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[802SEC] Comments/request for clarification/modification on the .16h PAR

Roger (and EC members),
While 802.22 believes that coexistence is a good thing (in fact, as you know, the scope of our PAR requires coexistence with the primary TV broadcast service and other licensed users in spectrum allocated to the TV broadcast service),  802.22 does have some comments and a request for clarification/modification of the .16h PAR.
While the title mentions only unlicensed coexistence, and it was my understanding that the scope was to be limited to unlicensed vs. unlicensed coexistence, the PAR (attached) indicates in its scope:
13. Scope of Proposed Project:

This amendment specifies improved mechanisms, as policies and medium access control enhancements, to enable

coexistence among license-exempt systems based on IEEE Standard 802.16 and to facilitate the coexistence of such

systems with primary users.

It is unclear to us what primary users in what band(s) are being referred to in the scope.
We are concerned that there is an ambiguity in the scope that would potentially create a situation where 802.16 might assert that the scope of this PAR enables it to develop systems designed to operate on an unlicensed basis in the TV bands, which is clearly the scope of the 802.22 PAR and would, in our view, create a situation that would run afoul of "distinct identity" and the principle of not duplicating work.
One .16 member indicated to me that the reference to "primary users" was intended to refer to radars and other primary users in the 5 GHz unlicensed bands ... if this is the intent, clarification in the scope to that effect would mitigate our concerns.
Additionally, section 16

(16. Are there other documents or projects with a similar scope?)

is answered "No" and we believe that a mention of the scope of the 802.22 PAR and a statement that the 802.16h PAR would not conflict with our scope would be appropriate.
Carl R. Stevenson
Interim Chair, IEEE802.22 WG
Chair, IEEE 802.18 RR-TAG
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