1. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 1 Shure Comments to 802.22 TG1 IEEE P802.22 Wireless RANs Date: 2006-09-19 Authors: Notice: This document has been prepared to assist IEEE 802.22. It is offered as a basis for discussion and is not binding on the contributing individual(s) or organization(s). The material in this document is subject to change in form and content after further study. The contributor(s) reserve(s) the right to add, amend or withdraw material contained herein. Release: The contributor grants a free, irrevocable license to the IEEE to incorporate material contained in this contribution, and any modifications thereof, in the creation of an IEEE Standards publication; to copyright in the IEEE’s name any IEEE Standards publication even though it may include portions of this contribution; and at the IEEE’s sole discretion to permit others to reproduce in whole or in part the resulting IEEE Standards publication. The contributor also acknowledges and accepts that this contribution may be made public by IEEE 802.22. Patent Policy and Procedures: The contributor is familiar with the IEEE 802 Patent Policy and Procedures http://standards.ieee.org/guides/bylaws/sb-bylaws.pdf including the statement "IEEE standards may include the known use of patent(s), including patent applications, provided the IEEE receives assurance from the patent holder or applicant with respect to patents essential for compliance with both mandatory and optional portions of the standard." Early disclosure to the Working Group of patent information that might be relevant to the standard is essential to reduce the possibility for delays in the development process and increase the likelihood that the draft publication will be approved for publication. Please notify the Chairhttp://standards.ieee.org/guides/bylaws/sb-bylaws.pdf Carl R. StevensonCarl R. Stevenson as early as possible, in written or electronic form, if patented technology (or technology under patent application) might be incorporated into a draft standard being developed within the IEEE 802.22 Working Group. If you have questions, contact the IEEE Patent Committee Administrator at patcom@iee.org.patcom@iee.org >

2. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 2 Abstract The 802.22.1 Task Group has proposed the use of dedicated beacons to protect licensed Part 74 secondary users of the TV spectrum from interference. Shure supports this proposal; however we have some concerns about certain of its aspects. Here we attempt to explain some of the use cases that must be considered in designing a standard for beacon operation and recognition by unlicensed devices sharing the TV bands.

3. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 3 Shure Comments to 802.22 TG1 Beacon frequency standardization: Standardizing the beacon frequency within a TV channel should make it easier for WRAN devices to detect and identify a beacon device quickly. Operation on the DTV pilot carrier frequency ~309 kHz above the bottom of the channel has been proposed. However, this is not the most spectrally efficient choice considering that other Part 74 devices will be operating in the same TV channel.

4. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 4 Shure Comments to 802.22 TG1 Given filter constraints, there is insufficient room for a Part 74 audio transmitter to operate below the beacon frequency. This part of the channel might be usable for narrowband data transmission for control purposes. A separation of at least 300-400 kHz above the beacon frequency will be required, particularly since the beacon will operate with 10-20 dB more power than a typical Part 74 audio device. Thus, the beacon effectively requires the use of the bottom 600 kHz of the TV channel.

5. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 5 Shure Comments to 802.22 TG1 Operation of multiple beacons: From the preceding discussion, it is clear that the operation of multiple beacons in separate TV channels would result in an unacceptable loss of spectrum in a large wireless audio setup. Even if additional beacons did not transmit continually, spectrum in each channel would have to be reserved. Therefore, in large, frequency coordinated events, additional beacons (if used) must operate in a single TV channel rather than occupying multiple TV channels.

6. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 6 Shure Comments to 802.22 TG1 What are the implications for 802.22 WRAN devices? The 802.22 device must scan for and detect the beacon signal regardless of which TV channel(s) it is using. The beacon will not be able to “hop” to another TV channel to get the WRAN device’s attention, as this would interfere with other Part 74 devices operating there. Therefore, 802.22 devices must scan all TV channels in the band for beacon signals, not just the channels they intend to use.

7. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 7 Shure Comments to 802.22 TG1 In the U.S., 802.22 devices will presumably operate in either VHF channels 2-6 (“low band”), 7-13 (“high band”), or UHF channels 14-51. (In other countries, the ranges are somewhat different, and some ranges are not available). It is not necessary for an 802.22 device to scan TV channels that are not contiguous with its band of operation. For example, UHF systems do not need to scan VHF channels.

8. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 8 Shure Comments to 802.22 TG1 Tuning Range: There has been some discussion about what tuning ranges an 802.22 device might be able to cover. Due to constraints on cost, complexity, and antenna factors, it may be desirable to subdivide the largest band (UHF) into sub-bands that a WRAN device might cover. In the U.S. the UHF band will be 38 channels (228 MHz) wide (operation is not permitted on channel 37).

9. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 9 Shure Comments to 802.22 TG1 IEEE 802.22 may wish to consider specifying four sub bands of approximately 60 MHz each; e.g. (in the U.S.) channels 14-21, 22-31, 32-41, and 42-51. A WRAN device manufacturer could elect to cover one or more of these sub-bands. Beacon devices could be similarly classified. We note that the FCC has proposed to disallow unlicensed operation in the lowest sub-band in areas where those channels are used by Public Safety stations.

10. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 10 Shure Comments to 802.22 TG1 Example of Incompatible Tuning Ranges

11. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 11 Shure Comments to 802.22 TG1 Proposed band sub-division plan

12. doc.: IEEE 802.22-06/0192r0 Submission September 2006 Edgar Reihl, Shure IncorporatedSlide 12 References IEEE 802.22 Draft Standard D0.1 (22-06-0067-00- 0000_P802-22_D0-1.doc) IEEE 802.22.1 FRD (22-05-0007-47- 0000_RAN_Requirements.doc)