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Re: Documents for urgent discussion and vote


In principal, I support the notion of these letters. 802 needs to stand up for its standards. A rules change that hurts deployment of systems based on 802.11 will be bad for 802 in general.

The concerns I have with the letters are that they should be stronger. The letters ought to start out by stating clearly and forcefully the specific objection to a rules change, then back up the point. Also, grammar, editing, and spelling problems can damage credibility.

I would not overemphasize the technical attacks on the viability of WBFH. It's fine to briefly state your concerns, but this can't be the cornerstone. One one side, you have millions of committed dollars believing that a technology will work. On the other, you have words on paper saying it won't. Words, no matter how convincing, cannot win this argument.

I would suggest that you consider an argument like this:
-The FCC has set up rules for the ISM band.
-Technical experts under IEEE have developed standards for useful services under these rules.
-Because there is a standard, and because it is a good one, the market is flourishing.
-Now someone wants to change the rules.
-There is no need for the change; the current rules allow the services people need.
-A rules change to allow alternative standards will simply slow the rate of acceptance.
-The specific rules change will result in harmful interference.

If 802 plays this game, it ought to play to win. I wish you had stronger material. On the other hand, I know that time is short. I'll support the the current letters if that's the best you have.

I've attached specific comments.


(1) Both documents 99/209 and 99/210 say:

"At the Interim Meeting 0f 802.11, there were xx members present, and this Amendment was debates. The vote to submit this documen to the FCC was 18 Yes, 0 No and 0 Abstain at the Interim meeting, xx-Yes, yy-No, zz-Abstain at the Letter Ballot among the full 802.11 Working Group. The Committee's Executive Committee voted to submit this document by a vote of xx-Yes, yy-No, zz-Abstain."

-As an SEC member, I'd like the first "xx" filled in.
-The grammar, spelling, and intelligibility of this section are all weak. This section should be easy to read and understand. [Although I'd probably move it to a footnote or endnote.]

(2) The SEC started asking in July where 802.15 stands on all of this. I am still wondering. It seems significant that 802.15 has signed both letters; this helps support the notion that this is a broad industry consensus. The point would be made much more strongly if you described 802.15, much like you have described 802.11, and reported 802.15 approval this letter, just as you reported 802.11 approval.

The following comments pertain to 99/209:

(3) "At the IEEE 802.11 interim meeting, the chair of the HomeRF Working Group presented opposing views that were not supported by the Committee."

"The Committee" is the "LAN/MAN Standards Committee", which was not in session at that meeting and wasn't in a position to support or not support the views. Anyway, the statement is vague. I would think that a better account of the discussion might bolster the letter. Otherwise, I'd prefer that the sentence be dropped.

(4) "To bring the delay spread robustness for a wide band frequency hopper to the level required for normal operation, there is a cost (nothing is free)."

Some things _are_ free. Such gratuitous comments only detract from the point.

(5) The letter is not organized so as to strongly make its points. The first time you list the key points is in (a) and (b) on Page 3, which I reproduce [followed by comments in brackets]:

(a) Direct Sequence Spread Spectrum (DSSS) systems were able to achieve higher throughput without requiring a change in the Commission's Rules. More importantly, higher data rates were achieved with no change in the Power Spectral Density (PSD) of the DSSS waveform. Therefore, there is little or no impact in terms of increased interference with other users of the band.
[So what? What is the point of this in regard to the NPRM? You need to be clear. And what does it have to do with the rest of the letter? Why isn't it ever mentioned again, even in the summary, if it's one of the two key points?]

(b) {that WBFH systems will be unable to consistently achieve substantially greater data rates than 1 MHz systems due to multipath}

In the Summary at the end you again to list the points of this letter, which are:

-the Committee opposes the changes to the operating rules for FHSS systems as described in the Commission's Notice of Proposed Rule Making in this proceeding
[This is the first time you have explicitly made this point in this letter. It should have been said up front.]

-the Committee reconfirms comments made in the August 19, 1999 comment letter to the Commission
[OK, you did say this up front, but it's hardly news that you haven't changed your mind.]

-and additionally concludes that WBFH systems with FSK modulation will suffer severe impairment due to multipath channel distortion
[You have basically said this, but the version in (b) was much more explicit and pointed.]

-The Committee additionally believes that these systems would not be economically viable
[Earlier you said the cost would be "to the level of currently employed direct sequence systems or higher". That's very different from "not economically viable". Anyway, people are committing dollars based on their assumption that it IS economically viable, and that's more convincing that an opinion otherwise.]

-and would represent a threat to existing users of the band
[You never address this point in the current letter, except where reiterating comments from your previous letter. You'd be better off to focus on what's new rather than jumbling it up with what is old.]

-The Committee is also forwarding two papers as described above in support of our comments in this matter.
[In what way do they support your comments? You haven't said. It appears they are relevant to your previous letter, not to the current one.]


>Dear SEC colleagues,
>Please find attached the bodies of the two draft letters we need to file at
>the FCC in response to an NPRM. Those drafts are a further enhancement of
>the ones I sent you on September 15, 1999 with the subject: "Heads-up for
>plan to run approval scheme for FCC NPRM Comment filings".
>In the mean time the IEEE-USA representative has approved them.
>Before Jim Carlo starts the ballot (I do hope tomorrow), he asked me to send
>these files to you for discussion.
>The filing deadline is Monday, October 4th, 1999, but I would like to have
>it filed on Friday October 1.
>Please help us achieving the goal of filing the end of this week!
>If you want to see the document 99/209 in its entirety, please go to the web
>Vic Hayes,
>Chair, IEEE P802.11, Standards WG for Wireless Local Area Networks
>Lucent Technologies Nederland B.V.
>Zadelstede 1-10
>3431 JZ  Nieuwegein
>The Netherlands
>voice phone number: +31 30 6097528 (Time Zone UTC+2)
>fax phone number: +31 30 609 7556