stds-802-16: Re: [802SEC] 802.18 document for 5 day EC pre-filing review
On September 17, Carl Stevenson notified the 802 EC
<http://ieee802.org/secmail/msg04318.html> of his intent to submit
802.18's 5 GHz reply comments to the FCC. Since then, changes to the
document have been suggested on the 802.16 reflector by Marianna
Goldhammer and Gordon Antonello (see the 802.16 email reflector
archives of 16 Sept
<http://ieee802.org/16/arc/802-16list2/thrd1.html>).
I'd like to outline the procedures on the issue, along with a summary
of my current views.
In accordance with Procedure 4 of the 802 Policies and Procedures,
the 802.18 TAG can submit the statement unless an EC member files a
"motion to block" within five-day review period (i.e., by 22 Sept at
6:38 am US ET). There is no procedure for the 802.16 Working Group to
decide to make this motion, so I have to decide myself (with Working
Group input).
Note that a motion to block would kill the submission. That's because
there is no time for a EC ballot before the FCC deadline of 23
September.
It is barely possible that 802.18 could amend the document and still
get it in by the deadline. However, that's very unlikely. As I
understand, the FCC deadline is about five days and eight hours from
now. The 802.18 TAG is meeting in Singapore, where it is currently
about 4 am. Another factor is that 802.11 and 802.15 have already
voted to approve the document under EC review.
If there were time to review the draft, I think we might be able to
make some improvements. I think it is clear that 802.16 was not
represented in the discussions, but we can't blame this on 802.18.
[We can discuss some procedural improvements for the future.]
I'd also like to express my opinion on the changes proposed by
Marianna and Gordon:
*I think that it would be very difficult to win 802.18 approval for
many of the requested changes.
*I think that much of the proposed text is inappropriate for reply
comments, since it's not clear to what we would be replying.
*I think that much of the proposed text is out of the scope of the NPRM.
*I think that key points on this topic were made forcefully in
previous comments, such as those of the License-Exempt Alliance (LEA)
<http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514784221>.
Here are some key aspects of the LEA paper:
-It is 802.16-friendly. It says "Recent developments in the
standards-setting process will only accelerate last mile broadband
deployments over license-exempt spectrum. By now the Commission is
aware of the recently-adopted IEEE 802.16a standard, which will
support delivery of outdoor broadband service over license-exempt
spectrum at distances up to 30 miles, with a typical cell radius of
4-6 miles." It continues with more positive comments on 802.16.
-It says "The LEA is troubled by the Commission's apparent assumption
that the 100 MHz at 5.725-5.825 MHz is adequate for higher power
outdoor operations (i.e., more than 1 watt), and that outdoor
providers in that spectrum can make do with what they have. As shown
below, this assumption is factually erroneous and, more important, is
at odds with the Commission's recent emphasis on finding more
spectrum for license-exempt operations and permitting license-exempt
operators to use higher power. The LEA is hopeful that the
Commission's statements on these issues in the NPRM are an
aberration, and urges the Commission to remain charted on its prior
course of regulatory reform targeted at optimizing the benefits of
last-mile license-exempt service."
If I were in the room during this discussion of the 802.18 document,
I would focus on amending it to provide reply comments in support of
the LEA's view, as expressed in the last quote above.
Roger
>Dear EC Colleagues,
>
>As one who fastidiously cleans out my "sent items," I just
>want to be certain that I sent the attached document.
>(I *think* I did, but want to be sure, so please excuse me
>if this is a duplicate.)
>
>The attached document was approved in accordance with
>LMSC TAG provisions in Procedure 4 by 802.18, as well
>as by 802.11, and 802.15.
>
>(802.16 is meeting elsewhere, and 802.20 does not have
>a quorum at the Singapore interim, so they are unable to
>take any "legal" actions.)
>
>The closing of the review period will be midnight (at the
>end of the day) on Monday, Sept. 22 and the filing deadline
>is Tuesday, Sept. 23.
>
>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