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[802SEC] 802.18 Draft response to Amtrak FCC Waiver Request

Dear EC Members:

Document link included.

Yesterday, in the 802.18 teleconference, we approved an input to the FCC regarding a request from Amtrak for a waiver of point-to-multipoint transmit power limits for their trackside networks (TSN) in the Northeast Corridor (NEC).

The waiver asks that in order to reduce the number of access points needed, that they be allowed to use the point-to-point transmit power limits to provide Wi-Fi on the trains. This limit, still 1 Watt conducted, allows the use of high gain antennas. For every 3 dB of antenna gain over 6 dB, the conducted power must only be reduced by 1 dB. This allows high power in narrow beams.

The Amtrak request was not accompanied by any study, simulations or test data to indicate the impact on Wi-Fi networks in the vicinity of the rail line. Our ask to the FCC is that they provide us with any Amtrak data on the impact, and that if they do not have data, that the FCC should require them to perform the necessary measurements, simulations and/or tests to show that this trackside network will not become a source of interference to neighboring Wi-Fi networks.

Please review the draft and provide any comments before final editing and formatting. I would need the EC to vote to approve on or before the 27th of February to meet the FCC deadline. It was approved by the members of 802.18 by a vote of 7/0/0. The meeting was announced more than 45 days ago.

The document is here:

Thank you.

Rich Kennedy

Director, Global Spectrum Strategy
HP Enterprise

Board Director, Dynamic Spectrum Alliance
Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group
Chair Emeritus, IEEE 802.11af WLAN in TVWS
Chair, Wi-Fi Alliance Spectrum & Regulatory Task Group<>
(737) 202-7014

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