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RE: stds-802-16: WirelessHUMAN report

David as usual you made some points worth considering in planning our
Wireless Human standardization efforts.
Attached find a USA Contribution that was brought in September 2000 to the
ITU-R 8A-9B that summarizes some aspects of Radio LANs(e.g., 802.11a) and
Broadband Fixed Wireless Access (e.g., Systems based on the proposed
Wireless Human Standard)coexistence in the 5.25-5.35GHZ band and other users
sharing that band, that are worth considering to include in planning our
discussions at the upcoming 802.16 Wireless Human meeting. 

United States of America Contribution to ITU-R JRG 8A-9B


On January 9,1997 the United States FCC Report and Order amended Part 15 and
made available 300 MHz in the 5150-5350 and 5725-5825MHz bands to
Unlicensed-National Information Infrastructure (U-NII) devices.  The
objective of the Part 15 amendments was to encourage innovation by
specifying minimum technical requirements for U-NII devices.
The key U-NII band-by-band requirements are that      
1. In the 5150-5250MHz devices are restricted to indoor operation, with an
EIRP limit of 200mw and a power spectral density limit 10mw/MHz. 
2. In the 5250-5350MHz devices can operate outdoor, with an EIRP limit of
1000mw and a power spectral density limit 50mw/MHz.
3. In the 5725-5825MHz devices can operate outdoor, with  an EIRP limit of
4000mw and a power spectral density limit 200mw/MHz.
4. If transmitting antennas of directional gain greater than 6dBi are used,
both the peak transmitted power and the peak power spectral density shall be
reduced by the amount of dB that the directional gain of the antenna exceeds

The reaction by the USA industry to these Part 15 changes was quick.
Manufacturers and service providers were quick to develop products and
services (e.g., Point-to-Multipoint Fixed Broadband Wireless Access) for
these bands that can give timely and cost-effective high speed internet
services to educational institutions, health care providers, libraries,
business and home users.  A number of these users in the USA are currently
being served by 5250-5350MHz PMP FBWA systems.
In 1997 the World Radiocommunications Conference (WRC '97) allocated on a
world wide-primary basis Earth Exploration Satellite Services (EESS) and
Space Research Services(SRS)  in the 5250-5350MHz.  So this band is
currently also being used on a world wide-primary basis for active
space-borne sensors, including Synthetic Aperture Radars (i.e., SAR 1-4).
WRC 2000 has invited ITU-R to conduct, and complete in time for WRC 2003,
the appropriate studies leading to technical and operational recommendations
that facilitate sharing between existing services and mobile service in the
bands 5150-5350 and 5470-5725MHz bands for the implementation of wireless
access systems including RLANs, and for Region 3/Japan FWA in the
a)	that the frequency band 5250-5350MHz is allocated to the Earth
Exploration Satellite Services (EESS)(active) and Space Research
Services(SRS)(active) on a primary basis; 
b)	that the allocation in the frequency band 5250-5350MHz will be
reviewed by WRC 2003 under agenda Item 1.5 with a view to allocate this band
to mobile service, and for Region 3 to fixed wireless access(FWA);
c)	that currently in USA the 5250-5350MHz band is part of the
Unlicensed National Information Infrastructure(U-NII) that permits operation
of FWA devices;
d)	that some administrations have proposed using the 5250-5350MHz band
for broadband radio local area networks (RLANs) in the mobile services;
e)	that the broadband RLANs in the mobile services are proposed to be
deployable in the 5250-5350MHz band world wide as unlicensed devices, making
regulatory control of their deployment density non-feasible;
f)	that there is a need to specify an appropriate E.I.R.P limit and
operational restrictions for RLANs and other wireless access transmitters in
this band in order to protect systems in the EESS (active) and SRS (active);

g)	that FWA devices can minimize their interference to EESS (active)
and SRS(active) through the permanent positioning of high directivity
antennas, and their back-off on the peak transmitted power and the peak
power spectral density reduction by the amount of dB that the directional
gain of the antenna exceeds 6dBi; 
h)	that RLANs using omni-directional antennas are likely to be
deployable in the 5250-5350MHz band world wide as unlicensed devices, the
regulatory control of their indoor/outdoor deployment is not-feasible;
i)	that the excess path loss (provided by building structures) is
beneficial to the sharing of the 5250-5350MHz frequency band among EESS
(active), SRS (active), FWA, and RLANs;

It is suggested that
- The current ITU-R Joint Rapporteurs Group's 8A-9B sharing studies should
consider the protection of EESS (active) and SRS(active)based systems when
in a Region both FWA and RLANs (or other wireless access transmitters in the
mobile service) are operated in the 5250-5350MHz band, and   
-The ITU-R JRG 8A-9B should also consider the EESS(active) and SRS (active)
interference issue in the context of likely innovations to the PMP FWA
technology; e.g., lower-cost, high directive fixed and steerable antennas,
and circularly polarized antennas.
It is recognised that the implications of these suggestions may require
modification to an existing Question(s) and/or modification to an existing

Dr. Demosthenes J. Kostas
Director, Industry Standards
Adaptive Broadband Corporation

3314 Dartmouth Ave
Dallas, TX 75205  USA

tel: 214 520 8411
fax: 214 520 9802
----Original Message-----
From: David Trinkwon [mailto:trinkwon@compuserve.com]
Sent: Friday, October 13, 2000 3:13 PM
To: 'zion'; 'IEEE - Marks, Roger'
Cc: 'IEEE stds-802-16'
Subject: RE: stds-802-16: WirelessHUMAN report

In addition to your pro's and cons, IEEE 802 has an important role to play
assure interoperability between products from different manufacturers.  But
a technical standards body, it is beyond their scope to undertake the
issue of keeping a frequency band "pure" for products that meet their 
standards, and to try to exclude non-interoperable products.   In fact, it 
violates US antitrust laws.

David Trinkwon
e-mail : trinkwon@compuserve.com
Telephone :  UK  (+44) (0) 7802 538315   USA   (+1) 972 345 5226
Fax :                UK (+44) (0) 20 7681 1695   USA   (+1) 602 532 7013

From: 	Roger B. Marks[SMTP:marks@boulder.nist.gov]
Sent: 	Friday, October 13, 2000 15:48
To: 	zion
Cc: 	stds-802-16@ieee.org
Subject: 	RE: stds-802-16: WirelessHUMAN report


Based on reading <http://ieee802.org/16/human/par_comments.html>, I
think I can summarize my guess as to how this debate might go.

Pro and Con (who get their names from their position with respect to
a WirelessHUMAN standard) have the following discussion:

Con: WirelessHUMAN will interfere with Wireless LANs if they share
the U-NII band. Therefore, there should be no WirelessHUMAN in the
U-NII band. Therefore, 802 shouldn't have a WirelessHUMAN standard.

Pro: Quasi-HUMAN or Sub-HUMAN (hominoid?) systems are being deployed
and will continue to be deployed. IEEE is not the regulator. Having
no WirelessHUMAN standard doesn't mean there will be no interfering

Con: While 802 can't stop HUMAN-like deployments, it should at least
avoid promoting their use.

Pro: Wrong. 802 should promote deployments that are, to a large
degree, harmonious with existing IEEE-based systems. Having a
WirelessHUMAN standard that is coordinated with 802.11 is the best
way for 802 to encourage cooperative use. Ultimately, will be the
best thing for 802.11.

Con: Well, maybe, but what do you mean by coordinated?

Pro: I'm not exactly sure, but I think we can work that out.
WirelessHUMAN chose the 802.11a PHY, and we think that should help.

Con: Well, if you also chose the 802.11 MAC, then maybe we could talk

Pro: We looked at the 802.11 MAC, and we think that the 802.16
approach is more in line with our needs.

Con: OK, so I ask again, what do you mean by coordinated?

Pro: How about if we agree to work on the problem together?

Con: Maybe. Where do you suggest we start?

I think that our WirelessHUMAN team needs to be prepared for a debate
like this. In particular, they need to be ready to address the last
question. This is going to require some advance work.

My suggestion is that the people interested in WirelessHUMAN get
together and work on this problem. They need a place of their own,
off the 802.16 reflector, where they can get some real work done.

To facilitate this process, I have created a discussion group at
<http://www.egroups.com/group/wirelesshuman>. I have made Durga the
moderator. I suggest that those of you interested in this topic go
over there, sign up, and work the problem. Let me know how it is
going and if you need any help.


At 2:06 PM +0200 00/10/13, zion wrote:
>Dear Roger
>I don't understand the 802.11a group, their reaction looks as
>misunderstanding of the following points:
>a. If 802.11a wants to have a spectrum just for them then they are taking a
>risk, someone may decided to treat the band as licensed band, with all the
>money involved around that. Some hypothesis: 1) If 802.11a will have the
>UNII band then the FCC will be asked by the industry to allocate another
>band for HUMAN and other license exempt systems. 2) The FCC can split the
>UNII band to two or more groups as well. 3) The FCC will leave the
>as is. With all the above scenarios I don't see why 802.11a should act
>especially against HUMAN.
>b. The chance to have the UNII spectrum just for 802.11a currently is very
>low. It is anticipated that more proprietary non-coordinated technologies
>will jump to that spectrum. The risk is bigger if other standard
>technologies will upgrade their frequencies to that band, assuming they
>fulfill the FCC rules (like upgrade of: 802.16.3 or Hiperlan2, FWA < 11
>ETSI). This other standard technologies may be sold in high quantities and
>will occupy the band without any farther coordination.
>c. If the 802.11a will stop HUMAN to develop under IEEE, it will not
>other HUMAN like systems to come from outside IEEE (we can see that from
>number of participation in the HUMAN study group, even if it runs in
>parallel to 802.16.3). If 802.11a did not developed for environment like
>UNII is defined today then they should modify it.
>d. In case where HUMAN standard will develop under the 802's wings, some
>coexistent and coordination with 802.11a can be achieved (using the same
>spectral shape, bandwidth, center frequency etc).
>e. HUMAN made a call that was pushed by Naftali Chayat from 802.11a to
>802.11a for help regarding the adaptation of 802.11a. Our technical
>decisions have been taken during the meeting on the reaction to that call
>and a full consideration of the 802.11a has been taken.
>f. Human decided to choose to be close to 802.11a Phy in order to use the
>same spectrum mask, power level, etc... for coexistence reasons and time to
>g. Human decided to choose to be close to 802.16.1 MAC in order to take the
>ACCESS and other advantages, the group has some freedom in the convergence
>MAC/PHY that may be developed for the HUMAN specific needs, where farther
>coexistence consideration will be taken. After all, The HUMAN group wants
>share the spectrum with 802.11a with minimum mutual interferences.
>h. Effort for HUMAN survival in the UNII band in outdoor environment under
>the FCC rules will be taken. Human understand the fact that UNII band may
>have other non coordinated technologies in that band, HUMAN may incorporate
>farther tools for reducing the mutual interference like APC, highly
>directional antennas where LOS condition exists, strong or optimize FEC in
>order to minimize the usage of ARQ transmissions in order to prevent
>possible interferences from HUMAN to the other systems, which will lead to
>less retransmission on the other systems, etc...
>i. Mutual interference consideration:
>802.11a was designed for indoor LAN  for short rang (250 m) and most of the
>time the terminal need low transmit power in order to be received correctly
>by the receiver, this means that the 802.11a has power margin against
>interferences in addition to the building power penetration from outside
>interference. The HUMAN RF path propagate throw outdoor environment can
>transmit the same maximum radiated power but need to go for longer ranges
>(~5-10 Km). If one will make the calculations he will fined that the
>doesn't have to be afraid from HUMAN that used similar RF parameters.
>Best Regards,
>Zion Hadad

>President and CEO
>Runcom Technologies LTD.
>Broadband Wireless Technologies DVB-RCT, LMDS, MMDS
>Tel: 972-3-9528440 ext. 102   Fax: 972-3-9528805
>14 Levi Moshe st. 75158, Rishon Lezion, Israel
>-----Original Message-----
>From: owner-stds-802-16@ieee.org [mailto:owner-stds-802-16@ieee.org] On
>lf Of Roger B. Marks
>Sent: Wednesday, October 11, 2000 10:54 PM
>To: stds-802-16@ieee.org
>Subject: stds-802-16: Wireless HUMAN report
>Here is a report on the status of and plans for Wireless HUMAN:
>*I submitted the PAR:
>         <http://ieee802.org/16/human/par.html> or
>         <http://ieee802.org/16/human/docs/80216h-00_13r2.pdf>
>to the 802 Executive Committee on time. I have also arranged to get
>it on the agenda of the IEEE-SA Standards Board for possible approval
>on December 7, provided that 802 approves on November 9.
>*The PAR has led to some strong reactions from people in 802.11. Some
>have voiced strong opposition; others have suggested placing the work
>under 802.11. I have collected the comments together and posted them:
>         <http://ieee802.org/16/human/par_comments.html>
>*Based on this reaction, we are planning a Monday evening (6
>November, 8:00-9:30 pm) discussion on "Implications of the proposed
>Wireless HUMAN PAR on the 802 wireless program." The abstract is
>below; the full description (with hardly any more detail) is at:
>         <http://ieee802.org/16/human/WirelessHUMAN_tutorial2.pdf>
>We originally discussed holding this session on Tuesday, but it was
>moved to Monday so that it will assist the other Working Groups in
>drafting their comments on the PAR (these are due to us by 5 pm on
>*Notice that the session is rather ill-defined. I would like to have
>some speakers presenting the thoughts from an 802.16 perspective on
>the issues in the abstract. If you would like to be one of those
>speakers, let Durga <mailto:durga.satapathy@mail.sprint.com> and me
>know. We need to have some people doing some serious preparation for
>this session. Otherwise, I am afraid the current PAR will be in
>*During Session #10, the WirelessHUMAN Study Group needs to focus on
>the following:
>    -Mon afternoon and up to 8 pm: organizing itself for the evening
>    -Mon 8-9:30 pm: advocating a position and looking for common ground
>    -Tue: discussing reactions to the meeting and developing a revised
>    -Tue at 5 pm: distributing comments received by other WGs
>    -Wed by 4 pm: preparing response to comments of other WGs
>    -Wed by 4:30 pm: getting WG to approve revised PAR at WG Midweek
>    -Wed by 5:00 pm: getting revised PAR into boxes of 802 ExCom members
>    -Thu before 3 pm: preparing Call For Proposals as described in PAR
>    -Thu 3-5 pm: getting plans approved at Closing Plenary
>    -Thu night: attending 802 ExCom meeting during WirelessHUMAN motion
>"Implications of the proposed WirelessHUMAN PAR on the 802 wireless
>This meeting, organized with a more interactive format than a
>traditional tutorial, covers the implications of 802.16's proposed
>Wireless High-Speed Unlicensed Metropolitan Area Network
>(WirelessHUMAN) PAR <http://ieee802.org/16/human/par> on 802's
>wireless program. The WirelessHUMAN PAR targets operation in the
>unlicensed bands between 5 and 6 GHz, where 802.11 already supports a
>physical layer and 802.15 may be considering operation. While the
>draft PAR proposes a PHY based on 802.11a, the intent is to base the
>MAC on 802.16, which the Study Group believes is more suitable.
>Questions to be addressed include:
>* Can we identify a prescription to ensure that WirelessHUMAN systems, as
>described in the draft PAR, can coexist with nearby 802.11a systems?
>* If not, should 802 reject the WirelessHUMAN PAR, and what will be the
>* Would it be wise to radically transform the WirelessHUMAN PAR?
>* Is there a procedural mechanism to ensure that the WirelessHUMAN standard
>development accounts for the interests of 802.11 (and possibly 802.15)