Re: [802SEC] +++ 10 Day EC Ballot - Reply Comments to the FCC's Incentive Auction Proposal - Docket No. 12-268 +++
James,
Good summary!
I think that spectrum regulatory filings should generally fall under your
procedure 3), with updates or corrections submitted as needed depending on
the need of the situation, or the process implemented by the regulatory
body.
For instance, ITU-R filings that are edited inputs to recommendations (like
tables of PHY characteristics) may need to be updated over the course of the
revision of the recommendation as new information becomes available. Once
the recommendation is published, the all the 802 submissions become
historical data.
Similarly, updates to documents like the WP 5D IMT specifications may have
multiple submissions with more detailed data in each submission, but once
the specification is published, the submissions have only historical value.
For FCC filings, and regulatory filings to other national administrations,
updates to the original document are rare in the 802 process, although they
can be submitted as a correction or further clarification depending on the
situation.
This is because we barely have enough time to meet the filing deadline in
the first place in most cases. So, this is more or less a file and forget
with respect to the particular filing.
Again, once the FCC, or other regulatory body, makes a final ruling in the
matter, our submission, like every other filer's submission, has only
historical value. The regulatory ruling effectively changes the playing
field, so whatever we advocated before becomes moot.
With respect to other documents in the 802 process, I have no opinion.
John
-----Original Message-----
From: James Gilb [mailto:jpgilb@gmail.com] On Behalf Of James P. K. Gilb
Sent: Thursday, March 07, 2013 6:05 PM
To: John Notor
Cc: 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 +++
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
>>>
>>
>>
>
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