Re: [STDS-802-11-REG] 13/444r1 FCC 13-49 comments posted on Mentor

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Mr. Reuss,

ABSOLUTELY aggreed; this is not ITU (Recommendations)! I think your suggestion is appropriate !

Francois Simon (IEEE 802.11p member)

From: *** Regulatory and Spectrum Allocation Topics *** [STDS-802-11-REG@xxxxxxxx] on behalf of Ed Reuss [edreuss@xxxxxxxxx]
Sent: Tuesday, May 14, 2013 9:13 AM
To: STDS-802-11-REG@xxxxxxxxxxxxxxxxx
Subject: Re: [STDS-802-11-REG] 13/444r1 FCC 13-49 comments posted on Mentor

Is anyone else besides me bothered by the phrase "IEEE 802.11 recommends"?

I do not recall anyplace within the IEEE 802.11-2012 standard where it recommends any of these things. I suggest replacing all instances with "The IEEE 802.11 Working Group recommends".

Perhaps this was just the editor's shorthand, and he intended to do this replacement already.

Mahalo. -- Ed Reuss

On May 14, 2013, at 1:49 AM, "Perahia, Eldad" <eldad.perahia@xxxxxxxxx> wrote:

Hi Andrew,

I believe that enabling a simpler implementation of peer-to-peer technology in DFS bands will open up exciting new applications for the Wi-Fi industry, so I disagree with your sentiment of “this is a big mistake”. However I do agree that a sharing study is necessary and it is reasonable for our NPRM comments to say so. I propose we adopt the changes that were discussed in the RegSC this evening, as given below.

P40 “In addition, we recommend studying the option for a low power mode on DFS channels, meaning, devices that do not support DFS, will be able to operate on DFS channels, with power limitation. ”

P41 “For that reason, IEEE 802.11 recommends studying a low power mode exemption for DFS.”

Regards,

Eldad

From: *** Regulatory and Spectrum Allocation Topics *** [mailto:STDS-802-11-REG@xxxxxxxx] On Behalf Of Andrew Myles (amyles)
Sent: Tuesday, May 14, 2013 12:01 AM
To: STDS-802-11-REG@xxxxxxxxxxxxxxxxx
Subject: [STDS-802-11-REG] 13/444r1 FCC 13-49 comments posted on Mentor

I would like to make a comment on the recommendations in 444 to add a new low power option, allowing soft APs and Wi-Fi Direct devices to operate without supporting DFS if they use low power. I personally believe this is a big mistake. The last thing we should be doing is inflicting a large number of unmanaged rogue APs on the 5GHz band.

However, I understand that some members are fans of the possibility of allowing soft APs and Wi-Fi Direct in the 5GHz band. I will not argue against that view because it is not a black and white argument. That said the current recommendations in document are not justified by the document. Nowhere in the document does it explain how soft APs can operate at low power without DFS without causing interference to radar stakeholders

Indeed the current ruling from the FCC (2uW/MHz) suggests that there is no power at which devices could operate without DFS and still satisfy the use cases in Attachment 1. We have not included any evidence to the contrary in this document, and is inappropriate to make a recommendation to allow low power operation without DFS. It is actually disrespectful to the goals of the radar stakeholders.

Recommendation 1

On pp40, delete,

“In addition, we recommend adding the option for a low power mode on DFS channels, meaning, devices that do not support DFS, will be able to operate on DFS channels, with power limitation”

I want to delete it here because there is no need to say the same thing twice (without justification in either case). The issue can better be handled once on pp41.

Recommendation 2

On pp41, change:

“For that reason, IEEE 802.11 is recommending a low power mode exemption to DFS”

To

“For that reason, IEEE 802.11 is recommending a new study to determine if it is possible to operate low power APs without DFS, while both protecting the radar users and providing sufficiently high power to enable the use cases in Attachment 1. This study should occur as soon as possible but it completion should not stop the implementations of the other recommendations of this response from IEEE 802”

This better expresses our desires, which are low power operation without DFS if it is possible without unreasonably affecting the interests of other stakeholders

Andrew

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