Let’s not do this again. This is the unanimously approved position of the IEEE 802.11/15 Regulatory SC. Roger’s addition is appropriate, as it lets the FCC know that there are 802 wireless technologies that are not dependent on massive volumes for commercial viability. Beyond that I would suggest we leave it as approved. Let’s not DSRC this one.
I would be okay with this going to the FCC as an 802.11/15 position instead of an 802 position.
Rich Kennedy
Manager, New Technology Development
(832) 298-1114
Wi-Fi Alliance Spectrum & Regulatory TG Chair
Wi-Fi Alliance White Spaces TTG Chair
Wi-Fi Alliance White Spaces MTG Vice-chair
IEEE802.11 TGaf (WLAN in White Spaces) Chair
IEEE802.11/15 Regulatory SC Chair
IEEE 802.11/18 Liaison
From: outlook_2cb8745b51aa14eb@outlook.com [mailto:outlook_2cb8745b51aa14eb@outlook.com] On Behalf Of Benjamin A. Rolfe
Sent: Tuesday, June 2, 2015 2:33 PM
To: Rich Kennedy; r.b.marks@IEEE.ORG; STDS-802-SEC@LISTSERV.IEEE.ORG
Subject: Re: [802SEC] Suggested additional wording for response to FCC 15-47
I do not think Roger's addition addresses Apurva's concern, which is that the message lacks a positive suggestion. The points raised by Rich and others, while based in 802.11 experience, impact the application of all 802 wireless technologies that meet the definition of broadband used in the proceeding. Roger's addition may be interpreted to suggest only 802.11 is affected by the uncertainty. Rich's example of how uncertainty surrounding TVWS applies equally to other 802 wireless standards dependent on the TVWS rules.
I would advocate rewording so it is clear the concerns from 802 are not uniquely 802.11 WG's concerns. I agree with Apurva that a more positive message would be better, but have not seen any specific recommendations circulated. Perhaps our RTAG has documented some, otherwise it seems appropriate to respond now with the general concerns and take up the task of generating more specific recommendations in the RRTAG and 15/11 Regulatory SC at the earliest opportunity.
Just a suggestion from an interested observer.
Regards
Ben
--
Benjamin A. Rolfe | Blind Creek Associates |
On 6/2/2015 12:14 PM, Rich Kennedy wrote:
Roger:
That is fine. The FCC has been touting this as a boon for Wi-Fi. IEEE 802.11 has spent six years developing standards that have been plagued by less than advertised spectrum offerings from the FCC. IEEE 802.11y went nowhere. During a visit to the FCC I was asked why we never utilized this spectrum. My answer was that the exclusion zones make it unsuitable for a technology that depends on high volume to be a commercial success.
The TVWS did not have exclusion zones, but the continued spectrum uncertainty has kept Wi-Fi at bay. The main thrust of this letter is to say that the current exclusion zone improvement was insufficient, and their promises of further improvements is sufficiently uncertain that they should not expect IEEE 802.11 to do anything soon with this spectrum.
Your addition does not change our position.
Thanks.
Rich Kennedy
Manager, New Technology Development
(832) 298-1114
Wi-Fi Alliance Spectrum & Regulatory TG Chair
Wi-Fi Alliance White Spaces TTG Chair
Wi-Fi Alliance White Spaces MTG Vice-chair
IEEE802.11 TGaf (WLAN in White Spaces) Chair
IEEE802.11/15 Regulatory SC Chair
IEEE 802.11/18 Liaison
From: ***** IEEE 802 Executive Committee List ***** [mailto:STDS-802-SEC@ieee.org] On Behalf Of Roger Marks
Sent: Tuesday, June 2, 2015 1:46 PM
To: STDS-802-SEC@LISTSERV.IEEE.ORG
Subject: Re: [802SEC] Suggested additional wording for response to FCC 15-47
In support of Apurva's concerns, I propose to add the following at the end of the introductory "COMMENTS OF IEEE 802" paragraph?
"Other standards developed under IEEE 802 may be more suitable for adaptation and use under CBRS rules."
Roger
Mody, Apurva (US SSA) wrote:
Rich,
Thanks for taking a lead on this.
I can understand the hesitation of the FCC in reducing the exclusion zones and the sensitivities involved.
In fact, FCC / NTIA have made a serious effort to reduce the exclusion zones from hundreds of km earlier to only tens of km now.
It would be better if IEEE 802 provides constructive suggestions to the FCC on how these exclusion zones may be further reduced rather than telling them that the Working Group overwhelmingly voted against creating an additional standard. It does not send the right signal to the FCC.
Just my humble opinion.
Regards
Apurva
Chair, IEEE 802.22 Working Group
Chairman, WhiteSpace Alliance
From: ***** IEEE 802 Executive Committee List ***** [mailto:STDS-802-SEC@ieee.org] On Behalf Of Rich Kennedy
Sent: Friday, May 22, 2015 2:09 PM
To: STDS-802-SEC@LISTSERV.IEEE.ORG
Subject: Suggested additional wording for response to FCC 15-47
All:
In document 11-15/0683r2 (https://mentor.ieee.org/802.11/dcn/15/11-15-0683-02-0reg-comments-in-fcc-15-47.docx), which will be up for review on the EC telecon, we respond to FCC 15-47, a Report & Order and Second FNPRM in the 3.5 GHz band. The position we take is that from prior spectrum offerings that met with failure or serious delay after IEEE 802.11 developed standard amendments (802.11y and 802.11af), we know that the 3.5 GHz band offering, as currently outlined, will meet a similar fate. The exclusion zones that doomed IEEE 802,11y-2009 are still in place today. The TVWS spectrum uncertainty has IEEE 802.11af-2013 facing a similar fate. Although the FCC talks about an Environmental Sensing Capability (ESC) to reduce the exclusion zones, its timeline is uncertain; the FSS exclusion zone reductions are also as yet undocumented.
In the past week I have had a number of discussions with the organization that will be the operator of the primary Spectrum Access System (SAS), which will also be the installer of the ESC. They have been involved in extensive discussions with the FCC over the past two years on this matter. As a result, we now have a better understanding of and timeline for these enhancements that will enable development of this market.
As a result I would like suggest the addition of a statement in the conclusion that does not change the position the group approved. With this addition the Conclusion section would read:
“IEEE 802 appreciates the Commission’s efforts to provide additional spectrum useful to IEEE 802.11 devices and applications. However, under the current restrictions, the additional spectrum cannot be used by the WLAN community to provide the hundreds of millions of WLAN users with a viable solution to congestion in existing unlicensed spectrum. IEEE 802 will continue to monitor progress towards resolving the exclusion zone and FSS protection limitations, and will re-evaluate our position as conditions dictate.”
I have attached a version of the document (r3) that contains this additional statement. I would ask that you approve this version. I have forwarded this to the IEEE 802.11/15 Regulatory SC and IEEE 802.11 reflectors to ask if there are any objections. So far, my discussions with a number of the people in the REG SC who voted to approve the r2 have been positive.
Thank you.
Rich Kennedy
Manager, New Technology Development
(832) 298-1114
Wi-Fi Alliance Spectrum & Regulatory TG Chair
Wi-Fi Alliance White Spaces TTG Chair
Wi-Fi Alliance White Spaces MTG Vice-chair
IEEE802.11 TGaf (WLAN in White Spaces) Chair
IEEE802.11/15 Regulatory SC Chair
IEEE 802.11/18 Liaison
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