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Re: [802SEC] +++EC Email Ballot+++Urgent motion to approve 802.18 doc+++



            I vote No but will change my No to a Yes if my recommendations listed below are implemented.


            My fundamentally concern is that,


In this response to the FCC NPRM the IEEE is recommending to the FCC that they place additional restrictions on IEEE 802 devices above and beyond what the FCC is proposing in the NPRM.


Special Protection for Part 74 Wireless Microphones

The FCC NPRM stated that because of the FM capture effect and a strong received signal strength of the wireless microphones, “the likelihood of interference from unlicensed device signals is therefore low such that unlicensed use should generally be compatible with wireless microphones”, and imposes no further restrictions on unlicensed 802-type devices.

However, the IEEE 802 response to the FCC NPRM recommends adding the following requirements on Part 15 unlicensed devices:

  1. The Part 15 must be able to sense the operation of a Part 74 device
  2. The Part 15 device must be able to sense the presence of a yet-to-be defined beacon emitting from a Part 74 device

It seems that the IEEE 802 is requesting additional restrictions be placed upon its devices above and beyond those recommended in the FCC NPRM. It does not seem like that is in the best interest of IEEE 802.


Remove Paragraphs 26, 27, 36 and 37.


Requirement for Professional Installation

The FCC NPRM proposes two installation methods for the fixed/access class:

  1. Geolocation coupled with database access
  2. Professional installation

In paragraph 25 of the IEEE response to the FCC NPRM it states that GPS may be the most practical means of protecting Part 90 devices.  However, the title of paragraph 28 states that professional installation is required and does not allow for GPS with database access as an alternative mechanism.  Once again the IEEE is recommending that the FCC place additional requirements on Part 15 devices above and beyond those recommended in the FCC NPRM.


The following words should be added to the beginning of Paragraph 28: “In instances where geolocation with database access is not used, “.  These same words should also be added to the end of the heading immediately preceding Paragraph 28.





Steve Shellhammer

Intel Corporation

(858) 391-4570


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