Re: [802SEC] +++ 10 Day EC Ballot - Reply Comments to the FCC's Incentive Auction Proposal - Docket No. 12-268 +++
Thanks James, I will leave this in the voting members hands with one comment that may help.
After comments from interested parties are excepted on line or in person per the due date, there is another date that was issued at the same time.
The FCC's Reply Comment due date. some months later.
In this reply the FCC will summarize, sometimes with specific references to ex pare comments, or could be to an SDO and will
agree or disagree. Should a comment disagree with 802, that sort of takes it off the table as it were. There are also times
when the FCC will extend, correct its original NPRM, because of a complicated issue as well. Any can amend their submissions if the comments
are not correct because of error on either side.
So if one Had to have an expiration date, maybe it would be with the Reply comment from the FCC to the inputs it has received.
Have fun, Sincerely, Nancy
On Mar 7, 2013, at 6:05 PM, James P. K. Gilb wrote:
> All
>
> There has been good discussion on this. So let me try a summary:
>
> - Documents should and do live essentially forever. They are archived on mentor or on an FCC database, in the Library of Congress, wherever.
> - Opinions change somewhat more rapidly than that.
>
> So, while there may be an IEEE 802 position document from 10 years ago on a web server somewhere, it is unlikely that it reflects the current position of IEEE 802. From a historical point of view, we want those documents to remain available.
>
> However, it should be equally obvious that the opinions of IEEE 802 change from time to time. So are alternatives are:
> 1) Review all previous position statements on a regular basis and rescind those that are not current (not unlike the revision procedure for standards)
> 2) Automatically time out position statements unless they are affirmatively extended by the appropriate group (what the rules currently state).
> 3) Say nothing regarding the shelf life of the statement, in which case a statement could be considered to be out of date as soon as they are issued.
>
> If there is a "timeout" for a statement, our options would be:
> - put the "timeout" on a web page with the list of position statements (what the rules say),
> - put a statement in each document, or
> - do both.
>
> I have my own theory on how we can accomplish this, but first, can we agree to the above as the basis of discussion.
>
> James Gilb
> IEEE 802 Second Vice Chair
>
> BTW: My hope is that we can do this with minimum effort for each document.
>
> On 03/07/2013 05:49 PM, John Notor wrote:
>> Pat,
>>
>> This is not an objection to including an expiration (or expiry) date in the
>> document, but I did do a brief review of some of the players (AT&T, Verizon,
>> Wi-Fi Alliance) who submitted comments in the FCC Incentive Auction
>> proceeding, and none of them included expiration dates or expiry dates based
>> on searching the document text, including cover letters when available.
>>
>> The one thing to remember is that the document does not disappear from the
>> FCC database, perhaps never, but at least over many years. I was not able to
>> find an explicit mention in the FCC rules or on the FCC web site that
>> suggested documents were ever removed from the database.
>>
>> The rules allow companies or individuals to submit corrections or updates,
>> but there does not seem to be any process to remove the document. The
>> persistence of the documents may be a requirement of some other Federal law,
>> I'm not sure.
>>
>> Other spectrum regulatory administrations may handle this differently.
>>
>> John
>>
>> -----Original Message-----
>> From: ***** IEEE 802 Executive Committee List *****
>> [mailto:STDS-802-SEC@ieee.org] On Behalf Of Pat Thaler
>> Sent: Thursday, March 07, 2013 9:46 AM
>> To: STDS-802-SEC@LISTSERV.IEEE.ORG
>> Subject: Re: [802SEC] +++ 10 Day EC Ballot - Reply Comments to the FCC's
>> Incentive Auction Proposal - Docket No. 12-268 +++
>>
>> Generally, an expiry date on a document ensures that it goes away at some
>> point even if it isn't replaced. It doesn't mean that it will always be
>> valid for that long. For example, some of our drafts and all IETF IDs have
>> an expiration date but they often are replaced with a new draft before it
>> expires.
>>
>> I don't think we send out a position statement expecting to contradict it 6
>> months later. Yes we may refine it and send out a new statement before 5
>> years. New information or new participation might change our views more
>> radically, but it isn't what we expect when we send a statement out. It
>> would undermine the usefulness of a position statement if we sent it out
>> with a very short expiration.
>>
>> Regards,
>> Pat
>>
>> -----Original Message-----
>> From: Michael Lynch [mailto:MJLynch@mjlallc.com]
>> Sent: Wednesday, March 06, 2013 9:04 AM
>> To: James P. K. Gilb; Roger Marks
>> Cc: EC List (STDS-802-SEC@LISTSERV.IEEE.ORG); John_DAmbrosia@dell.com;
>> jrosdahl@ieee.org Rosdahl; p.nikolich@ieee.org Nikolich; Pat Thaler;
>> clint.chaplin@gmail.com Chaplin; Tony Jeffree; David_Law@ieee.org Law;
>> bkraemer@ieee.org <bkraemer@ieee.org> Kraemer; Bob Heile;
>> subirdas21@gmail.com Subir; "Buzz paul.nikolich@ATT.NET"
>> <""apurva.mody"@baesystems.com SSA) Mody,freqmgr@ieee.org Lynch
>> <freqmgr@ieee.org>,shellhammer@ieee.org J Shellhammer
>> <shellhammer@ieee.org>,Riegel Maximilian
>> <maximilian.riegel@nsn.com>,Thompson Geoffrey <thompson@ieee.org>,Everett O.
>> Rigsbee <BRigsBieee@comcast.net>,Radhakrishna Canchi
>> <Radhakrishna.Canchi@kyocera.com>,John Lemon <jlemon@ieee.org>,Paul Nikolich
>> " ">
>> Subject: RE: +++ 10 Day EC Ballot - Reply Comments to the FCC's Incentive
>> Auction Proposal - Docket No. 12-268 +++
>>
>> James,
>>
>> Another item that doesn't seem to fit our filings with the FCC or any other
>> regulatory body: they are not position statements or papers and should not
>> have a five year life cycle.
>>
>> "All IEEE 802 LMSC communications to government bodies shall be issued by
>> the IEEE
>> 802 LMSC Chair as the view of IEEE 802 LMSC (stated in the first paragraph
>> of the statement). Such communications shall be copied to the Sponsor and
>> the IEEE-SA Standards Board Secretary and shall be posted on the IEEE 802
>> LMSC web site. The IEEE 802 LMSC web site shall state that all such position
>> statements shall expire five years after issue."
>>
>> For example what we filed after the January meeting may not be the view of
>> the wireless groups by the time they meet in September. So to have them
>> considered as IEEE 802 position statements or papers doesn't fit their
>> intended purpose. Our views can and sometimes do change in less than a year
>> rather than the five years referenced in the OM.
>>
>> Regards,
>>
>> Mike
>>
>> -----Original Message-----
>> From: James Gilb [mailto:jpgilb@gmail.com] On Behalf Of James P. K. Gilb
>> Sent: Wednesday, March 06, 2013 1:47 AM
>> To: Roger Marks
>> Cc: Michael Lynch; EC List (STDS-802-SEC@LISTSERV.IEEE.ORG);
>> John_DAmbrosia@dell.com; jrosdahl@ieee.org Rosdahl; p.nikolich@ieee.org
>> Nikolich; Pat Thaler; clint.chaplin@gmail.com Chaplin; Tony Jeffree;
>> David_Law@ieee.org Law; bkraemer@ieee.org <bkraemer@ieee.org> Kraemer; Bob
>> Heile; subirdas21@gmail.com Subir; "Buzz paul.nikolich@ATT.NET"
>> <""apurva.mody"@baesystems.com SSA) Mody,freqmgr@ieee.org Lynch
>> <freqmgr@ieee.org>,shellhammer@ieee.org J Shellhammer
>> <shellhammer@ieee.org>,Riegel Maximilian
>> <maximilian.riegel@nsn.com>,Thompson Geoffrey <thompson@ieee.org>,Everett O.
>> Rigsbee <BRigsBieee@comcast.net>,Radhakrishna Canchi
>> <Radhakrishna.Canchi@kyocera.com>,John Lemon <jlemon@ieee.org>,Paul Nikolich
>> " ">
>> Subject: Re: +++ 10 Day EC Ballot - Reply Comments to the FCC's Incentive
>> Auction Proposal - Docket No. 12-268 +++
>>
>> All
>>
>> With regards to item 3), unfortunately, there is some overlap between the OM
>> and the P&P.
>>
>> The P&P requires:
>> - 2/3 approval for public statements
>> - Public statements are only issued by the Chair.
>>
>> Both of these are in subclauses that can only be added to, hence these
>> requirements come from AudCom and it is highly unlikely we can change them.
>>
>> As for "Such communications shall be copied to the Sponsor and the IEEE-SA
>> Standards Board Secretary and shall be posted on the IEEE 802 LMSC web site.
>> The IEEE 802 LMSC web site shall state that all such position statements
>> shall expire five years after issue.", we can and probably should change
>> that in some fashion.
>>
>> IMHO, it would be nice to have a single area on the web site that does
>> contain EC positions so that we don't contradict ourselves or issue the same
>> position twice.
>>
>> I also agree with Roger that the argument that the OM was not followed in
>> the past does not mean that it should not be followed now.
>>
>> James Gilb
>>
>> On 03/04/2013 11:38 AM, Roger Marks wrote:
>>> On 2013/03/04, at 12:08 PM, Michael Lynch wrote:
>>>
>>>> Roger,
>>>>
>>>> 1. If you find the 2nd sentence of paragraph 11 unintelligible then
>> please propose new wording.
>>>>
>>> Maybe it was intended to be two sentences, like this:
>>>
>>> "In light of this proposal we would like to emphasize the importance of
>> ensuring that the entire spectrum under channel 51 will continue to be
>> utilized by licensed, unlicensed, wireless microphones or TV operation. IEEE
>> 802 Standards for operation in TVWS have been and are being developed to
>> minimize interference to DTV reception in compliance with FCC rules."
>>>
>>> I don't know the intent since I did not participate.
>>>> 2. You may not be aware of the issues that have been occurring with
>> regards to the EC reflector. Therefor it seemed that there was no other way
>> to guarantee that this email would ever reach the intended audience other
>> than to use the private list. I'm adding the reflector to this response.
>> Let's see if it will work this week. My last several attempts to use it
>> ended up with messages not being delivered. At Paul's request I was in
>> contact with the SA and they were not able to resolve the matter. In that
>> case last week the use of the private list was agreed to by Paul and with
>> the tight timeline that this ballot is on it seemed best to use it to better
>> guaranty being received by the EC..
>>>>
>>> I don't see your message in the archive. Maybe this response will end up
>> there.
>>>> 3. Paul did very clearly authorize me to conduct this ballot. Do you
>> feel that there was another reference other than 8.2 that should have been
>> used or, that under 8.2, he is not authorized to delegate to someone else
>> the role of conducting a ballot? The reference to 8.2 was also used on the
>> very recent comments on the FCC's 3.5 GHz NPRM without objection by anyone.
>> In reviewing 8.2 I see nothing that prevents the Sponsor Chair from
>> delegating the function of communicating with governmental bodies. On the
>> other hand if the Sponsor Chair is the only one who can communicate with
>> governmental organizations then indeed he should be the sole point of
>> contact for all communications to and from the FCC, Ofcom, ITU, etc. Maybe
>> the OM needs to be revised (again) to make it clear that this role can be
>> delegated?
>>>>
>>> I agree that the issue I've raised could have been applied to past
>>> ballots as well. Still, the precedent of ignoring the OM doesn't
>>> invalidate the OM. 8.2 doesn't specify who conducts the ballot, but it
>>> does state who needs to issue the statement (though the meaning of
>>> "issue" might be debated). There are also some specific post-ballot
>>> elements of 8.2.1 that I suspect have not been observed in the past
>>> ("Such communications shall be copied to the Sponsor and the IEEE-SA
>>> Standards Board Secretary and shall be posted on the IEEE 802 LMSC web
>>> site. The IEEE 802 LMSC web site shall state that all such position
>>> statements shall expire five years after issue.")
>>>
>>> Roger
>>>
>>>> Best regards,
>>>>
>>>> Mike
>>>>
>>>> From: Roger Marks [mailto:r.b.marks@ieee.org]
>>>> Sent: Monday, March 04, 2013 9:46 AM
>>>> To: Michael Lynch
>>>> Cc: John_DAmbrosia@dell.com; jrosdahl@ieee.org; p.nikolich@ieee.org;
>>>> pthaler@broadcom.com; gilb@ieee.org;clint.chaplin@gmail.com;
>>>> tony@jeffree.co.uk; David_Law@ieee.org; bkraemer@ieee.org;
>>>> bheile@ieee.org; subirdas21@gmail.com;apurva.mody@baesystems.com;
>>>> freqmgr@ieee.org; shellhammer@ieee.org; maximilian.riegel@nsn.com;
>>>> Geoffrey Thompson; Everett O. (Buzz) Rigsbee; Canchi, Radhakrishna;
>>>> John Lemon; Paul Nikolich (paul.nikolich@ATT.NET)
>>>> Subject: Re: +++ 10 Day EC Ballot - Reply Comments to the FCC's
>>>> Incentive Auction Proposal - Docket No. 12-268 +++
>>>>
>>>> Mike,
>>>>
>>>> I have a few editorial and procedural comments.
>>>>
>>>> (1) The second sentence of paragraph 11 is unintelligible.
>>>>
>>>> (2) Conducting a ballot by circulation to a closed email list does not
>> meet the requirement of OM 4.1.2: "Provision shall be made for the IEEE 802
>> LMSC membership to observe and comment on Sponsor electronic ballots. All
>> comments from those who are not members of the Sponsor shall be considered."
>>>>
>>>> (3) Since the language indicates OM Subclause 8.2, then the elements of
>> 8.2.1(b) apply. In particular: "All IEEE 802 LMSC communications to
>> government bodies shall be issued by the Sponsor Chair..."
>>>>
>>>> Roger
>>>>
>>>>
>>>>
>>>> On 2013/03/02, at 12:10 PM, Michael Lynch wrote:
>>>>
>>>>
>>>> Dear EC,
>>>>
>>>> During the January wireless interim meeting in Vancouver 802.18 began
>> work on a response to the FCC's 3.5 GHz NPRM proceeding. It was not possible
>> to complete the response at that meeting so a series of conference calls
>> were announced to complete the work. Two calls, one on January 24th and the
>> second on January 31st, were used to complete the document Doc.
>> 18-12-0109-06. The document was approved by 802.18 by a vote of 5 yes, 0 no
>> and 1 abstention, submitted to and approved by the EC and filed with the
>> FCC.
>>>>
>>>> During the discussion of any other business the group decided to continue
>> to have the Thursday evening calls during the period of February 7th to
>> March 14th. The positive result of that action was the approval on February
>> 28th of proposed reply comments to the FCC's "Incentive Auction" proposal
>> (Docket No. 12-268). This takes advantage of the FCC having extended the
>> reply comment date to March 12th.
>>>>
>>>> I have asked Paul to allow me to conduct a ten day EC email ballot to
>> approve submitting the reply comments (Doc. 18-13-0016-06-0000) to the FCC.
>>>>
>>>> Paul's response to my request is:
>>>>
>>>> "I will authorize a 10 day EC email ballot, to be conducted by Mike
>> Lynch, for the following motion."
>>>>
>>>> Motion:
>>>>
>>>> "To approve, under OM Subclause 8.2, document 18-13-0016-06-0000 subject
>> to the early close provision of OM Subclause 4.1.2.."
>>>>
>>>> Moved: Mike Lynch
>>>>
>>>> Seconded: Apurva Mody
>>>>
>>>> Link to the document:
>>>>
>>>> https://mentor.ieee.org/802.18/dcn/13/18-13-0016-06-0000-draft-reply-
>>>> comments-to-fcc-tv-band-incentive-auction-nprm.doc
>>>>
>>>> Reply comments are to be submitted to the FCC by March 12, 2013.
>>>>
>>>> The ballot will start March 2nd and end on March 11th, 2013.
>>>>
>>>> I am using the "private list" since once again there seems to be an issue
>> with either delay or non-delivery when using the EC reflector. This has also
>> impacted the 802.18 reflector.
>>>>
>>>> Best regards,
>>>>
>>>> Mike
>>>> +1.972.814.4901
>>>>
>>>
>>>
>>
>> ----------
>> This email is sent from the 802 Executive Committee email reflector. This
>> list is maintained by Listserv.
>>
>> ----------
>> This email is sent from the 802 Executive Committee email reflector. This list is maintained by Listserv.
>>
>
> ----------
> This email is sent from the 802 Executive Committee email reflector. This list is maintained by Listserv.
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