RE: stds-802-16-tg4: draft letter to ETSI BRAN
Thanx Roger,
I'm satisfied with your editorial revisions though a stronger
statement would certainly have been on the wish list. Let's hope
this version does the job anyway!
Then some clarification to Heinz' comments:
> 1. We want to be able to use FDD mode to take advantage
> of chipsets available today. This also allows us to
> use both the
> upper and middle UNII bands today.
With current US-regulations this works, unfortunately Europe will
not adopt the US-regulations as they are. In fact it looks more
probable that FCC will adopt the European view (which obviously
isn't in our interests).
> 2. We want to keep the ability to use the middle (5.25) band for
> FWA (fixed wireless access) applications in the USA.
> The use of
> another band, say
> 5.46 to 5.57, for FWA applications in the USA would
> also be OK
> instead, in the future.
The letter to ETSI has impact only on ETSI related stuff and thus indirectly
to regulators considering ETSI proposals (European ones). I can't recall FCC
taking ETSI very seriously compared to domestic groups. Thus the ETSI stand
will
not have any major impact on the US situation (if any at all).
> 3. We would like to be able to use the middle UNII band
> (5.25) in Europe
> as well for FWA applications. The use of part or all
> of another
> band, say 5.47 to 5.725, would also be OK instead.
This is the tricky part people not involved in BRAN or European regulations
don't understand. The WLAN people (HIPERLAN2) had very hard times achieving
the secondary allocation on bands A (5.15-5.35) and B (5.47-5.725). On band
A only low-power indoor operation is allowed based on the sharing studies
with
the primary users. I doubt FWA can show better sharing capabilities with
satellite
services than indoor WLAN!
Band B can't be split into blocks since the primary users (mainly radar)
already
now require WLAN equipment to be able to do DFS over 330MHz. This means in
practice
that a WLAN device must incorporate both bands A and B. Many of the radar
are
military and the national regulators won't even consider a rule change here
(national security you know...).
HIPERLAN2 tried to get also band C but they failed in the sharing studies.
We
(Nokia) did a similar study with mesh FWA devices (included in the
submission
that was approved in Annex A.2 in Denver) and showed that sharing might be
feasible.
Thus band C wouldn't create any conflict with HIPERLAN2.
Why is this so important? In Europe regulators are really slow or unwilling
to
move unless they get a clear message from ETSI. This on the other hand
requires
that there is an ETSI Work Item that creates a technical report. In FWA's
case
this particular work item falls under BRAN. To approve such an item you need
qualified majority in BRAN. If one already in the early beginning steps on
the
toes of HIPERLAN2 (that is exactly how these people see it once you talk
about
the same spectrum) then the HIPERLAN2 community will stop your effort.
Thus the strategy is clear. Instead of going for the whole cake (and with
100%
probability loosing it all) it is better to grab the piece easiest to pick.
Even this piece is going to be hard to catch, but the effort isn't doomed
from the
early beginning. This is the simple reason of talking only about band C
until
that is got. Once we have unlicensed FWA spectrum in Europe, then we can go
for
more (like band B)...
> 4. We want clarification from ETSI that the use of FWA devices
> would come under ETSI's definition of nomadic devices.
ETSI doesn't do this kind of rating. It's up to every national body to
decide whether FWA goes under ITU-R term nomadic. ITU-R defines the term in
a way that FWA devices easily can be considered nomadic.
BR
Jori