stds-802-16: RE: [802SEC] 802.18 document for 5 day EC pre-filing review
Thanks for this constructive suggestion.
I would suggest this edited version of your paragraph:
"While we understand that the Commission is bound by the ITU Radio
Regulations regarding the bands under consideration in the instant
Proceeding, we (consistent with our previously filed comments) share
the concerns of the License-Exempt Alliance (LEA) regarding the
Commission's assumption of the adequacy of the 100 MHz at 5.725-5.825
MHz for higher-power outdoor operations. While "out of scope" in the
instant Proceeding, we encourage the Commission to remain committed
to finding ways to provide increased capacity for such services
through another proceeding."
At 6:51 PM -0400 03/09/18, Stevenson, Carl R (Carl) wrote:
>Roger, 802.16, et al,
>Some comments on Roger's comments in context below ...
>I will [snip] a bit to the salient points to save space.
>> -----Original Message-----
>> From: Roger B. Marks [mailto:firstname.lastname@example.org]
>> Sent: Thursday, September 18, 2003 3:58 PM
>> To: email@example.com
>> Cc: Stevenson, Carl R (Carl); firstname.lastname@example.org
>> Subject: Re: [802SEC] 802.18 document for 5 day EC pre-filing review
>> I'd like to outline the procedures on the issue, along with a summary
>> of my current views.
>> In accordance with Procedure 4 of the 802 Policies and Procedures,
>> the 802.18 TAG can submit the statement unless an EC member files a
>> "motion to block" within five-day review period (i.e., by 22 Sept at
>> 6:38 am US ET). There is no procedure for the 802.16 Working Group to
>> decide to make this motion, so I have to decide myself (with Working
>> Group input).
>> Note that a motion to block would kill the submission. That's because
>> there is no time for a EC ballot before the FCC deadline of 23
>I hope that this won't happen. This filing is important.
>> It is barely possible that 802.18 could amend the document and still
>> get it in by the deadline. However, that's very unlikely. As I
>> understand, the FCC deadline is about five days and eight hours from
>> now. The 802.18 TAG is meeting in Singapore, where it is currently
>> about 4 am. Another factor is that 802.11 and 802.15 have already
>> voted to approve the document under EC review.
>> If there were time to review the draft, I think we might be able to
>> make some improvements. I think it is clear that 802.16 was not
>> represented in the discussions, but we can't blame this on 802.18.
>> [We can discuss some procedural improvements for the future.]
>Input from Marianna was considered in July, modified slightly with
>her agreement, and included in the original comments of IEEE 802,
>which were filed with the FCC and are in the record.
>To summarize, we DID, in our original comments, question the FCC's
>assumption, and expressed concerns that the 100 MHz from 5725-5825
>MHz would not be adequate for the needs of longer range outdoor
>(particularly rural) applications.
>> I'd also like to express my opinion on the changes proposed by
>> Marianna and Gordon:
>> *I think that it would be very difficult to win 802.18 approval for
>> many of the requested changes.
>This does NOT mean that 802.18 is "unfriendly" to 802.16 ... just
>that there are some EXTREME political sensitivities in the current
>proceeding and we are trying to avoid creat)ing problems with the
>FCC (and other branches of the US govt.) that could cause this whole
>thing to blow up in our collective faces.
>> *I think that much of the proposed text is inappropriate for reply
>> comments, since it's not clear to what we would be replying.
>> *I think that much of the proposed text is out of the scope
>> of the NPRM.
>The quorum of 802.18 present in Singapore strongly agreed with
>Roger's two comments above.
>> *I think that key points on this topic were made forcefully in
> > previous comments, such as those of the License-Exempt Alliance (LEA)
> > <http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf
>> Here are some key aspects of the LEA paper:
>> -It is 802.16-friendly. It says "Recent developments in the
>> standards-setting process will only accelerate last mile broadband
>> deployments over license-exempt spectrum. By now the Commission is
>> aware of the recently-adopted IEEE 802.16a standard, which will
>> support delivery of outdoor broadband service over license-exempt
>> spectrum at distances up to 30 miles, with a typical cell radius of
>> 4-6 miles." It continues with more positive comments on 802.16.
>> -It says "The LEA is troubled by the Commission's apparent assumption
>> that the 100 MHz at 5.725-5.825 MHz is adequate for higher power
>> outdoor operations (i.e., more than 1 watt), and that outdoor
>> providers in that spectrum can make do with what they have. As shown
>> below, this assumption is factually erroneous and, more important, is
>> at odds with the Commission's recent emphasis on finding more
>> spectrum for license-exempt operations and permitting license-exempt
>> operators to use higher power. The LEA is hopeful that the
>> Commission's statements on these issues in the NPRM are an
>> aberration, and urges the Commission to remain charted on its prior
>> course of regulatory reform targeted at optimizing the benefits of
>> last-mile license-exempt service."
>> If I were in the room during this discussion of the 802.18 document,
>> I would focus on amending it to provide reply comments in support of
>> the LEA's view, as expressed in the last quote above.
>I would have no issue with, under the editorial privilege granted me
>by the TAG/WG motions, adding in a brief paragraph in accord with
>what we said in our original comments to the effect that:
>"While we realize that the Commission is bound by the ITU Radio Regulations
>to not permit higher power in the bands under consideration in the instant
>Proceeding, consistent with our original comments, we share LEA's concern
>about the Commission's assumption that the 100 MHz at 5.725-5.825 MHz is
>adequate for higher power outdoor operations. While "out of scope"
>in the instant proceeding, we encourage the Commission to remain
>committed to finding ways to provide increased capacity for such
>services through another proceeding."
>In my view, that fundamental thought was ALREADY approved by .18, .11,
>.15, .16, and the Executive committee in our original (already filed)
>comments and I do not believe it would be improper to insert such a
>paragraph in the reply comments in the interest of being responsive to
>.16's needs and concerns in a way that would not run afoul of the extreme
>political sensitivities surrounding the NPRM.
>Additionally ... I'd like to include a snip of text from an e-mail
>that I sent to Marianna "off list" to emphasize that I and 802.18 are
>committed to balanced representation of ALL of the wireless
>workgroups and we are willing to assist .16 on this issue in the
>future in a more appropriate Proceeding:
>As I told you in San Francisco, the issue of other bands is
>"out of scope" for this NPRM and the FCC is not even allowed
>by their own rules to consider it in this proceeding ... however,
>there is interest in the FCC in making more unlicensed spectrum
>available, particularly for rural applications, and as I indicated
>I would be very happy to work cooperatively with you through
>802.18 to try to get a favorable outcome (some of the spectrum under
>consideration is at lower frequencies and would actually provide
>much more favorable propagation characteristics for the rural WISP
>sort of applications that you wish to address).
>Would this suggestion be an acceptable solution to everyone's concerns?
>Carl R. Stevenson
>Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group
>610-965-8799 (home office)
>610-712-3217 (fax mailbox)
>Short Message Service: email@example.com