Re: [802SEC] +++ EC review +++ a draft IEEE 802 submission to China MIIT

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Edward,

Can you explain the context? This is identified as a "Draft Liaison to China MIIT’s consultation.” I don’t know what that means. We don’t have a liaison relationship with a governmental agency.

As I understand, we responded earlier to an agency consultation, and now they have announced their resulting national regulations and some people are dissatisfied. And, I guess, since the regulations were notified to the WTO, there is an opportunity for comments. But it’s not clear to me how the comment process works, and what entities are entitled to comment. For all I know, it is only WTO members. Can you show us the process? Does IEEE 802 have standing to comment? Where and how should comments be addressed?

Basically, I’m concerned that sending an uninvited complaint about regulations adopted by national government may be poorly received and cast a bad light on us. If there is a process, we need to carefully follow the process, and the statement should precisely articulate the process we are following. This draft does not do that. It is addressed casually ("Dear Telecommunications Bureau”, which I presume is a typo). I’d like to know exactly to whom the statement is addressed (and why that’s the right entity). The draft then says "Please find below the IEEE 802 LMSC’s specific comments on the updated radio management regulations.” That needs to be expanded to cite the WTO notification and the procedure under which the comment is filed.

Can you help me understand this?

On Oct 6, 2023, 9:32 AM -0600, Edward Au <edward.ks.au@gmail.com>, wrote:

Dear EC members,

I would like to request the review of the following draft IEEE 802 submission by Monday, 9 October 2023, A.O.E, before asking the EC to consider approval of the submission through a 10-day letter ballot.

•Following the consultation on the “900MHz Frequency Band Radio Frequency Identification (RFID) Equipment Radio Management Regulations (Draft for Comments)” and “Ultra Wideband (UWB) Equipment Radio Management Regulations (Draft for Comments)” that was closed in February 2023 and IEEE 802 LMSC submitted a response, China sent a notification to World Trade Organization (WTO) in late August 2023 on its updated radio management regulations on UWB. The proposed date of adoption is November 2023 and the proposed date of entry into force is November 2024.

For the updated radio management regulations, MIIT of People's Republic of China accepted our comments on aligning the proposed spectral density mask with those in IEEE Std 802.15.4-2020. In the updated regulations, however, there is a new requirement (which did not show in the original consultation) on a maximum value of 650 MHz for the 10 dB bandwidth in the proposed regulations that we would like the administration to reconsider. It is because the proposed requirement on the 10 dB bandwidth may limit the capabilities of UWB equipment in utilizing the IEEE HRP UWB PHY channel 11 to support high-resolution sensing applications and high-accuracy ranging applications.

A few individuals prepared a response, which was reviewed and approved by IEEE 802.18 yesterday (5 October 2023) with the following voting results: 8 Yes, 0 No, 3 Abstain.

Link to the draft response:

https://mentor.ieee.org/802.18/dcn/23/18-23-0107-04-0000-draft-liaison-to-china-miit-s-consultation-on-its-updated-regulations-of-radio-management-on-uwb-equipment.pdf

Reference:

https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=q:/G/TBTN23/CHN1753.pdf&Open=True

https://docs.wto.org/dol2fe/Pages/FE_Search/ExportFile.aspx?id=297960&filename=2023/TBT/CHN/23_12098_00_x.pdf&Open=True

Thanks and Regards,
Edward

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