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Dear colleagues,
With this email I would like to announce the start of a LMSC ballot on an ex-parte submission to Ministry of Industry and Information Technology (MIIT) of People’s Republic of China in response to its notification to World Trade Organization on the updated radio regulations of the Ultra Wideband (UWB) equipment.
Paul has delegated to me to conduct a LMSC (EC) 10-day electronic ballot on the motion below to approve the comments to the administration. This EC motion is per IEEE 802 OM 7.2.1 Procedure, P&P 7.1 b) (majority response) and P&P 7.1.2 (2/3 approval of votes cast) for communication with government bodies and public statements. With that we would like to see everyone respond.
Move to approve document https://mentor.ieee.org/802.18/dcn/23/18-23-0107-06-0000-draft-ex-parte-submission-to-china-miit-s-consultation-on-its-updated-regulations-of-radio-management-on-uwb-equipment.pdf for submission to Ministry of Industry and Information Technology of People’s Republic of China before the submission deadline, with editorial license granted to the IEEE 802.18 chair.
• Approved in the RR-TAG: _8_ / _0_ / _3_ (The Chair did not vote)Mover: Edward Au
Seconder: Clint Powell
Start of ballot: 12 October 2023
Close of ballot: 21 October 2023
Reference documents:https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=q:/G/TBTN23/CHN1753.pdf&Open=Truehttps://docs.wto.org/dol2fe/Pages/FE_Search/ExportFile.aspx?id=297960&filename=2023/TBT/CHN/23_12098_00_x.pdf&Open=True
Regards,
Edward
On Wed, Oct 11, 2023 at 10:07 AM Edward Au <edward.ks.au@gmail.com> wrote:
Dear colleagues,
In the past two days, Roger and I discussed this draft submission to MIIT. The following is the latest update:
1) IEEE 802 is not a member of WTO and therefore, we do not have any means of submitting comments to WTO directly to raise the concerns identified by a few 802 participants. The best we can do is to send an ex parte to MIIT and ask them to reconsider their positions.
2) To avoid any confusion and misunderstanding, the title of the draft response is now "Draft ex-parte submission ...".
3) There are editorial changes to the draft response by considering the following suggestions from Roger:
a) Replace "Telecommunications Bureau” with "Radio Administration Bureau”
b) We add the following sentence in the first paragraph: "We understand that the consultation has closed. Nevertheless, we are writing to offer further comments on this topic, particularly in view of the updated regulations sent to the World Trade Organization."
4) The latest draft is available for your (quick) review before I may open a 10-day letter ballot tomorrow (12 October 2023)
a) Revision 5 that highlights the changes with respect to revision 4:
https://mentor.ieee.org/802.18/dcn/23/18-23-0107-05-0000-draft-ex-parte-submission-to-china-miit-s-consultation-on-its-updated-regulations-of-radio-management-on-uwb-equipment.pdf
b) Revision 6 that is a clean version of revision 5:
https://mentor.ieee.org/802.18/dcn/23/18-23-0107-06-0000-draft-ex-parte-submission-to-china-miit-s-consultation-on-its-updated-regulations-of-radio-management-on-uwb-equipment.pdf
5) Regarding the ex-parte submission to the administration, the following is the suggested guideline we received from an 802.15 participant who confirmed with the administration on the submission procedure:
---
We used the mailing address provided in the following link that was published by MIIT in January to solicit feedback regarding the UWB regulations.
https://www.miit.gov.cn/gzcy/yjzj/art/2023/art_42a55669ef094373a01a838e235088c1.html
Contact Person: Radio Administration Bureau, Ministry of Industry and Information Technology
Contact Number: 010-68206220 (Fax)
Email: xhhz@miit.gov.cnAddress: Radio Administration Bureau, Ministry of Industry and Information Technology, No. 13 Xichang'an Street, Xicheng District, Beijing
They have confirmed that it is still possible to collect feedback information through the channels provided in the January announcement. We also briefed them on the methods IEEE 802 LMSC is using to gather feedback. MIIT mentioned that you can continue to send them materials by mail or email for their review.
Although the deadline to feedback has expired according to the notice, we still sent our company's statement to the above address, and SRRC has confirmed the receipt of our material.
I also find the contact info of the SRRC from the following website. Although we haven't yet utilized this channel to contact MIIT/SRRC, we have it for future reference:
http://www.srrc.org.cn/contactus.aspxRadio Business Acceptance Phone Number: 010-68009200/68009208
Radio Equipment Testing Service Phone Numbers: 010-57996304/68009204/57996045/57996023
Address: 80 Bei Lishi Road, Xicheng District, Beijing
Postal Code: 100037
Phone: 86-10-68009292
Fax: 86-10-68009299
Website: http://www.srrc.org.cnEditorial Department Phone Numbers: 86-10-68009016/9018
Submission Email: srrcweb@srrc.org.cn---
Regards,
Edward
On Mon, Oct 9, 2023 at 2:35 PM Roger Marks <r.b.marks@ieee.org> wrote:
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?
Cheers,
Roger
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=Truehttps://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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