January 2009 doc.: IEEE 802.11-09/0050r1

IEEE P802.11
Wireless LANs

Initial Draft CID 104 Regulatory Comments proposed resolutions
Date: 2009-01-14
Author(s):
Name / Affiliation / Address / Phone / email
Peter Ecclesine / Cisco Systems / 170 W. Tasman Dr., San Jose, CA 95134-1706 / +1-408-527-0815 /


Introduction

Interpretation of a Motion to Adopt

A motion to approve this submission means that the editing instructions and any changed or added material are actioned in the TGmb Draft. This introduction, is not part of the adopted material.

Editing instructions formatted like this are intended to be copied into the TGmb Draft (i.e. they are instructions to the 802.11 editor on how to change the baseline documents).

TGmb Editor: Editing instructions preceded by “TGmb Editor” are instructions to the TGmb editor to modify existing material in the TGmb draft. As a result of adopting the changes, the TGmb editor will execute the instructions rather than copy them to the TGmby Draft.

Summission Note: Notes to the reader of this submission are not part of the motion to adopt. These notes are there to clarify or provide context.

Annex J

Comment 104 on Annex J says “Annex J needs to be cleaned up.”

The Proposed Change says “Accept the submission 11-08/1336r0”

The comment itself is not sufficiently detailed and the Proposed Change includes many technical and editorial changes, so the changes proposed in submission 11-08/1336r0 are examined.

Discussion:

In submission 11-08/1336r0, the 11mb baseline - 802.11-2007, as amended by 802.11k-2008, 802.11r-2008 and 802.11y-2008 – is shown with Track Changes on, and 16 changes are proposed. We number the proposed changes in 11-08/1336r0 for discussion, then propose a comment resolution for each proposed change:

1.  J.1 First sentence: Change “are subject to” to “may be subject to” “WLANs implemented in accordance with this standard and the specifications and definitions referenced in it may be subject to equipment certification and operating requirements established by regional and national regulatory administrations.” Propose accept change 1 because some WLANs are not certified by regional regulatory administrations.

2.  J.1 Second sentence: Change “based upon” to “taking into consideration” “The specification establishes minimum technical requirements for interoperability taking into consideration established regulations at the time this standard was issued.” Propose accept change 2 because some technical requirements for interoperability are not based on regulations, like ISM band channelization.

3.  J.1 Third sentence: Change “, or” to “and” Propose counter change 3 with Change “are subject to revision, or” to “may be revised, or”

4.  J.1 Fifth sentence: Insert “and their successors” after Table I.1 “Implementers are referred to the regulatory sources in Table I.1 and their successors for further information.” Propose accept change 4 because regulatory sources change over time.

5.  J.1 Third paragraph: Change text from “for the OFDM PHY is an index into a set of values for radio equipment sets of rules.” to " points to a row in Tables J.1, J.2, or J.3, wherein elements (specifically the Channel starting frequency, Nominal channel bandwidth, and Channel set) that enable a STA to calculate the center frequencies and nominal channel bandwidth of a set of RF channels are found.” Discussion: counter change 5 because it ignores channel sets and other behaviors that are not specified by regulation. It unnecessarily names Tables J.1, J.2 and J.3. Propose Change text from “for the OFDM PHY is an index into a set of values for radio equipment sets of rules.” to "is an index into a set of values for radio operation in a regulatory domain.”

6.  J.1 Third paragraph: Insert final sentence as shown: “The tables also contain pointers to regulatory documents for each regulatory domain wherein further transmission requirements may be found.” Propose counter change 6 to list the tables. Insert final sentence as shown: “The regulatory class tables also contain pointers to regulatory documents for each regulatory domain wherein further transmission requirements may be found.”

7.  J.1 Fifth paragraph: Change“channel spacing” to “channel bandwidth”. Discusssion: The base standard definition 3.20 Channel spacing is the frequency difference between nonoverlapping adjacent channel center frequencies. In 802.11-2007 “channel spacing” occurs in 14.6.6, 69 occurrances in clause 17, 112 occurrances in Annex A, and 802.11y-2008 adds 6 occurrances in clause 17. “Channel spacing” is used to indicate normative requirements for many emissions characteristics and behaviors, not just “the frequency difference between nonoverlapping adjacent channel center frequencies”. “Channel spacing” in Annex J is directly related to its use in clause 17 and Annex A for normative requirements. Propose reject change 7 because it would uncouple normative requirements from regulatory classes.

  1. J.1 Fifth paragraph: Change definition to “minimum frequency difference between center frequencies of nonoverlapping channels.” Discussion: One problem is the clause 18 PHY has two nominal channel bandwidths, 20 MHz for OFDM and 22 MHz for DSSS. This text change would become ambiguous for the clause 15 and 18 PHYs in DSSS and CCK modulations. Propose counter change 8 Change definition to “frequency difference between nonoverlapping adjacent channel center frequencies when using maximum bandwidth allowed for this regulatory class.”
  2. J.1 Sixth paragraph: Change “shall be the” to “is a” in first sentence. Discussion: This text change would remove the normative requirement to support all channels in a channel set. Propose counter change 9 because it would remove normative requirements from the baseline. Change “shall be the” to “is the” in first sentence.
  3. J.1 Sixth paragraph: Change “that are legal for a regulatory domain and class” to “that are used to calculate a set of RF channels. Discussion: For a device to legally operate on any or all of these channels, they must be allowed under the relevant regulatory specifications.” Propose reject change 10 as added sentence is redundant, the relevant regulatory specifications in the first three paragraphs of Annex I apply to all of Annex J.1.
  4. J.1 Seventh paragraph: Change “limit shall be the maximum transmit power that is legal for a regulatory domain and class” to “limits given in Tables J.1 through J.3 are informative and in all cases regulatory constraints on those power limits apply.” Discussion: The proposed change removes the normative specification of the transmit power limit from the baseline. Propose reject change 11 as the normative requirement for maximum transmit power for some PHYs are specified in J.1.
  5. J.1 Eighth paragraph: Change “of spectral masks and emissions limits that are legal for a regulatory domain and are listed in Table I.1.” to “each element of which points to a row in Table I.2 containing references to regulations where restrictions on emissions in various regulatory domains can be found. These documents are subject to revision and change.” Discussion: counter change 12, removing the redundant last sentence. Propose: Change “of spectral masks and emissions limits that are legal for a regulatory domain and are listed in Table I.1.” to “each element of which points to a row in Table I.2 containing references to regulations where restrictions on emissions in various regulatory domains can be found.”
  6. J.1 Ninth paragraph: Insert “NOTE:” before paragraph and reformat as a note. Propose accept change 13.
  7. J.1 Tenth paragraph: Change “of behaviors that are legal for a regulatory domain and are specified in Table I.3.” to “each element of which points to a row in Table I.3 containing behavior limits and references to regulations where behavior limits in various regulatory domains can be found. These documents are subject to revision and change.” Discussion: counter change 14, removing the redundant last sentence. Propose: Change “of behaviors that are legal for a regulatory domain and are specified in Table I.3.” to “each element of which points to a row in Table I.3 containing behavior limits and references to regulations where behavior limits in various regulatory domains can be found.”
  8. J.1 Eleventh, twelfth and thirteenth paragraphs: Change “The regulatory classes specified for operation” to “Regulatory classes for operation” in eleventh, twelfth and thirteenth paragraphs. Propose accept change 15.
  9. J.1 Insert editing instruction before Table J.1 Change the headers of the tables as follows:

and change “Channel spacing” to “Channel Bandwidth” Propose reject change 16 as it is part of proposed change 7 and would uncouple normative requirements from regulatory classes.

.

Summary of Proposed Resolutions:

Accept: changes 1, 2, 4, 13 and 15

Counter: changes 3, 5, 6, 8, 9, 12 and 14

Reject: based on discussion and editorial instructions in 09/0050r1; 7, 10, 11 and 16

Editorial Instructions:

TGmb Editor: Change baseline text in Annex J, as follows:

J.1 First sentence: Change “are subject to” to “may be subject to”

J.1 Second sentence: Change “based upon” to “taking into consideration”

J.1 Third sentence: Change “are subject to revision” to “may be revised”

J.1 Fifth sentence: Insert “and their successors” after Table I.1

J.1 Third paragraph: Change text from “for the OFDM PHY is an index into a set of values for radio equipment sets of rules.” to "is an index into a set of values for radio operation in a regulatory domain.”

J.1 Third paragraph: Insert final sentence as shown: “The regulatory class tables also contain pointers to regulatory documents for each regulatory domain wherein further transmission requirements may be found.”

J.1 Fifth paragraph: Change definition to “frequency difference between nonoverlapping adjacent channel center frequencies when using maximum bandwidth allowed for this regulatory class.”

J.1 Sixth paragraph: Change “shall be the” to “is the” in first sentence.

J.1 Eighth paragraph: Change “of spectral masks and emissions limits that are legal for a regulatory domain and are listed in Table I.1.” to “each element of which points to a row in Table I.2 containing references to regulations where restrictions on emissions in various regulatory domains can be found.”

J.1 Ninth paragraph: Insert “NOTE:” before paragraph and reformat as a note.

J.1 Tenth paragraph: Change “of behaviors that are legal for a regulatory domain and are specified in Table I.3.” to “each element of which points to a row in Table I.3 containing behavior limits and references to regulations where behavior limits in various regulatory domains can be found.”

J.1 Eleventh, twelfth and thirteenth paragraphs: Change “The regulatory classes specified for operation” to “Regulatory classes for operation” in eleventh, twelfth and thirteenth paragraphs

Submission page 2 Peter Ecclesine, Cisco Systems