Re: [802SEC] +++EC 5 Day Review+++802.18 Comments on FCC Smart Grid Notice
Mike-
For your consideration
(I would probably vote disapprove this pass if I had a vote)
Page 1 Change:
4. We note that many of the questions raised in this NOI are a repeat of
questions already posed within the NIST Smart Grid Interoperabilty
Standards Project. Answers to these
5. questions derived from the NIST...
To:
4. We note that many of the questions raised in this NOI are a repeat of
questions already posed within the NIST Smart Grid Interoperabilty
Standards Project.
5. Answers to these questions derived from the NIST ...
Regarding your response to #8 where you say:
"On the other hand, applications such as automatic meter reading and
data beyond SCADA, which are more latency-tolerant, could utilize
communications technologies such as broadband wireless, satellite,
unlicensed wireless mesh, and licensed wireless."
seems to (inappropriately) exclude wired 802 technologies. Much of the
grid metering will be in easy reach of the wired network infrastructure.
This particular aspect of network usage is about connectivity, not
bandwidth. The bandwidth requirements are trivial. Connection to the
wired network infrastructure belonging to the customer or to service
provide premises gateway devices should be included within the scope of
consideration.
Slightly further along in #8
Change:
"Power system equipment located in remote regions are not usually able
to take advantage of public wireless networks..."
To either:
"Power system equipments located in remote regions are not usually able
to take advantage of public wireless networks..."
-OR-
"Power system equipment located in remote regions is not usually able to
take advantage of public wireless networks..."
...And at the end of that same sentence where it says:
"...require the installation of private wireless or wired networks."
Change to:
"...require the installation of private wireless or wired networks with
independent power capability."
Add to #12
"To these ends, Smart Grid commuications systems should be developed in
a manner such that the higher levels of the software stack are
independent of considerations of the implementation of Layers 1 and 2 to
the greatest extent possible."
Number 16
"No comment"
should be replaced with a mention of both ensuring and keeping track of
the power systems which energize all communications elements of Smart
Grid. For Smart Grid to be fully functional in emergency situations
there may very well be rerouting of communications required that goes
beyond the normal reconfiguration capability of the nominal network.
Access to a database that details the power source capabilities of each
communication system element may well be a critical item in determining
priorities when scheduling the repair of system elements in a disaster
situation.
Number 17:
I do not consider the statement to be true.
The statement would be more accurate if it restricted itself to
broadband facilities. The desire to implement a "Smart Grid" should not
cause regulators or implementers to lose sight of the fact that much of
the necessary communications capability can be met by wired networking
at speeds that can be handled by service either ordinary telephone lines
(via autodialer) or by (multi-drop, if necessary) dedicated telco
circuits on the in-place infrastructure.
Number 18:
Should be answered in light my comment above.
Number 19:
See comment above. Should no be limited to broadband for a reply.
Number 42:
Change:
"...allowing large numbers of users to efficiently use the radio channels."
To:
"...allowing large numbers of users to efficiently share use of the
radio channels."
Number 54: Spellcheck
That's all
Geoff
On 9/27/09 10:46 AM, MJLynch@mjlallc.com wrote:
Dear EC,
On 4 September the FCC issued a notice calling for responses to their questions regarding the implementation of Smart Grid technology. This is related to the ongoing FCC work on the nationwide broadband proposal.. The response time was somewhat better than the previous item that 802 responded to but the timeframe was too short to allow a thorough response.
During last week's wireless interim 802.18, in conjunction with other WGs, developed a response. That document (18-09-0105-05) is available at:
https://mentor.ieee.org/802.18/documents
The FCC due date for the comments is 2 October.
Also available as 18-09-0104-00 is the FCC notice.
This document is being sent to you for the five day review process.
I am proposing that the EC review period begins now and closes on 1 October and the 802.18 response will be filed on 2 October.
Regards,
Mike
+1.972.814.4901 Mobile
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