Re: [STDS-802-11-REG] ECC Public Consultation on 2.3 GHz 0404r2 posted

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Hi All,

A review shows the Comment section needs more justification for the Proposed Change.

To that end, I’ve replaced the proposed comment and posted 14/0404r2 to Mentor

https://mentor.ieee.org/802.11/dcn/14/11-14-0404-02-0reg-ecc-14-bb-comments.docx

ECC Report 172 indicates very high potential interference into outdoor WLAN. In order to protect these WLANs operating in the 2400 – 2483.5 MHz, the maximum in-block e.i.r.p. for the upper 4 x 5 MHz channels (2380 – 2400 MHz) should be limited to 25 mW/5 MHz.

There is another risk which was not considered when ECC Report 172 was developed. Starting from 1 Jan 2015, 2.4 GHz WLAN devices can NO longer use CCA (Clear Channel Assessment) based on Carrier Sense or Carrier Sense with Energy Detect. From that date, the CCA mechanism shall be modified to do Energy Detect (CCA-ED) only. That makes WLAN systems sensitive to any signal, including LTE signals where current WLAN devices would only react on other WLAN devices. High out of band emissions (into the 2400 – 2483.5 MHz band) from LTE base stations in adjacent bands may trigger the CCA-ED mechanism in WLAN devices and make them back-off all the time.

A2.1.1 In-block requirements for MFCN base stations

· 2300-2380 MHz:

An in-block EIRP limit is not mandatory. In case an upper limit is desired by an administration, a value of 68 dBm/5 MHz EIRP per antenna may be applied.

· 2380-2400 MHz:

In-block EIRP limit of 14 dBm per 5 MHz.

· For femto base stations, the use of power control is mandatory in order to minimise interference to adjacent channels.

14/404r1 was approved in 11REG 16/0/4 and will be brought for WG approval in the midweek plenary.

Best Regards,

petere

From: Peter Ecclesine (pecclesi)
Sent: Monday, March 17, 2014 6:18 PM
To: Peter Ecclesine (pecclesi); STDS-802-11-REG@xxxxxxxxxxxxxxxxx
Subject: RE: ECC Public Consultation on 2.3 GHz

Hi All,

I’ve posted 802.11-14/0404r0 to Mentor with a proposed comment submission for 802.11

https://mentor.ieee.org/802.11/dcn/14/11-14-0404-00-0reg-ecc-14-bb-comments.docx

Comment number

Section number/ Clause

Paragraph Figure/ Table

Type of comment (General/ Technical/Editorial)

COMMENTS

Proposed change

IEEE/1

A2.1.1

Technical

Replace frequency block and text as shown

A2.1.1 In-block requirements for MFCN base stations

2300-2380 MHz:

An in-block EIRP limit is not mandatory. In case an upper limit is desired by an administration, a value of 68 dBm/5MHz EIRP per antenna may be applied.

2380-2400 MHz:

In-block EIRP limit of 25 dBm per cell.

XX/2

802.11 REG meets in L1 Function room 12 today AM2

petere

From: *** Regulatory and Spectrum Allocation Topics *** [mailto:STDS-802-11-REG@xxxxxxxx] On Behalf Of Peter Ecclesine (pecclesi)
Sent: Monday, March 17, 2014 1:40 PM
To: STDS-802-11-REG@xxxxxxxxxxxxxxxxx
Subject: Re: [STDS-802-11-REG] ECC Public Consultation on 2.3 GHz

Hi All,

The ECC (14)BB http://www.cept.org/ecc/tools-and-services/ecc-consultation

text (page 8) being commented on:

A2.1.1 In-block requirements for MFCN base stations

§ 2300-2400 MHz: An in-block e.i.r.p. limit is not obligatory. In case an upper limit is desired by an administration, a value which does not exceed 68 dBm / 5MHz e.i.r.p. per antenna may be applied. For the protection of WLAN above 2400 MHz, administrations may need to apply more stringent in-block e.i.r.p. limit in the upper part of the band 2300-2400 MHz.

The Ofcom consultation for this band proposes to limit 2390-2400 MHz to 61 dBm/5 MHz, but there remains the possibility that RLAN operation on channel 1 will be blocked by LTE base station operation in 2380-2390 MHz.

2300MHz-2400MHz into RLAN sharing analysis is presented in ECC Report 172, section 6.2, page 67

http://www.erodocdb.dk/docs/doc98/official/pdf/ECCRep172.pdf

Note ECC Rep 172 Annex A.1.3 Unwanted Emissions Mask (Table 64, page 82)

Rather that limiting the power only in 2390 to 2400 (2 x 5 MHz channels), I extended that to 4 channels (2380 – 2400 MHz). The reason is that report 172 indicates a high probability of interference into outdoor 802.11 networks. (82% for WLAN operating on 2412 and still 16% for WLAN operating on 2432 MHz).

Note that the 1^st channel (20 MHz wide with 2412 as centre) is from 2402 up to 2422 MHz. So just doing something on the upper 10 MHz of 2300 band is not sufficient.

Please look at the reference documents and come to 802.11REG AM2 CW-L1 Function 12 prepared to discuss an 802.11 comment to be taken forward.

Thanks in advance,

petere

From: *** Regulatory and Spectrum Allocation Topics *** [mailto:STDS-802-11-REG@xxxxxxxx] On Behalf Of Peter Ecclesine (pecclesi)
Sent: Tuesday, March 11, 2014 11:54 AM
To: STDS-802-11-REG@xxxxxxxxxxxxxxxxx
Subject: [STDS-802-11-REG] Ofcom Public Consultation 2.3 GHz & ECC Public Consultation on 2.3 GHz

My colleague Edgard Vangeel wrote to TG11:

This is a reminder on the below Public Consultations currently going on regarding the 2.3 GHz band (adjacent to the 2.4 GHz band being used by WIFI, Bluetooth, Zigbee, etc…)

1. OFCOM

Here is the link to the OFCOM public consultation on coexistence between 2.3 GHz LTE and 2.4 GHz WIFI.

http://stakeholders.ofcom.org.uk/consultations/pssr-2014/

2. ECC

The ECC public consultations can be found here:

http://www.cept.org/ecc/tools-and-services/ecc-consultation

That one includes the public consultation on the ECC Decision on ‘Harmonised technical and regulatory conditions for the use of the band 2300-2400 MHz for MFCN’.

If you have concerns about a possible negative impact of the deployment of LTE in 2.3 GHz on EN 300 328 type of applications in 2.4 GHz band, you can use the above URLs to raise your concerns.

Best regards,

Edgard Vangeel

ERM TG11 Chairman

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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