Dear Roger,
Thank you for all your suggestions (below) to improve the letter related to the: Endorsement of the proposal submitted by TICET, IIT Bombay towards the ongoing NFAP revision / review process in India for the 470 – 698 MHz band.
We also received comments from Brian Kiernan (InterDigital), Reza Arefi (Intel) and Peter Ecclesine (Cisco Systems). We have tried to incorporate the suggested changes in this new letter which I hope will satisfy you.
The updated letter can be found at:
We do plan to discuss this letter during tomorrow’ s 802.18 telecon to be held at 2.00 p.m. E. T. Instructions to join the telecon can be found below:
Although, our original intent was to create an IEEE 802 position in regards to the NFAP revision / review process in India, not all the Working Groups agreed to go through IIT Bombay. The IEEE 802.22 Working Group, through a motion decided to endorse the proposal submitted by the TICET, IIT Bombay. So this letter is specifically the IEEE 802.22 Working Group position.
If any other group wants to add more content about your standards in this letter, we have no objection to that. We are happy to receive any further comments to improve the quality of the letter and make it more relevant.
Warm regards
Apurva
Friday, Feb. 18th, 2.00 p.m. ET - 802.18 call on 802.22 Letter to the WPC (India) for 470 - 698 MHz Spectrum
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From: Roger Marks [mailto:r.b.marks@gmail.com] On Behalf Of Roger B. Marks
Sent: Monday, February 14, 2011 10:53 PM
To: Mody, Apurva (US SSA)
Cc: MJLynch@mjlallc.com Lynch; John Notor; Gerald Chouinard; Winston Caldwell; dot16 dot16
Subject: Re: 802.22 Letter to the WPC for 470 - 698 MHz Operation (India)
Thanks for your note. I posted it to the 802.16 reflector
By following the thread links, you can find the followup discussion.
After considering the views expressed, here are my comments:
(1) I think that the penultimate paragraph of the draft statement ("We hereby strongly encourage the Indian Government to consider the IEEE 802.22 technology as candidate for the 470 – 698 MHz band in India.") should be deleted, for several reasons:
(a) That paragraph arises without any foundation from the IEEE side. Up to that point, the draft statement simply provides information about the 802.22 Working Group. I don't think this substantiates the request. It's not even clear what it means by "the IEEE 802.22 technology." Is it referring to specific functional concepts, or it is referring to the entire draft standard in detail? Or perhaps to something in between?
(b) More importantly, that paragraph arises without any foundation from the Indian side. The letter is posed as an "endorsement for the proposal submitted by TICET, IIT Bombay towards the ongoing NFAP revision / review process in India for the 470 – 698 MHz band." However, TICET proposal was proposing NFAP changes to "promote innovative approaches," "reduce entry barriers," "maximize cost-effectiveness," and "ignite research." Nowhere in its paper did TICET discuss identifying a "candidate" for the band.
(c) The TICIT proposal is about revising NFAP 2008 towards NFAP 2010. I did a little research and determined that "NFAP" is "National Frequency Allocation Plan." This turns out to be a local version of the ITU Radio Regulations. A "National Frequency Allocation Plan" should not be calling out specific technologies. If anything, we should be congratulating India for keeping technology mandates out of the NFAP. The problematic paragraph seems to be suggesting that the government instead write a technology into the Allocation Plan. Any position like that from the IEEE side would be a mistake.
(2) Due to my points in (1), I think that the subject line of the letter ("Use of IEEE 802.22 Technology in the 470 – 698 MHz Band in India") in inappropriate. I think that the subject is "endorsement for the proposal submitted by TICET, IIT Bombay towards the ongoing NFAP revision / review process in India for the 470 – 698 MHz band."
(3) The letter should not refer to "IEEE 802.22 Standard" since no such standard exists.
(4) The letter should provide references that would document and explain the meaning of the statement that "During the last 5 years, the IEEE 802.22 Working Group has been actively working with the FCC and other regulators to create a standard for world-wide deployment in the TV bands to provide broadband access to the masses."
Thanks again for the chance to review the letter. I'd be happy to hear what you think about my comments.
On 2011/02/08, at 11:26 PM, Mody, Apurva (US SSA) wrote:
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.
Chair, IEEE 802.22 Standard Working Group
130 Daniel Webster Highway, Mail Stop 2350
Work: (603)885 2621, Mobile: (603)-809-0459
<IITB_proposal_TV_White_Space.pdf>