February 2009doc.: IEEE 802.11-09/0239r1

IEEE P802.11
Wireless LANs

Comments on 802.22 Input to 08-260 Petition for Reconsideration
Date: 2009-02-12
Author(s):
Name / Affiliation / Address / Phone / email
Peter Ecclesine / Cisco Systems / 170 W. Tasman Dr., San Jose, CA95134-1706 / +1-408-527-0815 /
Scott Blue / Sensible Radio
Vinko Erceg / Broadcom
Rich Kennedy / ETS-Lindgren

A- Fixed devices (base stations) should be allowed to have multiple fixed client/slave devices

Agree with 802.22 position.

B- Sensing for television signals should not be mandated by the Commission

Agree with 802.22 position.

C- Fixed Base Station Height Should Be Based on HAAT Rather than AGL and not limited to 30m AGL

Agree with 802.22 position

D- PSD Limits and Minimum Occupied Bandwidth Should Be Specified

Disagree with 802.22 position. FCC Part 15 does not specify Minimum Occupied Bandwidth in any other radio bands, and it is not necessary to specify one in this band. There are and will be many modulations in the UHF bands, some of which deliver 32 kilobits per second, and some deliver more. There is no need to restrict the opportunities afforded by shared use of VHF and UHF to the services envisioned by 802.22.

RF Mask

Do not agree with 802.22 position, but do not have an alternate proposal at this time.

The sensing threshold for wireless microphones should be -107 dBm rather than -114 dBm

Part 74 devices need to be sensed within 2 seconds, not 60 seconds

Regarding both of these points, it isimpossible to sense whether ornotawireless microphone is beingoperatedby a part 74licensee or is being operated without a license. The vast majority of mics in use today do not enjoy protection.The only technicallyfeasible way for the FCCtoaddressthis issueisto havelicensees entergeolocation information inthe database andthenrequire thatWSDsreceiverelevantdatabaseupdatesmore frequently.

Synchronized quiet periods are necessary for incumbent sensing

Disagree with 802.22 position. Outdoor operation over tens of square kilometers does not give a priority or right compared with indoor operation in Part 15. Just as individual LANs operating in radar bands must cease operation in order to be certified, the same should be true in TV white space.

802.11 did request that:

Personal/portable Client Mode devices should be relieved of sensing obligations where their master device has frequent contact with the database

•ETSI radar band rules allow a master radar sensing device for all stations that operate under its control – the sensor typically is mounted on the roof and communicates with all RLANs in the building. The same type of system plan should be allowed for Mode I client devices that are in a network receiving messaging from the TV bands database. Where their master device is able to receive changes in channel availability from the TV bands database, all the devices in the network benefit from current information. The rules for personal/portable Mode I client devices should be changed to remove sensing requirements.

Submissionpage 1Peter Ecclesine, Cisco Systems