RE: stds-802-16: 802.18 draft: Reply Comments on 5 GHz NPRM
Marianna, all,
I am concerned that we are risking our general credit with the FCC by
asking for more power as per the changes below.
What we really want is more spectrum - above the 5.9 band. More power
at the lower 5.5 band is a second best solution because it leads to
interference between RLAN and MANs and that does not help any body.
Even more important: the DoD/NTIA and industry spent a lot of time and
energy on hammering out a compromise for the sharing of the 5 GHz band.
A request for more power would but a bomb under that hard won compromise
and no-one can predict the consequences. Note that the compromise is a
political one - no amount of technical data will change that.
Therefore, we, the IEEE, are asking the FCC for something we are not
likely to get and that we do not want if we can get something else.
This is not a good way to work with the FCC - we run the risk of
becoming seen as just another narrow minded interest group instead of a
respected partner. We should cultivate our long term position and
therefore I suggest that the language below be removed from the .18
replies.
Jan Kruys
Standards and Regulations, EMEA
Cisco Systems
jkruys@cisco.com
desk: + 31 20 357 2447
gsm: + 31 6 518 434 93
-----Original Message-----
From: Marianna Goldhammer [mailto:marianna.goldhammer@alvarion.com]
Sent: 18 September 2003 00:30
To: Roger B. Marks
Cc: Ley John-QSTO04 (E-mail); Carl R Stevenson (Carl) (E-mail);
stds-802-16@ieee.org
Subject: RE: stds-802-16: 802.18 draft: Reply Comments on 5 GHz NPRM
Roger, ALL,
I did the following modifications to the 802.18 document:
- delete all the text related to the rejection of high power
transmission
- insert the following new text:
"We have the understanding of the Wireless ISP importance for US Rural
Internet Access and also we have the understanding that 5GHz spectrum,
in rural areas, will be almost not used by residential users, if no
broadband Internet connection will be provided.
The existing WRC-03 agreement has been based on co-existence studies
for scenarios that are not specific for Rural areas, considering, as an
example, very high user density on square mile. These scenarios have
not taken into account the possibility of using sectored antennae and
antenna tilt on Base Stations, or other mitigation techniques.
We consider that new sharing studies should be done, both by FCC and
ITU-R, in order to verify the possibility of increasing the EIRP
levels, for Rural ISP applications.
If, due to different reasons, it will not be possible to allow increased
power, we suggest considering the possibility of finding spectrum
suitable for these applications."
The modified file is up-loaded (consider rev 2). Maybe editorials are
still needed. I hope that this text is acceptable for 802.11 and 802.15
as well.
Regards,
Marianna
-----Original Message-----
From: Roger B. Marks [mailto:r.b.marks@ieee.org]
Sent: Wednesday, September 17, 2003 8:51 PM
To: Marianna Goldhammer
Cc: Ley John-QSTO04 (E-mail); Carl R Stevenson (Carl) (E-mail);
stds-802-16@ieee.org
Subject: RE: stds-802-16: 802.18 draft: Reply Comments on 5 GHz NPRM
Marianna,
The cited material from the July 802 Plenary was indeed filed with
FCC. See Page 7 of the filing:
http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_d
ocum
ent=6514784167
The language is also in the draft on the 802.18 web site. I agree
that 802.18 should post the submitted version too. {Better yet, they
should just include a link to the version on the FCC page.}
What 802.18 prepared this week is not a revision of 802's earlier
comments. It is, instead, a set of reply comments; in other words,
comments on other filed comments. Perhaps 802.18 included no reply
comments on this topic because no contradictory comments on 5725-5825
MHz were filed.
Regards,
Roger
At 9:12 PM +0200 03/09/17, Marianna Goldhammer wrote:
>I paste here the text that was in the July document:
>
>19. While we fully realize that the power limits for the 5150-5350
> and 5470-5725 MHz bands have been set by recent changes to the
> ITU Radio Regulations, and furthermore that the subject of additional
> "high power" spectrum in the 5 GHz region is beyond the scope of the
> instant NPRM, we are not convinced that the Commission's
> expectation as stated above is necessarily correct.
>
>20. The 5725-5825MHz U-NII "high-power" band is currently used
> by WLANs (IEEE 802.11a), point to point systems, point to multipoint
> WAN/local broadband wireless access systems (IEEE 802.16 and
> other systems), and numerous other Part 15 systems, including
> cordless phones. We therefore have a general concern that the
> Commission's expectation that the 100 MHz of the 5725-5825 MHz
> band will remain sufficient for higher power operations may not be
> realistic, particularly if the band is used by more than one public
> access or public service operator in the same geographic area.
>
>Marianna
>
>-----Original Message-----
>From: Marianna Goldhammer
>Sent: Wednesday, September 17, 2003 2:23 PM
>To: 'Roger B. Marks'; stds-802-16@ieee.org
>Cc: Ley John-QSTO04 (E-mail); Carl R Stevenson (Carl) (E-mail)
>Subject: RE: stds-802-16: 802.18 draft: Reply Comments on 5 GHz NPRM
>
>
>Hi,
>
>I recommend to "NOT APPROVE" the proposed text.
>
>5 GHz NPRM, pct. 18, is asking for comments regarding the
> spectrum for high power operations:
>
>" 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 July 802.18 meeting, at my and Ley John's request, the 802.18 agreed
> response was to make clear that this spectrum is not enough
>(appropriate
> text was in the document; as result of my satisfaction I supported
the
> document approval, as seconder).
>
>The mentioned response shall be re-inserted.
>
>I request that 802.18 input documents are posted on the Server,
> (my July input document is not on the 802.18 contribution list, but
> has been discussed) and the outputs as well, according to
> IEEE 802 rules. July output is also not available on 802.18 Server
>(wrong link).
>
>
>Best Regards,
>
>Marianna
>
>
>
>-----Original Message-----
>From: Roger B. Marks [mailto:r.b.marks@ieee.org]
>Sent: Wednesday, September 17, 2003 1:31 AM
>To: stds-802-16@ieee.org
>Subject: stds-802-16: 802.18 draft: Reply Comments on 5 GHz NPRM
>
>
>As noted below, the 802.18 TAG is considering a submission to the FCC
>and has sent it to the 802.11 and 802.15 plenaries in Singapore for
>review.
>
>Carl has uploaded the draft for our review. See the document beginning
>"18-03-0061" at <http://wg.wirelessman.org>.
>
>Let me know if you have comments.
>
>Roger
>
>
>>Dear folks,
>>
>>Please note that document
>>18-03-0061-00-0000_802_18_Rep_Cmts_ET-03-122.doc
> >is on the server in the 802.18 documents section.
>>
>>This document was approved this afternoon by 802.18, and I intend to
>>bring WG approval motions to the .11 and .15 mid-week plenaries on
>>Wed.
>>
>>Your attention to this matter would be appreciated.
>>
>>Regards,
>>Carl R. Stevenson
>>Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group
>>610-965-8799 (home office) 610-712-3217 (fax mailbox)
>>610-570-6168 (cellphone)
>>Short Message Service: 6105706168@voicestream.net
>>carl.stevenson@ieee.org
>
>
>This mail passed through mail.alvarion.com
>
>***********************************************************************
>****
*
>********
>This footnote confirms that this email message has been scanned by
>PineApp Mail-SeCure for the presence of malicious code, vandals &
>computer viruses.
>***********************************************************************
>****
*
>********
>This mail was sent via mail.alvarion.com
>
>***********************************************************************
>****
*********
>This footnote confirms that this email message has been scanned by
>PineApp Mail-SeCure for the presence of malicious code, vandals &
>computer viruses.
>***********************************************************************
>****
*********
This mail passed through mail.alvarion.com
************************************************************************
****
********
This footnote confirms that this email message has been scanned by
PineApp Mail-SeCure for the presence of malicious code, vandals &
computer viruses.
************************************************************************
****
********
This mail was sent via mail.alvarion.com
************************************************************************
************
This footnote confirms that this email message has been scanned by
PineApp Mail-SeCure for the presence of malicious code, vandals &
computer viruses.
************************************************************************
************