| Hi Andy, also, throughout the document TVWS are mentioned in 4.1,4.5, 4.6…so if you propose to remove any reference to TVWS it will affect the document as a whole, and information that seems necessary to explain how the DB and protocol interacts with TVWS devices and the methods of doing so. One can envision that current rules could change, but, why not give the information on both for countries to understand fully what it's choices are?
Thanks Andy, just some early morning thoughts…Sincerely, Nancy Begin forwarded message: Date: February 1, 2012 6:35:09 AM PST
Subject: Re: [paws] Use cases and requirements I-D: sections 1 to 3 (Introduction, Conventions and Terminology, Prior Work)
Hi Andy, All
In section 4.4, license exempt is also mentioned as well. I am conflicted in a global sense when emerging countries, or countries with very different types of gov't want to implement the protocol, will they have enough information to do so? and thereby join the existing DB companies, or will they do their own thing leaving holes in what one hopes will be an interoperable global protocol that deals with TVWS, and/or White spaces in general?
Thanks, just a thought.
SIncerely, Nancy
Scott, All I agree with Jussi that we have now narrowed the definition to apply to TV white spaces, whereas the scope of PAWS is white spaces in general. I would question not only why the lower-priority service would always be licence-exempt, but why the higher priority service would always be licenced. To avoid this issue on 27th Jan I proposed (http://www.ietf.org/mail-archive/web/paws/current/msg00576.html) a revision of the Abstract that avoids the terms licence exempt or unlicensed, or any mention of the regulatory status of the incumbent services. The Abstract derives from the Introduction and the text could be aligned to be the same in the Introduction, with “opportunistic” replacing “secondary” in later sentences in the Introduction. I have checked and there are no further references to licensing in the document, so we don’t need the definitions of licence exempt, light licensing or unlicensed. This is not a regulatory document – we are defining requirements fora protocol. Keep it simple. That just leaves the definition of white space, where the existing spectrum use has now got muddled with the potential for opportunistic use. This can be fixed by taking the white space and white space device definitions together. From Scott, Gerald and Jussi’s comments perhaps we could agree on: White Space (WS) Radio spectrum which is not fully occupied at a specific location and time. White Space device A device which opportunistically uses some part of the white space spectrum, under control of a white space database. A white space device can be an access point, base station, a portable device or similar. In this context, a white space device is required by local regulations to query a database with its location to obtain information about available spectrum. Regards Andy That statement is valid for TV White Spaces on UHF frequencies but does not necessarily apply to all under-utilised radio spectrum. Why would the lower priority service by default be licence-exempt? Kind regards, Jussi Scott, Very good improvements. I would suggest to insert the notion of opportunistic use of the spectrum by white space devices in the last sentence of the definition of “white space” as follows: White Space Radio spectrum which has been allocated and assigned for licensed use, but is not fully occupied by that licensed use at a specific location and time. This spectrum is then <delete>assigned<delete> <insert>allowed<insert> by local regulations <delete>for use<delete> <insert>to be used opportunistically<insert> as licensed-exempt spectrum under control of a white space database.</Insert> This way, it is understood that the database does not “assign” white space devices for them to choose from. Gerald Good to avoid overloading the term "secondary". I have made additional proposed changes to the text below based on your suggestion. "Lower priority opportunistic service" could indeed by used, but I am guessing that we would need some explanation of what that means. Since we now have descriptions of licensed spectrum and license-exempt spectrum, I used these words. Do these changes remove your concerns? I also corrected "location" to "local" in previous text proposed for "White Space". Scott, Great proposal. However, I am still a bit nervous about the definitions of “Protected Entity” and “White Space Devices (WSD)” where the notion of secondary use is included. The secondary status is used in the ITU-R Radio Regulations for a different purpose. In fact, it is possible that a band has already primary and secondary services allotted to it and that the White Space operation is a tertiary opportunistic operation where the two first types of services are not being used. The use of “lower priority opportunistic” service rather than “secondary” service would be preferable to describe white space allocations. Gerald I changed the subject line from " Re: [paws] Discussion on 'license-exempt' vs 'unlicensed' ". Here I try to propose some changes to the draft based on the email discussion. Below is a copy of chapter 2.2. Terminology. I have inserted new terms for 'licensed' and 'license-exempt' and made changes to the term 'white space'. I have tried to work from the perspective that the document should accurately explain the subject with aim that a reader can understand the use cases and the subsequent requirements. No doubt we could include much more text on this topic of spectrum allocation, assignment, licensing and usage. I hope this captures the key points of the discussion. Please do reply if something is still missing. In the context of white space and cognitive radio technologies, the database is an entity which contains current information about available spectrum at any given location and other types of A unique number for each master device and slave device that identifies the manufacturer, model number and serial number. Spectrum that is acquired by an operator over a given service area for a given time period. This is usually done through auctions,award (beauty contest), acquisition from secondary market, company merger & acquisition, first-come / first-served or by government allocation Spectrum that is not assigned to any specific user. One example is the 2.4 Ghz ISM band, where RF devices operate without a formal licensing process. In the USA, license-exempt spectrum is Typically referred to as "unlicensed" spectrum. In this document the terms license-exempt and unlicensed are used interchangeably. An application or device which provides data, information or service to a user based on their location. A device which queries the WS Database to find out the available <Insert>A licensed user of spectrum, when the licensed spectrum has been assigned as white space spectrum.</Insert> <Delete>A primary</Delete><Insert>A licensed</Insert> user of white space spectrum <Delete>which</Delete> is afforded protection against interference by <Delete>secondary</Delete><Insert>license-exempt white space</Insert> users <Delete>(white space devices) for its use</Delete> in a given area and time. The exclusion area for a Protected Entity, held in the database and expressed as a polygon with geospatial points as the vertices. A device which uses the spectrum made available by a master TV white space refers specifically to radio spectrum which has been allocated for TV broadcast, but is not occupied by a TV broadcast, or other licensed user (such as a wireless microphone), at a specific location and time. Radio spectrum which has been allocated <Delete>for some primary use</Delete><Insert>and assigned for licensed use</Insert>, but is not fully occupied by that <Delete>primary use</Delete><Insert> licensed use </Insert> at a specificlocation and time. <Insert>This spectrum is then assigned by <Delete>location</Delete><Insert>local</Insert> regulations for use as licensed-exempt spectrum under control of a white space database.</Insert> A device which is a <Delete>secondary</Delete><Insert>license-exempt</Insert> user of some part of white space spectrum. A white space device can be an access point, base station, a portable device or similar. In this context, a white space device is required to query a database with its location to obtain information about available spectrum. Nancy, This is not that simple. In fact, the qualifiers “license-exempt” and “unlicensed” can apply to more than one thing. If the qualifier applies to a frequency band, different options exist. As an example, in the ITU-R context, an “unlicensed” band is typically a new band, say in the 300 GHz, for which no request has been made for its use. It is therefore un-allocated to a specific service so far and thus it is an “unlicensed” frequency band. Once the ITU-R allocates this band to one or many services on a primary or secondary basis, then the administrations can thendecide under what king of regime it will ‘assign’ this band foroperation. They may decide to allow the use of the band on the basis of licensed operation (with different options to do the assignment: auction, first come/first served, etc.) or allow operation with an exemption of licenses, thus “license-exempt”such as in the 2.4 GHz ISM band. This is also called “unlicensed” in the USA. If the qualifier applies to an operation, the operation can be exempt of license by the local administration, thus a “license-exempt” operation. If, however, someone decides to start an RF transmission operation in a licensed band for which he has no license or in a license-exempt band for which he does not meet the requirements such as operating according to the type of operation for which the band is exempted from a license or he operates outside the technical limits imposed by this license-exempt ruling, his operation is therefore illegal and he is then considered to be running an “unlicensed” operation. If the qualifier applies to the transmission device, such device may be a “license-exempt” device if its operation does not require a specific license or registration with the local administration such as TV receivers of Wi-Fi devices in the 2.4 GHz ISM band. However, if someone smuggles a device that is not allowed in a country by, for example, buying it on eBay and operates it, this is then an illegal device in the country and id de-facto an “unlicensed” device since it has not passed through the normal certification process. Note that a “license-exempt” device still has to go through a certification process and meet the limits imposed by the local regulator for the “license-exempt” operation in the given frequency band whereas an “unlicensed” device may not pass the certification process since it has not been licensed to operation in the country. This is why the qualifier “unlicensed” has to be treated with care and the footnote will need to be crafted very carefully. With respect to your second point, if an administration only allows “licensed” operation, the situation will be much simpler to manage since specific conditions will be attached to these licenses. Gerald Gabor and Gerald, Since we are dealing on a global basis, can there a footnote to "unlicensed" we can use to indicate that "according to each countries regulatory requirements" How to get around the fact that some Countries are or will be "licensed only" by their gov'ts? Thanks Nancy On Jan 30, 2012, at 4:13 PM, Gerald Chouinard wrote:
Gabor, I agree with your proposal. Thisseems to be reasonable. However one needs to be careful with the word‘unlicensed’ which may mean ‘illegal’ operation of an RF device in many administrations. Gerald These look to be very precise definitions, however in everyday use I rarely hear people referring to ISM band as ‘license-exempt’, in most cases the term ‘unlicensed-band’ is used. Therefore, may I suggest that the draft will include the following statement: The terms unlicensed and license-exempt spectrum are used in this document interchangeably and refer to a spectrum in which no formal licensing process is needed for RF devices to operate in, such as the ISM band. - Gabor All, Here is my understanding of the terms: Licensed: Spectrum that is acquired by an operator over a given service area for a given time period. This is usually done through auctions (think of the Telcos), beauty contest, first-come / first-served or by government allocation (e.g., public service). Lightly licensed: Special case where thefrequency allocation is done through first-come / first-served process for a given time frame over a relatively limited service area. The annual license fee is usually small to facilitate the deployment of a service that would not normally be economically attractive. Small local operators would be interested by this (e.g., rural broadband in Canada) and not big Telcos that would normally work with full licensing through auction over large service areas. License-exempt: Operation of RF devices in a frequency band where no formal licensing process is needed such as in the 2.4 GHz ISM band. In the USA, this term is used for a specific type of operation. The FCC should be contacted to clarify it. Unlicensed: Illegal operation of an RF device that can transmit in a frequency band without a duly issued license. In the USA, this term is used to mean “license-exempt," see above. To my knowledge, the term “unlicensed” is used only in the USA to describe a legal operation because the term “license-exempt” has been used for another specific purpose. Since the PAWS addresses the interface to the database for the international market, it should rely on the definition of the terms recognized by the ITU-R. I would suggest the use of ‘licensed’ and ‘license-exempt’ with a footnote indicating that the term ‘unlicensed’ is used in the USA instead of the usual ‘license-exempt’. Gerald _______________________________________________
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