RE: [802SEC] [TIME-SENSITIVE MOTION] to APPROVE FCC FILINGS
I agree with Carl that the WG approval is not required for this procedure.
I also agree to the importance to file and to protect the spectrum used by
our standards. Therefore, I vote to APPROVE this motion.
However, I would caution against using statements such as "this was approved
by the WG" when that approval is given at an interim meeting, unless the WG
minutes or chair can confirm that this is actually an official WG position,
gained according to the operating rules of the LMSC and the WG.
-Bob
-----Original Message-----
From: Stevenson, Carl R (Carl) [mailto:carlstevenson@agere.com]
Sent: Thursday, May 23, 2002 3:24 PM
To: Paul Nikolich (E-mail); 'stds-802-sec@ieee.org'
Subject: [802SEC] [TIME-SENSITIVE MOTION] to APPROVE FCC FILINGS
Importance: High
Dear SEC Members:
**************************
PLEASE RESPOND ASAP TO THE FOLLOWING MOTION
AS THERE IS A HARD DEADLINE OF MAY 31 FOR FILING
WITH THE FCC ( which was already extended as the result of
a grant by the FCC of a request on my part for an extension of
time to file) on the first of the two documents referenced below,
with the deadline for the 2nd document trailing shortly behind.
**************************
Pursuant to Procedure 4 of the LMSC Rules "Procedure for
Communication with Government Bodies", and specifically the
subsection entitled "IEEE 802 Position Statements," after
consultation with the Chair of IEEE 802, I hereby make the
following motion to the SEC:
<begin formal motion>
MOTION:
"RECOGNIZING, that the 802.18 RR-TAG, 802.11 WLAN WG,
802.15 WPAN WG, and 802.16 WMAN WG have all approved,
with well more than 75% approval in each case, the following
two (attached) 802.18 radio regulatory documents for filing with
the FCC:
18-02-002r0_IEEE_802_Opp_98-156.doc
'OPPOSITION TO THE PETITION FOR RECONSIDERATION FILED
BY THE ARRL' (in ET Docket No. 98-156)
(and)
18-02-005r0-IEEE_802_Cmts_02-98doc.doc
'comments of IEEE 802 in et docket no. 02-98'
I HEREBY MOVE that the IEEE 802 SEC approve both of these
documents for filing with the Federal Communications Commission
as official IEEE 802 positions, authorizing the Chair of IEEE 802 to
instruct and empower the Interim Chair of the 802.18 RR-TAG to
perform the appropriate editorial reformatting (strip 802 headers and
footers, add appropriate cover letter and certificate of service, signature
blocks, etc.. to conform to FCC-prescribed standards for formal filings)
and to file, prior to the prescribed filing deadlines, both documents with
the Federal Communications Commission via the Commission's Electronic
Comment Filing System ("ECFS") and to deliver true and accurate copies
of the documents, as filed, to the Chair of IEEE 802 and to the Secretary
of the IEEE SA Standards Board."
<end of motion>
***PLEASE READ IMPORTANT NOTES BELOW***
Carl R. Stevenson
Interim Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group
610-965-8799 (home office)
610-570-6168 (cellphone)
Short Message Service: 6105706168@voicestream.net
home e-mail: wk3c@fast.net
NOTE: 1) My Agere e-mail server (and my IEEE alias that maps there
as well) will be out of service from at least 9:00 pm EDT, Thu. May
23,
through 6:00 am EDT, Tue., May 28, due to the relocation of the
entire Agere data center facility to our new corporate HQ campus.
During this time, feel free to call me at my home office or on my
cellphone,
or to send me e-mail at my personal e-mail address
mailto:wk3c@fast.net
should you have any questions on this motion or the documents.
PLEASE "cc:" THIS PERSONAL E-MAIL ADDRESS ON ALL SEC TRAFFIC
until at least Wed., May 29.
2) THESE FILINGS ARE IMPORTANT TO THE PROTECTION OF
THE SPECTRUM USED BY CURRENT AND PENDING 802 WIRELESS
STANDARDS. Due to the unfortunate fact that there is a holiday
weekend
between now and HARD FILING DEADLINES for the above-referenced
documents, I can envision the possibility that, due to vacations,
etc., the
necessary 2/3 of the SEC could conceivably not vote (either way, to
approve
or disapprove) the filing of these documents as an IEEE 802 position
within
the required timeframe.
If you believe you have a good reason to vote "Disapprove,"
please
do so ASAP, with your reasons, in the active sense, and let's see if
we
can resolve your concerns.
However, PLEASE, don't allow a "did not vote at all" to
translate into
its default of "Disapprove."
3) Because of a) factor (2) above, b) the fact that these
filings are
so important to 802 wireless standards, and c) the fact that the
documents
were so overwhelmingly approved by the 3 wireless WGs, "Plan B"
(though
less desirable) is to simultaneously consider my delivery of the
subject
documents to the SEC e-mail reflector (attached hereto) to be the
beginning
of the 5 day SEC review period specified in Procedure 4 of the LMSC
Rules
"Procedure for Communication with Government Bodies", and
specifically the
subsection entitled "Working group position statements."
Thus, if, due to the timing of the holiday, a "low voter
turnout" (lack
of 2/3 SEC approval response) makes filing of these documents as
IEEE 802
positions impossible, I intend to follow the procedure outlined in
the LMSC rules
for Working Group position statements, with the intention of filing
the documents
as the joint positions of the 802.11, 802.15, and 802.16 WGs and the
802.18 RR-TAG.
I WISH TO MAKE IT CLEAR THAT IT IS *NOT* MY INTENTION TO USE
THIS
PARALLEL PROCEDURE TO CIRCUMVENT THE WILL OF THE SEC ... BUT ONLY to
"cover the bases," within the provisions of LMSC rules, in the event
that too few SEC
members vote (at all), due to vacations over the holidays, etc.
I URGE YOU TO VOTE PROMPTLY TO APPROVE THE FILING OF BOTH DOCUMENTS
AS IEEE 802 POSITIONS.
Regards,
Carl R. Stevenson
Interim Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group
610-965-8799 (home office)
610-570-6168 (cellphone)
Short Message Service: 6105706168@voicestream.net
home e-mail: wk3c@fast.net
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