Index,Date,SA PIN,Name,Comment,Category,Proposed Change
1,07/18/2019 06:58:19 GMT,14778,Benjamin Rolfe,"14.1.2 Coexistence
""A WG proposing a wireless project shall prepare a Coexistence Assessment (CA) document unless it is not applicable.

a) Will the WG create a CA document as part of the WG balloting process as described in
Clause 13? (yes/no)

b) If not, explain why the CA document is not applicable
""
This text is problematic for at least 2 reasons:
(1) in that at the time this question is being answered (in the CSD) the WG normally does not know the content of the proposed new standard, amendment, or revision.
The actual content of the standard would need to be known, which is of course the purpose of creating a project.  It is impossible in the general case to know what will be accepted in the draft before the task group or task force has begun its work.
In the (rare) case where a wireless standard project would not have coexistence impacts, which can only be determined when the draft is near technically complete (e.g. being prepared for WG balloting), the assessment required can be completed and documented in the Coexistence Assessment Document (CAD).
The CAD would be the proper place to document why there are no coexistence impacts.
 (2) Any electromagnetic emission has the potential to impact the operation of a wired or wireless communication system.  The only case in which assessment of the impact would not relevant would be when the project is prohibited by the Project Authorization from transmitting, or  making changes to an existing standard that would affect in any way the transmitted signal, access to the  medium, likelihood, timing, duration or frequency of transmissions, etc.  The only case that comes to mind would be a ""roll up"" revision that adds no new content of any kind to the an existing standard or a standard that is limited to layers above the MAC (in which case there is still value in explaining this in a CAD).
Any new standard, or amendment to an existing standard, potentially impacts coexistence unless.
Unless the project scope is limited to making no changes to MAC or PHY or in any other way can affect what is transmitted and when.
In the (rare) case where the standard project will not substantially affect coexistence properties, the CAD would so document the analysis and conclusions.",Technical,"replace text with:
A WG proposing a wireless project shall prepare a Coexistence Assessment (CA) document,
with the exception of maintenance revisions of an existing standard that DO NOT make functional (normative) changes to the MAC or PHY specifications.
Approval of the coexistence document by both the originating working  group and the 802.19 coexistence working group shall be required prior to initiation of Standards Association balloting of the draft."
2,07/18/2019 07:31:05 GMT,14778,Benjamin Rolfe,"Regarding addition  to the IEEE 802 LMSC Chair's Guidelines and EC Policy Decisions document
Identifying wireless systems likely to be operating in the same frequency bands is certainly necessary to demonstrate ""consideration"" it is only the start of ""consideration"".
""Assessment"" requires more than listing the bands.  Recent history has clearly shown that further guidance is needed.
Specifically, guidance identifying what LMSC expects ""considered' to include ""assessment"" and provide some guidance on what adequate assessment.
Given the technical diversity of 802 wireless standards, there may be many valid methods of determining coexistence impact, but any valid assessment must include a description of how operation of systems based on the subject system will impact other systems likely to be in the band, as well as an assessment of the impacts of other systems operating in the same area will impact the subject systems.
Other considerations may also be valuable, and the LMSC should not constrain the WG from providing more useful information in the CAD nor overly constrain the methods used to assess impacts, but must be clear and unambiguous on what minimum consideration is expected.",Technical,"Add after last paragraph:
An assessment shall, at a minimum, identify the potential impact of the systems based on the proposed standard on the other identified users of the same bands, and what impacts other systems may have on the subject standard.
Assessment should describe the methods used to determine coexistence impacts and performance.
The assessment may include description of mitigating factors which reduce the coexistence impacts.
The assessment may identify mechanisms or characteristics of the subject standard that are available to improve coexistence performance."
3,07/21/2019 23:45:19 GMT,3834,Andrew Myles,"Clause 13 of the proposed IEEE 802 OM states, ""The IEEE 802.19 WG shall have one vote in WG letter ballots that include CA documents""

This text could be improved editorially. It does not make sense to say the WG ""shall have one vote"" because the WG may choose not to vote if it does not have consensus by the deadline. It makes more sense to say the WG may vote, or has the right to vote.",Editorial,"Change to, ""The IEEE 802.19 WG may have one vote in any WG letter ballots that include a CA document."""
4,07/21/2019 23:45:19 GMT,3834,Andrew Myles,"Clause 13 of the proposed IEEE 802 OM states, ""The IEEE 802.19 WG evaluates the CA document, and submits comments on the CA document to the WG letter ballot""

This text could be improved editorially. The second sentence is not written in a way that suggests any particular action. It would be better to say what the WG vote is based on in an active way, rather than some vague sentence about the process.",Editorial,"Change to, ""The IEEE 802.19 WG's vote, and any associated comments, shall be based on its evaluation of the CA document"""
5,07/21/2019 23:45:19 GMT,3834,Andrew Myles,"The proposed IEEE 802 LMSC Chair's Guidelines and EC Policy Decisions states, ""The CA document includes an assessment of the impact on coexistence on the identified standards.  The assessment should consider aspects such as: transmit power, bandwidth, duty cycle, channel access methods and proximity""

The first sentence suggests that an assessment is required for all the identified standards. The problem with this requirement is that it discourages the WG from identifying a full list of standards, because, while it is easy to identify standards operating in the same or adjacent channels, it is not always easy for the WG developing the standards to undertake coexistence assessments. The assessments will often require knowledge not available in the WG.

I am similarly concerned that any requirement reverses the onus of proof so that the WG developing the new standards is required to show there is not a problem, rather than those that believe there is a problem (with the expertise) having to show there is a problem. This is not good practice.",General,"A much better approach is to encourage the WG developing the standard to undertake coexistence assessments (as much as they can), and to set up the process where IEEE 802.19 votes as one that enables a conversation about coexistence to occur in a formal manner (ie under the rules of ballot comment resolution) between the WG developing the standard and other stakeholders (working through the IEEE 802.19 WG).

Change to, ""The CA document shall include any coexistence assessments on the impact of the proposed new standard on the identified standards that have been agreed by the WG developing the new standard. The coexistence assessments should consider aspects such as transmit power, bandwidth, duty cycle, channel access methods and proximity"""
6,07/29/2019 16:53:59 GMT,3256,Paul Nikolich,"The sentence ""The CA document includes an assessment of the impact on coexistence on the identified standards.""
is too vague and needs to be made more specific.",Technical,"Replace the above sentence with:
""The CA document describes nominal use cases and test scenarios in which diverse (new and
 existing) systems are expected to operate. Performance changes among the systems as demonstrated
 with the new system operational or not operational may be identified by suitable performance metrics
 identified in the test scenarios. The use cases and test scenarios should be of sufficient detail to enable
 system engineers to assess the performance change a new system may introduce. The performance
 changes should be used to assess the impact of the new system."""
7,08/01/2019 12:48:29 GMT,70135,Jay Holcomb,suggested up date to the op manual section 13.,General,"in section 13 of op manual: propose adding ...that it meets the intent...

The IEEE 802.19 WG shall have one vote in WG letter ballots that include CA documents. The IEEE 802.19 WG evaluates the CA document that it meets the intent and submits comments on the CA document to the WG letter ballot."
8,08/02/2019 11:36:35 GMT,54010,Billy Verso,"Regarding the proposed modification of LMSC Operations Manual clause 14.1.2 Coexistence... Since, the details of the project output is typically not sufficiently know when the CSD is being generated, it would be best to mandate a CA doc be prepared for every wireless project, except perhaps a revision, but maybe for revisions also just in case it ends up making a material change to the standard. Where there is no change in the PHY or the MAC, the CA doc produced can simply say that there is no coexistance impact since nothing material has changed.",Technical,"replace text with: A WG proposing a wireless project shall prepare a Coexistence Assessment (CA) document, with the exception of a maintenance revision of an existing standard that DOES NOT make functional (normative) changes to its MAC or PHY specifications. Approval of the CA document by both the originating working group and the 802.19 coexistence working group shall be required prior to initiation of Standards Association balloting of the draft."
9,08/02/2019 11:36:35 GMT,54010,Billy Verso,Regarding the addition to the IEEE 802 LMSC Chair's Guidelines and EC Policy Decisions document.... The text provided is okay but additional guidance is needed to clarify the appropriate level of consideration and assessment,Technical,"After the last paragraph add: The assessment shall identify the potential impact that systems based on the proposed standard have on the other identified users of the same bands, and the impact those other systems may have on the subject standard. The assessment should describe the methods used to determine these coexistence performance impacts. The assessment may include a description of mitigating factors which reduce the coexistence impacts.  The assessment may identify mechanisms or characteristics of the subject standard that are available to improve coexistence performance."
10,08/02/2019 12:03:23 GMT,96370,Jaroslaw Niewczas,"Regarding the proposed modification of LMSC Operations Manual clause 14.1.2 Coexistence... Since, the details of the project output is typically not sufficiently known when the CSD is being generated, it would be best to mandate a CA doc be prepared for every wireless project, except perhaps a revision, but maybe for revisions also just in case it ends up making a material change to the standard. Where there is no change in the PHY or the MAC, the CA doc produced can simply say that there is no coexistance impact since nothing material has changed.",Technical,"replace text with: A WG proposing a wireless project shall prepare a Coexistence Assessment (CA) document, with the exception of a maintenance revision of an existing standard that DOES NOT make functional (normative) changes to its MAC or PHY specifications. Approval of the CA document by both the originating working group and the 802.19 coexistence working group shall be required prior to initiation of Standards Association balloting of the draft."
11,08/02/2019 12:03:23 GMT,96370,Jaroslaw Niewczas,Regarding the addition to the IEEE 802 LMSC Chair's Guidelines and EC Policy Decisions document.... The text provided is okay but additional guidance is needed to clarify the appropriate level of consideration and assessment,Technical,"After the last paragraph add: The assessment shall identify the potential impact that systems based on the proposed standard have on the other identified users of the same bands, and the impact those other systems may have on the subject standard. The assessment should describe the methods used to determine these coexistence performance impacts. The assessment may include a description of mitigating factors which reduce the coexistence impacts.  The assessment may identify mechanisms or characteristics of the subject standard that are available to improve coexistence performance."
12,08/02/2019 18:56:09 GMT,49523,Timothy Harrington,"The term ""The CA document shall address coexistence..."" in paragraph 2 of clause 13 is vague",Technical,"replace text with: ""The CA document shall identify an evaluation of the proposed standards coexistence ..."""
13,08/02/2019 18:56:55 GMT,49523,Timothy Harrington,"This text in paragraph 8 of clause 14.2 is unclear: ""The CA document includes an assessment of the impact on coexistence on the identified standards.""",Editorial,"replace text with: ""The CA document includes an assessment of the impact of the proposed standard on coexistence with the existing identified standards."""
14,08/05/2019 20:23:20 GMT,5523,Robert Heile,"Regarding the proposed modification of LMSC Operations Manual clause 14.1.2 Coexistence... Since, the details of the project output is typically not sufficiently know when the CSD is being generated, it would be best to mandate a CA doc be prepared for every wireless project, except perhaps a revision, but maybe for revisions also just in case it ends up making a material change to the standard. Where there is no change in the PHY or the MAC, the CA doc produced can simply say that there is no coexistance impact since nothing material has changed.",Technical,"replace text with: A WG proposing a wireless project shall prepare a Coexistence Assessment (CA) document, with the exception of a maintenance revision of an existing standard that DOES NOT make functional (normative) changes to its MAC or PHY specifications. Approval of the CA document by both the originating working group and the 802.19 coexistence working group shall be required prior to initiation of Standards Association balloting of the draft."
15,08/05/2019 20:23:20 GMT,5523,Robert Heile,Regarding the addition to the IEEE 802 LMSC Chair's Guidelines and EC Policy Decisions document.... The text provided is okay but additional guidance is needed to clarify the appropriate level of consideration and assessment,Technical,"After the last paragraph add: The assessment shall identify the potential impact that systems based on the proposed standard have on the other identified users of the same bands, and the impact those other systems may have on the subject standard. The assessment should describe the methods used to determine these coexistence performance impacts. The assessment may include a description of mitigating factors which reduce the coexistence impacts.  The assessment may identify mechanisms or characteristics of the subject standard that are available to improve coexistence performance."
16,08/06/2019 03:04:59 GMT,70135,Jay Holcomb,"it seems co-existence is part of our standards process to understand how our IEEE 802 standards will work together and with other users when in the same frequency band.  even though the current proposal has moved closer, seems it still needs to go a little further on what is assessment impact that is intended.",Technical,"to help with that could add after the last paragraph in the chair's guidelines something like:
If the assessment impact determines the new standard will affect the performance of any of the identified active standards, the CA document shall explain how the performance is impacted in enough technical detail that improved coexistence could be started if IEEE 802 as a whole determines it is needed."
17,08/06/2019 05:42:18 GMT,96427,Luc DARMON,"Comment 1:
Regarding the proposed modification of LMSC Operations Manual clause 14.1.2 Coexistence... Since, the details of the project output is typically not sufficiently know when the CSD is being generated, it would be best to mandate a CA doc be prepared for every wireless project, except perhaps a revision, but maybe for revisions also just in case it ends up making a material change to the standard. Where there is no change in the PHY or the MAC, the CA doc produced can simply say that there is no coexistence impact since nothing material has changed.

Comment 2: Regarding the addition to the IEEE 802 LMSC Chair's Guidelines and EC Policy Decisions document.... The text provided is okay but additional guidance is needed to clarify the appropriate level of consideration and assessment.",Technical,"to comment 1: Proposed change:
Replace text with: A WG proposing a wireless project shall prepare a Coexistence Assessment (CA) document, with the exception of a maintenance revision of an existing standard that DOES NOT make functional (normative) changes to its MAC or PHY specifications. Approval of the CA document by both the originating working group and the 802.19 coexistence working group shall be required prior to initiation of Standards Association balloting of the draft.

To comment 2: Proposed change:
After the last paragraph add: The assessment shall identify the potential impact that systems based on the proposed standard have on the other identified users of the same bands, and the impact those other systems may have on the subject standard. The assessment should describe the methods used to determine these coexistence performance impacts. The assessment may include a description of mitigating factors which reduce the coexistence impacts.  The assessment may identify mechanisms or characteristics of the subject standard that are available to improve coexistence performance."
18,08/06/2019 12:47:36 GMT,96541,Anthony Fagan,"Regarding the proposed modification of LMSC Operations Manual clause 14
1.2 Coexistence. Since, the details of the project output is typically not
sufficiently know when the CSD is being generated, it would be best to
mandate a CA doc be prepared for every wireless project, except
perhaps a revision, but maybe for revisions also just in case it ends up
making a material change to the standard. Where there is no change in
the PHY or the MAC, the CA doc produced can simply say that there is
no coexistance impact since nothing material has changed.",Technical,"replace text with: A WG proposing a wireless project shall prepare a
Coexistence Assessment (CA) document, with the exception of a
maintenance revision of an existing standard that DOES NOT make
functional (normative) changes to its MAC or PHY specifications.
Approval of the CA document by both the originating working group
and the 802.19 coexistence working group shall be required prior to
initiation of Standards Association balloting of the draft."
19,08/06/2019 12:49:47 GMT,96541,Anthony Fagan,"Regarding the addition to the IEEE 802 LMSC Chair's Guidelines and EC
Policy Decisions document.... The text provided is good but additional
guidance is needed to clarify the appropriate level of consideration and
assessment",Technical,"After the last paragraph add: The assessment shall identify the potential
impact that systems based on the proposed standard have on the other
identified users of the same bands, and the impact those other systems
 may have on the subject standard. The assessment should describe
the methods used to determine these coexistence performance impacts.
 The assessment may include a description of mitigating factors which
reduce the coexistence impacts.  The assessment may identify
mechanisms or characteristics of the subject standard that are
available to improve coexistence performance."