IEEE 802.18-18/0061r00 Teleconference Agenda Summary

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"Stay informed about the details and guidelines for IEEE 802.18-18/0061r00 teleconference agenda, including important administrative items, participation rules, and compliance requirements for IEEE WG meetings."

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  1. 31 May 2018 doc.: IEEE 802.18-18/0061r00 IEEE 802.18 RR-TAG Teleconference Agenda Dates: 31 May 18 Authors: Name Jay Holcomb, Chair Affiliations Address Itron, Inc. Phone +1(509)891-3281 email jay.holcomb@itron.com Liberty Lake (Spokane) WA Agenda Slide 1 Jay Holcomb (Itron)

  2. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Call to Order / Administrative Items Number of voters: 41 (8 on EC); Nearly voters: 1; Aspirant members: 9 With teleconferences approval on 08 March 2018, quorum is met. Required notices Affiliation FAQ - http://standards.ieee.org/faqs/affiliationFAQ.html > Be sure to announce you name, affiliation, employer and clients the first time you speak. Anti-Trust FAQ - http://standards.ieee.org/resources/antitrust-guidelines.pdf Ethics - https://www.ieee.org/about/corporate/governance/p7-8.html IEEE 802 WG Policies and Procedures - http://www.ieee802.org/devdocs.shtml The 4 administration slides, reminder from your WG opening plenary new 02jan18 (note: call for essential patents is n/a, as the RR-TAG does not do standards) Officers or the RR-TAG / IEEE 802.18: Chair is Jay Holcomb (Itron) Vice-chair is open Secretary is Allan Zhu (Huawei) Agenda Slide 2 Jay Holcomb (Itron)

  3. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Other Guidelines for IEEE WG Meetings All IEEE-SA standards meetings shall be conducted in compliance with all applicable laws, including antitrust and competition laws. Don t discuss the interpretation, validity, or essentiality of patents/patent claims. Don t discuss specific license rates, terms, or conditions. Relative costs of different technical approaches that include relative costs of patent licensing terms may be discussed in standards development meetings. Technical considerations remain the primary focus Don t discuss or engage in the fixing of product prices, allocation of customers, or division of sales markets. Don t discuss the status or substance of ongoing or threatened litigation. Don t be silent if inappropriate topics are discussed do formally object. --------------------------------------------------------------- For more details, see IEEE-SA Standards Board Operations Manual, clause 5.3.10 and Antitrust and Competition Policy: What You Need to Know at http://standards.ieee.org/develop/policies/antitrust.pdf Agenda Slide 3 Jay Holcomb (Itron)

  4. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Participation in IEEE 802 Meetings Participation in any IEEE 802 meeting (Sponsor, Sponsor subgroup, Working Group, Working Group subgroup, etc.) is on an individual basis Participants in the IEEE standards development individual process shall act based on their qualifications and experience. (https://standards.ieee.org/develop/policies/bylaws/sb_bylaws.pdf section 5.2.1) IEEE 802 Working Group membership is by individual; Working Group members shall participate in the consensus process in a manner consistent with their professional expert opinion as individuals, and not as organizational representatives . (subclause 4.2.1 Establishment , of the IEEE 802 LMSC Working Group Policies and Procedures) Participants have an obligation to act and vote as an individual and not under the direction of any other individual or group. A Participant s obligation to act and vote as an individual applies in all cases, regardless of any external commitments, agreements, contracts, or orders. Participants shall not direct the actions or votes of any other member of an IEEE 802 Working Group or retaliate against any other member for their actions or votes within IEEE 802 Working Group meetings, see https://standards.ieee.org/develop/policies/bylaws/sb_bylaws.pdf section 5.2.1.3 and the IEEE 802 LMSC Working Group Policies and Procedures, subclause 3.4.1 Chair , list item x. By participating in IEEE 802 meetings, you accept these requirements. If you do not agree to these policies then you shall not participate. (and please leave the call.) Slide 4 Agenda Jay Holcomb (Itron)

  5. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Agenda Call to Order Discussion items, few more details: Attendance server is open Administrative items Need a recording secretary Approve agenda & last minutes WRC -19 AI 1.13 IMT , question from developing country regulatory why not IMT designation? EU Items, what is the latest from members. Anything we should respond to? Any interest in being the 802.18 Vice-Chair? Discussion items WRC -19 AI 1.13 IMT EU Items IEEE-SA draft position on Additional Spectrum Needed A Future for Unlicensed Spectrum 802.18 List Server 6th FNPRM on 4.9 GHz NPRM 2.5 GHz IEEE-SA draft position on Additional Spectrum Needed Another update from IEEE SA A Future for Unlicensed Spectrum What can we do to help regulators to open up more unlicensed spectrum. 802.18 List Server Good time to review, and its purpose. Also updated IEEE Privacy Policy 6th FNPRM on 4.9 GHz, any interest? alternatives to stimulate expanded use of and investment in the 4.9 GHz band NPRM 2.5 GHz, any interest? providing new opportunities for additional entities to obtain unused 2.5 GHz spectrum (seems licensed ) Actions required What happens during the call AOB and Adjourn Agenda Agenda Slide 5 Jay Holcomb (Itron)

  6. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Motions - administrative Motion: To approve the agenda as presented on previous slide Moved by: Seconded by: Discussion? Vote: Unanimous consent Motion: To approve minutes from the IEEE 802.18 teleconference on 17 May 2018; https://mentor.ieee.org/802.18/dcn/18/18-18-0059-00-0000-minutes-17may18-rr- tag-teleconference.doc; Posted: 29-May-2018 21:11:40 ET Moved by: Seconded by: Discussion? Vote: Unanimous consent Agenda Slide 6 Jay Holcomb (Itron)

  7. 31 May 2018 doc.: IEEE 802.18-18/0061r00 WRC -19 AI 1.13 IMT The document https://mentor.ieee.org/802.18/dcn/17/18-17-0073-06-0000- ieee-802-viewpoints-on-wrc-19-agenda-items.pptx has been passed onto some developing country regulators, a question came in on IMT. The summary of the question: In the light of the above understanding on (1) IMT identification not entailing exclusivity, and (2) IMT identification not entailing infeasibility of licence exempt, may I kindly seek clarification on your current view on AI 1.13. Our final bullet seems to speak to this: Given these facts, we believe that a wide variety of 5G services and use-cases will be deployed in this band globally without the need for an IMT identification. In fact, IMT identification could bar some key 5G technologies from operating in this band. Agenda Slide 7 Jay Holcomb (Itron)

  8. 31 May 2018 doc.: IEEE 802.18-18/0061r00 WRC -19 AI 1.13 IMT What else can we feed back to add to this? From 17 May. ITU-R has IMT defined primarily to support mobile services, so to get that primary designation it is not clear how un-licensed would be designated. ITU recommendations are not binding, and different regulators treat them differently. If a regulator sees IMT they may restrict or favor IMT and then to get reasonable unlicensed allocation maybe a difficult process. The contact in the African Telecommunications Union (ATU) was informed of the few points above, what else can we add? Agenda Slide 8 Jay Holcomb (Itron)

  9. 31 May 2018 doc.: IEEE 802.18-18/0061r00 EU items Anything to share on the EU front? 6 GHz - SE45: FM57: BRAN: . 60 GHz ITU-R WP5A: Agenda Slide 9 Jay Holcomb (Itron)

  10. 31 May 2018 doc.: IEEE 802.18-18/0061r00 IEEE SA - informational IEEE-SA draft position on Additional Spectrum Needed https://mentor.ieee.org/802.18/dcn/18/18-18-0010-02-0000-sa-use-of-spectrum-draft- position-06dec17.docx The SA Spectrum position needs to be picked up again in the SA Public Policy Advisory Group. They are getting this back in motion. Picked up last week their latest version. https://mentor.ieee.org/802.18/dcn/18/18-18-0010-03-0000-sa-use-of-spectrum-draft- position-06dec17.docx Will review and any feedback? Only 1 simple editorial seen in their latest version. Any feedback? Agenda Slide 10 Jay Holcomb (Itron)

  11. 31 May 2018 doc.: IEEE 802.18-18/0061r00 A Future For Unlicensed Spectrum A perspective on regardless of everything we do to develop new, better, faster wireless technologies, the available spectrum has a hard limit See: https://mentor.ieee.org/802.18/dcn/18/18-18-0060-00-0000-a-future- for-unlicensed-spectrum.pptx Will review and discuss Agenda Slide 11 Jay Holcomb (Itron)

  12. 31 May 2018 doc.: IEEE 802.18-18/0061r00 802.18 List Server Not a requirement of GDPR that has gone into effect, it may be a good time to remind all of the purpose of the 802.18 reflector, and if you do not wish to remain on this reflector, please follow instructions below for removing yourself. If you want to be removed and are unable to follow the instructions below, please send me an email privately, and I can assist in removing you from the list. STDS-802-18 List server description/purpose: Primarily for the members of the IEEE 802.18 Radio Regulatory Technical Advisory Group, RR-TAG, this list is open to members of IEEE 802. This list is used for IEEE 802.18 activities and discussions including meeting announcements, or announcements that are of importance for all IEEE 802.18 Members including receiving event information and registration reminder emails which are sent on this list for the RR_TAG. To unsubscribe from the STDS-802-18 list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=STDS-802-18&A=1 Updated IEEE Privacy Policy New checkbox getting into Mentor Discussion? Agenda Slide 12 Jay Holcomb (Itron)

  13. 31 May 2018 doc.: IEEE 802.18-18/0061r00 FCC FNPRM 4.9 GHz PUBLIC SAFETY AND HOMELAND SECURITY BUREAU ANNOUNCES COMMENT AND REPLY COMMENT DATES FOR THE SIXTH FURTHER NOTICE OF PROPOSED RULEMAKING ON THE 4.9 GHZ BAND AND CONSOLIDATES DOCKET NUMBERS FOR ALL FUTURE 4.9 GHz BAND MATTERS WP Docket No. 07-100, PS Docket No. 06-229, WT Docket No. 06-150, DA 18-468 https://www.federalregister.gov/documents/2018/05/07/2018-09416/49-ghz- band?utm_campaign=subscription%20mailing%20list&utm_source=federalregister.gov&utm_medium=email PN: https://apps.fcc.gov/edocs_public/attachmatch/DA-18-468A1.pdf https://mentor.ieee.org/802.18/dcn/18/18-18-0051-00-0000-fcc-pn-4-9-ghz-da-18-468-fcc-18-33-wp-07-100.docx FNPRM: https://ecfsapi.fcc.gov/file/03231913715191/FCC-18-33A1.pdf https://mentor.ieee.org/802.18/dcn/18/18-18-0052-00-0000-fcc-fnprn-4-9-ghz-fcc-18-33-wp-07-100.pdf https://www.fcc.gov/ecfs/search/filings?q=(proceedings.name:((07%5C- 100*))%20OR%20proceedings.description:((07%5C-100*)))&sort=date_disseminated,DESC Comments Due: July 6, 2018; (Approve by 21 June) Reply Comments Due: August 6, 2018 At this time, not seeing IEEE 802 has an interest, with the narrow bandwidth of this proceeding. The .18 chair will do a quick review and highlight possible discussion areas at an upcoming teleconference. Agenda Slide 13 Jay Holcomb (Itron)

  14. 31 May 2018 doc.: IEEE 802.18-18/0061r00 FCC NPRM 2.5 GHz -1 Amendment of Parts 1, 21, 73, 74 and 101 of the Commission s Rules to Facilitate the Provision of Fixed and Mobile Broadband Access, Educational and Other Advanced Services in the 2150-2162 and 2500-2690 MHz Bands (WT 03-66, terminated) Transforming the 2.5 GHz Band (WTB 18-120) Comments due: 30 days; Reply comments due: 60 days https://www.fcc.gov/ecfs/filing/0510125420096 https://www.fcc.gov/ecfs/search/filings?proceedings_name=18-120&sort=date_disseminated,DESC Any interest? The .18 chair will do a quick review and highlight possible discussion areas at an upcoming teleconference. Agenda Slide 14 Jay Holcomb (Itron)

  15. 31 May 2018 doc.: IEEE 802.18-18/0061r00 FCC NPRM 2.5 GHz -2 The 2.5 GHz band (2496-2690 MHz) constitutes the single largest band of contiguous spectrum below 3 gigahertz and has been identified as prime spectrum for next generation mobile Federal Communications Commission FCC 18-59 2 operations, including 5G uses.1 Significant portions of this band, however, currently lie fallow across approximately one-half of the United States, primarily in rural areas. Moreover, access to the Educational Broadband Service (EBS) has been strictly limited since 1995, and current licensees are subject to a regulatory regime largely unchanged from the days when educational TV was the only use envisioned for this spectrum. Today, we propose to allow more efficient and effective use of this spectrum band by providing greater flexibility to current EBS licensees as well as providing new opportunities for additional entities to obtain unused 2.5 GHz spectrum to facilitate improved access to next generation wireless broadband, including 5G. We also seek comment on additional approaches for transforming the 2.5 GHz band, including by moving directly to an auction for some or all of the spectrum.... Agenda Slide 15 Jay Holcomb (Itron)

  16. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Actions Required For WRC-19 AI 1.13 on IMT, all - send out additional comments to support our viewpoint to not have an IMT designation for 66 76 GHz, to send to regulator asking. FCC NPRMs on 4.9 and 2.5 GHz, review and any interest? Agenda Slide 16 Jay Holcomb (Itron)

  17. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Any Other Business The comments on FCC s NPRM on section 7 were uploaded to FCC. At the May IEEE 802 Interim meeting interest was expressed in discussing the coexistence of 802.11ax and 802.15.4 (UWB). At the time a conference call was preferred to avoid conflicts with meetings being held that week at the IEEE meeting. The initial conference call will be held on Thursday June 14 at 1 PM ET (10 AM PT). Agenda Slide 17 Jay Holcomb (Itron)

  18. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Adjourn Next teleconference: 07 June 2018 14:30 ET Call in info: https://mentor.ieee.org/802.18/dcn/16/18-16-0038-09-0000- teleconference-call-in-info.pptx or the latest. Note: If the call-in link doesn t work send the Chair an email right away. All changes/cancellations will be sent out to the 802.18 list server. Adjourn: Any objection to Adjourn. None heard, we are Adjourned at ________________ET Thank You The next face to face meeting of the 802.18 RR-TAG will be at the IEEE 802 Plenary 10-12 July 2018 at the Grand Hyatt, San Diego. Agenda Slide 18 Jay Holcomb (Itron)

  19. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Safe Travels Back up and/or previous slides follow Agenda Slide 19 Jay Holcomb (Itron)

  20. 31 May 2018 Jay Holcomb (Itron) doc.: IEEE 802.18-18/0061r00 AI 1.13 IMT to consider identification of frequency bands for the future development of International Mobile Telecommunications (IMT), including possible additional allocations to the mobile service on a primary basis, in accordance with Resolution COM6/20 (WRC-15); Due to the following developments, IEEE 802 recommends that WRC-19 not consider 66-76 GHz for IMT identification. On July 14, 2016, FCC published a Report and Order and Further Notice of Proposed Rulemaking (FCC 16-89) [https://apps.fcc.gov/edocs_public/attachmatch/FCC-16-89A1.pdf] to adopt 64-71 GHz band for License Exempt operation. In January 2018, the ITU-R published Recommendation M.2003-2 [https://www.itu.int/rec/R-REC- M.2003-2-201801-I/en] wherein this band was indicated for Multigigabit Wireless Systems. This facilitates the introduction of IEEE 802 technologies that are capable of supporting 5G use cases under the existing Mobile Allocation. In February 2018, the Radio Spectrum Policy Group of the European Union (RSPG) published their Second Opinion on 5G [http://rspg-spectrum.eu/2018/02/] in which they recommended making this band available on a general authorized access basis. Given these facts, we believe that a wide variety of 5G services and use-cases will be deployed in this band globally without the need for an IMT identification. In fact, IMT identification could bar some key 5G technologies from operating in this band. Agenda Slide 20

  21. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Any Other Business Note: in the 802.19 co-existence <1 GHz meeting it was brought up for IEEE 802 as a whole to put together a document on basic spectrum parameters that would be good for all IEEE 802 standards to co-exist (less interference .) Actually, need to have this for all IEEE 802 to just work in the spectrum, e.g. BWs needed. Not just coexistence. Point being that 802.18 can refer to / use when responding to regulators on different consultations, to encourage regulators in general to configure their spectrum to allow all the IEEE 802 standards in a more consistent/friendly way. For the many in attendance, it was felt many regulators would appreciate at least knowing this. Additional point to add to the doc, duty cycle is not for the protocol/standard/amendment being discussed, it is a regulation to allow others (and their packet lengths) to have access to the spectrum. Agenda Slide 21 Jay Holcomb (Itron)

  22. 31 May 2018 doc.: IEEE 802.18-18/0061r00 WiFi / UWB Coexistence -1 IEEE 802.19 and other WG chairs are working on IEEE 802 single voice. From a high level, could we list out some of the following. Do not want to get into detail, just high level points to consider to help. What criteria should be considered? Power out needed, different for each technology. Bandwidth considerations. Channel sense, e.g. LBT. Incumbent protection. Interference types, blocks .vs. range decrease. Operational ranges themselves. Different modulation types . Tuning range of UWB (global considerations). Thursday: Is there a way to ID that UWB is there and transmitting? Agenda Slide 22 Jay Holcomb (Itron)

  23. 31 May 2018 doc.: IEEE 802.18-18/0061r00 WiFi / UWB Coexistence -2 What Use Cases should be considered? Higher speed (wider BWs) for WiFi users, e.g. streaming video, etc. Global availability (S. Korea just this week consultation 6 10.2 GHz for UWB) UWB applications - Many (See 15-17/0660), e.g. location is a significant use case. Where devices are used, height, indoor/outdoor, etc. Review 15.2 co-existence of WiFi / BT / Co-located in a device, and non-co-located. Thursday: Nothing new. Agenda Slide 23 Jay Holcomb (Itron)

  24. 31 May 2018 doc.: IEEE 802.18-18/0061r00 IEEE EU Position Statement -1 IEEE European Public Policy Position Statement on Spectrum Management https://mentor.ieee.org/802.18/dcn/18/18-18-0028-00-0000-draft-ieee-european-public- policy-position-statement-on-spectrum-management.pdf We are being asked to review this statement, similar to the one in November, though some focus for the EU. Guidance is to review and comment in detail. Document 18-18/0028rxx, latest revision is our current review markup. Please send comments to .18 chair, to integrate, to be reviewed by the TAG. Becoming clearer the starting premise of the current paper is from several years ago and input is coming in the premise has changed in recent years. With that trying to understand how to propose edits to the paper. Agenda Slide 24 Jay Holcomb (Itron)

  25. 31 May 2018 doc.: IEEE 802.18-18/0061r00 IEEE EU Position Statement -2 Went through 18-18/0028r01 review copy, the remaining sections we have not reviewed and found a couple of specific areas that need clarity. And brought audience up to speed on point premise of paper is from a few years back and had agreement with those that spoke up. Some general questions: Should the IEEE SA (the position statement we reviewed in November and January) and the IEEE EU collaborate on these 2 separate position statements in some fashion? Then move above them. (.18 should still review) What was original driver to do the statement? Who is the general audience it is written for? As it is, there is a concern if it is sent out and organizations our members are working with, CEPT, BRAN, etc. it will cause confusion, and more. Request that anyone with specific input to continue to please pass on to the .18 chair, sooner. .18 chair will cleanup the review revision of the paper (should end up r02) and ask the IEEE 802 chair for further guidance on next steps. Agenda Slide 25 Jay Holcomb (Itron)

  26. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Motion EU Spectrum Management Motion: To approve document 18-___/00____r__, IEEE 802 comments on IEEE European Public Policy Position Statement (18-18/0028r00), with the 802.18 Chair having editorial privileges. Then send to the EC for approval and return IEEE EPPC WG. Moved by: Seconded by: Discussion? Vote: ___Y / ___N / ___A Agenda Slide 26 Jay Holcomb (Itron)

  27. 31 May 2018 doc.: IEEE 802.18-18/0061r00 Fellowship Request Fellowship request on reaching out to all regulators. Enhancing Collaboration between IEEE 802 and World Regulators on unlicensed spectrum regulations https://mentor.ieee.org/802.11/dcn/18/11-18-0580-01-coex-enhancing-collaboration- between-ieee-802-and-world-regulators-on-unlicensed-spectrum-regulations.pptx Thursday: A start is to keep in touch with the fellowship attendees. They are welcome to our meetings and calls. Could something be added to the IEEE newsletter/communication for the regulators, to answer the news letter input? Can IEEE be more pro-active with some of the other (e.g. regional) regulators? The challenge is to ID which we can, and being a volunteer / individual organization, the time and money from the volunteers? Many regulators don t have IEEE has a point of contact like they do with WFA or other implementing orgs do. Agenda Slide 27 Jay Holcomb (Itron)

  28. 31 May 2018 doc.: IEEE 802.18-18/0061r00 IEEE not connected and underserved (from last week) IEEE Connectivity Coalition Internet Inclusion means that all stakeholders are engaged in the planning and implementation of technology systems; that all potential people impacted can access and have certain rights to understand the implications of the technology and know how to use it safely and ethically; and that with these technologies come more services, tools, increased information and opportunities to expand access for communities around the world. As digital technology is increasingly used for educational, employment, health, commercial and informational purposes, Internet Inclusion is critical for full engagement, participation and opportunity in the social, economic and civic life of society. This ties into the effort brought up at the Chicago meeting on how to connect the 3.8B people, not connected today. Stayed tuned as we learn more. Rich will be talking to Senior Director, Technology Policy and International Affairs on this and what we can do. Agenda Slide 28 Jay Holcomb (Itron)

  29. 31 May 2018 doc.: IEEE 802.18-18/0061r00 IEEE 802 (.11) AANI review informational https://mentor.ieee.org/802.11/dcn/18/11-18-0583-00-AANI-aani-sc-closing-report- march-2018.pptx The 802 Chair has asked that 802.18 stay in tune with the 802.11 ANNI SC. In particular where they stand with IMT 2020. A debated motion in the 802.11 closing to add to its scope for IMT 2020: Approve that the AANI SC scope be modified to include the generation of a white paper and/or self evaluation assessing the performance of 802.11 against the IMT-2020 requirements for eMBB indoor hotspot and dense urban use case. Result: 28-34-8 Fails Agenda Slide 29 Jay Holcomb (Itron)

  30. 31 May 2018 doc.: IEEE 802.18-18/0061r00 IMT 2020: The buzz in the industry on future steps in mobile technology 5G has seen a sharp increase, with attention now focused on enabling a seamlessly connected society in the 2020 timeframe and beyond that brings together people along with things, data, applications, transport systems and cities in a smart networked communications environment. In this context, ITU and its partners, sharing a common community of interest, have recognized the relationship between IMT International Mobile Telecommunication system and 5G and are working towards realizing the future vision of mobile broadband communications. In early 2012, ITU-R embarked on a programme to develop IMT for 2020 and beyond , setting the stage for 5G research activities that are emerging around the world. Through the leading role of Working Party 5D, ITU s Radiocommunication Sector (ITU-R) has finalized its view of a timeline towards IMT-2020. The detailed investigation of the key elements of 5G are already well underway, once again utilizing the highly successful partnership ITU-R has with the mobile broadband industry and the wide range of stakeholders in the 5G community. Agenda Slide 30 Jay Holcomb (Itron)

  31. 31 May 2018 doc.: IEEE 802.18-18/0061r00 IMT 2020-cont: In September 2015, ITU-R has finalized its Vision of the 5G mobile broadband connected society. This view of the horizon for the future of mobile technology will be instrumental in setting the agenda for the World Radiocommunication Conference 2019, where deliberations on additional spectrum are taking place in support of the future growth of IMT. ITU has a rich history in the development of radio interface standards for mobile communications. The framework of standards for International Mobile Telecommunications (IMT), encompassing IMT-2000 and IMT-Advanced, spans the 3G and 4G industry perspectives and will continue to evolve as 5G with IMT-2020. https://www.itu.int/en/ITU-R/study-groups/rsg5/rwp5d/imt-2020/Pages/default.aspx Agenda Slide 31 Jay Holcomb (Itron)

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