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I have given our reactions below. 

Jim, if find it appropriate, please froward to Mr. Berger.
 Vic Hayes 
> ----------
> From: 	Jim Carlo[]
> Sent: 	Wednesday, September 29, 1999 00:37
> To: 	IEEE802
> fyi. Comments from Stephen Berger on ongoing 802 SEC ballot.
> 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: Berger, Stephen []
> Sent: Tuesday, September 28, 1999 2:16 PM
> To: 'Jim Carlo'
> Jim,
> Thank you for the opportunity to comment on this ballot.  A few minutes
> ago
> we had a conference call of those supporting the NPRM.  
VH--> The referenced group (is it the HomeRF Working Group?) has already
been heard by the FCC. Why is the opinion of this group important to IEEE
802? They have the full right to file their own comments. On the other hand,
Mr. Berger signed as Chair, IEEE EMC Society Standards Development
Committee. Does that committee only have supporters of the NPRM.

VH--> IEEE 802 opposes only the WBFH part of the Notice. We support the
proposal of the Notice for additional mathematical analysis for DS devices
using less than 10 chips.

VH--> We have provided ample opportunity to the HomeRF group to provide
technical arguments for the WBFH and against our technical material. We have
not received that information, though.

> A couple of things
> came from this converstation.  Please feel free to forward this to your
> committee if you so desire.
> The first is just an administrative item.  The attachment you have on this
> note has 8 pages in it.  The actually letter, which is available at the
> you supplied has 51 pages.  You may want to check that your committee
> reviews the full letter being proposed.
VH--> The file was much too large to attach to an majordomo reflector. Jim
clearly indicated that there was more to be found at the URL.

> More to the point we will be presenting to your committee by EoB Thursday
> a
> presentation of our position.  It essentially has two points.  The first
> is
> that we believe no further letters should be sent.  We will more fully
> explain our position in the letter now being drafted.  However, it rests
> on
> 2 basic points.  The first is that these comments affect a lot of
> equipment
> types beyond 802.11 equipment. Thus these comments go far beyond the PAR
> of
> 802.11.  The current letters amount to a single viewpoint of several
> within
> the IEEE.  
VH--> I assume Stephen means the potential rulemaking, not just the
comments, affects many types. This is true, but the fact that it has a
serious negative effect on equipment complying with the IEEE 802 standard
gives us ample reason to object to it. It would be a serious drawback to any
RF based standard we develop if we are not allowed to monitor and interact
on regulations that affect the standard. 

VH--> Further, the attachments show that most types of equipment complying
with the current rules would be affected negatively by the proposed rule

VH--> Also, it would be helpful if the supporters of the rules change would
tell us to what other types of equipment, other than the HomeRF equipment,
the proposed rules affect positively. Is this current equipment or just
proposed or planned equipment? Current equipment follows the current rules
and I suspect that most is very comparable to that which follows the 802

VH--> Lastly, we are protecting approved IEEE standards, not just PARs.

> Secondly, the arguements are technically flawed primarily in that
> they make certain opening assumptions which are not valid.  The detailed
> calculations all become meaningless because they are calculating effects
> from equipment which is not being proposed.
VH--> The supporters of the Notice have had ample opportunity to show us any
flaws in the assumptions. We cannot respond to such a general statement
about flawed assumptions until the alleged flaws are brought out. There is
an immediate deadline on filing the comments. This item now should be
resolved in the public comment and reply phase of the Notice.  

VH--> The second statement implies that the rules change would only apply to
some currently proposed equipment. The Notice doesn't propose equipment; it
proposes a regulation. When contemplating a new regulation it is always
necessary to think in terms of any future equipment that might be
forthcoming that follows the regulation

> We hope that our first position will find favor with your committee.
> However, should we fail in that we will attach to our letter a draft of an
> additional letter to the FCC.  We will ask if these additional 802.11
> letters are filed that this additional letter also be filed in order to
> document the legitimate range of valid technical opinion within the IEEE.
VH--> The supporters of the regulation should file the letter as their own
comment to the Commission. This apparently is the group that filed the
request that resulted in the Notice. They would be required to reply in the
appointed 30 day reply phase if IEEE 802 were not operating in a public
process. Our process gives them an advantage relative to us. 

VH--> IEEE 802 should not file a letter for this group.

> If we go this route there is one very important value to be realized in
> this
> additional letter.  If only one point of view is on file as from the IEEE
> then some of us may find ourselves in the undesired position of needing to
> expose the technical flaws in that position.  With 2 IEEE positions on
> file
> we can then support one or the other and not be in the position of
> attacking
> the IEEE position.  Those of us with strong IEEE heritage would really
> appreciate a way of defending our position in this NPRM without publically
> attacking the IEEE.
> Best Regards,
> Stphen Berger
> Chair, IEEE EMC Society Standards Development Committee
VH--> If this view represents that of the EMC Society, they should file the
comments and let two IEEE views be represented. It is too late and
impractical to organize a group that can get the view of the whole of IEEE.
It would be a terrible precedent if an IEEE standards group is prevented
from registering comments with the Commission because of a last minute
objection from the leadership of another group

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

> -----Original Message-----
> From: Jim Carlo []
> Sent: Tuesday, September 28, 1999 10:47 AM
> To: Judy Gorman; Berger, Stephen; Ian Gifford
> Cc: Vic Hayes; Don Heirman
> fyi. Here is actual SEC ballot now in progress. Would appreciate any
> inputs
> from Staff and other groups. Please send these to Vic Hayes and I. NOTE
> 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: Tuesday, September 28, 1999 9:48 AM
> To: IEEE802
> Cc: Vic Hayes
> ++++++++++++++++++++++++++++++++++++++
> SEC OFFICIAL EMAIL BALLOT     802.0/28Sept1999
> Issue Date:   28Sept1999        Closing Date: 1October1999
> Moved By:     Vic Hayes
> Seconded By:  Bob Heile
> Move: Authorize responding from IEEE 802 to the FCC NPRM (Docket No.
> 99-231)
> with the document 11-99/209-r5 (in principal). This letter has some
> opposition from
> the proposers of the rules-change.  It was approved by 802.11 by 802.11
> EMAIL ballot:
> 68-Yes, 3-No, 3-Abstain.
> This letter  "expresses opposition to the proposed rule changes which
> would
> allow wider channels for Frequency Hopping Spread spectrum (FHSS) systems
> as
> described in the Notice of Proposed Rule Making (the "Notice") in this
> proceeding. Since that time, the membership has continued to
> analyze the proposed rule changes. Two working groups of the Committee
> (802.11 on wireless Local Area Networks and 802.15 on Wireless Personal
> Area
> Networks) held an Interim Meeting in San Rosa CA (13 - 17September 1999)
> and, based on additional material submitted, 2 respectfully submits these
> additional comments in this proceeding."
> Note that this letter adds to information provided in letter approved by
> the
> SEC in July. Also another letter has been voted on (see ballot #2). The
> two
> letters may be combined into a single letter.
> Approval is requested for this letter (in principal) to allow for editing
> by
> Vic Hayes, Bob Heile and Jim Carlo based on various comments (including
> staff) being provided. The letter needs to be submitted to the FCC by
> 4October.
> If you want to see this proposed letter and appendices, please go to the
> web
> at: