Re: [STDS-802-11-REG] 5GHz NPRM comments

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Hi Richard and All, here is my proposal regarding databases on pg 31, similar points were made in two places (in yellow). I expanded first place and deleted second.

stringent set of emissions characteristics – together with actions already taken to reduce the ability of users to configure systems, are sufficient to address the issues raised by the TDWR examples. Unlike a “greenfield” band such as TV white spaces, the 5 GHz band has been in use to varying degrees for two decades. Imposing any database, much less a database that fully interacts with devices in the field, significantly alters equipment design, ~~significantly~~ raises cost, increases complexity, raises questions about database maintenance, and introduces ~~tremendous~~ significant uncertainty to an industry that today is delivering a wireless broadband access platform that by some measures accounts for over half of all IP traffic in the United States.[1] This is a far different proposition than when a device ecosystem is new, and there are no consumer expectations in terms of quality and price points yet built around it. For example, implementing a database requires numerous issues to be solved - issues about who pays for it, the cost of implementing software in the master devices to talk to the database, who is responsible for ensuring the system works, which equipment should be subject to it, how the federal users will interact with it, particularly if their activities are not ones that they wish to share with third parties, and how to design a system that works when a consumer plugs in an access point. These are difficult issues that could take years to sort out, and if technical and certification rules have already addressed the interference cases, then solving for a database solution becomes a needless exercise.

Thanks,

Vinko..

From: Vinko Erceg
Sent: Monday, May 13, 2013 8:00 PM
To: STDS-802-11-REG@xxxxxxxxxxxxxxxxx
Subject: [STDS-802-11-REG] 5GHz NPRM comments

Hi Richard and All,

Few comments, based on document 13/444r1:

- Pg 19 ln 4 please insert the following:

IEEE 802.11 also presumes that the general test procedures in KDB 789033 for measuring the emissions compliance of U-NII devices to Section 15.407 requirements will continue to apply.

- Pg 38 end of section B please insert the following:

In addition, IEEE 802.11 proposes to change PSD requirements from 8dBm/3KHz to 23.2dBm/100KHz for the sub-1GHz unlicensed bands that are not part of the TVWS rules.

- Remove replace “cognitive” in two places with “sensing” or similar

- On pages 23 and 31 maybe language against databases does not have to be that strong, just state that they are not necessary

Thanks and Regards,

Vinko..

[1] See Cisco Visual Networking Index (June 2012), estimating that after 2016, the majority of all IP traffic will originate or terminate on Wi-Fi. www.cisco/go/vni

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