[STDS-802-11] Fwd: [STDS-802-18] FCC NPRM reply comments suggestion

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fyi for today's adhocc,

jay holcomb

802.18

---------- Forwarded message ---------
From: Sebastian Schiessl <sebastian.schiessl9@xxxxxxxxx>
Date: Fri, Apr 3, 2020 at 10:38 AM
Subject: Re: [STDS-802-18] FCC NPRM reply comments suggestion
To: <STDS-802-18@xxxxxxxxxxxxxxxxx>

Dear all,

this is a proposed update on the new reply comments document 18-20-0057-00 on the FCC NPRM on 5.9 GHz.

Changes:

Merged the edits suggested by Joseph Levy
Clarified the section on cellular connectivity
Added a new section on non-periodic and variable-size messages (This section was already discussed in a previous ad-hoc session)

Looking forward to the ad-hoc call.

Best Wishes

Sebastian Schiessl (u-blox)

On Tue, 31 Mar 2020 at 18:13, Sebastian Schiessl <sebastian.schiessl9@xxxxxxxxx> wrote:

Dear all,

I have the following suggestions to further edit the reply comments document. I think the document is good as it is, but I had already written some additional remarks, and I wanted to put them in. I believe we can use the extended time to strengthen our comments further.
Main points
DSRC it not worse than LTE V2X simply because it is older. The physical layer performance is similar due to the use of similar basic technology.
Make a point that against LTE V2X by pointing out that it is worse than 5G NR V2X or IEEE 802.11bd, as it supports neither 256 QAM nor MIMO. Since 5G NR V2X is years from deployment and there is no same-channel evolution defined, I believe this is a safe statement.
Make a stronger point against a technology-neutral approach (US DOT comments).
Interoperability is crucially required for (traffic) safety. Example: disasters due to incompatible fire hoses.
Nevertheless, if two non-interoperable technologies are still allowed, they require at least co-existence, which LTE V2X cannot provide.
Why make this point? If DSRC deployments need to be re-channelized and experience harmful, uncoordinated interference from LTE V2X in crowded channels, they are likely to become useless. The Commission should at least be forced to acknowledge this loss of massive tax-payer funded investments when making a decision against DSRC, instead of being able to falsely claim that those deployments can still be used in a shared channel without limitations.
Looking forward to any comments or suggested changes in today's ad-hoc!
/Sebastian

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Regards,
Jay Holcomb
IEEE 802.18
Itron, Liberty Lake (Spokane), WA

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