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Roger, I totally support your position. The letter should
absolutely not specify any specific technology, which was the main point of my
original comment.. Brian From: Roger B. Marks
[mailto:r.b.marks@ieee.org] Dear Apurva, Thanks for your note. I posted it to the 802.16 reflector By following the thread links, you can find the followup
discussion. After considering the views expressed, here are my comments: (1) I think that the penultimate paragraph of the draft
statement ("We hereby strongly encourage the Indian Government to consider
the IEEE 802.22 technology as candidate for the 470 – 698 MHz band in
India.") should be deleted, for several reasons: (a) That paragraph arises without any foundation from
the IEEE side. Up to that point, the draft statement simply provides
information about the 802.22 Working Group. I don't think this substantiates
the request. It's not even clear what it means by "the IEEE 802.22
technology." Is it referring to specific functional concepts, or it is
referring to the entire draft standard in detail? Or perhaps to something in
between? (b) More importantly, that paragraph arises without any
foundation from the Indian side. The letter is posed as an "endorsement
for the proposal submitted by TICET, IIT Bombay towards the ongoing NFAP
revision / review process in India for the 470 – 698 MHz
band." However, TICET proposal was proposing NFAP changes to
"promote innovative approaches," "reduce entry barriers,"
"maximize cost-effectiveness," and "ignite research."
Nowhere in its paper did TICET discuss identifying a "candidate"
for the band. (c) The TICIT proposal is about revising NFAP 2008 towards
NFAP 2010. I did a little research and determined that "NFAP" is
"National Frequency Allocation Plan." This turns out to be a local
version of the ITU Radio Regulations. A "National Frequency
Allocation Plan" should not be calling out specific technologies. If
anything, we should be congratulating India for keeping technology mandates out
of the NFAP. The problematic paragraph seems to be suggesting that the
government instead write a technology into the Allocation Plan. Any position
like that from the IEEE side would be a mistake. (2) Due to my points in (1), I think that the subject line
of the letter ("Use of IEEE 802.22 Technology in the 470 – 698 MHz Band in
India") in inappropriate. I think that the subject
is "endorsement for the proposal submitted by TICET, IIT Bombay
towards the ongoing NFAP revision / review process in India for the 470 – 698
MHz band." (3) The letter should not refer to "IEEE 802.22
Standard" since no such standard exists. (4) The letter should provide references that would document
and explain the meaning of the statement that "During the last 5 years,
the IEEE 802.22 Working Group has been actively working with the FCC and other
regulators to create a standard for world-wide deployment in the TV bands to
provide broadband access to the masses." Thanks again for the chance to review the letter. I'd be
happy to hear what you think about my comments. Regards, Roger On 2011/02/08, at 11:26 PM, Mody, Apurva (US SSA) wrote:
Hi
Roger, The 802.22 Working Group would like to submit the following letter to
the Wireless Planning and Co-ordination (WPC) Advisor in India through Indian
Institute of Technology (IIT) Bombay. This letter was discussed during the
802.18 telecon held on Tuesday, Feb. 8th. We
(802.22) would like to endorse the IIT Bombay proposal for license-exempt use
in the 470 – 698 MHz spectrum in India. IITs are the premier Engineering
institutes in India. IIT academics are very well respected all around the world
and they have been known to work closely with the Indian Govt. in the advisory
role. The IIT-Bombay proposal has been attached for your reference. Please review the letter and let us know your comments if any by
Monday, Feb. 14th COB. Many
thanks Apurva Apurva
N. Mody, Ph. D. Chair, IEEE 802.22 Standard
Working Group BAE Systems Technology
Solutions 130 Daniel
Webster Highway, Mail Stop 2350 Merrimack, NH
03054 Work: (603)885 2621, Mobile:
(603)-809-0459 E-mail: apurva.mody@baesystems.com <IITB_proposal_TV_White_Space.pdf> |