Re: [ipwave] Commenting on the FCC plan

[Abdussalam Baryun <[e-mail]>]

Thanks Alex,

I will review again and reply as soon as possible,

AB

On Wed, Jan 15, 2020 at 5:41 PM Alexandre Petrescu <
[e-mail]> wrote:

> For information and update.
>
> 1. Deadline: We do not know whether or not today is a deadline.  The FCC
> notice (attached) says the deadline is "30 days after date of
> publication in the Federal Register" but we do not have that date of
> publication in the Federal Register.  For my part, I would like to keep
> that day today January 15th, if possible.  But an interested person of
> help is influenced by a very real-world event in a city in danger, which
> might delay his availability.
>
> The comment to submit at https://www.fcc.gov/ecfs/filings will be
> structured around the following points:
>
> 2. on what channel or frequency band to run IPv6-over-802.11OCB
> specified in RFC8691?  It is not clear from the FCC Notice whether or
> not in the future the implementations of RFC8691 are allowed to exist,
> because of two difficulties:
> 2.1. in the past, it was often suggested by FCC and independent
> commenters that IPv6 should not be put on the 'Control' channel.  The
> Control channel is known to be 5885-5895MHz in America and 5895-5905MHz
> in Europe.
> 2.1.1 Considering the American interpretation of the term 'Control
> channel' (5885-5895MHz), and the future allocation of 5885-5895MHz to
> WiFi, and considering that by that WiFi the FCC Notice assumes to be
> "802.11 with BSSID" (as opposed to '802.11-OCB - Outside the Context of
> a BSSID'), it is clear that RFC 8691 "IPv6 over OCB" can not be run on
> the Control channel - even less in the future than in the past.
> 2.1.2 Considering the EU interpretation of the 'Control channel'
> (5895-5905MHz): this channel would be allocated by FCC still to DSRC in
> the future.  It would be the only channel in which DSRC is allowed.  For
> this channel, the FCC Notice at page 40 refers clearly to IEEE
> 802.11p-2010 (and not to 802.11-2016 which covers both OCB and
> 'with-BSSID').  Is RFC8691 IPv6-over-OCB allowed on the channel
> 5895-5905MHz?  (called 'Control channel' in Europe).
>
> 3. with respect to this comment seek in the FCC Notice: "11. We propose
> to create sub-bands within the 5.9 GHz band to allow unlicensed
> operations to operate in the lower 45 megahertz of the band (5.850-5.895
> GHz) and reserve the upper 30 megahertz of the band (5.895-5.925 GHz)
> for ITS. We seek comment on this proposal"
>
> This is my comment: you seem to need a 45 MHz band from the 5.9GHz
> domain in order to stick close to another WiFi band such as to allow the
> codecs to do more bandwidth.  An alternative is the following: find
> another place for that 45MHz (not at 5.9GHz).  Invent a new technique of
> creating a wide band by virtually sticking two disparate bands from
> largely different domains: take one 20MHz band from WiFi 5GHz and
> another, e.g. 100MHz, from a 70GHz domain, for example.  The continuity
> of band is an artificial requirement.  Just as artificial limits existed
> in the max file length on FAT16 at 2Gbyte (if I recollect correctly the
> numbers).
>
> 4. "we seek comment on the state of DSRC-based deployment".
> This is my comment: there are very many RSUs installed in Europe and
> very few people who use them.  There are many individual demonstrators
> in cars.  There are no smartphones with DSRC capability.  There are some
> encouraging trials of IPv6-over-802.11-OCB RFC8691 including RSUs,
> platoons and in laboratory.
>
> 5. "We seek comment on the transportation and vehicular-safety related
> applications that are particularly suited for the 5.9 GHz band as
> compared to other spectrum bands, and how various bands can be used
> efficiently and effectively to provide these applications."
> This is my comment: 5.9GHz is more straight, or line-of-sight if you
> wish, than 3.5GHz or 2.4GHz; this means on one hand that it has a harder
> time to get around the corners but, just because of that, it is better
> suited for use with cheap simple reflectors.  Whether that is good or
> not of applications: there are many layers between PHY and APP.  These
> layers are what makes applications work ok on the right PHY.  It is not
> the 5.9GHz that is better adapted or less well adapted to a particular
> app (safety).  There are hugely safe apps that run on PHYs at very many
> frequencies, from very low to very high.  One should avoid a situation
> that risks the solution proposed in the notice to not be adapted, and to
> issue again the same problems later (i.e. use WiFi and C-V2X and still
> not obtain safety; examples abound: cellular technologies are bringing
> huge safety risks when applied like with Uber (sexism, wild parking,
> drivers' rights), scooter accidents (reserved over cellular), double
> Tesla accidents in just one last month, and more.
>
> more later.
>
> Alex
>
>
> Le 08/01/2020 à 16:13, Alexandre Petrescu a écrit :
> > For information and update,
> >
> > With Abdussalam we discussed in private:
> > - potential implication of an ISOC representative in making a comment
> > - the URL to file the comment is https://www.fcc.gov/ecfs/filings
> > - the potential comment is
> >    "what is the channel on which to use IPv6 (RFC8691 now)?"
> >    Because the FCC Notice of Proposed Rulemaking does not contain the
> >    word IPv6; and because often in the past FCC was not clear about
> >    allowing IPv6 on the 'control' channel 5895-5905MHz; this is
> >    potentially the only channel allowed for 802.11-OCB (aka DSRC) in the
> >    future - the rest of 5.9GHz channels would go to 802.11ax and to
> >    C-V2X.
> > - the deadline for filing comments is January 15th (30 days from Dec.
> >    17th).
> >
> > I am looking for interest in this.
> >
> > Alex
> >
> > Le 20/12/2019 à 13:04, Alexandre Petrescu a écrit :
> >> Hi, IPWAVErs,
> >>
> >> I am interested in commenting on the FCC plan for 5.9GHz band, in
> >> particular with respect to the channel(s) on which to use
> >> IPv6-over-802.11-OCB.
> >>
> >> There seems to be a window of opportunity of 30 days from publishing
> >> date of Dec. 17th.
> >>
> >> Is anybody planning to comment?  Is someone part of a group that would
> >> like to comment?
> >>
> >> (attached the FCC notice)
> >>
> >> Alex
> >>
> >> Le 18/12/2019 à 11:06, Alexandre Petrescu a écrit :
> >>>
> >>>
> >>> Le 17/12/2019 à 16:23, Jérôme Härri a écrit :
> >>>> Dear All,
> >>>>
> >>>> Sorry, wrong link..it was a presentation..
> >>>>
> >>>> But here is the paper:
> >>>>
> >>>>
> http://www.eurecom.fr/fr/publication/5191/detail/can-ieee-802-11p-and-wi-fi-coexist-in-the-5-9ghz-its-band
> >>>>
> >>>
> >>> Jérôme,
> >>>
> >>> Thanks for the pointer to that article of 2017.  Its introductory parts
> >>> are no short of predicting what is happening now with the FCC plan in
> >>> the 5850-5895MHz band for WiFi and OCB.
> >>>
> >>> The paper seems to suggest a WiFi-OCB co-existence solution backed by
> >>> cognitive radio concept and simulation.
> >>>
> >>> Are there implementations of the WiFi-OCB co-existence in the same
> band?
> >>>
> >>> Is there a demonstrator showing that WiFi with BSS and WiFi in OCB mode
> >>> can live together ok in same band?  A packet dump would be
> illustrative.
> >>>
> >>> The IPv6-over-OCB draft makes a MUST to use QoS Data headers.  Would
> >>> IPv6-over-WiFi-with-BSS also be a MUST to use such headers?
> >>>
> >>> Alex
> >>>
> >>>>
> >>>> BR,
> >>>>
> >>>> Jérôme
> >>>>
> >>>> -----Original Message----- From: Jérôme Härri <[e-mail]>
> >>>> Sent: Tuesday, 17 December 2019 16:09 To: 'Alexandre Petrescu'
> >>>> <[e-mail]>; 'Abdussalam Baryun'
> >>>> <[e-mail]> Cc: 'its' <[e-mail]> Subject: RE:
> >>>> [ipwave] FCC Moves Plan Forward to Chop Up Vehicle Safety Airwaves
> >>>>
> >>>> Dear All,
> >>>>
> >>>> We did a study a few months ago related to the coexistence between
> >>>> WiFi and OCB on the same channel. Please find it here:
> >>>>
> >>>>
> http://www.eurecom.fr/fr/publication/5395/detail/coexistence-challenges-between-rlans-and-etsi-its-g5-at-5-9ghz-for-future-connected-vehicles
> >>>>
> >>>>
> >>>>  John Kenney and his team also make a similar study as well...
> >>>>
> >>>> The methods have slightly changed since this publication, but
> >>>> problems would still occur: which technology should 'vacate' in case
> >>>> of interferences? As far as I understood, OCB still is the
> >>>> primary..but I leave other expert to correct this statement if I am
> >>>> wrong,
> >>>>
> >>>> BR,
> >>>>
> >>>> Jérôme
> >>>>
> >>>> -----Original Message----- From: its <[e-mail]> On Behalf
> >>>> Of Alexandre Petrescu Sent: Tuesday, 17 December 2019 15:45 To:
> >>>> Abdussalam Baryun <[e-mail]> Cc: its
> >>>> <[e-mail]> Subject: Re: [ipwave] FCC Moves Plan Forward to Chop
> >>>> Up Vehicle Safety Airwaves
> >>>>
> >>>>
> >>>>
> >>>> Le 17/12/2019 à 15:29, Abdussalam Baryun a écrit :
> >>>>> I think IEEE defines WLAN as IEEE802.11. so any IEEE802.11xx
> >>>>> standard can be called a WLAN standard. http://www.ieee802.org/11/
> >>>>
> >>>> Right.
> >>>>
> >>>> And a channel in the 2.4GHz band (WLAN) can not be linked with a
> >>>> channel in the 5.9GHz band (WLAN) because the former is ran with a
> >>>> BSS whereas the latter is Outside the Context of a BSS (OCB).  As
> >>>> such it is impossible to realize the FCC claim to provide cutting
> >>>> edge high throughput bandwidth ("the Commission proposes to designate
> >>>> the lower 45 megahertz of the band for unlicensed uses like Wi-Fi.
> >>>> This 45 megahertz sub-band can be combined with existing unlicensed
> >>>> spectrum to provide cutting-edge high-throughput broadband
> >>>> applications on channels up to 160 megahertz wide.")
> >>>>
> >>>> So if FCC wants to run WiFi with a BSS in this 5875-5895MHz band,
> >>>> such as to legitimately call it WiFi, and to achieve high throughput,
> >>>> then it can only be in mode with a BSS, and it can not be in mode
> >>>> without a BSS (OCB).
> >>>>
> >>>>> also IEEE defines WMAN as IEEE802.16 technology, which was replaced
> >>>>> by LTE cellular technology.
> >>>>
> >>>> There is indeed a similarity.
> >>>>
> >>>> But 802.16 is more different than 802.11 than 802.11-OCB is different
> >>>> than 802.11.
> >>>>
> >>>> 802.16 runs in licensed and paid spectrum (one has to acquire i.e.
> >>>> pay money to get) whereas 802.11-OCB one does not have to buy
> >>>> spectrum.
> >>>>
> >>>> There are other stronger differences I think.
> >>>>
> >>>>>
> >>>>> AB
> >>>>>
> >>>>> On Tue, Dec 17, 2019 at 3:54 PM Alexandre Petrescu
> >>>>> <[e-mail]
> >>>>> <mailto:[e-mail]>> wrote:
> >>>>>
> >>>>>
> >>>>>
> >>>>> Le 17/12/2019 à 14:40, Abdussalam Baryun a écrit :
> >>>>>> V2X and V2V communications had two design proposals:
> >>>>>>
> >>>>>> 1- using WLAN technology 2- using Cellular network technology
> >>>>>>
> >>>>>> So we worked on the first in this WG.
> >>>>>
> >>>>> OCB is not the typical WLAN - it is 802.11 in mode OCB.  One cant
> >>>>> link OCB channels to non-OCB channels (typical WiFi) such as to
> >>>>> make very large channel widhts they seem to need.
> >>>>>
> >>>>>
> >>>>> in frequency yes
> >>>>
> >>>> In practice: how do you think it is possible to link together two
> >>>> channels one from 5.4GHZ WiFi and one from 5.9GHz OCB?
> >>>>
> >>>> I think for my part of the 'iw' command.  That allows to link
> >>>> together two channels, by specifying the channel width: 10MHz, 20MHz,
> >>>> etc.  But they must be adjacent in the first places.
> >>>>
> >>>> And one cant do that linking to create a channel that is in part OCB
> >>>> and in part non-OCB.  Light can be wave and particle but channel cant
> >>>> be both OCB and with BSS.
> >>>>
> >>>>>
> >>>>> I think FCC wants much parts of the 5.9GHz for WLAN (not OCB) and
> >>>>> other parts for C-V2X.
> >>>>>
> >>>>> FCC is pushing for 5G services/qualities to be achieved.
> >>>>
> >>>> It is a good goal that I share entirely.  But dont invade other
> >>>> goals.
> >>>>
> >>>>> I think it may depend on locations/regions, because some locations
> >>>>> may not have good cellular communication signals.
> >>>>
> >>>> FCC does not talk about locations or regions.
> >>>>
> >>>> But I do agree with you on the principle.  I talked recently to a
> >>>> highway operator complaining about the lack of 3G 4G feasibility on
> >>>> their roads.
> >>>>>
> >>>>>
> >>>>> I think the FCC question is whether or not to keep the
> >>>>> 5895-5905MHz for DSRC or to give that too to C-V2X; that is the
> >>>>> only question they formulate.
> >>>>>
> >>>>>
> >>>>> I agree, they are pushing for that,
> >>>>>
> >>>>>
> >>>>> That channel is a place where FCC hardly allowed for IPv6 in the
> >>>>> first place.  Even in this WG it was often said that IPv6 is not
> >>>>> for that channel.
> >>>>>
> >>>>> I think there is no place for OCB mode anywhere and even less for
> >>>>> IPv6.
> >>>>>
> >>>>>
> >>>>> we never know what will happen tomorrow.
> >>>>
> >>>> BUt we cant work without a solid basis.
> >>>>
> >>>> Alex
> >>>>
> >>>>>
> >>>>> AB
> >>>>>
> >>>>>
> >>>>> Alex
> >>>>>>
> >>>>>> On Tue, Dec 17, 2019 at 12:58 PM Alexandre Petrescu
> >>>>>> <[e-mail]
> >>>>> <mailto:[e-mail]>
> >>>>> <mailto:[e-mail]
> >>>>> <mailto:[e-mail]>>> wrote:
> >>>>>>
> >>>>>>> https://docs.fcc.gov/public/attachments/DOC-361339A1.pdf
> >>>>>>
> >>>>>>> For Immediate Release FCC SEEKS TO PROMOTE INNOVATION IN
> >>>>> THE 5.9 GHZ
> >>>>>>> BAND WASHINGTON, December 12, 2019—The Federal Communications
> >>>>>>> Commission today voted[...]
> >>>>>>
> >>>>>> What does C in C-V2X mean?  Is it Cellular V2X like in 3GPP?
> >>>>> I assume
> >>>>>> this is what is meant by C-V2X: point-to-point links from 3GPP.
> >>>>>>
> >>>>>> Yes, there are 4G and 5G
> >>>>>>
> >>>>>> Or is C-V2X something more like BSM messages put on 802.11
> >>>>> kind of link
> >>>>>> (be it OCB or more traditional WiFi)?
> >>>>>>
> >>>>>>
> >>>>>> no it is cellular network communication  technologies/protocols
> >>>>>>
> >>>>>>
> >>>>>> What does C-V2X mean entirely?  Is it sending BSM messages or
> >>>>> is it also
> >>>>>> sending CAM messages (in 3GPP there are only CAM messages
> >>>>> AFAIremember).
> >>>>>>
> >>>>>> What are the implementations of C-V2X  and on which hardware
> >>>>> from which
> >>>>>> manufacturer?
> >>>>>>
> >>>>>>
> >>>>>> see our draft mentions c-v2x:
> >>>>>>
> >>>>>>
> >>>>>
> https://tools.ietf.org/html/draft-ietf-ipwave-vehicular-networking-03#
> >>>>>
> >>>>>
> >>> page-19
> >>>>>
> >>>>>
> >>>>>
> >>>>>
> >>>>>> I think it is important that we do more work for the C-V2X
> >>>>> section in
> >>>>>> the draft as well.
> >>>>>>
> >>>>>>
> >>>>>> Detailing this term is key to understand the plan and to be
> >>>>> able to
> >>>>>> answer the consultation.  It might be very worrisome as well
> >>>>> as it might
> >>>>>> be nothing new but a change in terms.
> >>>>>>
> >>>>>>
> >>>>>> The C-V2X is challenging with WiFi V2X, it depends on what is
> >>>>>> mostly used by countries, but the WiFi is probably will win.
> >>>>>>
> >>>>>> AB
> >>>>>>
> >>>>>>
> >>>>>
> >>>>
> >>>> _______________________________________________ its mailing list
> >>>> [e-mail] https://www.ietf.org/mailman/listinfo/its
> >>>>
> >>>
> >>> _______________________________________________
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> >>
> >> _______________________________________________
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> >>
> >
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