Re: [ipwave] Commenting on the FCC plan

Alexandre Petrescu <> Mon, 25 January 2021 16:58 UTC

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From: Alexandre Petrescu <>
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Date: Mon, 25 Jan 2021 17:58:40 +0100
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Subject: Re: [ipwave] Commenting on the FCC plan
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Do you know what is the result of this plan of allocating 5.9GHz bands 
for C-V2X?

Have I missed a follow up of it?


Le 10/07/2020 à 14:42, Alexandre Petrescu a écrit :
> Hello,
> I would like to know wheher FCC advanced well while seeking to promote 
> innovation in the 5.9GHz band?
> In particular, is now IPv6 allowed to run on the control channel 
> 5895-5905MHz on 802.11 in OCB mode?
> The URL to the FCC document stating that seeking of promotion of 
> innovation is this, but I cant figure out a conclusion of it(?)
> Alex
> Le 24/01/2020 à 15:11, Alexandre Petrescu a écrit :
>> for information, the filing is now visible at
>> Le 15/01/2020 à 21:34, Alexandre Petrescu a écrit :
>>> I submitted the comments that are shown in the attached file.
>>> It is possible to submit more comments, maybe with more help from 
>>> interested parties, or to clarify other things.  It's the same URL 
>>> Alex
>>> Le 15/01/2020 à 21:11, Alexandre Petrescu a écrit :
>>>> 6. "In support of its waiver request, 5GAA submitted studies of 
>>>> using 10- and 20-megahertz-wide channels for C-V2X that found that 
>>>> allowing operation on a single 20-megahertz channel will support the 
>>>> introduction
>>>> of services “that [will] enable many important safety applications, 
>>>> such as red light warnings, basic safety messages, emergency alerts, 
>>>> and others, to enhance traffic systems and operations.”"
>>>> My comment is the following: one would benefit from considering 
>>>> carefully the statements from 5GAA.  Depending how it is interpreted 
>>>> it might be advantageous or not.  For my part, I do think that some 
>>>> of the claims of 5GAA in some trials make confusions about cellular 
>>>> technology and DSRC technology.  I do think that there is at least 
>>>> one publicly demonstrated trial under the banner of 5GAA which uses 
>>>> DSRC but it claims cellular technology.
>>>> That said, with respect to the use of the term "C-V2X": it is not 
>>>> very clear throughout the FCC Notice whether C-V2X means the 
>>>> traditional traits of cellular technology that distinguishes it from 
>>>> WiFi (i.e. use cellular frequencies, use a SIM, specific codecs, 
>>>> mandatory base station, etc.) or otherwise it means some more 
>>>> generic "3GPP" technology.  The only place where C-V2X is defined 
>>>> more properly is when, on page 37, it refers to 3GPP Release 14.  
>>>> There is no pointer to a particular 3GPP Rel 14 document.  This lets 
>>>> open the imagination to think that it might mean the WiFi aspects of 
>>>> 3GPP. 3GPP is known to spec things by stepping into WiFi domain very 
>>>> often, even though in practice there are no 3GPP deployments on WiFi 
>>>> - and that, since 3G onwards :-)  In this sense, it might be that 
>>>> 'C-V2X' already means something from WiFi, and why not C-V2X to mean 
>>>> 802.11-OCB and BSM messages?
>>>> This lack of precision in mentioning "C-V2X" is what adds a lot to 
>>>> the confusion - should one accept C-V2X in 5.9GHz bands?  Well yes, 
>>>> provided 'C-V2X' means a WiFi issued by 3GPP by copy/pasting IEEE. 
>>>> Well no, if 'C-V2X' means a pure cellular interface with a SIM card 
>>>> or software, mandatory base station, cellular codecs and specific 
>>>> expensive specific IPR from well-known particular companies.
>>>> 7. "With this Notice, we propose that ITS in this band continue to 
>>>> provide safety of life services. We seek comment on this proposal."
>>>> This is my comment, and backed by a colleague from IETF: on which 
>>>> channel should we run IPv6-over-OCB? (RFC 8691)
>>>> 8. "C-V2X in the 5.905-5.925 GHz band. Specifically, we propose to 
>>>> authorize C-V2X operations in the upper 20 megahertz of the band 
>>>> (5.905-5.925 GHz). We seek specific and detailed comment on this 
>>>> proposal that can fully inform our decision."
>>>> This is my detailed comment: when one wants to authorize a 
>>>> particular technology on a particular band, then one would like to 
>>>> make sure that technology is fully specified and understood.  It is 
>>>> not the case now with 'C-V2X'.  It is a rather new term.  Is it only 
>>>> the V2X part of 3GPP?  Is it the WiFi part of it?  Which spec is 
>>>> meant more precisely?
>>>> This is why, in return, I would like to comment and request to 
>>>> publicize what more precisely is it meant by C-V2X?
>>>> 8. "We seek comment on the available technical studies on C-V2X that 
>>>> should inform our consideration of C-V2X, including any recent studies
>>>> that provide information about how C-V2X would operate in the 5.9 
>>>> GHz band."
>>>> Where are these technical studies?  Which ones?
>>>> 9. "We first seek comment on whether to authorize C-V2X operations 
>>>> in the 5.895-5.905 GHz band."
>>>> My answer is no.  C-V2X is not specified, and it is a too wide term 
>>>> that might mean too many things.  If C-V2X means the WiFi part of 
>>>> 3GPP, and in particular 802.11-2016, in particular OCB mode, in 
>>>> particular BSM messages, then the answer is yes, definitely.  This 
>>>> would also allow RFC 8691 IPv6 over 802.11-OCB to work.
>>>> 10. "Commenters should provide detailed justification to support 
>>>> specific band plan options, including the types of services that 
>>>> could or could not be delivered by unlicensed use or by 
>>>> vehicularrelated
>>>> services under each option."
>>>> The type of the service that I need is the following: forming of 
>>>> convoy of 3 self-driving cars - they use IPv6 over 802.11-OCB on 3 
>>>> distinct 5.9GHz channels in order to minimize interference.   This 
>>>> could not be delivered if only one channel was available for RFC 
>>>> 8691 IPv6-over-802.11-OCB.  The demo is filmed and publicly 
>>>> available on the web.
>>>> 11. "(a) DSRCS Roadside Units (RSUs) operating in the 5895-5905 MHz 
>>>> band must comply with the technical standard Institute of Electrical 
>>>> and Electronics Engineers (IEEE) 802.11p-2010."
>>>> This forgets that 802.11p is an old name and no longer in use.  The 
>>>> users of this name neglect that IEEE 802.11-2016 is the current 
>>>> spec, and which covers old 802.11p behaviour with an 'OCB' mode 
>>>> (Outside the Context of a BSSID).  That is the standard that should 
>>>> be referred to by this FCC Notice and not 802.11p.
>>>> Additionally, I suggest to add the keyword 'IPv6'.  I suggest to add 
>>>> a reference to RFC 8691 titled "Basic Support for IPv6 Networks 
>>>> Operating Outside the Context of a Basic Service Set over IEEE Std 
>>>> 802.11" which is publicly available on the web.
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