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Dear Adrian,
Really appreciate your detailed summary of the background information and comments from others.
I had couple of issues with the way in which this document was worded which was not constructive enough as a set of comments going from IEEE 802 to the FCC.
1.
Roger’ s suggestions of adding another sentence is a way forward but does not address my concerns completely.
2.
I do not like the idea of suggesting to the FCC that 802.11 is in overwhelming opposition to the development of an amendment –
To me, it is like throwing in the towel even before the game has started -
a.
“This opinion was confirmed as the Regulatory SC conducted a straw poll indicating overwhelming opposition to the development of an amendment to the IEEE 802.11 standard
to support it. It should be noted that the uncertainty in regards to how LAA-LTE/LTE-U will operate in this band has provided an additional concern for potential development.”
3.
FCC/ NTIA did pretty well in my opinion to reduce the Exclusion Zones from hundreds of km earlier to a few tens of km now. We must recognize that this is the V1 of their
3.5 GHz rules. Once we prove that they work and do not create interference to the incumbents, Exclusion Zones may reduce during their V2 Regulations. If this is of a real concern, we should tell the FCC what we would want as Exclusion Zones.
a.
But the priority should be to preserve the General Authorized Access in the current FCC Rules by supporting them.
I feel that this Document should be the position of the 802.11 / 802.15 Working Groups. So I am okay if this is sent out as a Liaison from IEEE 802.11 / 802.15 Regulatory Standing
Committee or the Working Groups but not as an IEEE 802 LMSC Position. I intent to Vote Against it at this time as an IEEE 802 Position.
Thanks Apurva From: ***** IEEE 802 Executive Committee List ***** [mailto:STDS-802-SEC@ieee.org]
On Behalf Of Stephens, Adrian P Dear 802 EC, Whereas IEEE 802.11 has approved (In the WG: Y:47 N:0 A:2) the following motion: “To approve document 11-15/683r2 as our comments in FCC 15-47, and forward to the IEEE 802 EC, for approval and transmittal to the FCC.” Move that EC approves
transmission of document 11-15/683r2 (https://mentor.ieee.org/802.11/dcn/15/11-15-0683-02-0reg-comments-in-fcc-15-47.docx) to the FCC as a letter in response to
FCC docket 15-47, granting the LMSC Chair editorial license. Moved: Stephens Seconded: Rosdahl Start of ballot: 2015-06-04 Close of ballot: 2015-06-14, 23:59 UTC-12 Early close: As required in subclause 4.1.2 'Voting rules' of the IEEE 802 LAN/MAN Standards Committee (LMSC) Operations Manual, this is notice that, to ensure the release is
provided in a timely manner, this ballot may close early once sufficient responses are received to clearly decide a matter. Sufficient responses to clearly decide this matter will be based on the required majority for a motion under subclause 7.1.1 'Actions requiring approval by a majority vote' item
(h), 'Other motions brought to the floor by members (when deemed in order by the Sponsor Chair)' of the IEEE 802 LAN/MAN Standards Committee (LMSC) Policies and Procedures. Background information and rationale on specific form of motion 1.
The motion made at the EC telecon on 2015-06-02 was modified from the motion made in 802.11, by the addition of a sentence intended to clarify possible future intentions. The sentence was suggested by the 802.11 REG SC chair, based
on discussion he had with various parties after approval of the WG motion. Time ran out on the telecon.
2.
There was an email thread on the EC reflector, abstracted as below… a.
Apurva: “It would be better if IEEE 802 provides constructive suggestions to the FCC” b.
Roger: “I propose to add the following at the end of the introductory "COMMENTS OF IEEE 802" paragraph? "Other standards developed under IEEE 802 may be more
suitable for adaptation and use under CBRS rules."” c.
Ben: “I do not think Roger's addition addresses Apurva's concern, which is that the message lacks a positive suggestion. … I would advocate
rewording so it is clear the concerns from 802 are not uniquely 802.11 WG's concerns.” I have given some thought to the role of the EC in communications from a WG concerning that WG to an external body. The LMSC rules require that such communications pass through EC for motion at 2/3 approval. The LMSC
rules do not limit what the EC can do with that document. But, I believe we should limit what the EC attempts to do with such a document. IMHO, it should limit its actions to editorial corrections and clarifications. If it fails to approve a document, then comments on its
substantive comment could be sent back to the WG, so that the WG can adjust the document, and send it back for approval. Recent experience with the DSRC report confirms to me that this is the way we should handle such matters. I believe that attempting to modify the substantive (i.e., non-editorial) content in the EC perilously moves its role away from keeper of the process into technical judge and jury. Given these beliefs and the history recited above, I have moved the original motion as approved by 802.11. If the motion is defeated, I will collect comments to be sent to 802.11 for consideration in a subsequent attempt
to communicate with the FCC. Also, I would like to see the Chair’s Guidelines provide clarification to bound and streamline this process in future. But that is another debate. On the specific changes requested, I think both the changes proposed are essentially harmless. But I think both are out of scope (i.e., not relevant) in a response originated by the 802.11 WG specific to WLAN, which
is the scope of this communication. Notwithstanding the above discussion, I did modify the motion from that presented to the WG, to add the “, granting the LMSC Chair editorial license”. I believe this should always be
present, because I wouldn’t want to insist the LMSC Chair sent an uncorrected liaison where he, e.g., spots a speeling misteak at the last moment. Best Regards, Adrian P STEPHENS Tel: +44 (1793) 404825 (office) ---------------------------------------------- ---------- This email is sent from the 802 Executive Committee email reflector. This list is maintained by Listserv.
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