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Submissions to FCC

A status note to let you know some ongoings. I'd appreciate any comments
(either private or to the reflector). Jim Carlo

Since the SEC is responsible for coordinating with Government Agencies
{Procedure 3 All communication with government agencies or regulatory
agencies shall go through the
Executive Committee.), I wanted to give you a heads-up on the latest issue.

In response to the FCC Wideband portion of FH NPRM (99-231), at our July
meeting, 802.11 and the SEC approved a motion to submit a controversial
letter to the FCC
against this proposed rule change on the basis that this change would
increase interference into 802.11 and 802.11b radios and that the change was
not needed
(the change had been requested by HomeRF). There was some discussion at the
SEC Thursday meeting on this issue, but the SEC supported the letter going
forward from 802.11 (802.15 did not endorse this action but did not oppose
the action). I subsequently reviewed this letter, Vic Hayes received
IEEE-USA approval, and the letter was submitted on 19August (I delayed
submission pending circulation of the draft to both Bluetooth and HomeRF for

Some events and questions at this point in time:

1) The question has been raised on who IEEE 802 speaks for? In the letter
submitted to the FCC, it is implied that this is a position of the IEEE and
Computer Society (the letter is submitted on Computer Society letterhead). I
believe the letter to the FCC over-represents the position in the industry.
Both Judy Gorman and Dick Hollerman have asked this question.

2) Who can vote on this letter? What about minority positions? What voting
guidelines do we use for these submissions? Since there is not really a
project within 802 to produce this letter (we do have projects to develop
standards, but not to develop positions), some people have complained that
they were not allowed to participate in the voting on this letter. The
question is have we enlarged the charter of 802 without providing due notice
and representation?

3) IEEE 802 must be able to defend its standards from rules changes that
negatively impact 802 standards.

4) The IEEE has an EMC Society (chair-Don Heirman) and an IEEE EMCS Standard
Development Committee (SDCOM-chair Stephen Berger) which has objected to not
being allowed to participate in the development of the 802 position. The
point made is whether developing such a position is clearly specified in the
PAR for the project.

What I would like to do going forward:

1) Clearly establish 802 as having the authority to develop industry
positions on the 2.4GHz band through the development of a project on
spectral interoperability. We have a study group to do this already in
802.15, and I believe we should drive this to develop a "Guide".

2) Review carefully the current two letters currently in ballot in 802.11
for further submission to the FCC. Unfortunately, time pressure requires
that inputs be made prior to 4Oct and further comments a month later, before
we will have time to meet again. I am not sure having another "position"
letter is the best thing to do.

Jim Carlo( Cellular:1-214-693-1776 Voice&Fax:1-214-853-5274
TI Fellow, Networking Standards at Texas Instruments
Chair, ISO/IEC JTC1/SC6 Telecom and Info Exchange Between Systems
Chair, IEEE802 LAN/MAN Standards Committee