November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 1Report Regulatory ad-hoc group

Report of the Regulatory ad-hoc group

November, 2000

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 2Report Regulatory ad-hoc group

LMSC ad-hoc RADIO REGULATIONS• the 802 Regulatory Ombudsman conducted a meeting on

Tuesday, November 7, 2000, 8-10 AM

• 50 individuals were present

• The following informational items were addressed:– Pitch for urgent need for activity in the 5 GHz ITU-R work

– Rules changes at various levels to streamline the submittal of position papers

– the establishment of a Memorandum of Understanding between the IEEE and the ITU-R

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 3Report Regulatory ad-hoc group

• Encourage members to informally reference the spectrum interest of IEEE 802 in their contacts with the FCC

• To inform /engage the 802 Regulatory ombudsman wherever actions from LMSC was requested

• To engage a related Interest Group like WECA in contracting a Law Firm to do the actual analysis and reporting work in close cooperation with LMSC

• That the preparatory work towards output papers by the ad-hoc RR group be reviewed and approved in the related Radio Working Groups.

Recommendations from Information items

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 4Report Regulatory ad-hoc group

• follow-up on a request from the FCC to get input from IEEE 802 regarding spread spectrum rules and part 15 rules

• an ad-hoc group was empowered to follow-up and prepare a position paper for review and approval by the various Working Groups

Actions required for this week

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 5Report Regulatory ad-hoc group

Motion for ad-hoc group work• To organize an 802 ad-hoc group to make agenda

suggestions and speakers to the FCC targeted to the Part 15 revision forum and ensure that meeting dates do not conflict with the January 2001 meetings.

• Potential points are: More spectrum for wireless data services World harmonisation of 3 G the use of the MMDS band to be figured

out Protection against interference via a policy Freeing up the regulatory burdens in part 15

15.203 (connector rules) processing gain rule Existing poor spectral efficiency rules

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 6Report Regulatory ad-hoc group

Motion for ad-hoc group work (2)• To empower the group to communicate with FCC people

to understand the requirements of the forum.

• The proposed agenda items to be approved at the 3 WGs at the Wednesday and Thursday plenaries.

• Moved Kerry / seconded Kuwahara

• 17/0/0 dot 11

• 3/0/0 dot 15

• 3/0/0 dot 16

• passes unanimously

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 7Report Regulatory ad-hoc group

• A telephone call by the LMSC Regulatory Ombudsman with Mike Marcus of the FCC taught the following:– The FCC has no plan to rewrite Part 15

– The FCC is looking for a regular communication with LMSC

– Input on a plan for a change of the 15.247 rules

Further information regarding FCC request

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 8Report Regulatory ad-hoc group

Introduction to Position paper• There is drive from industry to provide Direct

Sequence Spread Spectrum Systems with increased data rates which require the use of modulation schemes providing higher spectral efficiency.

• The current requirements for operating under 15.247 are sufficiently ambiguous such that the FCC must judge on a case by case basis which of these systems comply with the spirit of the regulations as written.

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 9Report Regulatory ad-hoc group

Introduction to Position paper (2)• LMSC was approached by the FCC to address two

issues:– To provide questions to the FCC regarding potential

changes to 15.247 for the purpose of discussion in an open forum to occur in the February 2001 timeframe.

– To start a dialog between FCC and IEEE 802 on a regular and ongoing basis.

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 10Report Regulatory ad-hoc group

Ad-hoc group work• The ad-hoc group met on Tuesday, November 7,

from 2-5:30 PM• it agreed on 3 questions and it left the editing and

formatting to a small group• 17 people were present at the end of the meeting

and all approved the forwarding of the questions– Dot11 9/0/1

– Dot15 2/0/0/

– Dot16 0/0/0

• Proposal is in document RR 00/006 Draft [1]

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 11Report Regulatory ad-hoc group

Motion for workk of ad-hoc group• To submit the following 3 questions to the radio

Working Groups for approval as a response to an FCC inquiry for questions to be placed on the agenda of an industry Forum involving revision of FCC part 15.247. (with the necessary editing to make a properly worded position paper and include the meeting schedule) Andren/Kuwahara

• Dot11 9/0/1• Dot15 2/0/0/• Dot16 0/0/0• 17 person presents all supported

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 12Report Regulatory ad-hoc group

Recommendation for FCC contact• The group concluded that in the future, after each

plenary meeting, starting at the March 2001 meeting, a tele-conference with the FCC will be held

• The FCC is asked to formulate questions before the meeting

• The tele-conference will be held on Friday 10 AM, Eastern time

• The conference is led by the LMSC Regulatory Ombudsman, with the 3 Chairmen of the Radio WGs assigning present to indicate who would respond

November 2000

doc.: IEEE 802.RREG-00/007 Dr 1

Vic Hayes, Lucent TechnologiesSlide 13Report Regulatory ad-hoc group

Thanks for your attention