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Re: [STDS-802-16] Fwd: 802.22 Letter to the WPC for 470 - 698 MHz Operation (India)

The success of wireless standards and use of spectrum require a number of coincidental factors: Volume mechanism(s) for adoption.  Low barriers of entry ie. IPR as needed to achieve low cost and wide adoption. Efficient use of spectrum.  Development of an enabling IC/SOC, RFIC supply chain. Access to capital which is largely determined by achieving the other factors. Interworking with other standards. Interoperability within and between incorporated standards.  And others.

A common goal of regulators is to promote efficient use of spectrum.  Another goal is to become more agnostic and flexible in policies in order to take advantage of progress and promote innovation. Meanwhile, regulators, operators, suppliers, advocacy groups and other vested interests must remain cognizant of the need to harness existing streams of commercial momentum and harmonization among standards.  The rationalization of these sometimes disparate means is to achieve optimal evolution of technology and harnessing of capital and human resources.

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A problem is created by the competition between standards groups and sub-groups.  Competition and realms of authority between IEEE, 3GPP, 802.16, 802.11, 802.22 etc. create a dynamic tension that is eventually thrashed out in the marketplace if not in the standards process.

The generally IEEE promotes fair and open access to technology and choice of standards. Thus it seems very appropriate to be agnostic in this instance.

It also seems to me to seek common ground to promote effective means for adoption of IEEE standards, specifically license-exempt use of 802.16, 802.11, 802.22 in relative harmony.

The competition between standards groups comes up in how 3GPP positions as a furtherance of UMTS/GSM preponderance of adoption.  From recent 3GPP announcement of IMT-Advanced acceptance:

"the 3GPP technology family supports the evolving and expanding needs of the broad international base of mobile operators and allows the users of wireless mobile broadband to experience, on a global basis, a rich and innovative range of service and capabilities that is unparalleled by any other technology."

The question might be legitimately asked, "Given that the 3GPP standards have been widely adopted then why is an alternative or complimentary set of standards needed?"

A counter argument as to why alternative standards work out to be beneficial is that 802.11 which has become incorporated out of necessity delivers higher bandwidth per unit of spectrum and area and per cost basis than has been achieved in a the body of mobile standards.

Without getting into a dissertation about tendencies for coalescence of IPR and commerce into the hands of the few, it can be simply stated that IEEE provides alternative standards that benefit open competition and diverse participation in creation and adoption of evolving communications technologies that has proven valuable to society.

A suggested way to express that in the current situation is exampled by the impact of 802.11 and 802.16. I'll use 802.11 since it applies directly to license exempt and provides a strong example:
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IEEE 802.11 (Wi-Fi) has been widely adopted due to its ability to be deplored at low cost in small coverage areas  by end users. Owing to its rapid 'viral' adoption in international license exempt spectrum, Wi-Fi has been taken advantage by incorporation into most 3GPP based 3G mobile phones and other devices. Furthermore, Wi-Fi is now depended upon to help average achieve the high bandwidth rates demanded by the market as use of web-enabled devices capable of file transfers and video stress the capacity of wide area mobile networks.

Recent studies by the US FCC and others show that while operating in limited available spectra, Wi-Fi has achieved 3X-5X the spectral utilization per unit area, per unit time, compared to operation of licensed networks.

It is appropriate for regulators to consider the impact of license exempt spectrum allocation in context of its ability to be used in conjunction with existing and new allocations of licensed spectrum as this has demonstrated significant benefits in current commercial deployments.
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Furthermore, where spectrum allocation is contested between licensed and license-exempt and conditions deemed  favorable, consideration should be given to dual-MAC pairing of licensed and license-exempt allocation for the purpose of promoting capitalized deployments and development of common supply ecosystem.  For example, if sufficiently broad spectrum is available, such as over 60 MHz in a contiguous or nearby sub-bands, a consideration should be given to allocation of a portion for licensed and a portion for license-exempt.  Consideration should be given to requirements that devices that operate in licensed spectrum must also operate in license-exempt.

The appropriateness of use of divisional standard 802.1x or other standards should be determined through the standards groups with an eye towards harnessing of both the flow of technology and commercial momentum and benefits.
Robert Syputa
 206-367-6931


On Thu, Feb 10, 2011 at 3:39 AM, zhengyanxiu <zhengyanxiu@itri.org.tw> wrote:

Dear all,

 

I would share further consideration on unlicensed band usage model.

In fact, if there is geographical information regarding spectrum usage, all technologies could be used even for current 16e. This has happened in some application relating to environmental surveillance system.

 

When we consider the coverage of unlicensed band , it could also be large as WAN/RAN or be small as PAN/LAN similar as WLAN and Bluetooth in ISM band. If there is geographical information, I guess all 802 wireless technologies are applicable.

 

Another point is the price. The main difference between unlicensed and licensed band is price. The unlicensed band is more cheap than licensed band. In India, we may more agree price first if the Letter is to India administration. If the price of com requires 100USD, I guess there is still no market in India. By the way, collisions has high probability occurring in the unlicensed band like WLAN and Bluetooth. The spectrum efficiency would be much poor. High price with poor performance is hard to attract end users. End users may still consider WiFi, low price with acceptable performance.

 

I would support to escalate from IEEE 802.22 to IEEE 802 level. In my point of view, some combination of IEEE 802 technologies can support.

 

Further comment to PAR of 1900.7, a good strategy for P1900 is to reuse existing PHY and MAC instead of new PHY and MAC especially when WiFi only costs couple dollars. Leveraging existing specification or market proven technology would be more helpful for the success of P1900 or DySPAN. Even P1900.7 have a specific PHY and MAC, without chip vendor, the future of this standard is  still doubtable.

 

Best regards,

 

Zheng Yan-Xiu

 

 

From: Kiernan, Brian G [mailto:Brian.Kiernan@INTERDIGITAL.COM]
Sent: Thursday, February 10, 2011 4:11 AM


To: STDS-802-16@LISTSERV.IEEE.ORG
Subject: Re: [STDS-802-16] Fwd: 802.22 Letter to the WPC for 470 - 698 MHz Operation (India)

 

Mike,

 

I’m glad to hear that, as it fits directly with my main premise, that the spectrum not be technology specific.  I assume the letter has been modified appropriately to remove the 802.22 references.

 

Brian

 

From: Mike Lynch [mailto:freqmgr@SBCGLOBAL.NET]
Sent: Wednesday, February 09, 2011 12:59 PM
To: STDS-802-16@LISTSERV.IEEE.ORG
Subject: Re: [STDS-802-16] Fwd: 802.22 Letter to the WPC for 470 - 698 MHz Operation (India)

 

Brian and Reza,

 

Based on the discussion on yesterday’s conference call the letter is to lobby for more technology neutral spectrum and not touch on the licensed or unlicensed use. Administrations will implement these bands as they feel is best for their requirements.

 

While many 802 technologies are used in an unlicensed mode that is not always the case. For example in some administrations the use of 802.11 in the 2.4 GHz band requires users to have a license. So it doesn’t seem useful to label some 802 technologies as “unlicensed” only as that may imply that they should not be permitted where an administration require users to obtain a license.

 

Regards,

 

Mike

 

From: Arefi, Reza [mailto:reza.arefi@INTEL.COM]
Sent: Wednesday, February 09, 2011 11:11
To: STDS-802-16@LISTSERV.IEEE.ORG
Subject: Re: [STDS-802-16] Fwd: 802.22 Letter to the WPC for 470 - 698 MHz Operation (India)

 

I support Brian’s comment below.

 

Regards,

Reza

 

From: Kiernan, Brian G [mailto:Brian.Kiernan@INTERDIGITAL.COM]
Sent: Wednesday, February 09, 2011 11:58 AM
To: STDS-802-16@LISTSERV.IEEE.ORG
Subject: Re: [STDS-802-16] Fwd: 802.22 Letter to the WPC for 470 - 698 MHz Operation (India)

 

If the intent of the letter is to lobby for  unlicensed operation in that frequency band (TV White Spaces), then it should NOT be limited to just 802.22, but should encompass any 802 unlicensed technology aimed at that spectrum to include 802.11af, 802.19, or even 802.16h.  From both a market and regulatory perspective, making a band technology specific is too limiting and is counter to the direction of where the industry (and most regulators) are heading.  The EC should change any references to “802.22” to something like “IEEE 802 unlicensed technologies”.

 

Brian

 

From: Roger B. Marks [mailto:r.b.marks@ieee.org]
Sent: Wednesday, February 09, 2011 3:37 AM
To: STDS-802-16@LISTSERV.IEEE.ORG
Subject: [STDS-802-16] Fwd: 802.22 Letter to the WPC for 470 - 698 MHz Operation (India)

 

Please let me know if you have any comments on this letter.

 

Roger

 

 

Begin forwarded message:

 

From: "Mody, Apurva (US SSA)" <apurva.mody@baesystems.com>

Date: 8 February 2011 10:26:34 PM PST

To: "Roger B. Marks" <r.b.marks@ieee.org>

Cc: "MJLynch@mjlallc.com" <MJLynch@mjlallc.com>, John Notor <gnu@notor.com>, Gerald Chouinard <gerald.chouinard@crc.ca>, Winston Caldwell <Winston.Caldwell@fox.com>

Subject: 802.22 Letter to the WPC for 470 - 698 MHz Operation (India)

 

 

Hi Roger,

 

The 802.22 Working Group would like to submit the following letter

to the Wireless Planning and Co-ordination (WPC) Advisor in India through Indian Institute of Technology (IIT) Bombay. This letter was discussed during the 802.18 telecon held on Tuesday, Feb. 8th.

 

We (802.22) would like to endorse the IIT Bombay proposal for license-exempt use in the 470 – 698 MHz spectrum in India. IITs are the premier Engineering institutes in India. IIT academics are very well respected all around the world and they have been known to work closely with the Indian Govt. in the advisory role. The IIT-Bombay proposal has been attached for your reference.

 

Please review the letter and let us know your comments if any by Monday, Feb. 14th COB.

 

Many thanks

 

Apurva

 

Apurva N. Mody, Ph. D.

 

Chair, IEEE 802.22 Standard Working Group

BAE Systems

Technology Solutions

130 Daniel Webster Highway, Mail Stop 2350

Merrimack, NH 03054

Work: (603)885 2621, Mobile: (603)-809-0459

 

 

 

 

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