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


Thanks for the explanation.

One thing that I thought was confusing and perhaps not well stated in the the document was that this is a report and does not represent the consensus of IEEE 802 or any of its Working Groups. The former requires 2/3 and the latter 75% approval.

I think a summary of the results of the task is appropriate to issue from the EC, but it should be clear in the cover letter and document that this is a report of activity but not a conclusion or endorsement.

As you state, showing that the IEEE 802 community wants to work with other stakeholders to share frequency bands is a very good thing. That should be stated in the cover letter as well.

It is not clear to me at this time that the cover letter and document stated these things clearly. It could be that I simply missed where they were in the documents.

James Gilb

On 03/13/2015 08:51 AM, Rich Kennedy wrote:


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

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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