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hello all,as Joseph mentions below, the effort on the putting together IEEE 802 comments to the FCC NPRM on revisiting and re-configuration of the 5.9 GHz band has moved into 802.18 the RR-TAG. after today's work on the comments we are currently at 18-20/0020r03:with only a week to go to our target to approve the comments on thursday the 20th, next week, we are still in need of drop in text/clear edits keeping in mind we need agreement/approval by all of IEEE 802 as a whole.the weekly 802.18 teleconference this thursday, the 13th, (15:00-et) we have some other agenda items, though will spend what time we can on this. call in information is in:then the next editing ad hoc is this friday, the 14th, also at 15:00-et. below is the call in information:thanks to all that have contributed and appreciate all the drop in text we can get to review with only hours left to get to final comments.thanksJay Holcomb802.18Meeting number (access code): 927 467 590 Meeting password: RRTAG14
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Can't join the meeting?From: Joseph Levy <Joseph.Levy@xxxxxxxxxxxxxxxx>
Date: Mon, Feb 10, 2020 at 8:20 PM
Subject: RE: Discussion on: FCC NPRM impacting the 5.9 GHz Band
To: STDS-802-11-TGBD@xxxxxxxxxxxxxxxxx <STDS-802-11-TGBD@xxxxxxxxxxxxxxxxx>
Cc: STDS-802-11@xxxxxxxxxxxxxxxxx <STDS-802-11@xxxxxxxxxxxxxxxxx>, STDS-802-18@xxxxxxxxxxxxxxxxx <STDS-802-18@xxxxxxxxxxxxxxxxx>, jlepp@xxxxxxxx <jlepp@xxxxxxxx>, Ioannis.Sarris@xxxxxxxxxx <Ioannis.Sarris@xxxxxxxxxx>, Yossi.shaul@xxxxxxxxxxxxxx <Yossi.shaul@xxxxxxxxxxxxxx>, sebastian.schiessl@xxxxxxxxxx <sebastian.schiessl@xxxxxxxxxx>, hsoh5@xxxxxxxxxx <hsoh5@xxxxxxxxxx>, Jay Holcomb <jholcomb@xxxxxxxx>Dear All,
I have updated the “Draft TGbd Comments on FCC NPRM Docket 19-138” 11-20/0104r12.
11-20/0104r13 – Edits to align paragraph reference numbering with the published NPRM, reference [B], paragraph numbering, and insert contributed modifications and additions provided by Sebastian Schiess via the STDS-802.11-TGbd reflector on 7 February 2020. Also, provided a list of possible NPRM references for section 8 and added some comments.
11-20/0104r14 – A clean copy (all changes accepted) of r13, with all comments moved “in line” in the 802.18 format: in line comments are proceeded by a “{“ then followed by comment text.
https://mentor.ieee.org/802.11/dcn/20/11-20-0104-14-00bd-draft-tgbd-comments-on-fcc-nprm-docket-19-138.docx802.18 will be taking over the document development and editing – so if you wish to participate please join the 802.18 meetings where this will be discussed:
802.18 will have an ad hoc meeting for 5.9GHz comment drafting session on:
11 Feb 3pm EST/noon PST – for 2 hours. The WebEx link for the meeting is below.
Additional 802.18 ad hoc meetings are being considered for:
Friday 14th – 3pm–et-2hr
Tuesday 18th – 3pm–et-2hr
Wednesday 19th - 3pm–et-2hr
Friday 21st - 3pm–et–2hr
Tuesday 25th - 3pm–et-2hr
(note 802.18 meetings, only require a 5 day notification)
(Please see the 802.18 meeting agendas for these ad hoc meeting for conference call information and meeting details: https://mentor.ieee.org/802.18/documents)
Also 802.18 will have their regular weekly meetings (where the work of 802.18 will be address, the 5.9GHz comments will be on the agenda): 802.18 meets on every Thursday 3:pm EST – for 1 hour. (Please see the meeting agenda for the conference call information and meeting details: https://mentor.ieee.org/802.18/documents)
If you cannot join these 802.18 meetings, but want to follow or participate in this activity, please follow the document development on the 802.18 mentor site (see links above). If you have comments or text contributions, please provide them to the 802.18 listserv, the Chair of 802.18 Jay Holcomb (jholcomb@xxxxxxxx), or on the TGbd listserv by responding to this email.
Regards,
Joseph Levy
802.11 TGbd Vice Chair
ad hoc WebEx information:
Meeting number (access code): 925 685 375 Meeting password: RRTAG11
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Dial 925685375@xxxxxxxxxxxxxxxxxx
You can also dial 173.243.2.68 and enter your meeting number.
Join by phone
Tap to call in from a mobile device (attendees only)
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Can't join the meeting?
From: Joseph Levy
Sent: Thursday, February 6, 2020 2:34 PM
To: 'STDS-802-11-TGBD@xxxxxxxxxxxxxxxxx' <STDS-802-11-TGBD@xxxxxxxxxxxxxxxxx>
Cc: 'STDS-802-11@xxxxxxxxxxxxxxxxx' <STDS-802-11@xxxxxxxxxxxxxxxxx>; 'STDS-802-18@xxxxxxxxxxxxxxxxx' <STDS-802-18@xxxxxxxxxxxxxxxxx>; 'jlepp@xxxxxxxx' <jlepp@xxxxxxxx>; 'Ioannis.Sarris@xxxxxxxxxx' <Ioannis.Sarris@xxxxxxxxxx>; 'Yossi.shaul@xxxxxxxxxxxxxx' <Yossi.shaul@xxxxxxxxxxxxxx>; 'sebastian.schiessl@xxxxxxxxxx' <sebastian.schiessl@xxxxxxxxxx>; 'hsoh5@xxxxxxxxxx' <hsoh5@xxxxxxxxxx>
Subject: RE: Discussion on: FCC NPRM impacting the 5.9 GHz Band
Dear All,
The FCC NPRM impacting the 5.9 GHz Band was published today in the US federal register:
Proposed Rule
Use of the 5.850-5.925 GHz Band
FR Document:
Citation:
85 FR 6841
Pages 6841-6856 (16 pages)
This publication starts the clock running on the Comment and Reply Comment due dates:
- Comments are due Monday 09 March 2020 (one week before the 802.11 March meeting)
- Reply comments are due Monday 06 April 2020.
A quick review of the published NPRM did not yield any significant changes from the previously FCC published NPRM. I will continue to review the document and will note any changes.
Given the time line set by the NPRM being published today, we are now will rely on 802.18 to provide comments to the FCC from 802. As discussed at the 802.11 closing plenary in January.
802.18 will be meeting today Thursday 06 February 2020 @ 3:00 PM EST. Details on the 802.18 meeting can be found on the 802.18 web page: http://grouper.ieee.org/groups/802/18/
Jay Holcomb the 802.18 Chair, has asked me to continue to be the editor for the for 802.18 document, which will be based on the 802.11 TGbd document: https://mentor.ieee.org/802.11/dcn/20/11-20-0104-12-00bd-draft-tgbd-comments-on-fcc-nprm-docket-19-138.docx.
Therefore, if you have edits or content to provide for the 802 comments on the FCC NPRM impacting the 5.9 GHz Band, please send them to me, share them with 802.11, 802.11 TGbd over this reflector, and also with 802.18 so all potentially interested parties are aware of this work. Also, if you want to actively participate in this work please join the 802.18 meetings. I’ll share the 802.18 progress and meeting plans and milestones as they are developed (I assume this will be done at today’s meeting) as well as the drafts as the work progresses.
Lastly, a comment on the reply comment period, as noted above the reply comment period ends 06 April 2020, this means we can discuss and approve a reply comment response from 802.11 and/or 802.18 at the March F2F meeting – so if you see the need to reply to some of the filings/comments on the record we have time to generate and approve a reply comments document that can be provided to the record (the FCC). The 118 filings made to date are available: https://www.fcc.gov/ecfs/search/filings?limit=25&offset=0&proceedings_name=19-138&sort=date_disseminated,DESC
The number of filings/comments will continue to grow as comments and reply comments are generated and posted.
Regards,
Joseph Levy
802.11 TGbd Vice Chair
From: Joseph Levy
Sent: Friday, January 31, 2020 5:55 PM
To: 'STDS-802-11-TGBD@xxxxxxxxxxxxxxxxx' <STDS-802-11-TGBD@xxxxxxxxxxxxxxxxx>
Cc: 'STDS-802-11@xxxxxxxxxxxxxxxxx' <STDS-802-11@xxxxxxxxxxxxxxxxx>; STDS-802-18@xxxxxxxxxxxxxxxxx
Subject: RE: Discussion on: FCC NPRM impacting the 5.9 GHz Band
Dear All,
I have received additional edits and content from Hyun Seo Oh via e-mail and the TGbd reflector. I have added the contributed content and have also edited section 3.2:
Also I have added the 802.18 list serve as a cc, so that 802.18 can monitor our progress – as they requested at the 802.18 meeting 30 Jan 2020.
Note: 11-20-0104 is a working document it has not been approved, it is a compilation of contributed content. Additional contributions and opinions on the current content are encouraged. Please, respond to this email thread on the reflector to participate in this activity. 11-20-0104 has been reviewed and discussed both in 802.11 TGbd and in 802.18 (but as was stated above, it has not been agreed or approved in either group).
Regards,
Joseph Levy
802.11 TGbd Vice Chair
From: Joseph Levy
Sent: Thursday, January 30, 2020 3:25 PM
To: STDS-802-11-TGBD@xxxxxxxxxxxxxxxxx
Cc: STDS-802-11@xxxxxxxxxxxxxxxxx
Subject: RE: Discussion on: FCC NPRM impacting the 5.9 GHz Band
Dear All,
I have received additional edits and content from Hyun Seo Oh via e-mail and the TGbd reflector. I have added the contributed content and done some additional edits to the document:
Note on r11 – Text and edits provided by Hyun Seo OH, provided by e-mail/reflector, with additional edits, particularly in 1.2 to improve readability (please review to insure content was not impacted).
Note: 11-20-0104 is a working document it has not been approved, it is a compilation of contributed content. Additional contributions and opinions on the current content are encouraged. Please, respond to this email thread on the reflector to participate in this activity. 11-20-0104 has been reviewed and discussed both in 802.11 TGbd and in 802.18 (but as was stated above, it has not been agreed or approved in either group).
Regards,
Joseph Levy
802.11 TGbd Vice Chair
From: Joseph Levy
Sent: Tuesday, January 28, 2020 11:02 AM
To: Joseph Levy <Joseph.Levy@xxxxxxxxxxxxxxxx>; STDS-802-11-TGBD@xxxxxxxxxxxxxxxxx
Subject: RE: Discussion on: FCC NPRM impacting the 5.9 GHz Band
Dear All,
As Mentor is down, and I have gotten a few e-mails asking if there is any other way to get the document (11-20/104r10) I am attaching it to this e-mail.
Note: I have no information as to when Mentor will be back on line – but I have been assured that notifications will be sent out when Mentor is back on line.
Regards,
Joseph Levy
802.11 TBbd Vice Chair
From: ** STDS-802-11-TGbd -- Enhancements for Next Generation V2X.Task Group ** [mailto:STDS-802-11-TGBD@xxxxxxxx] On Behalf Of Joseph Levy
Sent: Tuesday, January 28, 2020 10:21 AM
To: STDS-802-11-TGBD@xxxxxxxxxxxxxxxxx
Subject: Re: [STDS-802-11-TGBD] Discussion on: FCC NPRM impacting the 5.9 GHz Band
Dear All,
The r9 draft of the “Draft TGbd Comments on FCC NPRM Docket 19-138” (https://mentor.ieee.org/802.11/dcn/20/11-20-0104-09-00bd-draft-tgbd-comments-on-fcc-nprm-docket-19-138.docx) was discussed on the 802.18 teleconference 23 Jan 2020 and several comments and edits were made. I have included these edits and comments in r10 (https://mentor.ieee.org/802.11/dcn/20/11-20-0104-10-00bd-draft-tgbd-comments-on-fcc-nprm-docket-19-138.docx).
Also mentioned on the 802.18 teleconference were two items that may be of interest:
- Chairman Pai’s Statement on Announcement of New C-V2X Deployment: https://www.fcc.gov/document/chairman-pai-statement-announcement-new-c-v2x-deployment
- The letter from the US House of Representatives Committee on Transportation and Infrastructure to the FCC: https://transportation.house.gov/imo/media/doc/2020-01-22%20Full%20TI%20Letter%20to%20FCC.pdf
Your comments and text contributions are requested.
Please feel free to provide your comments and text contributions via either method described below (email to the reflector or posting an updated document in your name see below for details).
Regards,
Joseph Levy
802.11 TGbd Vice Chair
P.S. Sorry for the delay in sending this e-mail – it got caught in my “out box”. Also please note that Mentor is currently not available, though it should be soon, so you will have no access to the latest draft.
From: Joseph Levy
Sent: Thursday, January 23, 2020 1:18 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>; 'Ioannis.Sarris@xxxxxxxxxx' <Ioannis.Sarris@xxxxxxxxxx>; 'Yossi.shaul@xxxxxxxxxxxxxx' <Yossi.shaul@xxxxxxxxxxxxxx>; 'sebastian.schiessl@xxxxxxxxxx' <sebastian.schiessl@xxxxxxxxxx>
Subject: RE: Discussion on: FCC NPRM impacting the 5.9 GHz Band
Dear All,
I have done some editing on the “Draft TGbd Comments on FCC NPRM Docket 19-138”, as I indicated I would do at the closing TGbd meeting on Thursday 16 January 2020.
Two revisions have been uploaded to mentor:
r8 – Accepted all additions and edits to establish a clean baseline document
r9 - Edits made to address structure, organization, and provide references to the NPRM – these references need to be reviewed.
Note additional organization may be necessary as we may want to put our comments in NPRM paragraph order. Also, reference “numbering” needs to be cleaned up and I didn’t update the rev properly in the header (it still says r8)
If you have additional material to include in this document or edits you think should be made, please either:
- Provide your content to this e-mail stream (including all the cc’s) and I will integrate the content into the draft (please be sure to indicate where you intend to insert the provided content.
- If you desire to edit the document directly, please feel free to do so. But, when you post your updated document to the reflector please indicate yourself as the source (do not leave it to the default which is currently me (Joseph Levy (InterDigital)). Also please add your name and information to the author list and provide a revision description in the Abstract. Lastly, please provide an e-mail to this e-mail stream (including all the cc’s) summarizing the changes you have made so that everyone is aware of your contribution. Lastly if you need any assistance regarding how to update the draft or upload to mentor please ask me for assistance or use method 1, above.
Regards,
Joseph Levy
802.11 TGbd Vice Chair
From: Joseph Levy
Sent: Tuesday, January 14, 2020 11:34 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,
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):
- The NPRM will be published in the US Federal Register (https://www.federalregister.gov/) – this is expected to occur after the Open Commission Meeting
- Once published there will typically be a 30 day comment period, during which comments by individuals and entities on the NPRM can be provided to the FCC.
- The comment period is then typically followed by a reply-comment period, where comments on the comments that have been provided to the FCC can be responded to by individuals and entities by an additional submission.
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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--Regards,
Jay Holcomb
IEEE 802.18
Itron, Liberty Lake (Spokane), WA
Regards,
Jay Holcomb
IEEE 802.18
Itron, Liberty Lake (Spokane), WA
To unsubscribe from the STDS-802-11-TGBD list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=STDS-802-11-TGBD&A=1