FW: +++ SEC BALLOT #1 ON FCC SUBMISION (WBFH)
fyi. Comments from Stephen Berger on ongoing 802 SEC ballot.
Jim Carlo(jcarlo@ti.com) Cellular:1-214-693-1776 Voice&Fax:1-214-853-5274
TI Fellow, Networking Standards at Texas Instruments
Chair, ISO/IEC JTC1/SC6 Telecom and Info Exchange Between Systems
Chair, IEEE802 LAN/MAN Standards Committee
-----Original Message-----
From: Berger, Stephen [mailto:Stephen.Berger@icn.siemens.com]
Sent: Tuesday, September 28, 1999 2:16 PM
To: 'Jim Carlo'
Subject: RE: +++ SEC BALLOT #1 ON FCC SUBMISION (WBFH)
Jim,
Thank you for the opportunity to comment on this ballot. A few minutes ago
we had a conference call of those supporting the NPRM. A couple of things
came from this converstation. Please feel free to forward this to your
committee if you so desire.
The first is just an administrative item. The attachment you have on this
note has 8 pages in it. The actually letter, which is available at the URL
you supplied has 51 pages. You may want to check that your committee
reviews the full letter being proposed.
More to the point we will be presenting to your committee by EoB Thursday a
presentation of our position. It essentially has two points. The first is
that we believe no further letters should be sent. We will more fully
explain our position in the letter now being drafted. However, it rests on
2 basic points. The first is that these comments affect a lot of equipment
types beyond 802.11 equipment. Thus these comments go far beyond the PAR of
802.11. The current letters amount to a single viewpoint of several within
the IEEE. Secondly, the arguements are technically flawed primarily in that
they make certain opening assumptions which are not valid. The detailed
calculations all become meaningless because they are calculating effects
from equipment which is not being proposed.
We hope that our first position will find favor with your committee.
However, should we fail in that we will attach to our letter a draft of an
additional letter to the FCC. We will ask if these additional 802.11
letters are filed that this additional letter also be filed in order to
document the legitimate range of valid technical opinion within the IEEE.
If we go this route there is one very important value to be realized in this
additional letter. If only one point of view is on file as from the IEEE
then some of us may find ourselves in the undesired position of needing to
expose the technical flaws in that position. With 2 IEEE positions on file
we can then support one or the other and not be in the position of attacking
the IEEE position. Those of us with strong IEEE heritage would really
appreciate a way of defending our position in this NPRM without publically
attacking the IEEE.
Best Regards,
Stphen Berger
Chair, IEEE EMC Society Standards Development Committee
-----Original Message-----
From: Jim Carlo [mailto:jcarlo@ti.com]
Sent: Tuesday, September 28, 1999 10:47 AM
To: Judy Gorman; Berger, Stephen; Ian Gifford
Cc: Vic Hayes; Don Heirman
Subject: +++ SEC BALLOT #1 ON FCC SUBMISION (WBFH)
fyi. Here is actual SEC ballot now in progress. Would appreciate any inputs
from Staff and other groups. Please send these to Vic Hayes and I. NOTE THIS
LETTER NEEDS TO BE AT FCC BY 4OCTOBER.
Jim Carlo(jcarlo@ti.com) Cellular:1-214-693-1776 Voice&Fax:1-214-853-5274
TI Fellow, Networking Standards at Texas Instruments
Chair, ISO/IEC JTC1/SC6 Telecom and Info Exchange Between Systems
Chair, IEEE802 LAN/MAN Standards Committee
-----Original Message-----
From: owner-stds-802-sec@majordomo.ieee.org
[mailto:owner-stds-802-sec@majordomo.ieee.org] On Behalf Of Jim Carlo
Sent: Tuesday, September 28, 1999 9:48 AM
To: IEEE802
Cc: Vic Hayes
Subject: +++ SEC BALLOT #1 ON FCC SUBMISION (WBFH)
++++++++++++++++++++++++++++++++++++++
SEC OFFICIAL EMAIL BALLOT 802.0/28Sept1999
Issue Date: 28Sept1999 Closing Date: 1October1999
Moved By: Vic Hayes
Seconded By: Bob Heile
Move: Authorize responding from IEEE 802 to the FCC NPRM (Docket No. 99-231)
with the document 11-99/209-r5 (in principal). This letter has some
opposition from
the proposers of the rules-change. It was approved by 802.11 by 802.11
EMAIL ballot:
68-Yes, 3-No, 3-Abstain.
This letter "expresses opposition to the proposed rule changes which would
allow wider channels for Frequency Hopping Spread spectrum (FHSS) systems as
described in the Notice of Proposed Rule Making (the "Notice") in this
proceeding. Since that time, the membership has continued to
analyze the proposed rule changes. Two working groups of the Committee
(802.11 on wireless Local Area Networks and 802.15 on Wireless Personal Area
Networks) held an Interim Meeting in San Rosa CA (13 - 17September 1999)
and, based on additional material submitted, 2 respectfully submits these
additional comments in this proceeding."
Note that this letter adds to information provided in letter approved by the
SEC in July. Also another letter has been voted on (see ballot #2). The two
letters may be combined into a single letter.
Approval is requested for this letter (in principal) to allow for editing by
Vic Hayes, Bob Heile and Jim Carlo based on various comments (including IEEE
staff) being provided. The letter needs to be submitted to the FCC by
4October.
If you want to see this proposed letter and appendices, please go to the web
at:
http://grouper.ieee.org/groups/802/11/Documents/index.html#FCC_NPRM_99-231