for taking a lead on this.
can understand the hesitation of the FCC in reducing the
exclusion zones and the sensitivities involved.
fact, FCC / NTIA have made a serious effort to reduce
the exclusion zones from hundreds of km earlier to only
tens of km now.
would be better if IEEE 802 provides constructive
suggestions to the FCC on how these exclusion zones may
be further reduced rather than telling them that the
Working Group overwhelmingly voted against creating an
additional standard. It does not send the right signal
to the FCC.
my humble opinion.
IEEE 802.22 Working Group
In document 11-15/0683r2 (https://mentor.ieee.org/802.11/dcn/15/11-15-0683-02-0reg-comments-in-fcc-15-47.docx),
which will be up for review on the EC telecon, we respond
to FCC 15-47, a Report & Order and Second FNPRM in the
3.5 GHz band. The position we take is that from prior
spectrum offerings that met with failure or serious delay
after IEEE 802.11 developed standard amendments (802.11y
and 802.11af), we know that the 3.5 GHz band offering, as
currently outlined, will meet a similar fate. The
exclusion zones that doomed IEEE 802,11y-2009 are still in
place today. The TVWS spectrum uncertainty has IEEE
802.11af-2013 facing a similar fate. Although the FCC
talks about an Environmental Sensing Capability (ESC) to
reduce the exclusion zones, its timeline is uncertain; the
FSS exclusion zone reductions are also as yet
In the past week I have had a number of
discussions with the organization that will be the
operator of the primary Spectrum Access System (SAS),
which will also be the installer of the ESC. They have
been involved in extensive discussions with the FCC over
the past two years on this matter. As a result, we now
have a better understanding of and timeline for these
enhancements that will enable development of this market.
As a result I would like suggest the
addition of a statement in the conclusion that does not
change the position the group approved. With this addition
the Conclusion section would read:
“IEEE 802 appreciates the Commission’s
efforts to provide additional spectrum useful to IEEE
802.11 devices and applications. However, under the
current restrictions, the additional spectrum cannot be
used by the WLAN community to provide the hundreds of
millions of WLAN users with a viable solution to
congestion in existing unlicensed spectrum. IEEE 802 will continue to monitor
progress towards resolving the exclusion zone and FSS
protection limitations, and will re-evaluate our
position as conditions dictate.”
attached a version of the document (r3) that contains
this additional statement. I would ask that you approve
this version. I have forwarded this to the IEEE
802.11/15 Regulatory SC and IEEE 802.11 reflectors to
ask if there are any objections. So far, my discussions
with a number of the people in the REG SC who voted to
approve the r2 have been positive.
New Technology Development
Alliance Spectrum & Regulatory TG Chair
Alliance White Spaces TTG Chair
Alliance White Spaces MTG Vice-chair
TGaf (WLAN in White Spaces) Chair
Regulatory SC Chair
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