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Re: stds-802-16-tg3: FCC Letter re more UNII Bandwidth in5.47-5.725 GHz

Just to clarify the full details:

The draft 802.16 minutes say that, after WG turned down the letter:

'Roger Marks requested that members of the Working Group that 
objected to Motion 11 would draft a rebuttal. Nico van Waes submitted 
a draft to Roger. The changes were: (a) changing "EIRP" to "power" in 
section 22; (b) deleting section 24 ("Concerning the WCA's suggested 
EIRP limits in the proposed band, we feel, for reasons based on 
considerations of spectrum sharing with incumbent primary users, that 
it is not appropriate to support the 1 Watt transmitter powers and 
higher EIRPs for point-to-point systems that are currently allowed in 
the 5725-5825 MHz band. We believe that it is more appropriate to use 
the emission requirements currently applied to the U-NII 5250-5350 
MHz band.")'

A few minutes later, I discussed this result with Vic Hayes and Carl 
Stevenson at the SEC meeting. It turned out that 802.16 was working 
from an outdated draft (RR-02-043d2). The then-current draft was 
In that version, 802.16's change (a) was immaterial. However, section 
(24) remained. Vic and Carl decided to put forward a motion to 
approve the letter without the problematic paragraph. As I report 
last week, the following motion was passed: "To authorize Carl 
Stevenson to make the final edits, including the removal of paragraph 
24 in accordance with 802.16's motion, to the Proposed Reply Comments 
on the WECA petition, to file the result with the FCC and mail the 
required service copies to the appropriate parties." The revised 
letter is not yet on the RR web site.

Please note that the approved letter takes no position on the EIRP issue.

Finally, as I also reported last week, the SEC agreed "To establish a 
new Technical Advisory Group for Radio Regulatory matters and direct 
the interim Chair to work with the Chairs of 802.11, 802.15, and 
802.16, by e-mail correspondence, to develop an SEC approved charter 
for the TAG." Carl Stevenson was named Interim Chair, and the Radio 
Regulatory TAG was given the number 802.18.

Carl has thanked me for our quick action in identifying the problem 
and solution. I have thanked him for his cooperation. Carl lived up 
to the proposed RR TAG charter, which includes "To prepare, review, 
and submit balanced position statements on radio regulatory matters 
for those Working Groups responsible for producing standards for 
radio devices and to fairly reflect all points of view."

I thank John for explaining the thinking of the RR group. I also want 
to caution 802.16 that the RR TAG is going to be a much better place 
than the WG Closing Plenary to hammer out "balanced position 
statements." We need to listen to those who sit in on the RR TAG 
discussions and have a good view of where the balance lies. Those 
representatives also need to be able to convince us to accept their 
proposed position statements. As the RR TAG process gets defined, we 
need to find a way to ensure that the TAG's drafts can pass a WG 


>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