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stds-802-16-tg3: FCC Letter re more UNII Bandwidth in 5.47-5.725 GHz

Hello All:
It appears that the IEEE letter to the FCC that was tabled on the Friday, 
March15  802.16 Plenary has been approved....albeit with a paragraph 
concerning lower EIRP removed. That the letter did finally get out is good 
news for all of us. The FCC needs input from the user community if they are 
going to consider granting more bandwidth for UNII applications.

The letter almost failed to be approved because of the issue of 
EIRP.....some members disapproved of the letter in its original form 
because it recommended the use of the lower EIRP's consistent with the 
5250-5350 MHz band rather than  the higher EIRP used in the 5725-5825 MHz 
band. There were a number of reasons that those of us who helped draft the 
letter considered  in the  recommendation for lower EIRP :
1. IEEE 802.11a/16a faces significant opposition from the  current primary 
and secondary users of the 5470-5725 MHz band. We (the new applicants for 
extended bandwidth) have major technical issues that we must address  in 
order to convince the incumbent users  that we can co-exist with them: DFS, 
interference with radars, interference with EESS, etc are some issues that 
802.16a has not looked at in sufficient detail, nor provided convincing 
arguments that our standard will deal with these issues.  Asking for the 
higher EIRPs at this stage  was not politically or technically advisable . 
After the FCC approves of LE operation in the 5470-5725 MHz bands., we can 
then deal with issues such as EIRP, peak-to-average power, etc Right now we 
simply must convince the FCC that we need additional bandwidth without 
belaboring the EIRP issue.
2. The lower power limit was suggested to counter the WCA request to the 
FCC for the higher EIRP . The regulatory committee that drafted the letter 
to the FCC believed that it was not wise for the WCA to be asking for high 
EIRPs without fully addressing the co-existence issue on all fronts ( with 
satellite, radars, etc), especially since we ( IEEE, WECA, and WCA) are 
going to the FCC with our collective hat-in-hand looking for more bandwidth.
3. Our 802.11a brethren have yet to be convinced that the operation of 
equipment conforming to their standards would not be adversely affected by 
our 802.16a  equipment operating at much higher EIRPs. We need to undertake 
an interference/co-existence study (any volunteers ?) to the satisfaction 
of 802.11a  before we can go about asking for higher EIRP.

Carl Stevenson  ( with be 
directing  the  Regulatory affairs work for the IEEE (I believe through 
something called the IEEE 802.18 committee). It is important the the 802.16 
members  stay in close touch with him and the Regulatory Affairs group 
because  it will be through this group  that can speak with a strong 
collective voice and deal with issues such as peak-to-average EIRP , which 
significantly limits  the operation of OFDM in the Licence-Exempt 5 GHz band.

John Sydor
Research Broad Band Wireless
Communications Research Centre
3701 Carling Avenue
Ottawa, Canada
K2H 8S2
Ph. 613-998-2388