stds-802-16-tg3: FCC Letter re more UNII Bandwidth in 5.47-5.725 GHz
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 (email@example.com) 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.
Research Broad Band Wireless
Communications Research Centre
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