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Hello Steve,
thanks for joining the call yesterday, so you were able to see how we have been working the comments and how different folks know the different topics. with 18 folks on yesterday, have been getting good discussions.
with that i
have updated the comments in rev17, responding to your questions and here is a
high-level summary.
Section 1.2
No need to hyphenate “Coexistence” (Editorial)
== this is copied from other docs, so will leave. were 2 other places updated, however.
Section 4.1
Change “IEEE 802 believes that the Commission is misinformed and has made a significant error in judgement in its belief that C-V2X is “the technology most capable of …”. ”
To “IEEE 802 disagrees with the Commission statement that C-V2X is “the technology most capable of …”. ”
=== we agree and change made.
Delete “To date, we are unaware there have been any field tests of C-V2X at scale with hundreds of units in complex RF environments.”
=== pdf reviewed and some were aware of it. there were 8 vehicles mostly on a test track, so will be leaving the text as it was.
Section 4.2
Delete this sentence, “In its waiver request, the 5GAA stated that “C-V2X enables direct, peer-to-peer mode communications […] between vehicles and pedestrians, cyclists and other vulnerable persons (“V2P”) […]”. This statement is false: C-V2X would not “enable” V2P, but instead make V2P vastly more complex compared to existing DSRC technology”
=== we agree and changes made.
Section 5.1
Delete “Despite the name, this is not true. C-V2X in its current form is only capable of broadcasting packets and is not capable of establishing direct peer-to-peer communications over any network including a 5G network”
This seems to be a misinformed statement. See https://5gaa.org/5g-technology/c-v2x/
=== discussion in team again and still saying this is accurate as the NPRM is defining C-V2X as 3GPP LTE release 14, not 5G. Even in the rules sections of the NPRM has this, not 5G. a NPRM reference is being added.
Section 8.1.1
Delete, “We believe that the fourth and fifth generations of cellular V2X sidelink technology (i.e. Release 14 and 16) do not have any of these characteristics: same-channel coexistence, backward compatibility, or interoperability.”
=== after further discussion we will go back to: We note that the fourth and fifth…… and added a reference to show why this is true.
Section 9.2
Delete,
“It is now clear that NR V2X PC5 will fail to achieve any of these key evolution characteristics not only with DSRC but also with the previous generation cellular V2X (LTE V2X PC5). To be clear, NR V2X PC5 will not be able to coexist in the same channel, interoperate, or be backward compatible with LTE V2X PC5.”
=== the discussion was this is true and we are adding an example to support it (note also ties to section 8 above.)
Section 9.3
Once again another negative unsubstantiated statement about 3GPP,
“The 3GPP V2X technology evolution model implies a high societal cost, a cost that is completely avoided in the IEEE 802 V2X evolution model. The 3GPP model implies that V2X spectrum must be fragmented into sub-bands associated with every different V2X technology”
hope this
helps,
jay
Jay,
I reviewed the document and I am not sure the negative comments about 3GPP is the right approach. It would seen to be better to focus on the benefits of the IEEE technology. In any case, here are my comments.
Regards,
Steve
-----------------------------
Section 1.2
No need to hyphenate “Coexistence” (Editorial)
Section 4.1
Change
“IEEE 802 believes that the Commission is misinformed and has made a significant error in judgement in its belief that C-V2X is “the technology most capable of …”. ”
To
“IEEE 802 disagrees with the Commission statement that C-V2X is “the technology most capable of …”. ”
I think the current wording is quite rude to the FCC.
Delete
“To date, we are unaware there have been any field tests of C-V2X at scale with hundreds of units in complex RF environments.”
See
Section 4.2
Delete this sentence,
“In its waiver request, the 5GAA stated that “C-V2X enables direct, peer-to-peer mode communications […] between vehicles and pedestrians, cyclists and other vulnerable persons (“V2P”) […]”. This statement is false: C-V2X would not “enable” V2P, but instead make V2P vastly more complex compared to existing DSRC technology”
Just because C-V2X is more complex than DSRC, that does not make the statement false. Modern 802.11 technology is also vastly more complex than 802.11p, but it is very popular in the marketplace.
Section 5.1
Delete
“Despite the name, this is not true. C-V2X in its current form is only capable of broadcasting packets and is not capable of establishing direct peer-to-peer communications over any network including a 5G network”
This seems to be a misinformed statement. See https://5gaa.org/5g-technology/c-v2x/
Section 8.1.1
Delete,
“We believe that the fourth and fifth generations of cellular V2X sidelink technology (i.e. Release 14 and 16) do not have any of these characteristics: same-channel coexistence, backward compatibility, or interoperability.”
It is my understanding that 3GPP is providing a path to 5G. If someone has some evidence otherwise, maybe it could be provided to support the statement.
Section 9.2
Delete,
“It is now clear that NR V2X PC5 will fail to achieve any of these key evolution characteristics not only with DSRC but also with the previous generation cellular V2X (LTE V2X PC5). To be clear, NR V2X PC5 will not be able to coexist in the same channel, interoperate, or be backward compatible with LTE V2X PC5.”
Why are we making these negative unsubstantiated statements about 3GPP technology? Such statements hurts our credibility.
Section 9.3
Once again another negative unsubstantiated statement about 3GPP,
“The 3GPP V2X technology evolution model implies a high societal cost, a cost that is completely avoided in the IEEE 802 V2X evolution model. The 3GPP model implies that V2X spectrum must be fragmented into sub-bands associated with every different V2X technology”
From: ***** IEEE 802 Executive Committee List ***** <STDS-802-SEC@ieee.org> On Behalf Of Roger Marks
Sent: Wednesday, February 26, 2020 3:12 PM
To: STDS-802-SEC@LISTSERV.IEEE.ORG
Subject: Re: [802SEC] +++ 10-day EC Motion+++ Approval of comments to the FCC NPRM on revisiting and re-configuration of the 5.9GHz band
Jay,
I agree with Jon's comments and remain a bit concerned with the responses. In particular:
(4.1) Regarding "to delete would be a content change, not an editorial," that may be true, but it's not a valid reason to reject. The long-term interest of IEEE 802 requires maintaining a positive relationship with external entities.
(5.1) According to my web research, Jon's view is widely held. You may be right, or you may be wrong; perhaps it depends on some detailed interpretation of "establishing direct peer-to-peer communications". I'm not concerned when we make educated statements about IEEE 802 technologies, but I worry when we make assertions about someone else's technologies (which this draft statement does extensively).
Cheers,
Roger
On Feb 26, 2020, 3:44 PM -0700, Jay Holcomb <jholcomb@ieee.org>, wrote:
hi Jon,
I have been working with Joseph going through each of your points and have accepted some and some we feel would be okay to leave as is. a brief summary of a few of them.
1.2 – would like to leave IEEE NGV to denote we are talking about .11bd and not other technologies that is later in the point.
4.1 – this was a notable discussion in the ad hocs and actually is less than some wanted. to delete would be a content change, not an editorial.
we do agree to soften the comment on the field tests of the C-V2X.
4.2 yes, this is a valid statement as .11p and .11bd use downclocking to get to 10MHz channels. and would not be a significant hdwe change.
5.1 C-V2X will need a second radio and does not establish peer to peer to the cellular network, it is broadcast based, so would like to leave as is.
6.1 table is for time synchronization not for time stamping. we had a longer discussion about the synchronization in the ad hocs and examples and difference from DSRC to C-V2X. So DSRC would be a yes in this context, it is not needed.
9.2 we are not saying they will fail to develop, but fail to be backward compatible, since LTE and NR uses different waveforms and different characteristics, so would like to leave as is.
10.1 we are viewing this as an action of market adoption of V2X, not market commitments, so would like to leave as is.
a rev16 with the editorial markups has been uploaded.
thanks for your input,
jay
On Tue, Feb 25, 2020 at 3:18 PM Jon Rosdahl <jrosdahl@ieee.org> wrote:
HI Roger et.al,
I vote Disapprove
I agree with most of Roger's changes/comments.
I have added my changes to his file and attached for consideration.
I think that the tone is a bit aggressive and possibly offensive to some readers.
Regards,
Jon
-----------------------------------------------------------------------------
Jon Rosdahl Engineer, Senior Staff
IEEE 802 Executive Secretary Qualcomm Technologies, Inc.
office: 801-492-4023 10871 North 5750 West
cell: 801-376-6435 Highland, UT 84003
A Job is only necessary to eat!
A Family is necessary to be happy!!
On Tue, Feb 25, 2020 at 1:37 PM Roger Marks <r.b.marks@ieee.org> wrote:
Jay,
I can vote Approve on Rev 15. Thanks for fixing the incorrect references to the annex.
Thanks for answering me about what it means to put a 160 MHz transmission into a 75 MHz channel. I think it would be better to put an explanation into the document as well, particularly by explaining how the "proposed rules" would enable this.
Personally, I don't think it helps the case to, throughout the document, use so many different names for the thing you are advocating, and I don't think it's a good idea to use the name of a superseded amendment as the name.
Cheers,
Roger
On Feb 25, 2020, 12:30 PM -0700, Jay Holcomb <jholcomb@ieee.org>, wrote:
hi Roger,
I have been working with Joseph and have accepted many of your editorial edits. there are a couple we feel would be okay to leave as is.
= for the use of NGV, 802.18 had several discussions on what terminology to use and that it would be best to use only one label for the ongoing IEEE 802.11 NGV work and IEEE P802.11bd was chosen, as it is the correct name of project that is developing the NGV/802.11bd amendment. So based on the consensus that was reached we should continue to use IEEE P802.11bd.
= For calling out the 802.11p standard, we feel we should use the proper name also, instead of IEEE 802.11 OCB.
= for your question on the 80/160MHz channels fitting in, this would be a case where they would be allowed to combine the U-NII-3 band with the U-NI-4 band to get the full 80 and 160MHz channels.
= on the Annex D.5 you are correct, it is not there. The reference was meant to be tables D-2 and D-5, though that would be too specific, so will reference the full Annex D to cover it all.
a rev15 with the editorial markups has been uploaded.
thanks for you input,
jay
From: Roger Marks <r.b.marks@ieee.org>
Date: Fri, Feb 21, 2020 at 5:19 PM
Subject: Re: [802SEC] +++ 10-day EC Motion+++ Approval of comments to the FCC NPRM on revisiting and re-configuration of the 5.9GHz band
To: <STDS-802-SEC@listserv.ieee.org>Jay,
I've attached comments. Based on my review, I vote Disapprove on this version.
Cheers,
Roger
On Feb 21, 2020, 3:40 PM -0700, Stanley, Dorothy <dorothy.stanley@hpe.com>, wrote:
Hello Jay,
I vote approve.
Thanks,
Dorothy
------------------------
Dorothy Stanley
Hewlett Packard Enterprise
+1 630-363-1389
From: ***** IEEE 802 Executive Committee List ***** [mailto:STDS-802-SEC@ieee.org] On Behalf Of Jay Holcomb
Sent: Friday, February 21, 2020 12:21 PM
To: STDS-802-SEC@LISTSERV.IEEE.ORG
Subject: [802SEC] +++ 10-day EC Motion+++ Approval of comments to the FCC NPRM on revisiting and re-configuration of the 5.9GHz band
Dear LMSC Members,
With this email I would like to announce the start of an LMSC(EC) ballot on comments to the FCC on response to their NPRM proposing re-configuration of the 5.9GHz band from ITS to unlicensed and ITS and allowing C-V2X instead of just DSRC (802.11p and .11bd). The deadline for comments is 09 March 20, a Monday.
Paul has delegated to me to conduct a LMSC(EC) 10-day electronic ballot on the motion below to approve the comments to the FCC. This EC motion is per IEEE 802 OM 7.2.1 Procedure, P&P 7.1 b) (majority response) and P&P 7.1.2 (2/3 approval of votes cast) for communication with government bodies and public statements. With that we would like to see everyone respond.
Motion: Move to approve the comments in https://mentor.ieee.org/802.18/dcn/20/18-20-0020-14-0000-comments-on-fcc19-138-nprm-revisiting-use-of-the-5-850-5-925-ghz-band.docx ; response to FCC NPRM (ET 19-138) on revisiting use of the 5.850-5.925 GHz-band. For review and approval by the EC and uploading to the FCC on or before 08 March 2020. The Chair of 802.18 is authorized to make editorial changes as necessary.
Approved in the RR-TAG: _11_ / 0_ / 1_
Mover: Jay Holcomb
Seconder: Dorothy Stanley
Start of ballot: 21 February 2020
Close of ballot: 02 March 2020
Note: In the last review during the .18 teleconference we had several edits and then mentor was erroring out and only the last marked-up version was able to be uploaded in the time we had. Voters were okay for the chair to do the editorial edits of a clean revision and updating the reference numbers (not content), why the revision is later than the one approved.
Reference documents:
The NPRM:
Proceeding OET 19-138:
https://www.fcc.gov/ecfs/search/filings?proceedings_name=19-138&sort=date_disseminated,DESC
Regards,
Jay Holcomb
Liberty Lake (Spokane), WA
Itron, Inc.
IEEE 802.18 Chair
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Regards,
Jay Holcomb
IEEE 802.18
Itron, Liberty Lake (Spokane), WA
To unsubscribe from the STDS-802-SEC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=STDS-802-SEC&A=1