Thread Links Date Links
Thread Prev Thread Next Thread Index Date Prev Date Next Date Index

Re: [802SEC] Comments and reply comments to Public Trial of Google TVWS Database

All
The 30 day rule is to ensure openness in the standards development process. It is found in: 
 - IEEE 802 LMSC P&P, clause 6.0 Meetings for the Sponsor
 - IEEE 802 LMSC WG P&P, clause 10 Meetings for WGs.
However, TAGs, which don't do standards development, are specifically excluded from this requirement in the IEEE 802 LMSC P&P, subclause 5.5 Technical Advisory Groups (TAGs), item e), which states:
"e) Between plenary and interim meetings, the TAG Chair is empowered to schedule teleconference meetings to allow the TAG to conduct business as required, provided that the date and time of the teleconference and agenda are published on the TAG website and e-mail reflector at least 5 days before the meeting."
This is from our current P&P, as approved by AudCom. This rule has also been in there for quite some time.
So, if 802.18 wants to schedule a teleconference, the notice is 5 days after posting to the reflector and the website. I am confused why Mike thought the 30 day rule applied to TAGs. 

30 days applies to the Sponsor and WGs, but not TAGs.

James Gilb

On 07/30/2014 07:45 AM, John H Notor wrote:

James and all,

The reply comment period for the FCC is often shorter than the initial
comment period, since, after all, the proceeding notification has been
published for some time, so it¹s not so much that the FCC didn¹t give
enough initial notice for public comment. In very complex proceedings,
like the FCC 600 MHz reverse auction proceeding we dealt with recently,
the reply comments require review of a large number of difficult to digest
documents, and the FCC is often open to a request for an extension.

The complications for 802 come when a proceeding, or, for other
international regulators, a consultation, that affects IEEE 802 is
published between 802 plenary or interim meetings, with due dates before
the next scheduled 802 meeting, plenary or interim.

802¹s actual radio regulatory response time between regularly scheduled
meetings is a 30 day meeting notice, at least one 802.18 meeting day,
another day or two for notice to the EC and a 10 day EC ballot, followed
by maybe a day to get the item to the regulatory body. Basically, in big
round numbers, that¹s around 45 days minimum.

We can argue about the 5 day review rule to shorten the time, but when
there is the possibility of some disagreement on the issue, that is not
the reliable approach for most submissions, since it could cost an
additional 5 days, then a 10 day EC ballot to resolve.

For these kinds of regulatory activities, there is no need for 802 to have
a 30 day notice, since most companies who participate in 802 whose
products depend on regulation are usually following the relevant
regulatory activity and have some idea of when the request for comments to
regulations will be published, so the notice is procedural rather than
necessary. No one is harmed by the shorter time period.

John

John Notor
President/Chief Technologist
Notor Research

Mobile: 1.408.316.8312
Mobile: 1.408.799.2738
Web: www.notor.com






On 7/29/14, 11:50 PM, "James P. K. Gilb" <gilb@ieee.org> wrote:


Mike

These are not new rules.  They are the rules under which we have been
operating for at least 4 years.

We may have been ignoring these rules, but it is not correct to say that
they are new.

BTW: Since when does the government only allow 20 day responses to any
proposed rule change?  I am not as familiar with the processes as you
are, but I thought that they needed to give adequate notification.

Thanks

James Gilb

On 07/29/2014 12:40 PM, Michael Lynch wrote:

John,

Correct, another item that the new rules prevent us, as 802, from
commenting on. The member's sponsors will be the ones having to do these
filings.

Best regards,

Mike

From: ***** IEEE 802 Executive Committee List *****
[mailto:STDS-802-SEC@ieee.org] On Behalf Of John H Notor
Sent: Tuesday, July 29, 2014 09:28
To: STDS-802-SEC@LISTSERV.IEEE.ORG
Subject: [802SEC] Comments and reply comments to Public Trial of Google
TVWS Database

FYI,

Released:  07/29/2014.  OFFICE OF ENGINEERING AND TECHNOLOGY REQUESTS
COMMENT ON THE PUBLIC TRIAL OF GOOGLE, INC.'S TV BAND DATABASE SYSTEM
REGISTRATION PROCEDURES. (DA No.  14-1079). (Dkt No 04-186 ). Comments
Due:  08/13/2014. Reply Comments Due:  08/19/2014.  OET . Contact:  Alan
Stillwell at (202) 418-2925 or Hugh Van Tuyl  (202) 418-7506
https://apps.fcc.gov/edocs_public/attachmatch/DA-14-1079A1.docx
https://apps.fcc.gov/edocs_public/attachmatch/DA-14-1079A1.pdf
https://apps.fcc.gov/edocs_public/attachmatch/DA-14-1079A1.txt

Comments Date:  August 13, 2014
Reply comments Date:  August 19, 2014

Unfortunately, 802.18 won't be able to comment on this, since our first
teleconference meeting is scheduled on August 20, due to the 802 P&P 30
day notice requirement for meetings.

John

John Notor
President/Chief Technologist
Notor Research

Mobile: 1.408.316.8312
Mobile: 1.408.799.2738
Web: www.notor.com<http://www.notor.com>
---------- 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.


----------
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.