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



With some changes to the original text:

 

Furthermore, IEEE 802.11 working group is asking to clarify that FCC allows in the rules the following behavior by a Master device:   A Master is allowed to perform the channel availability check on multiple channels during device power up or during operation per existing Part 15 test methods to ensure that no radar is operating .  In this way a list of “available channels” may be formed and retained by the Master as long as it is powered up.  The Master would be allowed to immediately commence operation on any available channel during operation and immediately commence in-service-monitoring. No new CAC would be required immediately before commencing operation on an available channel or switching to another channel in the list of “available channels”.  All other existing channel closing and non-occupancy rules would remain in force.  In summary, the Master can operate in one or more of the “available channels” and change its operating channel, without repeating a new CAC before commencing operation on another available channel.  This behavior is recognized in DFS conformance rules in other regions and was originally understood to be allowed by NTIA during development of the DFS solution.   It is also believed that no current text or test procedure for DFS in Part 15 explicitly precludes this behavior.

 

Thanks

Tevfik

 

 

 

 

From: *** Regulatory and Spectrum Allocation Topics *** [mailto:STDS-802-11-REG@xxxxxxxx] On Behalf Of Yucek, Tevfik
Sent: Tuesday, May 14, 2013 2:20 PM
To: STDS-802-11-REG@xxxxxxxxxxxxxxxxx
Subject: Re: [STDS-802-11-REG] 5GHz NPRM comments

 

Hi Rich and All,

 

I would like to have the following paragraph added to Page 41 of 13-444 just before “B. UNII-1 Proposed revisions” section.

 

 

Furthermore, IEEE 802.11 working group is recommending that FCC allow in the rules, the following behavior by a master device:   A Master is allowed to perform the channel availability check on multiple channels during device power up or in any continuous 60 second per the existing Part 15 test method, to ensure that no radar is operating on the scanned channels.  In this way a list of “available channels” would be retained by the Master as long as it is powered up.  The Master would be allowed to immediately commence operation on any available channel during operation and immediately commence in-service-monitoring. No new CAC would be required immediately before commencing operation on an available channel.  All other channel closing and non-occupancy rules remain in force as usual.  In summary, the Master can operate in one or more of the ‘available channels’ and change its operating channel, without repeating a new CAC before commencing operation on another available channel.  This behavior is recognized in DFS conformance rules in other regions and was originally understood to be allowed by NTIA during development of the DFS solution.   It is also believed that no current text or test procedure for DFS in Part 15 explicitly precludes this behavior.

 

 

Regards,

Tevfik

 

From: *** Regulatory and Spectrum Allocation Topics *** [mailto:STDS-802-11-REG@xxxxxxxx] On Behalf Of Vinko Erceg
Sent: Monday, May 13, 2013 5:00 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..

 

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