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Please find
below some comments which can be used for the 5.9 GHz NPRM. Feel free to use
and modify accordingly whatever you find useful.
The spectrum needs to achieve the full benefit of traffic
safety technologies are misaligned with the NPRM:
Over the past
decade, a lot of effort has been dedicated to validate the spectrum
requirements and needs to guarantee that the full potential of traffic safety
goals are met in order to save more lives. None of these studies has suggested
or brought any evidence that the spectrum needs have decreased. On the
contrary, the conclusion is that not only the already dedicated 75 MHz band is
going to be fully utilized in the near term, but that there is a need to extend
this spectrum for future dedicated traffic safety use cases that will build
upon day-1 applications. The US Department of Transportation (DoT) stated in
its latest report “Preparing for the Future of Transportation” [Ref:
1] that today all seven channels in the 5.9 GHz band are actively
utilized by over 70 active deployments of V2X communications throughout the US.
Moreover, an in-depth assessment made by the Car2Car Communication
Consortium [Ref:
2] estimates that regardless of the communication technology, the
already allocated 75 MHz in the US is required to support applications such as
automated driving, collective perception, cooperative maneuvering and truck
platooning.
5G
connectivity benefits should not be coupled to C-V2X:
It is wrongly assumed that the benefits of 5G connectivity are uniquely
associated with C-V2X. Furthermore, often the capability of 5G in terms of
Vehicle-to-Network (V2N) communication achieved through the (Uu) communication
interface, is widely confused with V2X. It is important to clarify that the V2N
capability is a distinct function using separate frequency resources and
hardware. Therefore, we believe that 5G connectivity in terms of (Uu)
communication is an excellent complement to DSRC V2X operations in the same
manner as is 4G today. An example implementations of this “hybrid”
communication mode is the SCOOP project with a fleet of 3000 vehicles [Ref:
3].
Choosing
LTE-V2X as a V2X technology does not address the slow market adoption of V2X:
While it is true that the adoption of DSRC has moved slowly, we believe that
the reasons are not due to a shortfall of DSRC as a technology or to its
maturity for mass deployment. On the contrary, there is strong evidence coming
from the US-DoT pilot programs, of which many have already started their operation
phases, and showing that the technology is ready for mass market rollout. In
fact GM, Toyota, and other automotive manufacturers [Ref:
4, Ref:
5, Ref:
6] made prior commitments to mass
deployment of DSRC based system across their respective brands. It is in our
belief that the slow adoption of DSRC is more related to the lack of incentive
and motivation from road operators scaling up their deployments as well as a
reluctance of automotive manufacturers to voluntarily invest in a technology
whose benefits are only evident once a significant level of penetration of the
technology is reached. This is in contrast to other safety technologies such as
radars, lidars, where such dependency on other vehicles to have similar systems
is not necessarily needed to achieve a safety benefit. This situation is also
valid for C-V2X and there is no reason to believe that choosing C-V2X will be
the answer.
Best Regards
Ioannis Sarris, PhD
Senior Principal Engineer
u-blox Athens
Voriou Ipeirou 74
GR-15125 Maroussi
Phone +30 2155004287
locate.communicate.accelerate
In case you need something to read during a long flight this weekend, here are two "Preliminary Technical Assessments" published by USDOT regarding the 5.9GHz spectrum 802.11bd is targeting.Look forward to seeing everyone on Monday.Regards,JamesOn Tue, Jan 7, 2020 at 3:31 PM James Lepp <jlepp@xxxxxxxx> wrote:Hi Joseph,Thanks for keeping the conversation going on this topic.Referencing the December 17 version of the NPRM...Paragraph 44 discusses changing the reference used in the Part 90 and Part 90 from "ASTM E2213-03" to "IEEE 802.11p-2010". I think we should comment on this. The current IEEE publication which incorporates that amendment is IEEE 802.11-2016. Having rules written in a way that would allow 802.11bd in the future without rewriting the rules would be even better. Since 802.11bd is being drafted to be inclusive of 802.11p rates with the addition higher performance rates, is there a wording we can propose that refers to a baseline RF performance and is inclusive of additional rates within those RF specs? Based on footnote 12, the C-V2X is locked in as an older version of 4G-LTE as well. I think locking the rules to old versions of the standards prevents innovation and doesn't benefit anyone. We have a long history of innovating while keeping necessary levels of backwards compatibility, interoperability and coexistence in the same band.Paragraph 4 discusses "traffic-related" applications which are provided using other radio spectrum (such as unlicensed or commercial cellular). A point needs to be made about the DSRC system being designed with user privacy in mind. Great care was taken to provide pseudo-anonymity in the design of the IEEE 1609 stack and its use of IEEE 802 MAC addresses and security. This type of user privacy is not provided by all of the commercial services and other applications referenced in the NPRM as alternatives to DSRC, particularly referencing the note in footnote 7.Regarding Appendix A figure 2 we may want to suggest adding the 10MHz channels 170, 172, 174, 176 and 178 for unlicensed use under the proposed new UNII-4 rules. I'll prepare a short presentation on this for 11bd next week. That and other topics could be submitted as responses to the paragraph 68 and 69 questions.Regards,JamesOn Thu, Jan 2, 2020 at 7:56 PM Joseph Levy <Joseph.Levy@xxxxxxxxxxxxxxxx> wrote:Dear All,
This is a reminder and call for discussion on the FCC NPRM impacting the 5.9 GHz Band. This NPRM will make changes that will impact how 802.11 and 802.11bd based equipment will be able to access the 5.9 GHz Band and the level of interference that will be allowed in the Band from neighboring bands.
The NPRM has not yet been published in the Federal Registry, hence the 30 day comment period has not started. But, it is likely that it will be published in the next few weeks, which means that if we (TGbd) want 802.11 and/or 802.18 to provide comments on this NPRM we should work to have the comments approved at the upcoming 802.11 and 802.18 F2F meetings. Therefore, it would be best to have a TGbd position going into the meeting, hence this call/reminder for discussion.
802.18 has asked for TGbd’s inputs and comments on the NPRM and in particular the OOBE (Out of Band Emissions) requirements, provided below. Please note that the FCC only specifies OOBE performance requirements, it does not address channelization or in band interference requirements (these are typically specified by 802.11 or other technologies using the band).
The OOBE requirements being proposed for comment in the NPRM (https://ecfsapi.fcc.gov/file/1217200308588/FCC-19-129A1.pdf) are discussed in paragraphs 54, 55 and 56 of the NPRM (copied below):
“54. We propose that U-NII-4 devices, or devices that operate across a single channel that spans the U-NII-3 and U-NII-4 bands, meet an OOBE limit of -27 dBm/MHz at or above 5.925 GHz, which is the same limit required for U-NII-3 devices at this frequency. We note that, for U-NII-3 devices,
the -27 dBm/MHz limit increases incrementally closer to the edge of the U-NII-3 band.94 Because the UNII-4 band is above the U-NII-3 band and closer to adjacent services (e.g., ITS services in the adjacent portion of the 5.9 GHz band (5.895-5.925 GHz) and 6 GHz fixed services), should we also establish a
separate limit at the upper U-NII-4 band edge (i.e., at 5.895 GHz)?95 If so, what should this limit be? Should the slope of the OOBE from U-NII-4 devices at the upper edge of the band be adjusted to match the OOBE limits from U-NII-3 devices or should a different limit be established? If the OOBE limits from the U-NII-4 band are adjusted to match the U-NII-3 band OOBE limits, can unlicensed devices and ITS devices operate directly adjacent to each other as the emissions into the ITS band would be identical from either U-NII-3 or U-NII-4 devices? We seek comment generally on the OOBE limits we should
apply at the upper end of the U-NII-4 band and whether any spectrum must be reserved to protect ITS services,96 and if so, whether such spectrum should be in the U-NII or ITS segment of the 5.9 GHz band.
“55. We further propose that U-NII-4 devices, or devices that operate across a single channel that spans the U-NII-3 and U-NII-4 bands, meet the same OOBE limits as U-NII-3 devices at the lower edge of the combined U-NII-3 and U-NII-4 band, i.e., at 5.725 MHz. Because we expect devices designed for the U-NII-3 and U-NII-4 bands to be similar and therefore compatible with each other, we do not believe it is necessary to set a separate OOBE limit for U-NII-4 devices at the U-NII-3/U-NII-4 band edge.97 We seek comment on these proposals as well as seeking comment on whether there are alternative OOBE limits that we should adopt.
“56. Our proposals support a separate U-NII-3 and U-NII-4 band to provide flexibility for designing U-NII-3 equipment under the less stringent OOBE rules at the upper edge of the band. Our proposals also provide flexibility for devices to operate across the U-NII-3 and U-NII-4 bands using the widest bandwidths permitted under the 802.11 standard. Alternatively, we could expand the U-NII-3 band and implement a single set of OOBE limits for the combined 5.725-5.895 GHz band using the OOBE limits proposed for U-NII-4 band devices or devices that operate across a single channel that spans the U-NII-3 and U-NII-4 bands. What advantages would a single band under uniform rules provide? What would be the drawbacks, especially considering the effect on OOBE limits? We seek comment on this alternative. Under our proposal or this alternative, we also seek comment on any other rule changes that are needed to support communications across the combined U-NII-3 and U-NII-4 bands. Finally, we seek comment on how our proposals might affect device design and cost.”
Fillings made to this FCC docket 19-138 can be found: https://www.fcc.gov/ecfs/search/filings?limit=25&offset=0&proceedings_name=19-138&sort=date_disseminated,DESC
There have also been numerous public comments made in various media: e.g. pro https://cei.org/content/cei-praises-fcc-breaking-impasse-59-ghz-spectrum-band and con https://ride.tech/self-driving/fcc-plan-could-stall-v2x-car-safety-revolution/
Regards,
Joseph Levy
802.11 TGbd Vice Chair
From: Joseph Levy
Sent: Wednesday, December 18, 2019 7:13 PM
To: ** STDS-802-11-TGbd -- Enhancements for Next Generation V2X.Task Group ** <STDS-802-11-TGBD@xxxxxxxx>
Cc: sun.bo1 (sun.bo1@xxxxxxxxxx) <sun.bo1@xxxxxxxxxx>; James Lepp <jlepp@xxxxxxxx>; Hongyuan Zhang <hongyuan@xxxxxxxxxxx>; Sadeghi, Bahareh <bahareh.sadeghi@xxxxxxxxx>
Subject: RE: Discussion on: FCC NPRM impacting the 5.9 GHz Band
Dear All,
As you may already know – the NPRM for the 5.850-5.925 GHz Band is has been released by the FCC as well as the statements by the commissioners made at the 12 December 2019 Open Meeting. (see: https://www.fcc.gov/ecfs/filing/1217200308588)
Jay Holcomb, the 802.18 chair, has the released NPRM posted to the 802.18 document area on Mentor:
The time line provided in the NPRM is:
Adopted: December 12, 2019
Released: December 17, 2019
Comment Date: [30 days after date of publication in the Federal Register]
Reply Comment Date: [60 days after date of publication in the Federal Register]
Please note that even though this document has been released, it has not yet been published in the Federal Register, so the clock has not yet started ticking.
Also note:
Today 18 December 2019, an announcement of the FCC Open Meeting was published in the Federal Register - https://www.federalregister.gov/documents/2019/12/18
(The FCC meeting announcement is copied here for your convenience, note links below are clickable):
Federal Communications Commission:
Meetings:
Open Commission; Thursday, December 12, 2019
FR Document:
Citation:
84 FR 69372
Pages 69372-69373 (2 pages)
Regards,
Joseph Levy
802.11 TGbd Vice Chair
From: Joseph Levy
Sent: Tuesday, December 17, 2019 12:07 AM
To: ** STDS-802-11-TGbd -- Enhancements for Next Generation V2X.Task Group ** <STDS-802-11-TGBD@xxxxxxxx>
Cc: sun.bo1 (sun.bo1@xxxxxxxxxx) <sun.bo1@xxxxxxxxxx>; James Lepp <jlepp@xxxxxxxx>; Hongyuan Zhang <hongyuan@xxxxxxxxxxx>; Sadeghi, Bahareh <bahareh.sadeghi@xxxxxxxxx>
Subject: RE: Discussion on: FCC NPRM impacting the 5.9 GHz Band
Dear All,
As you are probably aware at the United States (US) Federal Communications Committee (FCC) Open Commission Meeting on 12 December 2019, the commissioners unanimously approved the proposed Notice of Proposed Rule Making (NPRM). The comment period on the NPRM will begin when the NPRM is published in the US Federal Register, which has not yet happened.
I have generated contribution summarizing the 5.9 NPRM status to aid in structuring the discussion during the upcoming TGbd Teleconference 17 December 2019 @ 9:00 AM EST. Note the contribution also provide multiple links where additional information can be found.
Regards,
Joseph Levy (InterDigital)
802.11 TGbd Vice Chair
From: Joseph Levy
Sent: Thursday, December 5, 2019 12:57 AM
To: '** STDS-802-11-TGbd -- Enhancements for Next Generation V2X.Task Group **' <STDS-802-11-TGBD@xxxxxxxx>
Cc: sun.bo1 (sun.bo1@xxxxxxxxxx) <sun.bo1@xxxxxxxxxx>; 'James Lepp' <jlepp@xxxxxxxx>; Hongyuan Zhang <hongyuan@xxxxxxxxxxx>; Sadeghi, Bahareh <bahareh.sadeghi@xxxxxxxxx>
Subject: Discussion on: FCC NPRM impacting the 5.9 GHz Band
This e-mail is a call for discussion (as requested by the TGbd Chair) on the TGbd reflector (this e-mail stream) to reach a conclusion as to what, if any, actions/position should be taken by TGbd, in response to the announced FCC plans for the 5.9 GHz band.
As mentioned during the teleconference, I believe that the best way forward for TGbd is to generate a document (preferably a PowerPoint document) that provides 802.11 TGbd’s position/comments on the proposed FCC NPRM. I will create a draft document based on this e-mail discussion, that will be discussed and hopefully approved by TGbd. Once TGbd has agreed, the document can then be shared with the 802.11 WG during one of the plenary time slots of the upcoming January 802.11 meeting and hopefully the 802.11 WG will pass it along to 802.18 and the 802 EC.
The rest of this e-mail provides information: the FCC documents and related web pages, a summary of the 802 process to send information to the FCC, and additional 802.11 and DSRC background information:
FCC Information:
As announced and discussed on the TGbd 3 December Telephone Conference:
The United States (US) Federal Communications Committee (FCC) has announced that at their upcoming Open Commission Meeting on 12 December 2019 at 10:30 am - 12:30 pm EST (https://www.fcc.gov/news-events/events/2019/12/december-2019-open-commission-meeting) they will consider a Notice of Proposed Rulemaking (NPRM) that would change the rules for the 5.9 GHz band (the DSRC band).
As stated on the FCC “FACT SHEET”:
What the NPRM Would Do:
• Propose to repurpose the lower 45 megahertz of the band (5.850.5.895 GHz) for unlicensed operations to support high-throughput broadband applications.
• Propose that unlicensed device operations in the 5.850-5.895 GHz band be subject to all of the general Part 15 operational principles in the Unlicensed National Information Infrastructure (U-NII) rules. Propose to adopt technical and operational rules (e.g., power levels, out-of-band emissions limits) similar to those that already apply in the adjacent 5.725-5.850 GHz (U-NII-3) band.
• Propose to continue to dedicate spectrum in the upper 30 megahertz of the 5.9 GHz band (5.895-5.925 GHz) to support ITS needs for transportation and vehicle safety-related communications. o Propose to revise the current ITS rules for the 5.9 GHz band to permit Cellular Vehicle to Everything (C-V2X) operations in the upper 20 megahertz of the band (5.905-5.925 GHz).
o Seek comment on whether to retain the remaining 10 megahertz (5.895-5.905 GHz) for DSRC systems or whether this segment should be dedicated for C-V2X.
o Propose to require C-V2X equipment to comply with the existing DSRC coordination rules for protection of the 5.9 GHz band Federal Radiolocation Service.
o Propose to retain the existing technical and coordination rules that currently apply to DSRC, to the extent that we allow DSRC operations in the 5.895-5.905 GHz band.
• Seek comment on how DSRC incumbents would transition their operations out of some or all of the 5.9 GHz band if the proposals are adopted.
The FCC typical process is (The specifics of this process will be provided in the published NPRM):
- The NPRM will be published in the US Federal Register (https://www.federalregister.gov/) – this is expected to occur after the Open Commission Meeting
- Once published there will typically be a 30 day comment period, during which comments by individuals and entities on the NPRM can be provided to the FCC.
- The comment period is then typically followed by a reply-comment period, where comments on the comments that have been provided to the FCC can be responded to by individuals and entities by an additional submission.
802 Process Information:
The IEEE 802 process for submitting comments or reply-comments to the FCC requires the submission to be generated and approved by 802.18 and then approved by the 802 EC. 802.18 has already added the 5.9 GHz band NPRM discussion to its agenda and has had a brief discussion on the possibility of submitting comments (see 18-19/0147r1 (slides 14 and 18) and 18-19/0151r0, note minutes for the telephone conference from 21 Nov are not currently available). 802.18 has regularly scheduled teleconference on Thursday 15:00-16:00 EST (see more details » for teleconference details).
802.11 Background Information:
The last area of information is related to past 802.11 discussion on the 5.9 GHz band:
In 2013 the FCC release NPRM 13-22 (Docket 13-49) which requested comments regarding allowing unlicensed devices such as those using 802.11-based standards to share the 5.9 GHz band, which is currently allocated for DSRC and other services. 802.11 formed a DSRC Coexistence Tiger Team, to generate a 802.11 position: 802.11 DSRC Band Sharing Report
This report was approved by 802.11 was sent to 802.18 to be forwarded to the EC for its approval and submittal to the FCC (item 28 in the 802.11 March 2015 minutes: 11-14/0287r0). 802.18 made some small modifications and forwarded the report to the 802 EC (18-15/0016r1 and cover letter 18-15/0018r1), (item 16 and 18 in the 802.19 March 2015 minutes: 18-15/0019r0). However, the 802 EC did not approve the motion: “Move to approve document 18-15/0016r1 providing a view of the work done in the IEEE802.11DSRC Tiger Team with the cover letter as contained in Document 18-15/0018r1 and submit it to the FCC. The Chair of 802 is authorized to make editorial changes as necessary.” (Note the details of how this was not approved can only be understood from the EC minutes, the EC e-mail archive, I have not included all these details as it is quite complex.) The 802 EC eventually sent letter to Marlene H. Dortch, Secretary Federal Communications Commission in May (ec-15/0035r1) that basically stated that 802.11 had some initial discussion regarding the feasibility and practicality of sharing the 5.9 GHz band and the documents of the discussion can be found on Mentor.
Other 802.11 documents of interest are:
11-15/0402r2 DSRC Band Sharing TT Status and Report Finalization, Rolf de Vegt (Qualcomm)
11-13/1449r2 Proposal for DSRC band coexistence, Tevfik Yucek (Qualcomm)
Regards,
Joseph Levy (InterDigital)
802.11bd Vice Chair
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