The FCC should the rule changes “miscellaneous” proposed IEEE 802.11 supports the following miscellaneous rule changes detailed in the Notice, and urges their prompt adoption: Section 15.403 definitions replaces Power Spectral Density” with Power “Peak “Maximum Spectrum Density. IEE 802.11 also suggest a modification to Section 15.403(s) to include the 5.825-5.850 MHz spectrum in the definition of U-NII spectrum to help ensure that spectrum will be used by broadband technologies. Section 15.407 deletes the second sentence which is no longer relevant; also replaces – “peak” with and specifies that all peak excursion measurements are to the highest average “maximum”; in each corresponding 1 megahertz band. Section 15.215 clarify that the 20 dB bandwidth limitation for ultrawideband devices does not – apply to 15.407 devices so as to allow wide channelization of U-NII devices. Section 15.247 the section numbers in paragraph (b). –correcting In addition, IEEE 802.11 proposes to change PSD requirements from 8dBm/3kHz to 23.2dBm/100KHz for the sub-1GHz unlicensed that are not part of the TVWS rules. Adopt the proposed transition period for equipment to comply with newly-enacted rules The Notice proposes a 12-month period for manufacturers to produce compliant equipment after adoption of a rule change and a two year period from the date of rule change to actual cessation of permissive changes to formerly compliant equipment. Essentially, the cessation of permissive changes functions as a date, as manufacturers can no longer evolve the formerly compliant equipment to “stop” keep up with new technology and capabilities. The Notice proposes to grandfather existing equipment
The FCC should the “miscellaneous” rule changes proposed IEEE 802.11 supports the following miscellaneous rule changes detailed in the Notice, and urges their prompt adoption: Section 15.403 definitions replaces “Peak Power Spectral Density” with “Maximum Power Spectrum Density. IEE 802.11 also suggest a modification to Section 15.403(s) to include the 5.825-5.850 MHz spectrum in the definition of U-NII spectrum to help ensure that spectrum will be used by broadband technologies. Section 15.407 – deletes the second sentence which is no longer relevant; also replaces “peak” with “maximum”; and specifies that all peak excursion measurements are to the highest average in each corresponding 1 megahertz band. Section 15.215 – clarify that the 20 dB bandwidth limitation for ultrawideband devices does not apply to 15.407 devices so as to allow wide channelization of U-NII devices. Section 15.247 –correcting the section numbers in paragraph (b). In addition, IEEE 802.11 proposes to change PSD requirements from 8dBm/3kHz to 23.2dBm/100KHz for the sub-1GHz unlicensed that are not part of the TVWS rules. Adopt the proposed transition period for equipment to comply with newly-enacted rules The Notice proposes a 12-month period for manufacturers to produce compliant equipment after adoption of a rule change and a two year period from the date of rule change to actual cessation of permissive changes to formerly compliant equipment. Essentially, the cessation of permissive changes functions as a “stop” date, as manufacturers can no longer evolve the formerly compliant equipment to keep up with new technology and capabilities. The Notice proposes to grandfather existing equipment
18-13-0064-00-0000-draft-802-comments-to-fcc-u-nii-band-nprm-fcc-13-49.docx