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Re: [802SEC] +++ Early Close 10-day EC Motion+++ Approval of response to FCC on a 5GAA ex parte requesting the FCC to re-configure most all of the U-NII-4 band to cellular V2X, away from the DSRC (802.11p)

hi Roger,

I think I understand your points though I am not sure just how to work them. I will need to work with some different folks on the different points and get their opinions if we can do anything from an editorial basis.

not sure how long this will take, and we are already a couple of weeks later than we wanted to get this out.


From: Roger Marks <>

Date: Fri, May 31, 2019 at 1:24 PM
Subject: Re: [802SEC] +++ Early Close 10-day EC Motion+++ Approval of response to FCC on a 5GAA ex parte requesting the FCC to re-configure most all of the U-NII-4 band to cellular V2X, away from the DSRC (802.11p)
To: Jay Holcomb <>, <>


This looks good to me. I have a few quick comments:

(1) In our 17 January 2019 filing, we used the terms "OCB", "DSRC", and "NGV" instead of identifying the technology by name instead of by the amendment that introduces it. I think that's great. However, this document is reverting to extensive usage of "802.11p" and "802.11bc", even when the usage is far from meaningful in an IEEE sense (for example, it says "future extension of IEEE 802.11p and IEEE 802.11bd," even though IEEE doesn't extend an amendment). I think it would be wise to use language consistent with our own earlier filing. It might be useful to repeat something like this statement from the earlier filing: 'The term "OCB" was introduced in the amendment IEEE Std 802.11p, which specified "Wireless Access in Vehicular Environments" and was later incorporated into IEEE Std 802.11. The OCB specifications with IEEE Std 802.11 continue to support DSRC-compatible operation.'

(2) I am uncomfortable with the use of the reference in footnote 6 because it has no attribution or marked status. The document has no source information on the cover, and it is not stored on mentor, which would otherwise identify a source. I think that somewhere (either in the footnote or in the source document) there should be some kind of attribution. Ideally, it would say that it's the view of the IEEE 802.11 WG.



On May 31, 2019 at 1:48:42 PM, Jay Holcomb ( wrote:


Dear LMSC Members,


From the email I sent on 17may, I would like to announce the start of an EC ballot on a response to the FCC on 5GAA’s 05 April 2019 ex parte requesting the FCC to re-configure the U-NII-4, 5.9 GHz band, for even more of the band to C-V2X (cellular). This is a further reduction for DSRC from their original request for waiver last November (we commented on).  The ex parte would reduce DSRC (IEEE 802.11p) to only a single 10MHz channel.


Note: 5GAA also filed this ex parte under the original proceeding that lead up to DSRC and all, docket ET 13-49 (U-NII) Devices in the 5 GHz Band.  This request came after the RR-TAG vote, though I would like to file the same comments in that docket also.


Paul has delegated to me to conduct a LMSC Early Close 10-day electronic ballot on the motion below to approve our 5GAA ex parte response to the FCC.  This EC motion is per 802 OM 7.2 Procedure for communication with government bodies.


Motion:  Move to approve the response to the FCC in to 5GAA’s 05 April 2019 ex parte to the FCC. With the chair of 802.18 to have editorial privileges and send to the FCC under GN 18-357 and ET 13-49.


Approved in the TAG:   9 / 0 / 1 to send to FCC


Mover:        Jay Holcomb

Seconder:     Dorothy Stanley


Start of ballot: 31 May 2019

Close of ballot: 10 June 2019




Reference documents:

5GAA’s original waiver request in November and our comments in January:


5GAA’s ex parte on 05april19:


FCC proceeding sites overall:

1. 5GAA waiver: GN 18-357:,DESC

2. Parent proceeding: ET 13-49:,DESC


From the FCC sites:

5G Automotive Association

5GAA Ex Parte Notice 4.5.19.pdf  49Opens a New Window.

GN 18-357

ET 13-49



ex parte



Early close: As required in subclause 4.1.2 'Voting rules' of the IEEE 802 LAN/MAN Standards Committee (LMSC) Operations Manual, this is notice that, to ensure the release is provided in a timely manner, this ballot may close early once sufficient responses are received to clearly decide a matter. Sufficient responses to clearly decide this matter will be based on the required majority for a motion under subclause 7.1.1 'Actions requiring approval by a majority vote' item (h), 'Other motions brought to the floor by members (when deemed in order by the Sponsor Chair)' of the IEEE 802 LAN/MAN Standards Committee (LMSC) Policies and Procedures.



Note2, as mentioned in email on 17th, the RR-TAG passed a second motion to send the same comments to the US DoT, and logistics for that have taken some time and are just now being finalized, why the delay to start balloting. It was decided in this week's RR-TAG’s teleconference to start the FCC ballot and will run the ballot for the DoT submission soon.  A draft for that document:



Jay Holcomb

Liberty Lake (Spokane), WA

Itron, Inc.

IEEE 802.18 Chair

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Jay Holcomb
IEEE 802.18
Itron, Liberty Lake (Spokane), WA

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