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Dear All, On August 22nd it was announced that IEEE 802.18 (RR-TAG) would have a conference call on September 5th to develop a response to the FCC regarding the proposal to for more time to construct MULTILATERATION LOCATION AND MONITORING SERVICE SYSTEMS in the 902 – 928 MHz and to use LTE as the technology. This appeared to present a major impact on license exempt use of that band. This band is an exception to the general rule in that license exempt systems were granted a “safe harbor” (protection) to make certain that they would be able to operate without interference from the licensed user. The call was held as announced on September 5th. A document (18-12-0082-02) was developed and is on Mentor as are the minutes of the call (Doc.18-12-0083). There was a quorum on the call and the comments were approved by a vote of 6 yes, 0 no, 1 abstain. These comments must be filed with the FCC on September 17th. Later today I plan on asking Paul to authorize a ten day EC ballot which will allow us to make the filing date/time. Sorry for the short notice but it was unavoidable. The group that met and developed these comments felt that they should go as an 802 input rather than simply from 802.18. Historically IEEE 802 has opposed the use of this frequency band by the MULTILATERATION LOCATION AND MONITORING SERVICE, so these comments do not represent a new position or change of position by IEEE 802. Glad to discuss. Regards, Mike From: MJLynch [mailto:mjlynch@MJLALLC.COM] All, Just a friendly reminder to have your comments in to John Notor by this Friday, August 31st. Regards, Mike From: Holcomb, Jay [mailto:Jay.Holcomb@itron.com] hello all, here is the call in information, jay Date/Time: SEP 5, 2012 at 12:00 PM America/Los_Angeles Length: 60 Frequency: 1 Meeting ID: 3041 Meeting Password: Phone Number(s): 3994 Extension +1-509-891-3994 Direct 866-994-8766 US and Canada Tollfree From: MJLynch [mailto:mjlynch@mjlallc.com] Steve, Good question. Jay Holcomb, Do you have the conference bridge details to share with the group? Thank you. Regards, Mike From: Shellhammer, Steve [mailto:sshellha@qualcomm.com] Mike, Is there a bridge number for this call? Steve From: MJLynch@mjlallc.com [mailto:MJLynch@mjlallc.com] To the RR-TAG and all other interested parties, This is to announce that IEEE 802.18 will hold a meeting by conference call at 2:00 p.m. CDT on September 5th, 2012. The purpose of the meeting will be to respond to the FCC’s latest notice that impacts the 902 – 928 MHz frequency band and its use by license exempt devices. The date established by the FCC to receive comments is September 17th, the first day of the September interim, making it impossible to develop a response in a F2F meeting. However at the interim the RR-TAG/IEEE 802.18 will review other comments submitted to the FCC by that date and may decide to submit reply comments. Reply comments are due October 2nd. The FCC document can be found on the IEEE 802.18 Mentor web site as Doc. 18-12-0080 and the FCC’s title of the document is: “WIRELESS TELECOMMUNICATIONS BUREAU SEEKS COMMENT ON REQUESTS BY SKYBRIDGE SPECTRUM FOUNDATION AND TELESAURUS HOLDINGS GB, LLC FOR WAIVER AND EXTENSION OF TIME TO CONSTRUCT 900 MHZ MULTILATERATION LOCATION AND MONITORING SERVICE LICENSES” For those unfamiliar with the rules for this frequency band license exempt devices are protected from interference from licensed services. That is just the opposite of what the norm is for license exempt devices. The current proposal by Skybridge and Telesaurus would allow Multilateration LMS systems to continue to operate in this band on a nationwide basis, extend the time that they are allowed to build out their networks and to use LTE as their new technology. The earlier email from John Notor (attached) shows what portions of the 902 – 928 MHz band that Multilateration LMS systems are allowed to operate in. Comments on the FCC proposal should be submitted to John Notor (jnotor@sunaorg.com) not later than the close of business on August 31st. John and others will use those comments to assemble a draft response. That draft will be reviewed, edited as needed and voted on during the September 5th conference call. As you may remember at the July meeting IEEE 802 commented against the extension of the build out dates for those holding licenses in 902 – 928 MHz frequency band. As of today (August 22nd) there are only two responses to that FCC action (WT 12-202), ours and one other and both recommend against an extension of time. This current FCC request for comments has nothing to do with that previous one. Over the past several years the IEEE 802 position presented to the FCC is that Multilateration LMS systems not be allowed to operate in this frequency band. One of those filings dealt with Progeny’s report regarding interference into license exempt users of the spectrum and the report essentially confirmed that there would be interference to license exempt users. The current proposal would allow Multilateration LMS systems to continue to operate in this band but using LTE as their new technology. The earlier email from John Notor (attached) shows what portions of the 902 – 928 MHz band that Multilateration LMS systems are allowed to operate in. It is not the intent of IEEE 802.18 to criticize the LTE technology. Rather it is our intent to point out that with GPS and other technologies (e.g. Wi-Fi) currently providing position location services there would seem to be no market for Multilateration LMS systems and that the petition be denied. We may also include a suggestion that was made on a preparatory call this week that Multilateration LMS systems be moved to the 1.6 GHz frequency band. Jay Holcomb of Itron has generously offered to provide a conference bridge. The details of that bridge will be sent separately. Questions on this FCC item may be directed to either John Notor or to myself. Regards, Mike +1.972.814.4901 |