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[STDS-802-11-REG] 13/444r1 FCC 13-49 comments posted on Mentor



I would like to make a comment on  the recommendations in 444 to add a new low power option, allowing soft APs and Wi-Fi Direct devices to operate without supporting DFS if they use low power. I personally believe this is a big mistake. The last thing we should be doing is inflicting a large number of unmanaged rogue APs on the 5GHz band.

 

However, I understand that some members are fans of the possibility of allowing soft APs and Wi-Fi Direct in the 5GHz band. I will not argue against that view because it is not a black and white argument. That said the current recommendations in document are not justified by the document.  Nowhere in the document does it explain how soft APs can operate at low power without DFS without causing interference to radar stakeholders

 

Indeed the current ruling from the FCC (2uW/MHz) suggests that there is no power at which devices could operate without DFS and still satisfy the use cases in Attachment 1. We have not included any evidence to the contrary in this document, and is inappropriate to make a recommendation to allow low power operation without DFS. It is actually disrespectful to the goals of the radar stakeholders.

 

Recommendation 1

 

On pp40, delete,

 

In addition, we recommend adding the option for a low power mode on DFS channels, meaning, devices that do not support DFS, will be able to operate on DFS channels, with power limitation

 

I want to delete it here because there is no need to say the same thing twice (without justification in either case). The issue can better be handled once on pp41.

 

Recommendation 2

 

On pp41, change:

 

For that reason, IEEE 802.11 is recommending a low power mode exemption to DFS

 

To

 

For that reason, IEEE 802.11 is recommending a new study to determine if it is possible to operate low power APs without DFS, while both protecting the radar users and providing sufficiently high power to enable the use cases in Attachment 1. This study should occur as soon as possible but it completion should not stop the implementations of the other recommendations of this response from IEEE 802

 

This better expresses our desires, which are low power operation without DFS if it is possible without unreasonably affecting the interests of other stakeholders

 

Andrew

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