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Dear All,
I send comments on FCC NPRM from the view point on ITU-R ITS study work.
Please, check attached files.
Regards
Dr. Hyun Seo Oh
Principal Researcher, ETRI.
Dear All,
Based on last night’s discussion at the IEEE 802.11 TGbd meeting (EVE1), I have updated the “Draft TGbd Comments
on FCC NPRM Docket 19-138” https://mentor.ieee.org/802.11/dcn/20/11-20-0104-01-00bd-draft-tgbd-comments-on-fcc-nprm-docket-19-138.docx,
which is an unapproved working draft document.
Regards,
Joseph Levy
IEEE 802.11 TGbd Vice Chair
From: Joseph Levy
Sent: Thursday, January 2, 2020 7:56 PM
To: '** STDS-802-11-TGbd -- Enhancements for Next Generation V2X.Task Group **' <STDS-802-11-TGBD@xxxxxxxx>
Cc: sun.bo1 (sun.bo1@xxxxxxxxxx) <sun.bo1@xxxxxxxxxx>; 'James Lepp' <jlepp@xxxxxxxx>; 'Hongyuan Zhang' <hongyuan@xxxxxxxxxxx>; 'Sadeghi, Bahareh' <bahareh.sadeghi@xxxxxxxxx>
Subject: RE: Discussion on: FCC NPRM impacting the 5.9 GHz Band
Dear All,
This is a reminder and call for discussion on the FCC NPRM impacting the 5.9 GHz Band. This NPRM will make changes that will impact how 802.11 and 802.11bd based equipment will be able to access
the 5.9 GHz Band and the level of interference that will be allowed in the Band from neighboring bands.
The NPRM has not yet been published in the Federal Registry, hence the 30 day comment period has not started. But, it is likely that it will be published in the next few weeks, which means that
if we (TGbd) want 802.11 and/or 802.18 to provide comments on this NPRM we should work to have the comments approved at the upcoming 802.11 and 802.18 F2F meetings. Therefore, it would be best to have a TGbd position going into the meeting, hence this call/reminder
for discussion.
802.18 has asked for TGbd’s inputs and comments on the NPRM and in particular the OOBE (Out of Band Emissions) requirements, provided below. Please note that the FCC only specifies OOBE performance
requirements, it does not address channelization or in band interference requirements (these are typically specified by 802.11 or other technologies using the band).
The
OOBE requirements being proposed for comment in the NPRM (https://ecfsapi.fcc.gov/file/1217200308588/FCC-19-129A1.pdf) are discussed in paragraphs 54, 55 and 56 of the NPRM (copied
below):
“54. We propose that U-NII-4 devices, or devices that operate across a single channel that spans the U-NII-3 and U-NII-4 bands, meet an OOBE limit of -27 dBm/MHz at or above 5.925 GHz, which is the same limit required
for U-NII-3 devices at this frequency. We note that, for U-NII-3 devices,
the -27 dBm/MHz limit increases incrementally closer to the edge of the U-NII-3 band.94
Because the UNII-4 band is above the U-NII-3 band and closer to adjacent services (e.g., ITS services in the adjacent portion of the 5.9 GHz band (5.895-5.925 GHz) and 6 GHz fixed services), should we also
establish a
separate limit at the upper U-NII-4 band edge (i.e., at 5.895 GHz)?95
If so, what should this limit be? Should the slope of the OOBE from U-NII-4 devices at the upper edge of the band be adjusted to match the OOBE limits from U-NII-3 devices or should a different limit be established?
If the OOBE limits from the U-NII-4 band are adjusted to match the U-NII-3 band OOBE limits, can unlicensed devices and ITS devices operate directly adjacent to each other as the emissions into the ITS band would be identical from either U-NII-3 or U-NII-4
devices? We seek comment generally on the OOBE limits we should
apply at the upper end of the U-NII-4 band and whether any spectrum must be reserved to protect ITS services,96
and if so, whether such spectrum should be in the U-NII or ITS segment of the 5.9 GHz band.
“55. We further propose that U-NII-4 devices, or devices that operate across a single channel that spans the U-NII-3 and U-NII-4 bands, meet the same OOBE limits as U-NII-3 devices at the lower edge of the combined
U-NII-3 and U-NII-4 band, i.e., at 5.725 MHz. Because we expect devices designed for the U-NII-3 and U-NII-4 bands to be similar and therefore compatible with each other, we do not believe it is necessary to set a separate OOBE limit for U-NII-4 devices at
the U-NII-3/U-NII-4 band edge.97
We seek comment on these proposals as well as seeking comment on whether there are alternative OOBE limits that we should adopt.
“56. Our proposals support a separate U-NII-3 and U-NII-4 band to provide flexibility for designing U-NII-3 equipment under the less stringent OOBE rules at the upper edge of the band. Our proposals also provide
flexibility for devices to operate across the U-NII-3 and U-NII-4 bands using the widest bandwidths permitted under the 802.11 standard. Alternatively, we could expand the U-NII-3 band and implement a single set of OOBE limits for the combined 5.725-5.895
GHz band using the OOBE limits proposed for U-NII-4 band devices or devices that operate across a single channel that spans the U-NII-3 and U-NII-4 bands. What advantages would a single band under uniform rules provide? What would be the drawbacks, especially
considering the effect on OOBE limits? We seek comment on this alternative. Under our proposal or this alternative, we also seek comment on any other rule changes that are needed to support communications across the combined U-NII-3 and U-NII-4 bands. Finally,
we seek comment on how our proposals might affect device design and cost.”
Fillings made to this FCC docket 19-138 can be found:
https://www.fcc.gov/ecfs/search/filings?limit=25&offset=0&proceedings_name=19-138&sort=date_disseminated,DESC
There have also been numerous public comments made in various media: e.g. pro
https://cei.org/content/cei-praises-fcc-breaking-impasse-59-ghz-spectrum-band and con
https://ride.tech/self-driving/fcc-plan-could-stall-v2x-car-safety-revolution/
Regards,
Joseph Levy
802.11 TGbd Vice Chair
From: Joseph Levy
Sent: Wednesday, December 18, 2019 7:13 PM
To: ** STDS-802-11-TGbd -- Enhancements for Next Generation V2X.Task Group ** <STDS-802-11-TGBD@xxxxxxxx>
Cc: sun.bo1 (sun.bo1@xxxxxxxxxx) <sun.bo1@xxxxxxxxxx>; James Lepp <jlepp@xxxxxxxx>; Hongyuan Zhang <hongyuan@xxxxxxxxxxx>; Sadeghi, Bahareh <bahareh.sadeghi@xxxxxxxxx>
Subject: RE: Discussion on: FCC NPRM impacting the 5.9 GHz Band
Dear All,
As you may already know – the NPRM for the 5.850-5.925 GHz Band is has been released by the FCC as well as the statements by the commissioners made at the 12 December 2019 Open Meeting. (see:
https://www.fcc.gov/ecfs/filing/1217200308588)
Jay Holcomb, the 802.18 chair, has the released NPRM posted to the 802.18 document area on Mentor:
The time line provided in the NPRM is:
Adopted: December 12,
2019
Released: December 17,
2019
Comment Date: [30 days after date of publication in the Federal
Register]
Reply Comment Date: [60 days after date of publication in the Federal Register]
Please note that even though this document has been released, it has not yet been published in the Federal Register, so the clock has not yet started ticking.
Also note:
Today 18 December 2019, an announcement of the FCC Open Meeting was published in the Federal Register -
https://www.federalregister.gov/documents/2019/12/18
(The FCC meeting announcement is copied here for your convenience, note links below are clickable):
Federal Communications Commission:
Meetings:
Open Commission; Thursday, December 12, 2019
FR Document:
Citation:
84 FR 69372
Pages 69372-69373
(2 pages)
Regards,
Joseph Levy
802.11 TGbd Vice Chair
From: Joseph Levy
Sent: Tuesday, December 17, 2019 12:07 AM
To: ** STDS-802-11-TGbd -- Enhancements for Next Generation V2X.Task Group ** <STDS-802-11-TGBD@xxxxxxxx>
Cc: sun.bo1 (sun.bo1@xxxxxxxxxx) <sun.bo1@xxxxxxxxxx>; James Lepp <jlepp@xxxxxxxx>; Hongyuan Zhang <hongyuan@xxxxxxxxxxx>; Sadeghi, Bahareh <bahareh.sadeghi@xxxxxxxxx>
Subject: RE: Discussion on: FCC NPRM impacting the 5.9 GHz Band
Dear All,
As you are probably aware at the United States (US) Federal Communications Committee (FCC) Open Commission Meeting on 12 December 2019, the commissioners unanimously approved the proposed Notice
of Proposed Rule Making (NPRM). The comment period on the NPRM will begin when the NPRM is published in the US Federal Register, which has not yet happened.
I have generated contribution summarizing the 5.9 NPRM status to aid in structuring the discussion during the upcoming TGbd Teleconference 17 December 2019 @ 9:00 AM EST. Note the contribution
also provide multiple links where additional information can be found.
Regards,
Joseph Levy (InterDigital)
802.11 TGbd Vice Chair
From: Joseph Levy
Sent: Thursday, December 5, 2019 12:57 AM
To: '** STDS-802-11-TGbd -- Enhancements for Next Generation V2X.Task Group **' <STDS-802-11-TGBD@xxxxxxxx>
Cc: sun.bo1 (sun.bo1@xxxxxxxxxx) <sun.bo1@xxxxxxxxxx>; 'James Lepp' <jlepp@xxxxxxxx>; Hongyuan Zhang <hongyuan@xxxxxxxxxxx>; Sadeghi, Bahareh <bahareh.sadeghi@xxxxxxxxx>
Subject: Discussion on: FCC NPRM impacting the 5.9 GHz Band
This e-mail is a call for discussion (as requested by the TGbd Chair) on the TGbd reflector (this e-mail stream) to reach a conclusion as to what, if any, actions/position should be taken by TGbd,
in response to the announced FCC plans for the 5.9 GHz band.
As mentioned during the teleconference, I believe that the best way forward for TGbd is to generate a document (preferably a PowerPoint document) that provides 802.11 TGbd’s position/comments
on the proposed FCC NPRM. I will create a draft document based on this e-mail discussion, that will be discussed and hopefully approved by TGbd. Once TGbd has agreed, the document can then be shared with the 802.11 WG during one of the plenary time slots
of the upcoming January 802.11 meeting and hopefully the 802.11 WG will pass it along to 802.18 and the 802 EC.
The rest of this e-mail provides information: the FCC documents and related web pages, a summary of the 802 process to send information to the FCC, and additional 802.11 and DSRC background information:
FCC Information:
As announced and discussed on the TGbd 3 December Telephone Conference:
The United States (US) Federal Communications Committee (FCC) has announced that at their upcoming Open Commission Meeting on 12 December 2019 at 10:30 am - 12:30 pm EST (https://www.fcc.gov/news-events/events/2019/12/december-2019-open-commission-meeting)
they will consider a Notice of Proposed Rulemaking (NPRM) that would change the rules for the 5.9 GHz band (the DSRC band).
As stated on the FCC “FACT SHEET”:
What the NPRM Would Do:
• Propose to repurpose the lower 45 megahertz of the band (5.850.5.895 GHz) for unlicensed operations to support high-throughput broadband applications.
• Propose that unlicensed device operations in the 5.850-5.895 GHz band be subject to all of the general Part 15 operational principles in the Unlicensed National Information Infrastructure
(U-NII) rules. Propose to adopt technical and operational rules (e.g., power levels, out-of-band emissions limits) similar to those that already apply in the adjacent 5.725-5.850 GHz (U-NII-3) band.
• Propose to continue to dedicate spectrum in the upper 30 megahertz of the 5.9 GHz band (5.895-5.925 GHz) to support ITS needs for transportation and vehicle safety-related communications.
o Propose to revise the current ITS rules for the 5.9 GHz band to permit Cellular Vehicle to Everything (C-V2X) operations
in the upper 20 megahertz of the band (5.905-5.925 GHz).
o Seek comment on whether to retain the remaining 10 megahertz (5.895-5.905 GHz) for DSRC systems or whether this segment should
be dedicated for C-V2X.
o Propose to require C-V2X equipment to comply with the existing DSRC coordination rules for protection of the 5.9 GHz band
Federal Radiolocation Service.
o Propose to retain the existing technical and coordination rules that currently apply to DSRC, to the extent that we allow
DSRC operations in the 5.895-5.905 GHz band.
• Seek comment on how DSRC incumbents would transition their operations out of some or all of the 5.9 GHz band if the proposals are adopted.
The FCC typical process is (The specifics of this process will be provided in the published NPRM):
802 Process Information:
The IEEE 802 process for submitting comments or reply-comments to the FCC requires the submission to be generated and approved by 802.18 and then approved by the 802 EC. 802.18 has already added
the 5.9 GHz band NPRM discussion to its agenda and has had a brief discussion on the possibility of submitting comments (see
18-19/0147r1 (slides 14 and 18) and
18-19/0151r0, note minutes for the telephone conference from 21 Nov are not currently available). 802.18 has regularly scheduled teleconference on Thursday 15:00-16:00 EST (see more
details »
for teleconference details).
802.11 Background Information:
The last area of information is related to past 802.11 discussion on the 5.9 GHz band:
In 2013 the FCC release NPRM 13-22 (Docket 13-49) which requested comments regarding allowing unlicensed devices such as those using 802.11-based standards to share the 5.9 GHz band, which is
currently allocated for DSRC and other services. 802.11 formed a DSRC Coexistence Tiger Team, to generate a 802.11 position:
802.11 DSRC Band Sharing Report
This report was approved by 802.11 was sent to 802.18 to be forwarded to the EC for its approval and submittal to the FCC (item 28 in the 802.11 March 2015 minutes: 11-14/0287r0).
802.18 made some small modifications and forwarded the report to the 802 EC (18-15/0016r1 and cover letter
18-15/0018r1), (item 16 and 18 in the 802.19 March 2015 minutes:
18-15/0019r0). However, the 802 EC did not approve the motion: “Move to approve document 18-15/0016r1 providing a view of the work done in the IEEE802.11DSRC Tiger Team with the cover letter as contained in Document 18-15/0018r1 and submit it to the FCC.
The Chair of 802 is authorized to make editorial changes as necessary.” (Note the details of how this was not approved can only be understood from the EC minutes, the EC e-mail archive, I have not included all these details as it is quite complex.) The 802
EC eventually sent letter to Marlene H. Dortch, Secretary Federal Communications Commission in May (ec-15/0035r1)
that basically stated that 802.11 had some initial discussion regarding the feasibility and practicality of sharing the 5.9 GHz band and the documents of the discussion can be found on Mentor.
Other 802.11 documents of interest are:
11-15/0402r2
DSRC Band Sharing TT Status and Report Finalization, Rolf de Vegt (Qualcomm)
11-13/1449r2
Proposal for DSRC band coexistence, Tevfik Yucek (Qualcomm)
Regards,
Joseph Levy (InterDigital)
802.11bd Vice Chair
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Attachment:
Comments_FCCNPRM.doc
Description: Comments_FCCNPRM.doc
Attachment:
R-REC-M.2084-1-201911-I!!PDF-E.pdf
Description: R-REC-M.2084-1-201911-I!!PDF-E.pdf
Attachment:
R-REC-M.2121-0-201901-I!!PDF-E.pdf
Description: R-REC-M.2121-0-201901-I!!PDF-E.pdf