 did not regulate
>     in the recent rules change how the wireless working groups should
>     ensure coexistence, we just are requiring that they do coexist,
>     using any design they like, and then show that the new standard
>     coexists with current standards.  So 802.19 did not tell the
>     wireless working group how to do their job, just that they need to
>     show that they did do there job.
>
>
>
>     That is an internal 802 matter, not a question of what regulation
>     may be necessary to assure protection of licensed services. (The
>     latter is the domain/responsibility of the FCC, and we have simply
>     tried to recommend the minimum regulation that our studies and
>     discussions with the incumbent licensees indicate to be appropriate.)
>
>
>
>                 However, I do understand that this band is different
>     than the ISM bands so I appreciate that it may be necessary for the
>     FCC to set additional regulation on industry.
>
>
>
>                 So I will accept your response on the Part 74 devices
>     and will withdraw my recommendation to remove those paragraphs.
>
>
>
>     Thank you.
>
>
>
>     *Professional Installation*
>
>                 I do not accept that argument that GPS systems and
>     database systems are always unreliable, and hence the only valid
>     method of installation is a professional. I believe that in many
>     cases GPS and a database can be made reliable and can be used for
>     installation.  In the case that they do not work professional
>     installation is also available.  So I believe that both methods of
>     installation should be allowed by the FCC.
>
>
>
>     The issue is not that "GPS and database systems are *always*
>     unreliable."  The issue is that GPS can be unreliable in some
>     situations *and* that the FCC database of information on licensed
>     facilities (TV stations) contains many omissions and
>     inaccuracies and isn't maintained in a timely fashion due to a lack
>     of resources and other factors.  The combination of these
>     factors results in the conclusion that relying on "GPS and database"
>     as a sole means of determining channel availability at any given
>     location/time would be unreliable often enough to present
>     significant interference potential.  Since we will have an
>     obligation not to cause interference, we believe that relying on
>     "GPS and database" as a sole means is inappropriate and would result
>     in interference that could/should be avoided (at least at this time,
>     under the current circumstances).
>
>
>
>     Note that the professional installation recommendation applies
>     *only* to the base station in fixed access networks, not to the CPE
>     (user terminals), nor to "personal portable" devices.  What this
>     means is that a WISP, for example, will have to have someone capable
>     of doing "due diligence" in terms of locating the base station,
>     predicting its coverage, looking at what channel(s) can be used from
>     that site with the intended technical parameters and coverage, and
>     making initial channel selections that assure that the coverage
>     (interference range) of the base station does not overlap into the
>     "Grade B protected contour" of surrounding TV stations at levels
>     that would violate the required D/U (desired/undesired signal)
>     ratios. (after turn-on, the base station and its associated CPEs
>     would use the sensing mode to verify channel availability and to
>     respond to changes in the RF environment as TV facilities and
>     channel assignments change with time).
>
>
>
>     Perhaps with time, if the FCC database were to become more accurate
>     and were updated in a very timely manner, the problems associated
>     with the reliability of the "GPS and database" technique will be
>     resolved to the point where sufficient reliability could be
>     obtained.  At that time, I am confident that the FCC would entertain
>     a request for a rules change, but at the moment, we believe that we
>     cannot, in good professional conscience, endorse this technique as a
>     sole, "stand-alone" means of determining channel availability and
>     ensuring that interference to the incumbent licensed services does
>     not occur.
>
>
>
>     Finally, personal portable devices (obviously) cannot be
>     "professionally installed," and there is no suggestion that they
>     should be, as, by definition they are easily moved about/relocated.
>     Clearly, such devices will have to operate autonomously to prevent
>     interference.  I would also point out that relatively short-range,
>     relatively low power systems like 802.11x are not treated as fixed
>     systems precisely because of the ease with which they can be
>     relocated.  (Note that, under the changes made to the ITU Radio
>     Regulations at WRC-03, the new global, primary allocation to
>     "Wireless Access Systems, including RLANs" (which includes 802.11)
>     was made to the MOBILE service, not to the FIXED service.)
>
>
>
>                 I maintain my recommendation to add text to the document
>     allowing for either professional or GPS/Database types of installation.
>
>
>
>     In the event that my further explanation on this topic has not
>     changed your view, I can only say that I am not empowered to make
>     such substantive changes to the document.  I would also refer you to
>     the following text from the 802.11 technical reflector, submitted by
>     Bob O'Hara in response to some supportive comments there:
>
>
>
>     --- This message came from the IEEE 802.11 Technical Reflector ---
>
>     I would like to echo the position expressed here, this response
>     needs to be filed in a timely fashion and with out any substantive
>     changes.
>
>     There has been significant cooperation between the incumbent license
>     holders and the members of the 802 wireless working groups.
>
>     Since this NPRM addresses operation in a band relatively far removed
>     from any where existing 802 operate, any devices ultimately designed
>     to operate here will be based on new silicon and new PHY specifications.
>
>     There are no existing 802 device manufacturers to protect. Therefore
>     I think that there is little danger to the extra protection that
>     some see in the response. If this is helpful to getting consensus
>     from all the parties involved in the NPRM, I think that it is not
>     too high a price to pay.
>
>     -Bob
>
>     Regards,
>
>     *Carl R. Stevenson*
>
>     /*President and Chief Technology Officer*/
>
>     *WK3C /Wireless/ LLC/ /*
>
>     */Where wireless is a passion, as well as a profession./ ^SM *
>
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>
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>
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>
>     Emmaus, PA 18049-4955 USA
>
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>
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>
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>
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>
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--
Michael Takefman              tak@cisco.com
Distinguished Engineer,       Cisco Systems
Chair IEEE 802.17 Stds WG
3000 Innovation Dr, Ottawa, Canada, K2K 3E8
voice: 613-254-3399       cell:613-220-6991

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