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Re: [STDS-802-11] Questions -- EPD for IEEE 802.11 5.9GHz Operations



--- This message came from the IEEE 802.11 Working Group Reflector ---

Marc,

Thanks for your interest in this topic.  I've tried to answer your questions
as best I can below.

Cheers,

RR

> -----Original Message-----
> From: Marc Emmelmann [mailto:marc.emmelmann@xxxxxx]
> Sent: Friday, November 07, 2014 12:01 PM
> To: dickroy@xxxxxxxxxxxx
> Cc: STDS-802-11@xxxxxxxxxxxxxxxxx
> Subject: Questions -- EPD for IEEE 802.11 5.9GHz Operations
> 
> Dick,
> 
> many thanks for your presentation you gave today in the dot11
> WG (https://mentor.ieee.org/802.11/dcn/14/11-14-1521-01-000m-epd-for-
> ieee802-11-5-9ghz-operations.pptx).
> 
> I support in general the optimization you propose to be made given that we
> have a full understanding
> on the potential implications, and given that are are none causing
> compatibility issues
> with certified or deployed equipment.

[RR>] To date there are NO regulations by governmental entities requiring
compliance/conformance to any standard for ITS communications in the 5.9GHz
band. Thus, it is not possible to have regulatory-compliant deployed
equipment in those bands. The prototypes in the field today are compliant to
various versions of standards, and in some cases those are drafts!

> 
> I have some initial questions.
> 
> (1) Involved (government) entities
> 
> 	(1a) Which (government) entities are involved in setting the rules
> and certifying
> 	equipment for 5.9GHz operation?  I do not only ask this for the US,
> I would like
> 	to see an overview for all possible involved entities (Americas,
> Europe, Asia, etc.)

[RR>] I am not a regulatory or certification expert, however I'll give you
what I know.  In the US, NHTSA is responsible for setting rules that apply
to vehicle safety-related matters and have stated their intention to make a
ruling regarding 5.9GHz V2V communications in September 2015. There is an
ANPRM that has completed the comment period and the comments are being
processed by NHTSA and the US DoT.  The intended output of the process is a
rulemaking that will point to a set of standards that will be "mandated in
all vehicles." In the US, the FCC makes rules related to spectrum and its
usage in general (e.g. Part 90 rules in the 5.9GHz band state that ASTM-2213
must be complied with regarding the PHY and FCC 06-110 states channel 172 is
to be used solely for safety of life and property services). 

As far as equipment certification goes, in the US there is a consortium of
entities called OmniAir that has gotten some funding to develop test and
certification procedures for 5.9 equipment.  A notice of inquiry as recently
posted in the federal register I believe, asking if there were other
entities interested inparticipating in such a testing program.  In Europe,
ETSI as you know claims to be THE test house for such things, however,
ISO/CEN has recently started getting involved.  

Japan currently has no 5.9GHz V2V program.  They are thinking they'll do V2V
safety at 700MHz, and that may change.

China intends to test 5.9GHz V2V safety soon, however, there are no
frequency allocations yet, and no regulations I am aware of.

Australia, New Zealand, Korea and Canada are "following what the US does",
however there are no regulations in place yet. That said, Korea has been
running 5.9GHz V2V and V2I tests for several years now. 

South America is watching and will most likely follow what the US and Europe
do. I say "do" because there is an EU-US Task Force (which now includes
Australia and to some extent Japan) that is working feverishly to harmonize
the standards related to usage of these bands (and I have participated in
that as well).  

Africa ... ????  They'll probably follow ITU recommendations, and we (ISO
and IEEE) are looking to get all the standards we've developed considered as
ITU Recommendations.  If that does happen, then Africa would be following as
well.

Antarctica, Greenland (they'll probably follow Europe since they're Danish),
the Arctic north ... I'm not sure the penguins or polar bears care that
much.

Russia, Ukraine, Latvia, Estonia, Lithuania ... they'll do whatever they
want! And if I were a vendor of 5.9 radio units, I wouldn't be banking on
that market for my survival.

The middle east is too busy blowing up cars to worry about outfitting them
with devices to prevent collisions. When the conflict ends, there will be no
more oil, hence no more industry. Cars, along with pretty much everything
else invented since the industrial revolution will cease to function,
including 5.9 GHz 802.11p radios.

India, Indonesia, Thailand, Cambodia, Laos, Burma, Vietnam ... no clue. They
participate minimally, if at all, in any of the global standards meetings
related to ITS. 

I have no idea what the protectorates and nations in the South Pacific are
thinking.  And as Clarke Gable said to Vivian Leigh, "Frankly my dear, I
don't give a damn!" (Gone With the Wind, Margaret Mitchell, last century)

The Easter Islands are Ecuadorian and will probably do what Ecuador does.
Since there are more big stone statues than people there, I'm not sure it
matters.

If I've missed a country or two, I apologize.

> 
> 	(1b) Has any of those entities already approved a rule set /
> requirement document
> 	that cites 802.11p (as standing today)?

[RR>] THere is a European Norm (EN) EN 302 663 that points to the deprecated
802.2 standard as well as 802.11-2012 as normative.  These would need to be
revised and I am working on that.  In the US, there are stated intentions to
do so as I mentioned above, however, there are no "approved rule sets" yet.

> 
> 	(1c) Are there any testing / certification programs that test agains
> 802.11p (as it stands
> 	today) for 5.9GHz operations?

[RR>] Nothing formal that I am aware of.  However, as I stated above,
OmniAir and ETSI are currently testing prototype implementations against
various versions of the (draft) standards. They are both well aware that the
standards are subject to revision!

> 
> ad 1) I understand that it might be impossible to get an official response
> from all involved
> 	(government) entities that states "we have not approved any
> requirement that points
> 	to 802.11p as it exists today";  but I would like to see a complete,
> documented analysis of the
> 	status quo

[RR>] So would I, however it is very unlikely to happen unless someone pays
for it, and I have no idea who that would be. Probably the best you are
going to get is by querying people like me who have been attending the large
number of ITS related standards meetings around the world, and there are
only a few of those.

> to make a profound decision on the suggested changes.

[RR>] Not sure what you mean by a "profound decision".  Just as every 802.11
device on the market today would have to be reprogrammed to do FILS, those
prototype ITS 5.9GHz systems (there are several thousand such) in the field
today will have to be reprogrammed to include all the security-related
functions that will be mandated if nothing else. Making the change to EPD is
trivial in comparison.  The change from LPD to EPD is a simple decision to
get it right while we have the chance!  Once automobiles start rolling off
the production line with embedded radio systems that use LPD, there will be
NO chance to change ... period.  And this will impact ALL portable devices
(smartphones) built to save lives as well.  All of 802 will be migrating to
EPD over the next few years, and ITS communications will be chained to LPD
which will be very costly!  You might be interested to know that in ALL
aircraft built today, the communication system used for ground
communications is an AM radio!!!  
> 
> (2) Deployed system
> 
> 	(2a) Are there any (known) deployments that build upon 802.11p as it
> exists today?

[RR>] NO. There are only trial projects (SafetyPilot, CVIS, and a few others
planned).
> 
> (3) Involved product manufacturers.
> 
> 	(2a) Are you aware of any manufacturer / implementer that has
> (pending) products
> 	that implement 802.11p as it exists today?

[RR>] Yes. In no particular order, Arada Systems, Savari Networks, DENSO,
lesswire, Imtech, Kapsch-Trafficom, Q-Free, Cohda Wireless, Commsignia,
Ranix, Autotalks, ITRI, to name most (if not all) of them. I suspect a few
others will be entering the market soon, however, I don't want to speculate
at this point.  You can probably guess who they are.

> 
> ad 2 & 3) I know you already stated that you are personally not aware of
> any such deployment /
> 	manufacturers. I just added (2) & (3) for other potentially involved
> decision maker to check
> 	themselves and consider this issue.

[RR>] I have asked most of the companies in the list above to make the
change from LPD to EPD and let me know how it went. To date, the four I
mentioned have implemented the change in less than several hours and
successfully tested communications between transmitting and receiving
devices and given wireshark output as "proof". Several others have stated
their intent to do so, and others have simply said it's a good idea, easily
accomplished, and they're prepared to do it.

> 
> 
> Answering all three points will also help to identify the set of entities
> that should be actively
> informed if 802.11 adopts the changes you propose as they will break
> backward compatibility.

[RR>] For the most part, they are already aware.  I did not make this
proposal to IEEE 802 without first "making the rounds".  I have been all
over the world in many forums promoting this change.  The ONLY pushback I
have ever gotten is from people who say it's "too late to make the change",
and these are the SAME people who intend on mandating changes to the current
prototypes that will seriously break backward compatibility requiring
substantial changes.  A bit disingenuous in my opinion! 

> 
> 
> Many thanks in advance for kindly considering my questions.

[RR>] Great questions.  Thanks for asking! They essentially made me
transcribe what I said during the meeting, with a few additions (:^)) and
that's probably a good thing!

Cheers,

RR
> 
> Cheers,
> 
> Marc
> 
> 
> --------------------------------------------------------------------------
> ---------------
> Marc Emmelmann
> e-mail:  emmelmann@xxxxxxxx  web:  http://www.emmelmann.org
> 
> IEEE 802.11 TGai Vice-Chair
> 
> Google Scholar: http://scholar.google.de/citations?user=_EfkmxcAAAAJ
> 
> 
> 

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