stds-802-16: Urgent: filling with FCC for 5GHz NPRM - by Sept. 3
Folks,
FCC has an NPRM open process (ET Docket No. 03-122 ), to close
tomorrow, regarding the supplementary allocation 255MHz in 5GHz.
We should support this allocation and to address the pct. 18, that is
802.16 specific:
"Consistent with the agreements cited earlier, we propose to add the
5.470-5.725 GHz band to the U-NII bands with the same technical
requirements that apply to the existing 5.250-5.350 GHz U-NII sub-band.
This is consistent with the WECA petition and the U.S. position for
the upcoming WRC-03. The Federal Government believes that the
power must be limited to 1 watt e.i.r.p. to protect incumbent systems.
We also believe that this will best provide for communications among
devices within and among buildings where demand is greatest. We
expect that the 100 MHz of spectrum that is already available at
5.725-5.825 GHz will remain sufficient for higher power operations.
We note in particular that operations over longer distances employ
directional antennas that allow for high reuse and sharing of the
spectrum, which mitigates the need for additional spectrum for these
types of operations. We seek comment on this analysis."
In my view, 802.16 companies should support Wi-Fi and fill the
following points, with special attention to pct. 18 answer. Below are
directions, please use your own wording:
- allocation of additional 255 MHz of internationally harmonized
spectrum should be encouraged and expedited;
- the new spectrum should be reserved for "broadband" digital
technology and not narrowband uses;
- Dynamic Frequency Selection (DFS), with radar detection, is an
acceptable method to protect incumbent users;
- DFS algorithm should be aligned with ETSI
- DFS should only be required for central controller devices, not for
units under control of the central controller;
- Regarding pct. 18 in ET Docket No. 03-122, we should answer
that 100MHz are not enough, based on using this band for sectorized
Base Stations and their feeding, by at least 2 operators in the same
area and using one channel as guard band). The 5.8GHz band is also
occupied by different ISM devices, as cordless phones, creating
un-controlled interference.
The comment filling (Wi-Fi instructions):
1. Go this web site: http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
2. For the field 1 "Proceeding", enter "03-122" and tab to the next field
(do not use the "enter" button, but use "tab" to move through the fields)
3. Tab to field 3 and fill in the company name for "Applicant/Petitioner"
4. Tab to field 7, 8, 9 and 10 and fill in the company address.
5. Leave the remaining fields as the default and scroll to the section
labeled: "Send Comment Files to the FCC (Attachments)"
6. In the field labeled "File:"; use the "Browse" tab to locate the file
you wish to upload to the FCC (the FCC will accept PDF, Word and
WordPerfect files)
7. Once the file is selected and entered into the "File" field, tab to
the field labeled "Select one of these file types or convert your file to
one of these types:" and choose the type of file to be uploaded; you
can also submit simple comments - see pct. 12
8. Look back over everything entered, to be sure that you are ready to
submit the filing to the FCC
9. Next select the tab labeled "Send Attached File to the FCC"
10. A prompt will come up asking if you want to attach any additional
filings or attachments, choose the first tab "Finish Transaction and
Receive Confirmation"
11. After selecting this tab, the FCC will respond with a web HTML
confirmation page that can either be saved or printed. Keep this
confirmation page in case anything does not upload properly.
12. You have the "Brief Comment" option, that allows you to send
actually long texts.
Marianna
Marianna Goldhammer
Director - Strategic Technologies
Alvarion, Ltd.
10 years of wireless expertise
21 HaBarzel Street
P.O.Box 13139, Tel Aviv 61131, Israel
Tel: (972)- 3 -6456241/6262
Fax: (972) -3 -6456204
Email: marianna.goldhammer@alvarion.com
www.alvarion.com
This mail was sent via mail.alvarion.com
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