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Re: [802SEC] +++10 day ECM (early close)+++ FCC NOI Response

Rich,

Overall, the text looks good. However, I've consulted with some of my wireless colleagues and we have concerns that some of the content is premature.

Specifically, in III, it is too early to take higher power levels completely off the table with "limits  equal to the U-NII-1 band". Therefore, we would prefer "with limits equal to the current 5 GHz U-NII rules as appropriate." That leaves open the potential for 4 W EIRP in circumstances where it technically justifiable. 

Also, while the challenges of protecting incumbents are different in the different bands, we think the bands should be addressed as they are able. Lower power and/or indoor only use may mitigate the concerns in U-NII-6 and UNII-8 bands so we aren't comfortable with the suggestion to addess U-NII-5 and U-NII-7 first. We suggest this replacement for the last sentence in III: "Therefore the bands should be released as soon as possible for each band. "

Regards,
Pat

On Mon, Sep 18, 2017 at 2:37 PM, Roger Marks <r.b.marks@ieee.org> wrote:
Rich,

I vote Approve, but please consider my attached suggestions for improvement. Most are strictly editorial, but some are more substantive; for example, I believe that Footnote 2 contains an erroneous reference.

Regards,

Roger


On September 15, 2017 at 4:53:03 PM, Kennedy, Rich (rich.kennedy@hpe.com) wrote:

Dear EC members,

 

On Thursday, the 14th of September the IEEE 802.18 Radio Regulatory Technical Advisory Group approved an input document to the FCC Notice of Inquiry entitled “Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz”.

 

The vote in the TAG was 15/0/0.

 

I would now like to proceed to the motion in respect to this submission. I am seeking an early close (see below), as this is a somewhat urgent matter, as Paul has been instructed to run this response through the IEEE BoD Global Public Policy Committee process, which will take some time.  The deadline for filing is 02 October 2017. Paul has delegated the conduct of the EC electronic ballot to me.

 

Motion

======

 

Approve https://mentor.ieee.org/802.18/dcn/17/18-17-0114-06-0000-ieee-802-response-to-fcc-17-104.docx as communication to the U.S. Federal Communications Commission, granting the IEEE LMSC chair (or his delegate) editorial license.

 

Moved by: Rich Kennedy, on behalf of the TAG

Seconded by: Adrian Stephens

 

Start of ballot: Friday 15 September 2017

End of ballot: Monday 24 September 2017 AOE

 

Early close: As required in subclause 4.1.2 'Voting rules' of the IEEE 802 LAN/MAN Standards Committee (LMSC) Operations Manual, this is notice that, to ensure the release is provided in a timely manner, this ballot may close early once sufficient responses are received to clearly decide a matter. Sufficient responses to clearly decide this matter will be based on the required majority for a motion under subclause 7.1.1 'Actions requiring approval by a majority vote' item (h), 'Other motions brought to the floor by members (when deemed in order by the Sponsor Chair)' of the IEEE 802 LAN/MAN Standards Committee (LMSC) Policies and Procedures.

 

Thank you.

 

Rich Kennedy

 

Director, Global Spectrum Strategy

HPE logo

 

Board Director, Dynamic Spectrum Alliance

Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group

Chair Emeritus, IEEE 802.11af WLAN in TVWS

Chair, Wi-Fi Alliance Spectrum & Regulatory Task Group

 

rich.kennedy@hpe.com

(737) 202-7014

 

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