Re: [802SEC] +++EC Email Ballot+++Urgent motion to approve 802.18 doc+++
Given that Steve is satisfied, I am happy to vote to approve.
mike
Carl R. Stevenson wrote:
> Steve, and EC colleagues,
>
> Again, comments in context below with a .pdf for those whose mail
> clients may not handle HTML.
>
>
> ------------------------------------------------------------------------
> *From:* Shellhammer, Stephen J [mailto:stephen.j.shellhammer@intel.com]
> *Sent:* Tuesday, November 23, 2004 9:14 PM
> *To:* wk3c@wk3c.com; paul.nikolich@att.net;
> STDS-802-SEC@listserv.ieee.org
> *Subject:* RE: [802SEC] +++EC Email Ballot+++Urgent motion to
> approve 802.18 doc+++
>
> Carl,
>
>
>
> Thank you for your detailed response. Let me try to
> summarize my concerns in this response. They relate to wireless
> microphones and professional installation.
>
>
>
> *Wireless Microphones*
>
> I am not trying to question the accuracy of the
> technical work within 802.18. My concern is that the IEEE is
> recommending to the FCC that they regulate how industry ensures that
> Part 15 devices do not interfere with Part 74 devices. Typically the
> FCC limits power and power spectral density (PSD) of Part 15 devices
> but does not specify rules for spectrum sharing. They typically
> leave any spectrum sharing designs to the industry.
>
>
>
> That has been their practice in unlicensed vs. unlicensed sharing
> situations (the ISM bands), but again, unlicensed under licensed is
> a very different situation, as you note before.
>
>
>
> You mention my position as chair of 802.19 Coexistence
> TAG which is a very good point. By analogy, 802.19 did not regulate
> in the recent rules change how the wireless working groups should
> ensure coexistence, we just are requiring that they do coexist,
> using any design they like, and then show that the new standard
> coexists with current standards. So 802.19 did not tell the
> wireless working group how to do their job, just that they need to
> show that they did do there job.
>
>
>
> That is an internal 802 matter, not a question of what regulation
> may be necessary to assure protection of licensed services. (The
> latter is the domain/responsibility of the FCC, and we have simply
> tried to recommend the minimum regulation that our studies and
> discussions with the incumbent licensees indicate to be appropriate.)
>
>
>
> However, I do understand that this band is different
> than the ISM bands so I appreciate that it may be necessary for the
> FCC to set additional regulation on industry.
>
>
>
> So I will accept your response on the Part 74 devices
> and will withdraw my recommendation to remove those paragraphs.
>
>
>
> Thank you.
>
>
>
> *Professional Installation*
>
> I do not accept that argument that GPS systems and
> database systems are always unreliable, and hence the only valid
> method of installation is a professional. I believe that in many
> cases GPS and a database can be made reliable and can be used for
> installation. In the case that they do not work professional
> installation is also available. So I believe that both methods of
> installation should be allowed by the FCC.
>
>
>
> The issue is not that "GPS and database systems are *always*
> unreliable." The issue is that GPS can be unreliable in some
> situations *and* that the FCC database of information on licensed
> facilities (TV stations) contains many omissions and
> inaccuracies and isn't maintained in a timely fashion due to a lack
> of resources and other factors. The combination of these
> factors results in the conclusion that relying on "GPS and database"
> as a sole means of determining channel availability at any given
> location/time would be unreliable often enough to present
> significant interference potential. Since we will have an
> obligation not to cause interference, we believe that relying on
> "GPS and database" as a sole means is inappropriate and would result
> in interference that could/should be avoided (at least at this time,
> under the current circumstances).
>
>
>
> Note that the professional installation recommendation applies
> *only* to the base station in fixed access networks, not to the CPE
> (user terminals), nor to "personal portable" devices. What this
> means is that a WISP, for example, will have to have someone capable
> of doing "due diligence" in terms of locating the base station,
> predicting its coverage, looking at what channel(s) can be used from
> that site with the intended technical parameters and coverage, and
> making initial channel selections that assure that the coverage
> (interference range) of the base station does not overlap into the
> "Grade B protected contour" of surrounding TV stations at levels
> that would violate the required D/U (desired/undesired signal)
> ratios. (after turn-on, the base station and its associated CPEs
> would use the sensing mode to verify channel availability and to
> respond to changes in the RF environment as TV facilities and
> channel assignments change with time).
>
>
>
> Perhaps with time, if the FCC database were to become more accurate
> and were updated in a very timely manner, the problems associated
> with the reliability of the "GPS and database" technique will be
> resolved to the point where sufficient reliability could be
> obtained. At that time, I am confident that the FCC would entertain
> a request for a rules change, but at the moment, we believe that we
> cannot, in good professional conscience, endorse this technique as a
> sole, "stand-alone" means of determining channel availability and
> ensuring that interference to the incumbent licensed services does
> not occur.
>
>
>
> Finally, personal portable devices (obviously) cannot be
> "professionally installed," and there is no suggestion that they
> should be, as, by definition they are easily moved about/relocated.
> Clearly, such devices will have to operate autonomously to prevent
> interference. I would also point out that relatively short-range,
> relatively low power systems like 802.11x are not treated as fixed
> systems precisely because of the ease with which they can be
> relocated. (Note that, under the changes made to the ITU Radio
> Regulations at WRC-03, the new global, primary allocation to
> "Wireless Access Systems, including RLANs" (which includes 802.11)
> was made to the MOBILE service, not to the FIXED service.)
>
>
>
> I maintain my recommendation to add text to the document
> allowing for either professional or GPS/Database types of installation.
>
>
>
> In the event that my further explanation on this topic has not
> changed your view, I can only say that I am not empowered to make
> such substantive changes to the document. I would also refer you to
> the following text from the 802.11 technical reflector, submitted by
> Bob O'Hara in response to some supportive comments there:
>
>
>
> --- This message came from the IEEE 802.11 Technical Reflector ---
>
> I would like to echo the position expressed here, this response
> needs to be filed in a timely fashion and with out any substantive
> changes.
>
> There has been significant cooperation between the incumbent license
> holders and the members of the 802 wireless working groups.
>
> Since this NPRM addresses operation in a band relatively far removed
> from any where existing 802 operate, any devices ultimately designed
> to operate here will be based on new silicon and new PHY specifications.
>
> There are no existing 802 device manufacturers to protect. Therefore
> I think that there is little danger to the extra protection that
> some see in the response. If this is helpful to getting consensus
> from all the parties involved in the NPRM, I think that it is not
> too high a price to pay.
>
> -Bob
>
> Regards,
>
> *Carl R. Stevenson*
>
> /*President and Chief Technology Officer*/
>
> *WK3C /Wireless/ LLC/ /*
>
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Distinguished Engineer, Cisco Systems
Chair IEEE 802.17 Stds WG
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