Re: [STDS-802-11-REG] 13/444r1 FCC 13-49 comments posted on Mentor
Hi Peter and All:
Following up on my comments on the May 2 and 9 teleconferences, here are some specific changes I recommend to 444/r1. All of them pertain to Section VII on the U-NII-4 band. I welcome comments and discussion.
Note on page numbers: I'm viewing 444/r1 as it came from the server, with the Review/Show Markup/Balloons option set to "Show only Comments and Formatting in Balloons," which creates a 60 page document. The page numbering is different if one views with "Show revisions in balloons".
1. Change: In the first paragraph of the section, at the top of page 44, after the sentence ending "shared with U-NII-4 devices," insert this sentence: "Sharing in both the U-NII-3 and U-NII-4 bands would add one 80 MHz and one 160 MHz channel."
Rationale: the earlier part of the paragraph notes the number of 80 and 160 MHz channels with and without "contiguous spectrum." It notes that contiguous spectrum can increase the number of 80 and 160 MHz channels by 4 and 3, respectively. Without the inserted sentence, a reader might easily infer that this gain in 80 and 160 MHz channels is to be achieved solely through sharing in the U-NII-4 band. In fact, sharing of U-NII-4 alone does not add any 80 or 160 MHz channels.
2. Change (editorial): In the first partial paragraph of p. 45, 6th line on the page, in the sentence that starts "The issue is not," change "detection if one" to "detection of one" (i.e. if to of).
Rationale: typo [Note: the remainder if the sentence is a bit awkward, and could probably be improved]
3. Change: In the paragraph on p. 46 that begins "In the view of IEEE 802.11 ...", change the 3rd and 4th sentences to: "From
our membership, we are aware that there are many companies whose engineers are
were represented in 802.11p standards and continue to be involved as well as in the other 802.11
working groups, which means much of the industry is actively supporting both commercial
802.11 as well as DSRC technologies. As the standards body that oversees both, wWe strongly prefer a set of FCC rules that will
allow both sets of technologies to flourish.
Rationale: The intended meaning of the sentences is ok (though a bit overstated in terms of common participation), but it implies that 802.11p standardization is ongoing when in fact TGp became inactive in 2010.
4. Change: Later in the same paragraph, now at the top of p. 47, change the penultimate sentence as follows: "Infrastructure
transmissions are licensed by the FCC to the states – again, these have
primary status in the band."
Rationale: According to FCC part 90.373, RSUs can be licensed to commercial as well as governmental bodies, i.e. they are not always licensed to the states.
5. Change (editorial): In the second paragraph on p. 47, first sentence, change "stakeholder" to "stakeholders"
Rationale: typo
6. Change: In the sentence that spans the break between pages 47 and 48, substitute:
- "802.11 recognizes its role in standardizing aspects of the solution, as appropriate, and encourages participation from stakeholders in the ITS community."
for
- "From a standards
perspective, IEEE 802.11 encourages
the two 802.11 standards groups to work together to jointly develop a
co-existence mechanism between the two technologies."
Also, insert "It is" at the start of the next sentence to make it grammatically correct.
Rationale: There are no longer "two 802.11 standards groups" representing both sides of this issue.
7. In the first full paragraph on p. 48 (final paragraph of Section VII), in the third sentence substitute:
- "While 802.11 recognizes the benefits for unlicensed devices if the revised Section 15.407 is applied to the U-NII-4 band, it also recognizes that those rules create a potential for harmful interference with DSRC devices operating at typical (10 dBm to 20 dBm) transmit power. The technical parameters for operation in U-NII-3 and U-NII-4 represent a part of the sharing solution that must be developed."
for
- "IEEE 802.11 agrees,
and endorses the harmonization of Section 15.407 with the U-NII-3 and U-NII-2C
bands."
Rationale: The power difference between 15.407 maximum transmit power (1 Watt) and typical DSRC transmit power (10 to 100 milliwatts) creates a prima facie case that U-NII-4 transmissions can harmfully interfere with simultaneous DSRC transmissions, and indeed that the U-NII-4 device might not even be aware of the DSRC device. A simple endorsement of 15.407 for U-NII-4 thus contradicts earlier statements expressing the need to avoid such interference. We should be frank in admitting that this is an area where some work will have to be done.
8. Change: In the final two sentences on page 48 (end of Section VII), omit the words "of DSRC or" so that the text reads:
"IEEE 802.11 does not
agree that imposing adjacent channel sensing is necessary for the protection of
DSRC or of radar in the band [1]. As stated above, we believe the case for
adjacent channel sensing is speculative, not borne out by real world examples,
and is very costly in terms of degrading the operation of commercial Wi-Fi
equipment that would operate in the band. "
Also, move these two sentences to the end of the paragraph on radar detection at the top of page 45.
Rationale: While our previous experience may justify us in saying that adjacent channel sensing is not necessary for protection of radar, we have no experience that justifies this with respect to protection of DSRC. To the contrary, a simple analysis shows that a 1 Watt transmission on a 20 MHz channel from a U-NII device conforming to the transmit spectral mask and located within a vehicle can cause harmful interference to that vehicle's reception of a simultaneous DSRC transmission in adjacent 10 MHz channels. We should not take potential solutions off the table until alternate solutions are identified. Furthermore, it is apparent that the scope of NPRM paragraph 98, to which this comment is directed, is limited to radar detection.
Best Regards,
John
--
John Kenney
Sr. Research Manager
Toyota InfoTechnology Center, USA
465 Bernardo Avenue
Mountain View, CA 94043
Tel: 650-694-4160. Mobile: 650-224-6644
On Tue, Apr 30, 2013 at 8:37 AM, Peter Ecclesine (pecclesi)
<pecclesi@xxxxxxxxx> wrote:
Hi All,
Added Executive Summary, additional focus on “adjacent channel” and “out-of-channel” emissions, updated footnotes. Track changes on
https://mentor.ieee.org/802.11/dcn/13/11-13-0444-01-0reg-fcc-13-49-comment.docx
petere
Hi All,
The authors of 13/353 Comment Framework have posted a draft FCC Comment on Docket 13-49.
https://mentor.ieee.org/802.11/dcn/13/11-13-0444-00-0reg-fcc-13-49-comment.doc
Unfortunately the 802.11 portrait template mangles an FCC comment template, and page numbering suffered.
Note that 802.18 allows posting the FCC documents with a boilerplate header page.
Please review the submission and prepare for our next 802.11REG teleconference May 2nd.
Best Regards,
petere
Peter Ecclesine, Technology Analyst
MS SJ-14-4 170 West Tasman Dr, San Jose, CA 95134-1706
Ph 408/527-0815, FAX 408/525-9256
"Time doesn't fool around." "Without Prejudice" U.C.C. 1-207
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