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Please find below some propose text to consider for inclusion into the 802 response in reply to the following sections:
NPRM Item I-2
In the NPRM: Section 24, in the Federal Register, #11
In the Federal Register, #16
Thanks,
Dorothy
==================================
NPRM Item I-2
IEEE 802 is somewhat in agreement with the observation by the Commission (II-4) that “the DSRC service has evolved slowly and has not been widely deployed within the consumer automobile market (it has found use in certain specialized, traffic-related projects)”
DSRC is a communications technology that has been and continues to be optimized to allow the provisioning of a large number of ITS-related services including safety-of-life and property in the 5.850-5.925GHz ITS band. While deployments have been slow to materialize for a variety of market-driven reasons, there are nonetheless today a significant number of deployments in the US with tens of thousands of vehicular units and thousands of infrastructure units in operation preventing accidents and saving lives.
IEEE 802 believes that DSRC technology has indeed been proven and productized. DSRC technology including the Link Layer protocol component was standardized in IEEE Std 802.11-2010 (now IEEE Std-802.11-2016 Annex D2 and D5) and products implementing the DSRC technology have been in the market for purchase from multiple vendors for over 10 years.
Furthermore, the protocol specified in IEEE Std 802.11-2010
was designed specifically for the technical characteristics of V2V/V2I
applications (peer-to-peer operation, dynamically changing network topologies,
support for both unicast and broadcast operation, use of a common 802.11
preamble to enable straightforward evolution and backwards compatibility). This
technology has been shown to work as designed in hundreds of demonstrations,
trials and numerous deployments globally [need references … the corridor
project in Europe, the CV Pilots in Tampa, New York, Wyoming, and Columbus,
Safety Pilot project in MI, CVIS in Europe].
A summary of the completed and ongoing relevant standards development and
product availability milestones is listed below:
Milestones in DSRC Link Layer IEEE Std 802.11p-2010 standard and product development
2003 FCC licensing and service rules for DSRC operations in 2003
2006 Initial IEEE 802.11 WG draft of P802.11p MAC/PHY amendment available, implementation begins: April 2006
2008 Initial IEEE P802.11p hardware available
2010 IEEE Std 802.11p amendment publication: July 2010
2008 – 2020 IEEE Std 802.11p Chipset/system products available for purchase from multiple vendors globally
2018 IEEE 802.11bd project approved, re: Enhancements for Next Generation V2X: December 2018
IEEE 802 believes that the slow adoption of the DSRC technology is due to factors other than the link layer specified in IEEE 802.11. The existing defined link layer is optimized for ITS applications, robust, proven, tested and deployed. Protocol extensions to and evolution of the 802.11p-based link layer are under development, adding capabilities of the very widely adopted IEEE Std 802.11n and IEEE Std 802.11ac standards to the DSRC PHY. Based on the current status of developments and deployments, IEEE 802 believe all of the 5.9GHz spectrum allocated to ITS services should remain allocated to the implemented, tested and proven DSRC technology to ensure a seamless, non-disruptive path forward with existing products and chipsets.
Critically, IEEE 802 observes that applications and benefits of any 4G/5G Vehicle to Network (V2N) applications using existing LTE or 5G carrier frequencies can be achieved with the allocation of the proposed 30 MHz V2V and initial MAC/PHY link of V2I communications to the IEEE 802.11 DSRC link layer. The SCOOP project with a fleet of 3000 vehicles demonstrated that cellular 4G connectivity for V2N can be successfully and efficiently combined with DSRC for V2V [6].
IEEE 802 additionally observes that the automotive industry suffered a near collapse of many companies in the 2008-2010 time frame, with mergers and government bailouts required for some companies (globally) to remain solvent. To have expected automotive manufacturers and industry players to commit to deploying any new communications technology (regardless of the specific MAC/PHY link layer being used) that did not have a clear, immediate cost/benefit in the years following does not take into account the extant market realities. The fact that hundreds of successful DSRC trials and demonstrations have occurred since then, followed by deployments of ITS applications that have cost/benefit justification is actually a very positive development.
In the NPRM: Section 24, in the Federal Register, #11
11. C–V2X in the 5.905–5.925 GHz band. The Commission proposes to authorize C–V2X operations in the upper 20 megahertz of the 5.9 GHz band (5.905–5.925 GHz) as a means of authorizing the ITS technology that is most capable of ensuring the rapid development and deployment of continually improving transportation and vehicular safety-related applications now and into the future, that is robust, secure, and spectrally efficient, and that is able to integrate spectrum resources from other bands as part of its transportation and vehicular safety-related system. The Commission seeks specific and detailed comment on this proposal and views.
IEEE 802.11p-2010 (updated reference is IEEE 802.11-2016 Annex D2 and D5) has been demonstrated to be the ITS communications technology that is most capable of ensuring the rapid development and deployment of continually improving transportation and vehicular safety-related applications now and into the future. It has been demonstrated to be robust, secure, and spectrally efficient in the 5.9GHz band, and is just as robust, secure and spectrally efficient in all other frequency bands if and when they become part of the ITS communications infrastructure for transportation and vehicular safety-related services.
a) Products implementing IEEE 802.11p-2010 (updated reference is IEEE 802.11-2016 Annex D2 and D5) exist today in the market and are available from many vendors, with multiple chipset suppliers.
b) Products implementing IEEE 802.11p-2010 (updated reference is IEEE 802.11-2016 Annex D2 and D5) have been deployed in hundreds of trials, demonstration projects, and more recently pilot deployments.
c) Existing products and deployments implement ITS services in the existing allocated 75MHz of spectrum. Any change in the current ITS frequency allocations will incur significant cost and will significantly reduce the benefits accruing in the systems already deployed. [ed. Add text about the modifications needed to move to 30 MHz … hopefully this works].
d) The IEEE 802.11p-2010 (updated reference is IEEE 802.11-2016 Annex D2 and D5) protocol has been demonstrated to be optimal, robust, and spectrally efficient for ITS deployments of safety-related services.
e) Security has been addressed by the IEEE Std 1609.2 set of standards, and several vendors have developed and deployed the necessary components of the necessary Security Credential Management System to secure DSRC and other communications in the ITS space.
IEEE 802 also notes that all vendors’ products that currently have DSRC communications technology incorporated also have at a minimum some form of cellular technology included as well. This use of multiple communications interfaces is not new; every smart phone in existence today has at least one IEEE 802.11 Wi-Fi and one cellular interface in addition to a GPS module and more than likely an IEEEE 802.15 Bluetooth interface. While current ITS deployments take optimal advantage of these means of communication for implementing value-added ITS services, they all use 5.9GHz DSRC technology for critical safety-related services, and IEEE 802 strongly recommends this be mandated going forward.
In the Federal Register, #16
The Commission asks that commenters supporting DSRC in the 10 megahertz of spectrum at 5.895–5.905 GHz discuss the benefits and costs of their preferred approach. The Commission also seeks comment on whether there is a more appropriate division of the upper 30-megahertz portion of the band at 5.895–5.925 GHz between C–V2X and DSRC.
IEEE 802 believes that 10MHz of spectrum is insufficient for achieving maximum benefit from deployment of ITS safety-related services. IEEE 802 notes that current deployments of DSRC technology have provisions such as congestion control for handling situations where there is a need for more resources than are currently available. This situation is likely to be exacerbated when personal devices (smart phones) include 5.9GHz DSRC technology and ITS safety-related services that prevent pedestrians and cyclists from becoming casualties are deployed. IEEE 802 believes that any and all spectrum reserved for ITS safety-related services be allocated to IEEE 802.11 technologies as those technologies have been proven to be optimal in ITS RF environments and continues to be deployed in the US and around the world. DSRC leverages ubiquitous IEEE 802.11 products in mass production for over a decade to provide life-saving benefits at costs consistent with those of 802.11 based products.
==========end======
----------------------
Dorothy Stanley
IEEE 802.11 WG Chair, dstanley@xxxxxxxx
Hewlett Packard Enterprise
dorothy.stanley@xxxxxxx
dstanley1389@xxxxxxxxx
+1 630-363-1389
--- This message came from the IEEE 802.11 Working Group Reflector ---hello all,
with the last couple of days to finish up the FCC NPRM 5.9GHz band comments, want to remind/share that for the tuesday ad hoc call at 3pm-et, here are the sections with questions in the current draft we would like to finalize.
• Ad hoc Tuesday 18th – 3pm–et-2hr
• Sections 4, 5.1, 6 and 7.4
• Do we remove OOBE?
• Need more contributions for 6.1 (for the compatibility/backward compatibility or will drop this point).
latest draft comments:
https://mentor.ieee.org/802.18/dcn/20/18-20-0020
(note: for the wednesday’s ad hoc, we will finalize questions in section 8, conclusion, references and final review)
any drop in edits ahead will really help with the call to cover all these sections and get them ready for approval.
thanks
Jay Holcomb
802.18
From: Jay Holcomb <jholcomb@xxxxxxxx>
Date: Sat, Feb 15, 2020 at 5:40 AM
Subject: tuesday call-in info for ad hoc on FCC 5.9GHz NPRM comment drafting and announcement for additional ad hoc call
To: STDS-802-18@xxxxxxxxxxxxxxxxx <stds-802-18@xxxxxxxxxxxxxxxxx>, STDS-802-11@xxxxxxxxxxxxxxxxx <stds-802-11@xxxxxxxxxxxxxxxxx>hello all,
here is the call-in information for the tuesday ad hoc. we will be using the IEEE 802 webex for the first time, fyi.
802.18 ad hoc 5.9GHz NPRM
Hosted by Seat4 802Webex
3:00 PM - 5:00 PM Tuesday, Feb18 2020 (UTC-05:00) Eastern Time (US & Canada)
Meeting Information
Meeting link:
https://ieee802.my.webex.com/ieee802.my/j.php?MTID=m4af3f33f89f37207218c57f704cc2ca0
Meeting number: 794 413 224
Password: RRTAG18
More ways to join
Join by phone
+1-510-338-9438 USA Toll
+44-20-3198-8144 UK Toll
Access code: 794 413 224
also, from the discussion in the call on friday (14th), will add one additional ad hoc call next Thursday morning, the 20th, from 10-12et (7-9pt). just in case it is needed. call-in info will be coming later and all call-ins are in the back of the ad hoc agendas e.g. https://mentor.ieee.org/802.18/dcn/20/18-20-0021.
this is a few hours before the RR-TAGs weekly teleconference at 3pm-et, where we are targeting to vote on the comments.
we are making progress, thank you.
Jay Holcomb
802.18
latest draft comments: https://mentor.ieee.org/802.18/dcn/20/18-20-0020
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