====================
COMMENT #: 1
IEEE #: 8944704
NAME: O'Hara, Bob
E-MAIL: bob@informed-technology.com
PHONE: +1 408 986 9596
FAX: +1 408 727 2654
CO/ORG: Informed Technology, Inc.
PAGE: 0
LINE: 0
CLAUSE: 0
TYPE OF COMMENT: T
COMMENT: "This proposed standard operates in the same band as an existing IEEE approved standard, 802.11 and its approved supplement 802.11b.  It has been demonstrated that the operation of this proposed standard interferes with devices complying with the 802.11 standard operating in the same band."
SUGGESTED REMEDY: "A means of mitigating or, preferably, eliminating the interference with the 802.11 standard is required and must be incorporated into this proposed standard in order for it to be acceptable.  It is not acceptable to approve this proposed standard based on potential work being done in other task groups that, obviously, will not be incorporated in devices built to comply with this proposed standard."
RESPONSE: "REJECT.
We, the 802.15.1 Ballot Review Committee (BRC), thank the voter very much for taking the time to comment on the draft standard. The BRC acknowledges that it did not communicate its position properly to the sponsor voter in earlier opportunities. The BRC has re-reviewed the voter's comments and it does not share the voter's view.

In the original 802.15 WG IEEE 802 Five Criteria response (http://ieee802.org/15/pub/par/5C.html), we identified that coexistence with 802.11 LANs in the 2.4 GHz band is a critical success factor. The WG has worked and continues to work to assure that its family of 802.15 WPAN standards does coexist with other technologies in this band.

The WG established the 802.15.2 coexistence task group to study this issue within the WG (e.g., 802.15.1) and across WGs (e.g, 802.11). The 802.11 WG formally participates in 802.15.2 activities. Based on studies within and outside this task group, it has been shown, as expected and as the voter mentions, that there is interference between 802.11 and 802.15 nodes operating in the same space, at the same time, and in the same spectrum. However, these studies have also repeatedly demonstrated that the 802.11 nodes continue communicating with each other, and the 802.15.1 nodes continue to communicate with each other even when the 802.11 and 802.15.1 nodes are in the vicinity of each other and utilize the same (2.4 GHz) band. Thus, the 802.15.1 draft standard has demonstrated to satisfy the level of coexistence (the 6th of the IEEE 802 five criteria) advocated in the 802.15.1 PAR.

Based on studies that the group has made (plus studies outside the group and everyday observations), nodes designed based on the first IEEE WPAN draft standard have demonstrated that they can successfully coexists with other 802 wireless solutions.

Some of the coexistence results from the 802.15.2 studies are tabulated in document IEEE 802.15-01/195r0 (http://ieee802.org/15/pub/2001/May01/01195r0P802-15_TG2-BT-802-11-Model-Results.pdf). Some of the external studies have been recently reported in the press, e.g., http://www.80211-planet.com/news/article/0,4000,1481_937781,00.html”
COMMENT STATUS: R
RESPONSE STATUS: U
--------------------
COMMENT #: 2
IEEE #: 06810238
NAME: Fischer, Michael
E-MAIL: mfischer@choicemicro.com
PHONE: +1-210-614-4096
FAX: +1-210-614-8192
CO/ORG: Intersil Corp.
PAGE: 1
LINE: 29-30
CLAUSE: 1.1
TYPE OF COMMENT: T
COMMENT: "In clause 1.1 it states:  ""The proposed WPAN standard will be developed to ensure coexistence with all 802.11 networks."" however this subject is not addressed in any normative clause of this draft.  In fact, the word ""coexistence"" does not even appear anywhere else within the 1159 pages of D0.0.2. The characteristics of the 2.4GHz radio and physical layer protocol specified in subsequent clauses shows no clear manner by which such coexistence is even possible in overlapping space with any of the 802.11 PHYs that operate in the 2.4GHz band (FH, DS, 802.11B, and the pending P802.11G).  802.15.1 is the first instance in the past 10 years, and probably the first instance ever in the history of 802 that an 802 draft has gone to sponsor ballot with a proposal to transmit conflicting and mutually incompatible signals onto the SAME INSTANCE of the physical medium as is already in use by another 802 MAC/PHY.  There is not even a plausible argument that 802.11 and 802.15 networks will rarely be operated in overlapping space, since there are devices, such as notebook and subnotebook computers, which are explicitly stated as needing to attach to both WLANs and WPANs, concurrently if not simulatneously."
SUGGESTED REMEDY: "The proper technical solution is to modify the Bluetooth protocol to support an ""etiquette"" for sharing access to the 2.4GHz ISM band -- preferably listen-before-talk, although an approach based on a maximum duration for any transmission and a maximum transmit duty cycle are likely to be easier to implement than LTB."
RESPONSE: "REJECT.
We, the 802.15.1 Ballot Review Committee (BRC), thank the voter very much for taking the time to comment on the draft standard. The BRC acknowledges that it did not communicate its position properly to the sponsor voter in earlier opportunities. The BRC has re-reviewed the voter's comments and it does not share the voter's view.

In the original 802.15 WG IEEE 802 Five Criteria response (http://ieee802.org/15/pub/par/5C.html), we identified that coexistence with 802.11 LANs in the 2.4 GHz band is a critical success factor. The WG has worked and continues to work to assure that its family of 802.15 WPAN standards does coexist with other technologies in this band.

The WG established the 802.15.2 coexistence task group to study this issue within the WG (e.g., 802.15.1) and across WGs (e.g, 802.11). The 802.11 WG formally participates in 802.15.2 activities. Based on studies within and outside this task group, it has been shown, as expected and as the voter mentions, that there is interference between 802.11 and 802.15 nodes operating in the same space, at the same time, and in the same spectrum. However, these studies have also repeatedly demonstrated that the 802.11 nodes continue communicating with each other, and the 802.15.1 nodes continue to communicate with each other even when the 802.11 and 802.15.1 nodes are in the vicinity of each other and utilize the same (2.4 GHz) band. Thus, the 802.15.1 draft standard has demonstrated to satisfy the level of coexistence (the 6th of the IEEE 802 five criteria) advocated in the 802.15.1 PAR.

Based on studies that the group has made (plus studies outside the group and everyday observations), nodes designed based on the first IEEE WPAN draft standard have demonstrated that they can successfully coexists with other 802 wireless solutions.

Some of the coexistence results from the 802.15.2 studies are tabulated in document IEEE 802.15-01/195r0 (http://ieee802.org/15/pub/2001/May01/01195r0P802-15_TG2-BT-802-11-Model-Results.pdf). Some of the external studies have been recently reported in the press, e.g., http://www.80211-planet.com/news/article/0,4000,1481_937781,00.html.

The 802.15.1 editors believe that a coexistence analysis is not part of a protocol standards document. Having assured a desired level of coexistence, such analyses, can be added and presented through the continuing work from the 802.15.2 task group. Thanks to the voter’s comments, the editors have located a typo where the term “co-existence” instead of “coexistence” appears on page 1069, line 2, subclause C.2.5.

Regarding the assertion that 802.15.1 is the first 802 draft to go to sponsor ballot transmitting conflicting and mutually incompatible signals onto the same instance of the physical medium, the BRC notes that the FH and DS PHYs in 802.11 are a previous instance of such a proposal. In CSMA one can listen only to transmissions from similarly modulated transmissions. Furthermore, energy detection is not a required feature for 802.11 implementations. Thus, it is quite possible that FH and DS 802.11 systems operating in the same space interfere with each other. However, there exists no assertion that they cannot coexist. Similarly, the work by 802.15.2 (and from outside groups) has shown that despite mutual interference between 802.11 and 802.15.1 systems, the two technologies can coexist."
COMMENT STATUS: R	
RESPONSE STATUS: U
--------------------
COMMENT #: 9
IEEE #: 06810238
NAME: Fischer, Michael
E-MAIL: mfischer@choicemicro.com
PHONE:  +1-210-614-4096
FAX: +1-210-614-8192
CO/ORG: Intersil Corp.
PAGE: 29
LINE: 34-48
CLAUSE: 7.3
TYPE OF COMMENT: T
COMMENT: "Power class 1 specifies a maximum transmit power of 100mW, which is far in excess of what is reasonably required to provide RF coverage for a 10-meter personal operating space (see 6.1.2.1).  Indeed, according to 6.1.2.1 the principal difference in radio characteristics which justifies the distinction between WLAN and WPAN is that WLAN radios are optimized to provide coverage on the order of 100 meters at the expense of power consumption, and therefore typically use 100mW of transmit power!"
SUGGESTED REMEDY: "Power class 1 should be eliminated, or reduced to a maximum level which is sensible for coverage of a 10-meter personal operating space (such as 4mW or 10mW).  This has the ancillary benefit of simplifying the 802.11 coexistence scenarios by reducing the range at which a Bluetooth piconet can interfere with an 802.11 BSS."
RESPONSE: "REJECT.
We, the 802.15.1 Ballot Review Committee (BRC), thank the voter very much for taking the time to comment on the draft standard. The BRC recognizes that it did not communicate its position properly to the sponsor voter in earlier opportunities. Following a re-review of the voter’s comments, the BRC continues not sharing the voter's view.

The BRC is in full agreement with the voter that power considerations and battery life are indeed among the key differentiating elements between wireless LANs and wireless PANs. Devices that will primarily employ wireless PAN technologies are personal, portable devices like headsets, PDAs, digital cameras, cellular phones, notebook computers, etc. All these devices (even, on occasion, notebook computers) typically operate in a cordless manner away from permanent power (AC) sources. Because of the power constraints, these personal devices will indeed use class 2 (2.5mW) or class 3 (1mW) radios.

However, due to the nature of personal area networking, wireless PAN technologies are heavily driven by the wide range of applications that users of these technologies are and will be involved with. Wireless PAN usage scenarios do not consider simply the wireless connectivity between, say, a PDA and a notebook computer for synchronizing one’s PIM data stored in these personal devices. 

Applications involving wireless PANs envision people in public spaces like malls, airports, museums, etc., using their personal devices to access (extremely) local information resources. For example, using their personal, carry-on devices like PDAs and 3G cellular phones, users will access mall maps, airline flight schedules, exhibit and floor plan information in museums, and so on. For these important wireless PAN applications, the battery-operated personal devices will typically communicate over WPANs with "fixed" WPAN devices, like data attachment gateways (e.g., information kiosks) These fixed devices do not have the power constrains of the personal, carry-on devices, as they can be powered from fixed (regular) electrical outlets. The radios used for these (non-personal) fixed WPAN devices could be made to exceed the power and cost constraints covering the radios to be used in the overwhelming majority of personal devices. Radios for these fixed WPAN devices can thus use class 1 (100mW) radios and, as manufacturers have already demonstrated, have radio receiver sensitivity much higher than the minimum required by the draft standard. The increased power and receiver sensitivity will enable personal devices that use class 2 or 3 radios to interact with information kiosks located beyond the small coverage of these battery-operated devices. Furthermore, the increased coverage area for these fixed WPAN devices will permit information providers to reach WPAN users using a decreased number of information kiosks thus reducing the overall cost for deploying this WPAN application.

The larger coverage area for class 1 radios results in increased challenges in managing their coverage in the presence of additional wireless technologies (WPAN or not) cohabiting in the same space. To provide the necessary tools to the wireless network/deployment administrators to manage the coverage of multiple radios located in the same space, class 1 radios have a mandatory power control feature down to a class 2 level, and an additional optional power control feature (down to -30dBm).”
COMMENT STATUS: R
RESPONSE STATUS: U	
--------------------
COMMENT #: 26
IEEE #: 06810238
NAME: Fischer, Michael
E-MAIL: mfischer@choicemicro.com
PHONE: +1-210-614-4096
FAX: +1-210-614-8192
CO/ORG: Intersil Corp
PAGE: 440-441
LINE: 49-54 and 1-47
CLAUSE: 12.2.2
TYPE OF COMMENT: T
COMMENT: "This clause appears to have been copied from 8802-2, clause 2.3.2.2, which defines MA-UNITDATA.indication from the LLC side of the MAC SAP.  Much of this text is inappropriate when defining the MAC side of the MAC SAP (for example, line 22 on page 441)."
SUGGESTED REMEDY: Please modify this clause to be a definition of the MA-UNITDATA.indication primitive and associated parameter values that will actually be generated by 802.15.1 MAC entities.
RESPONSE: "REJECT.
We, the 802.15.1 Ballot Review Committee (BRC), thank the voter very much for taking the time to comment on the draft standard. The BRC acknowledges that it did not communicate its position properly to the sponsor voter in earlier opportunities. The BRC has re-reviewed the voter's comments and it does not share the voter's view.  We believe that the use of this section from the IEEE Std 802.2 is valid and consistent with this draft standard."
COMMENT STATUS: R
RESPONSE STATUS: U
--------------------
COMMENT #: 27
IEEE #: 06810238
NAME: Fischer, Michael
E-MAIL: mfischer@choicemicro.com
PHONE: +1-210-614-4096
FAX: +1-210-614-8192
CO/ORG: Intersil Corp
PAGE: 441-442
LINE: 49-54 and 1-38	
CLAUSE: 12.2.3
TYPE OF COMMENT: T
COMMENT: "This clause appears to have been copied from 8802-2, clause 2.3.2.3, which defines MA-UNITDATA-STATUS.indication from the LLC side of the MAC SAP.  Much of this text is inappropriate when defining the MAC side of the MAC SAP (a glaring example is the discussion of an ""excessive collisions"" status value on line 19 of page 442)."
SUGGESTED REMEDY: Please modify this clause to be a definition of the MA-UNITDATA-STATUS.indication primitive and associated parameter values that will actually be generated by 802.15.1 MAC entities.
RESPONSE: "REJECT.
We, the 802.15.1 Ballot Review Committee (BRC), thank the voter very much for taking the time to comment on the draft standard. The BRC acknowledges that it did not communicate its position properly to the sponsor voter in earlier opportunities. The BRC has re-reviewed the voter's comments and it does not share the voter's view.  We believe that the use of this section from the IEEE Std 802.2 is valid and consistent with this draft standard."
COMMENT STATUS: R
RESPONSE STATUS: U
--------------------
COMMENT #: 28
IEEE #: 06810238
NAME: Fischer, Michael
E-MAIL: mfischer@choicemicro.com
PHONE: +1-210-614-4096
FAX: +1-210-614-8192
CO/ORG: Intersil Corp
PAGE: 443-447
LINE: 1-54
CLAUSE: 12.3.2
TYPE OF COMMENT: T
COMMENT: "This is a critically important section that appears to be seriously incomplete.  A useful nomenclature is defined, along with references to appropriate items in the foregoing clauses.  There is also useful information in the attempt to identify what portions of the Bluetooth functional decomposition correspond to the 802 PHY layer and 802 MAC sublayer.  However, there is no information about what L2CA primitives are generated, in what order, to perform the MA-UNITDATA.request function; what L2CA_Indications cause an MA-UNITDATA.indication; nor what transmission status information is conveyed in the MA-UNITDATA-STATUS.indication and which (if any) L2CA_Confirm messages supply this status information.  Without a definition of the mapping between the MAC SAP primitives and L2CA primitives, there is insufficient information to understand the ""relationship of Bluetooth entities to IEEE 802 constructs."""
SUGGESTED REMEDY: "Please define which L2CA primitives are generated, in what order, to perform the MA-UNITDATA.request function; which L2CA_Indications cause an MA-UNITDATA.indication; and which transmission status information is conveyed in the MA-UNITDATA-STATUS.indication and which (if any) L2CA_Confirm messages supply this status information.  State whether these definitions are strict (normative) or exemplary (informative), with consideration for whether interoperation of peer MAC entities will be reliable if these definitions are exemplary."
RESPONSE: "REJECT.
We, the 802.15.1 Ballot Review Committee (BRC), thank the voter very much for taking the time to comment on the draft standard. The BRC acknowledges that it did not communicate its position properly to the sponsor voter in earlier opportunities. The BRC has re-reviewed the voter's comments and it does not share the voter's view. We believe that a sufficient level of detail has been provided in this draft standard that allows implementers to build interoperable WPAN devices compliant to this document."
COMMENT STATUS: R
RESPONSE STATUS: U
====================