problems at a technical level has merit. While a few commenters dismissed the notion that spectrum can or should be shared with unlicensed devices, most commenters signalled “their” their willingness to work with the Commission to determine whether, and under what conditions, U-NIIs might be able to share the band. With skyrocketing demand for commercial broadband wireless technology and services, IEEE 802.11 appreciates those parties willing to engage technical discussions and analysis that must precede a Commission decision to allow U-NIIs to operate in new spectrum or to substantially alter the rules for operating in bands where U-NII devices already exist. In the view of IEEE 802.11, a data-driven analysis, including rigorous testing where needed, is the best approach to ensuring that spectrum resources are put to work for the greatest possible public benefit. IEEE 802.11 urges the Commission to remind all interested parties that time tested administrative processes, which give all parties due process, govern its decisions about whether and how to utilize spectrum resources. The comments highlighted strong alignment around attempting to harmonize emissions rules to enable 802.11ac technology to take maximum advantage of the 5 GHz band. With respect to U-NII-1, a number of parties, including IEEE 802.11, noted the benefits that would flow from alignment with U-NII-2A rules, creating 200 MHz of contiguous spectrum. Other parties highlighted the advantages of harmonizing U-NII-1 with U-NII-3 rules due to the need to find spectrum that will work for outdoor use. This is particular interest the cable industry which is in the process of deploying a massive outdoor Wi-Fi network. After reviewing the comments, IEEE 802.11 joins those parties who believe the Commission should explore the possibility of adopting U-NII-3 rules for the U-NII-1 band, including outdoor use. If such a result were possible, then under U-NII-3 rules, manufacturers would have the flexibility of producing equipment for U-NII-1 that harmonized with either U-NII-2A or U-NII-3.
problems at a technical level has merit. While a few commenters dismissed the notion that “their” spectrum can or should be shared with unlicensed devices, most commenters signalled their willingness to work with the Commission to determine whether, and under what conditions, U-NIIs might be able to share the band. With skyrocketing demand for commercial broadband wireless technology and services, IEEE 802.11 appreciates those parties willing to engage technical discussions and analysis that must precede a Commission decision to allow U-NIIs to operate in new spectrum or to substantially alter the rules for operating in bands where U-NII devices already exist. In the view of IEEE 802.11, a data-driven analysis, including rigorous testing where needed, is the best approach to ensuring that spectrum resources are put to work for the greatest possible public benefit. IEEE 802.11 urges the Commission to remind all interested parties that time tested administrative processes, which give all parties due process, govern its decisions about whether and how to utilize spectrum resources. The comments highlighted strong alignment around attempting to harmonize emissions rules to enable 802.11ac technology to take maximum advantage of the 5 GHz band. With respect to U-NII-1, a number of parties, including IEEE 802.11, noted the benefits that would flow from alignment with U-NII-2A rules, creating 200 MHz of contiguous spectrum. Other parties highlighted the advantages of harmonizing U-NII-1 with U-NII-3 rules due to the need to find spectrum that will work for outdoor use. This is particular interest the cable industry which is in the process of deploying a massive outdoor Wi-Fi network. After reviewing the comments, IEEE 802.11 joins those parties who believe the Commission should explore the possibility of adopting U-NII-3 rules for the U-NII-1 band, including outdoor use. If such a result were possible, then under U-NII-3 rules, manufacturers would have the flexibility of producing equipment for U-NII-1 that harmonized with either U-NII-2A or U-NII-3.