Subject: Re: [ipwave] Commenting on the FCC plan

From: Alexandre Petrescu <[email-masked]>
Date: Fri, 10 Jul 2020 14:42:59 +0200

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(?)
https://www.fcc.gov/document/fcc-seeks-promote-innovation-59-ghz-band-0

Alex

Le 24/01/2020 à 15:11, Alexandre Petrescu a écrit :
> for information, the filing is now visible at
> https://www.fcc.gov/ecfs/filing/10115292918548
> 
> 
> 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 
>> https://www.fcc.gov/ecfs/filings
>>
>> 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.
>>
>> _______________________________________________
>> its mailing list
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>> https://www.ietf.org/mailman/listinfo/its
>>
> 
> _______________________________________________
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---

From: Abdussalam Baryun <[email-masked]>
Date: Fri, 10 Jul 2020 15:31:27 +0200

thanks Alex,

On Fri, Jul 10, 2020 at 2:43 PM Alexandre Petrescu <
[email-masked]> wrote:

> I think it will be licensed or on demand.

> https://www.fcc.gov/document/fcc-seeks-promote-innovation-59-ghz-band-0

Best regards
AB

---

From: "[email-masked]" <[email-masked]>
Date: Fri, 10 Jul 2020 10:33:06 -0400

IPv6 was never restricted on the DSRC Control Channel by the FCC.  I believe this was a restriction mandate by IEEE 1609.x standard(s).

The applicable US Codes of Federal Regulations are:

FCC 47 90.377 for RSU

FCC 47 95.325, 95.359, 95.3159, 95.3163, and 95.3167 which replace 95.1511 since 2017.

Have any questions, let me know.

Francois Simon

Sent from Mail for Windows 10

From: Abdussalam Baryun
Sent: Friday, July 10, 2020 9:31 AM
To: Alexandre Petrescu; its
Subject: Re: [ipwave] Commenting on the FCC plan

thanks Alex,

On Fri, Jul 10, 2020 at 2:43 PM Alexandre Petrescu <[email-masked]> wrote:

Hello,

Best regards

AB

---

From: Alexandre Petrescu <[email-masked]>
Date: Fri, 10 Jul 2020 17:37:08 +0200

This IPv6 restriction doubt aside, has now FCC allocated 5.9GHz channels 
to non-802.11 technologies?

Le 10/07/2020 à 16:33, [email-masked] a écrit :
> IPv6 was never restricted on the DSRC Control Channel by the FCC.  I
>  believe this was a restriction mandate by IEEE 1609.x standard(s).

I can only hope by now that IEEE 1609.x drafts do say "RFC 8691".

> FCC 47 95.325, 95.359, 95.3159, 95.3163, and 95.3167 which replace 

These should say "RFC 8691" to clarify any potential confusion.

Alex

> Sent from Mail <https://go.microsoft.com/fwlink/?LinkId=550986> for 
> Windows 10
> 
> *From: *Abdussalam Baryun <mailto:[email-masked]> *Sent:
> *Friday, July 10, 2020 9:31 AM *To: *Alexandre Petrescu
> <mailto:[email-masked]>; its <mailto:[email-masked]> 
> *Subject: *Re: [ipwave] Commenting on the FCC plan
> 
> thanks Alex,
> 
> On Fri, Jul 10, 2020 at 2:43 PM Alexandre Petrescu 
> <[email-masked] <mailto:[email-masked]>>
> wrote:
> 
> Hello,
> 
> I would like to know wheher FCC advanced well while seeking to
> promote innovation in the 5.9GHz band?
>