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RE: Letter to the FCC by IEEE802


I could not find you in the office the plenary, that is why I acted.

See my embedded comments.

> ----------
> From: 	Jim Carlo[]
> Sent: 	Sunday, November 14, 1999 11:44
> To: 	Hayes, Vic (Vic)
> Cc: 	IEEE802
> Subject: 	Letter to the FCC by IEEE802
> Importance: 	High
> <<File: 92658r2_Proposed_Reply_Comments_on_FCC_99-231r1.doc>>
> Vic, I am very concerned with the appropriateness of this letter. We had
> quite a go-around and discussion on whether the other two letters that
> 802 submitted to the FCC had gone through due-process and I believe we
> made
> significant progress by our inviting different parties to hear the
> responses
> before submission. In the end, I felt we had done our job properly.
> We still have concerned parties on the prior letters, with an appeal into
> the IEEE, and I do not know what the status of this is.
> The problem I have with the letter below:
> 1) I was not aware of the fact that the FCC had extended the response time
> for comments.  Therefore in a previous note you sent me that there was no
> need to submit additional comments by the IEEE 802. I am concerned that
> interested parties may not have realized that this issue would be
> discussed
> at the 802 meeting.
VH--> My note to 802.11 and yourself just mentioned that no petition to
"extend the time for reply-comments" was needed and that I can save me the
time to write such letter. I have NOT said anything about a letter myself.
Now that the FCC has extended the time, and all people knowing that we had
the meeting, the group felt that failing to file may be proof of
I have to follow up on the 802.11 action. 

> a) Was the discussion of this letter announced as part of your agenda for
> the 802.11 meeting and when. I probably missed it?
VH--> I did not change the original announcement in my agenda after my
decision NOT to make the petition to extend the time:

Send letters to liaison groups and to regulatory agencies as needed, for
FCC NPRM ET Docket No. 99-231
FCC NPRM ET Docket No. 99-42
WRC 2000/2002

There were people in the meeting room from both Proxim, Siemens as well as
Intel. They did not use their option to participate in debate.

> 2) Your updated letter to the FCC is confusing. Do I understand correctly
> that the cover page will not actually be submitted? Therefore the clear
> definition of what is the RAHG Regulatory Ad Hoc group, how many members
> were in this group (I think five members - I'd like a list and their
> companies) to show some balence.
VH-->The group that took part in the overall Regulatory work had the
following list of participants (I do not have the times they participated):
Lou Delaverson    Motorola
Don Johnson         WLAN Consulting (contracted by Lucent)
Denis Kuwahara   Boeing
Richard Paine        Boeing
Reiner Mim           Proxim
Peter Murray         NWN
Harry Worstell      AT&T

>  I believe this should be included in the
> actual letter with the other tallies.
VH--> At the meeting you were of the opinion that such was too much detail.
I agree with that. 802.11 members are sufficiently aware of their rights in
order to vote NO if they disagree.

> 3) What more review does this letter need? Why does it need review by
> Council? 
VH--> At the SEC meeting, I felt people wanting to do so, and especially
from a non-company related counsel. I discussed it while on the floor with
Jerry Walker and he said there was a budget to get counsel from a "unbiased"
person. I would have asked my own counsel else. 
> We discussed this in the SEC meeting, and the summary was not clear
> on how council could modify an 802 letter. 
VH--> Editorials are always possible. They can also warn against
undiplomatic phrases.
> As I understand it, the letter,
> after we get it correct, will be circulated to IEEE-USA and IEEE-SA Staff
> for comment and review.
VH--> I was already asking that in my e-mails.

> 4) I would also send the letter, after you update per 2), to Steve Berger
> and Ian Gifford for forwarding to Bluetooth and HomeRF for information.

> I will be in Hawaii for the next four days, so you can call me at my room,
> or on my cellular phone. Can you call me at 9:00am on Monday?
VH--> Will be in LA till 6 AM Monday. Las Vegas till Wednesday 4 AM

> 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: Hayes, Vic (Vic) []
> Sent: Friday, November 12, 1999 3:55 PM
> To: Pribula, Denise IEEE; Sauthoff, Dr. Ned - IEEE-USA VP
> Cc: Rutigliano, Janet; Carlo, Jim TI
> Subject: Request for review by Counsel
> Importance: High
> Hi Denise,
> Could you please request counsel to review this letter planned for filing
> at
> the FCC for the proceedings in ET Docket 99-231 as Reply-Comments.
> The filing date should be November 19, 1999 (FCC delayed the deadline). I
> can make a PDF file of the version Tom approves. I will then have that one
> e-mailed to him for electronic filing.
> In addition, I ask Dr. Ned Sauthof to review the contents with the
> policy.
> Thanks a lot.
> ----------
> 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+1)
> fax phone number: +31 30 609 7556
> e-mail:
>   <<92658r2_Proposed_Reply_Comments_on_FCC_99-231r1.doc>>