I’ve been combing through ETSI EN 300 220 on this and it’s not actually clear that channel switching is required for single-channel operation or avoiding the duty cycle. It’s one possible mode of achieving AFA equivalence but not by any means the only way to achieve compliance.
The requirements are:
- Polite spectrum access: already satisfied by 802.11ah with CSMA/CA and CCA;
- Random deferral: already satisfied by 802.11ah with the binary exponential backoff;
- CCA threshold: configurable in 802.11ah via the energy detect threshold;
- Minimum transmitter off time & listening time: already satisfied by 802.11ah with the mandatory idle time after transmission;
- Maximum transmitter on time: already satisfied by 802.11ah with the TXOP limits, further improved by limiting PPDU aggregation.
With that, equivalent coexistence behaviour to AFA is already demonstrated and there’s no reason that the duty cycle can’t be avoided or that 802.11s shouldn’t be usable within ETSI regions?