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RE: Submissions to FCC/ future framework

SEC Colleagues,

On reading the e-mail from Jim again, it struck me that the lead for
regulatory matters would shift from 802.11 to 802.15 if the regulatory
matters are placed under the PAR currently in preparation by 802.15.

However, the motion on the establishment of 802.15 clearly stated that
802.11 was the leader in regulatory matters.

So in conclusion, we either need to find another method to bring those
regulatory matters into a formal framework, or we need to assign the work on
the Co-existence PAR under 802.11.

For the time being, I urge that we continue the current approval process:

Approve by 802.11, approve by 802 and ensure approval from the IEEE-USA
board for filings in the USA.

By the way, I already obtained approval from Dr. Sauthoff on both new


> ----------
> From: 	Jim Carlo[]
> Sent: 	Thursday, September 23, 1999 00:20
> To:
> Subject: 	WLAN/ Submissions to FCC
> Importance: 	High
> Vic asked me to send this out to the 802.11 Working Group (to speed
> dissemination) per my long discussions with Vic and others this morning.
> 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
> -----Original Message-----
> From:
> [] On Behalf Of Jim Carlo
> Sent: Wednesday, September 22, 1999 2:12 PM
> To: IEEE802
> Subject: Submissions to FCC
> Importance: High
> 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
> comments).
> 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