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[802SEC] Suggested additional wording for response to FCC 15-47



In document 11-15/0683r2 (, which will be up for review on the EC telecon, we respond to FCC 15-47, a Report & Order and Second FNPRM in the 3.5 GHz band. The position we take is that from prior spectrum offerings that met with failure or serious delay after IEEE 802.11 developed standard amendments (802.11y and 802.11af), we know that the 3.5 GHz band offering, as currently outlined, will meet a similar fate. The exclusion zones that doomed IEEE 802,11y-2009 are still in place today. The TVWS spectrum uncertainty has IEEE 802.11af-2013 facing a similar fate. Although the FCC talks about an Environmental Sensing Capability (ESC) to reduce the exclusion zones, its timeline is uncertain; the FSS exclusion zone reductions are also as yet undocumented.


In the past week I have had a number of discussions with the organization that will be the operator of the primary Spectrum Access System (SAS), which will also be the installer of the ESC. They have been involved in extensive discussions with the FCC over the past two years on this matter. As a result, we now have a better understanding of and timeline for these enhancements that will enable development of this market.


As a result I would like suggest the addition of a statement in the conclusion that does not change the position the group approved. With this addition the Conclusion section would read:


“IEEE 802 appreciates the Commission’s efforts to provide additional spectrum useful to IEEE 802.11 devices and applications. However, under the current restrictions, the additional spectrum cannot be used by the WLAN community to provide the hundreds of millions of WLAN users with a viable solution to congestion in existing unlicensed spectrum. IEEE 802 will continue to monitor progress towards resolving the exclusion zone and FSS protection limitations, and will re-evaluate our position as conditions dictate.”


I have attached a version of the document (r3) that contains this additional statement. I would ask that you approve this version. I have forwarded this to the IEEE 802.11/15 Regulatory SC and IEEE 802.11 reflectors to ask if there are any objections. So far, my discussions with a number of the people in the REG SC who voted to approve the r2 have been positive.


Thank you.


Rich Kennedy

Manager, New Technology Development

MediaTek Inc.

(832) 298-1114


Wi-Fi Alliance Spectrum & Regulatory TG Chair

Wi-Fi Alliance White Spaces TTG Chair

Wi-Fi Alliance White Spaces MTG Vice-chair

IEEE802.11 TGaf (WLAN in White Spaces) Chair

IEEE802.11/15 Regulatory SC Chair

IEEE 802.11/18 Liaison





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