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[802SEC] Confusion regarding document 18-15/0016



What the 802.18 Chair should have presented is an explanation of the project, and what this document represents. This is now going to become a reflector review and approval, so let me take this early step of explaining what this document is all about.


1.     In a 2013 Notice of Proposed Rule Making (NPRM), the FCC proposed unlicensed sharing of the U-NII-4 band (5850-5925 MHz). This band currently has an allocation for Dedicated Short Range Devices (DSRC) for the Intelligent Transport Systems, which currently uses a version of IEEE 802.11p as its wireless technology.

2.     This sharing would be regulated under the rules of FCC Part 15, which means we cannot interfere with the ITS because it has a primary allocation. In order for us to engage the DSRC community to find a sharing mechanism they would approve, I set up a Tiger Team comprised of members of the  WLAN community and the DSRC community.

3.     There were two major reasons for this approach

a.     There was a chance we could define a mechanism that they would be able to accept as not harmful to their safety-of-life network, and we would share with DSRC in a similar fashion to our sharing in other bands with radars, FSS installations, etc.

b.     We had to show the FCC that we were willing to work with the DSRC, as the FCC would be responsible for letting us share, so they were very concerned that this be a solution that both sides agreed to. This tends to foster good relations with the regulator. With many more bands queued up for sharing, I felt that building trust with the FCC was critical for this, and for future sharing opportunities. The FCC Chairman even mentioned our Tiger Team on a couple of occasions, asking that a Senate bill to rush opening of the upper 5 GHz band wait for results from our effort.

4.     After 20 months of trying to reach an agreement, which almost happened last November, it became clear that the two sides could not agree on a solution. At that point I asked the Tiger Team chair to gather some opinions from both sides, which he did with a series of straw polls.

5.     I did not ask the Regulatory SC to vote to approve the report, which draws no conclusions, make no suggestion and states only that a compromise could not be reached. In a small group, any concerned party can find enough votes to avoid approving the report. Especially one as small as 802.18. I therefore asked the full 802.11 WG to vote, so it truly represented the undistorted view of the full WG. Here it passed by 53-48; in the SC a straw poll was noticeably different.

6.     The 802.11 WG motion read: Believing that the report in document 11-15/0347r0 represents the work of the DSRC Coexistence Tiger Team, forward it to 802.18 for approval to send to the EC for its approval and submittal to the FCC. “…represents the work of the Tiger Team”, which it factually did.

7.     By sending the report to the FCC, where we clearly state that no consensus was reached, but that we tried hard to reach one, we still could show the FCC our good faith effort. In the RR-TAG vote, we were forced to remove section 11, because straw poll results were slightly skewed towards the DSRC preferred mechanism, and some members wanted to take it out because they felt that slight edge could be misinterpreted. However, it was clearly stated in the report that 57% of the straw poll respondents were from the DSRC side.

8.     The motion to approve sending the report was simply an effort to send the full results of the Tiger Team work to the FCC. There was no IEEE endorsement and no conclusions.

9.     When we removed section 11 and added the note to the abstract that there was no (Tiger Team) consensus among the participants, we created a new document with this clean version: 18-15/0016r0. This should have been motioned at the EC meeting; not the r1 version. I was told that an EC member was going to ask us to remove two references that were orphaned when section 11 was removed, so rather than take EC time to edit the document, I created a version that deleted those references. While doing that I made an editorial change, removing the line numbering along the left side of the text. Otherwise it is identical to r0.


Unfortunately, the 802.18 Chair did not explain any of this, and I apologize for the confusion it caused.


I hope you use this email as a starting point for your review of the Tiger Team report, and vote to approve sending it to the FCC.


Thank you.


Rich Kennedy

Manager, New Technology Development

MediaTek Inc.

(832) 298-1114


Wi-Fi Alliance Spectrum & Regulatory TG Chair

Wi-Fi Alliance White Spaces TTG Chair

Wi-Fi Alliance White Spaces MTG Vice-chair

IEEE802.11 TGaf (WLAN in White Spaces) Chair

IEEE802.11/15 Regulatory SC Chair

IEEE 802.11/18 Liaison





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