doc.: ieee 802.22-05/0044r2 submission june 2005 carl r. stevenson, wk3c wireless llcslide 1 [draft]...

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June 20 05 Carl R. St evens Slide 1 doc.: IEEE 802.22-05/0044r2 Submission [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless RANs Date: 2005-06-28 N am e C om pany A ddress Phone em ail Carl R.Stevenson W K3C W irelessLLC 4991 Shim erville Rd., Em m aus,PA 18049-4955 610-841-6180 wk3c@ wk3c.com Authors: Notice: This document has been prepared to assist IEEE 802.22. It is offered as a basis for discussion and is not binding on the contributing individual(s) or organization(s). The material in this document is subject to change in form and content after further study. The contributor(s) reserve(s) the right to add, amend or withdraw material contained herein. Release: The contributor grants a free, irrevocable license to the IEEE to incorporate material contained in this contribution, and any modifications thereof, in the creation of an IEEE Standards publication; to copyright in the IEEE’s name any IEEE Standards publication even though it may include portions of this contribution; and at the IEEE’s sole discretion to permit others to reproduce in whole or in part the resulting IEEE Standards publication. The contributor also acknowledges and accepts that this contribution may be made public by IEEE 802.22. Patent Policy and Procedures: The contributor is familiar with the IEEE 802 Patent Policy and Procedures http://standards.ieee.org/guides/bylaws/sb-bylaws.pdf including the statement "IEEE standards may include the known use of patent(s), including patent applications, provided the IEEE receives assurance from the patent holder or applicant with respect to patents essential for compliance with both mandatory and optional portions of the standard." Early disclosure to the Working Group of patent information that might be relevant to the standard is essential to reduce the possibility for delays in the development process and increase the likelihood that the draft publication will be approved for publication. Please notify the Chair Carl R. Stevenson as early as possible, in written or electronic form, if patented technology (or technology under patent application) might be incorporated into a draft standard being developed within the IEEE 802.22 Working Group. If you have

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Page 1: Doc.: IEEE 802.22-05/0044r2 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 1 [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless

June 2005

Carl R. Stevenson, WK3C Wireless LLC

Slide 1

doc.: IEEE 802.22-05/0044r2

Submission

[DRAFT] FCC ex parte presentation on WRANIEEE P802.22 Wireless RANs Date: 2005-06-28

Name Company Address Phone email Carl R. Stevenson WK3C Wireless LLC 4991 Shimerville Rd.,

Emmaus, PA 18049-4955 610-841-6180 [email protected]

Authors:

Notice: This document has been prepared to assist IEEE 802.22. It is offered as a basis for discussion and is not binding on the contributing individual(s) or organization(s). The material in this document is subject to change in form and content after further study. The contributor(s) reserve(s) the right to add, amend or withdraw material contained herein.

Release: The contributor grants a free, irrevocable license to the IEEE to incorporate material contained in this contribution, and any modifications thereof, in the creation of an IEEE Standards publication; to copyright in the IEEE’s name any IEEE Standards publication even though it may include portions of this contribution; and at the IEEE’s sole discretion to permit others to reproduce in whole or in part the resulting IEEE Standards publication. The contributor also acknowledges and accepts that this contribution may be made public by IEEE 802.22.

Patent Policy and Procedures: The contributor is familiar with the IEEE 802 Patent Policy and Procedures http://standards.ieee.org/guides/bylaws/sb-bylaws.pdf including the statement "IEEE standards may include the known use of patent(s), including patent applications, provided the IEEE receives assurance from the patent holder or applicant with respect to patents essential for compliance with both mandatory and optional portions of the standard." Early disclosure to the Working Group of patent information that might be relevant to the standard is essential to reduce the possibility for delays in the development process and increase the likelihood that the draft publication will be approved for publication. Please notify the Chair Carl R. Stevenson as early as possible, in written or electronic form, if patented technology (or technology under patent application) might be incorporated into a draft standard being developed within the IEEE 802.22 Working Group. If you have questions, contact the IEEE Patent Committee Administrator at [email protected].>

Page 2: Doc.: IEEE 802.22-05/0044r2 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 1 [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless

June 2005

Carl R. Stevenson, WK3C Wireless LLC

Slide 2

doc.: IEEE 802.22-05/0044r2

Submission

Abstract

This is a DRAFT outline of a proposed ex parte presentation to the FCC, explaining 802.22’s charter, studies and conclusions to date, goals, etc.

This document is intended for WG approval, review and approval by 802.18, and review and approval by the 802 EC before being formally presented to the FCC.

Page 3: Doc.: IEEE 802.22-05/0044r2 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 1 [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless

June 2005

Carl R. Stevenson, WK3C Wireless LLC

Slide 3

doc.: IEEE 802.22-05/0044r2

Submission

IEEE 802.22 WG Scope and Purpose

• The IEEE 802.22 WG on Wireless Regional Area Networks (“WRANs”) has the following charter, per its approved PAR:– To develop “Cognitive Wireless RAN Medium Access Control (MAC)

and Physical Layer (PHY) specifications” … “(specifying) the air interface, including the medium access control layer (MAC) and physical layer (PHY), of fixed point-to-multipoint wireless regional area networks operating in the VHF/UHF TV broadcast bands between 54MHz and 862 MHz.”

– “This standard is intended to enable deployment of interoperable 802 multivendor wireless regional area network products, to facilitate competition in broadband access by providing alternatives to wireline broadband access and extending the deployability of such systems into diverse geographic areas, including sparsely populated rural areas, while preventing harmful interference to incumbent licensed services in the TV broadcast bands.”

Page 4: Doc.: IEEE 802.22-05/0044r2 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 1 [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless

June 2005

Carl R. Stevenson, WK3C Wireless LLC

Slide 4

doc.: IEEE 802.22-05/0044r2

Submission

Background

• The IEEE 802.22 WG started as a Study Group in the IEEE 802.18 RR-TAG (approved November 2003)– We noted the Commission’s interest in the possibility of making unused

TV spectrum available for use by license-exempt devices, starting with the Spectrum Policy Task Force, NOI ET 02-380, etc.)

– We thought it prudent to begin studies on how this spectrum might best be put to use, should it become available.

– We wanted to explore the issues surrounding coexistence/non-interference with the licensed incumbents.

• All interested stakeholder communities were represented in the Study Group and are actively participating in the 802.22 WG (MSTV, NAB, CEA, wireless microphone interests, PLMRS interests, and “traditional” IEEE 802 participants)

• The PAR for the 802.22 WG was approved iu September 2004, the WG held its first meeting in November 2004, and has been meeting regularly since then.

Page 5: Doc.: IEEE 802.22-05/0044r2 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 1 [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless

June 2005

Carl R. Stevenson, WK3C Wireless LLC

Slide 5

doc.: IEEE 802.22-05/0044r2

Submission

802.22 Progress to Date

• The following slides will summarize the results of our studies and discussions to date – many of which have resulted in broad agreement and point to the need for somewhat different requirements and methodologies than were outlined by the Commission in its NPRM in order to provide reliable protection to licensed services.

Page 6: Doc.: IEEE 802.22-05/0044r2 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 1 [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless

June 2005

Carl R. Stevenson, WK3C Wireless LLC

Slide 6

doc.: IEEE 802.22-05/0044r2

Submission

Fundamental requirements for WRAN systems to protect TV broadcasting

• Fixed outdoor P-MP System with base station professionally installed at known location.

• Base Station pre-programmed with disallowed channels based on pre-installation site survey/system engineering

• Customer Premises Equipment (“CPE”s) should be user-installable, though some operators may opt to require professional installation of CPEs

• Master/Slave relationship between base station and CPEs Base Station controls CPE frequency of operation, TX power, modulation, timing, etc.

• Cognitive radio approach to sensing/avoiding (protecting) incumbents to make system adaptive to changes in incumbent usage, environment, etc.

• Distributed sensing by ALL CPEs across the entire network cell w/centralized intelligence/control at the base station

• Systems should NOT operate on N or N±1 within the protected contour of a DTV station [need clarification on what constitutes protected contour]

• Need to consider DTV D/U’s and DTV receiver saturation for N±2 channels and beyond and resulting possible need for an “EIRP profile”

• Our studies indicate that Part 15.209(a) out-of-band emission levels are insufficient to protect DTV receivers for N±2 and beyond

• We have developed an out-of-band emission mask, based on an agreed deployment scenario {link to values/table}

Page 7: Doc.: IEEE 802.22-05/0044r2 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 1 [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless

June 2005

Carl R. Stevenson, WK3C Wireless LLC

Slide 7

doc.: IEEE 802.22-05/0044r2

Submission

Distributed sensing and Master/Slave control (for DTV protection)

• Base station initially programmed with “keep out” channels, based on site survey/system engineering

• Cognitive radio sensing threshold of -116 dBm in 6 MHz bw (based on sensing DTV pilot at 11.3 dB below total power in the channel), with sensing done by ALL CPEs and centralized intelligence/control at the base station

• CPE antennas outside, sense antennas omni• CPEs may NOT transmit, absent receipt of a control signal from a base

station• Base station totally controls RF operation of CPEs

– Frequencies that may be used– Modulation, Timing, TX power control– Commands to perform sensing on used channel [during quiet periods] or to scan

other channels and report results• Adaptive ability of cognitive radio sensing will preclude interference

despite future changes in incumbent locations and channel assignments

Page 8: Doc.: IEEE 802.22-05/0044r2 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 1 [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless

June 2005

Carl R. Stevenson, WK3C Wireless LLC

Slide 8

doc.: IEEE 802.22-05/0044r2

Submission

Fundamental requirements for WRAN systems to protect Part 74 licensed operations such as

wireless microphones• OOB emissions requirements similar to protecting DTV• Cognitive radio sensing threshold of -107 dBm in 200 kHz bw for sensing wireless

microphones recommended by IEEE 802 in its comments in the NPRM is a best effort, but is not sufficient to fully protect Part 74 wireless microphone operation since the interference range of the CPEs into wireless microphone receivers would be larger than their sensing range for wireless microphone transmitters

• Likelihood of false alarms from unlicensed wireless microphones would render WRAN operation susceptible to potential unintentional (and/or intentional) interference or “denial of service”– Can’t differentiate current between licensed Part 74 users and unlicensed users with current

wireless microphone technology– Use of beacons by the Part 74 wireless microphone operators would alleviate the problem,

assuming the Commission ruled that such devices could only be sold to/operated by Part 74 licensees [no agreement yet as to whether this can be stated or not]

• The Commission should consider a limited number of reserved channels per market – Part 74 users should by required by rule to use these preferentially – Fewer channels needed in more rural areas/smaller markets where WRAN is most needed– In unusual cases (major event in rural area), use of other than reserved channels allowable,

but Part 74 users should coordinate to minimize avoidable impact on WRAN capacity

Page 9: Doc.: IEEE 802.22-05/0044r2 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 1 [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless

June 2005

Carl R. Stevenson, WK3C Wireless LLC

Slide 9

doc.: IEEE 802.22-05/0044r2

Submission

Additional Topics

• Since base station has centralized intelligence/control, it’s easier to update policies to accommodate future change needs

• There is a good likelyhood that IEEE 802.22 will develop a Recommended Practice for installation/deployment of .22 WRAN systems

• Base station registration/light licensing???• Possibility of (proprietary) DTV retransmission equipment (DVD

player to monitor, etc.) or similar devices (outdoor security cameras) could VERY seriously compromise WRAN channel availability/system capacity and ability to provide broadband services to the public

• Urge the FCC not to create another “food fight” band, particularly underneath of primary/secondary licensed operations

Page 10: Doc.: IEEE 802.22-05/0044r2 Submission June 2005 Carl R. Stevenson, WK3C Wireless LLCSlide 1 [DRAFT] FCC ex parte presentation on WRAN IEEE P802.22 Wireless

June 2005

Carl R. Stevenson, WK3C Wireless LLC

Slide 10

doc.: IEEE 802.22-05/0044r2

Submission

References