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Based on the letters presented by Jim Carlo, there is a significant procedural
question raised about the appropriateness of the submission.  I don't believe
there will be any short resolution of this issue and therefore I ABSTAIN on this

Ballot # 2:    ABSTAIN - RD Love

Best regards.

Robert D. Love
Program Manager, IBM ACS - US
Chair IEEE 802.5 Token Ring Working Group
500 Park Offices                   Phone: 919 543-2746
P. O. Box 12195 CNPA/656           Fax: 419 715-0359
Research Triangle Park, NC 27709, USA    E-Mail:

"Jim Carlo" <> on 09/28/99 10:47:16 AM

To:   "IEEE802" <>
cc:   "Vic Hayes" <>
Subject:  +++ SEC BALLOT #2 ON FCC SUBMISION  (DS Test)

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 doc.: 11-99/210-r4 (in principal). Approved by 802.11 EMAIL ballot:
69-Yes, 2-No, 3-Abstain.

This letter states that  "The Committee supports the CW jammer test,
together with the additional requirement for mathematical justification for
systems utilizing codes with less than 10 chips as proposed in paragraph 15
and advises the Commission of our concerns regarding an alternative Gaussian
noise test as proposed in paragraph 14. Members of the Committee have
performed extensive analysis and technical trade-off studies that were
discussed at the IEEE 802.11 Interim Meeeting (Santa Rosa, 13-17 September
1999) to ensure that its 2.4 GHz high data rate waveform adheres to the
processing Gain requirement of at least 10dB.2 As a result of these
studies, it has concluded that the processing Gain test using the CW jamming
test as proposed in paragraph 15 of the Notice is a valid method to confirm
the processing gain requirement.

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 IEEE
staff) being provided. The letter needs to be submitted to the FCC by

If you want to see the document 99/209 in its entirety, please go to the web