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PASS: [802SEC] +++Approve Response to FCC FNPRM


Vic, could you rework the details of editorial comments and send "proof"
version to the SEC. Then, we will submit.

Bob Grow - Approve with Comments
Bob O'Hara- Approve
Paul Nikolich - Approve with Comment
Buzz Rigsbee -
Vic Hayes - Approve
Tony Jeffree - Approve
Geoff Thompson -
Stuart Kerry - Approve
Bob Heile - Approve
Roger Marks - Approve with comment
Mike Takefman - Approve

>From Roger Marks: (1) I requested input from my Working Group by yesterday
and received
no comments. (2) I may have some editorial comments to add; if so, I'll send
to Jim and Vic before the ballot closes.

>From Paul Nikolch: I have a few editorial comments:
1a) section 1.4 IEEE 802.11 does not explicitly define 802.11g as the
"additional radio entity for higher than 20Mbps data rates in the 2.4GHz
band" project, yet the term 802.11g is used in at least 2 places later in
the document (section 2.1).  Please explicity define 802.11g.
1b) similarly in section 1.4 IEEE 802.15 should explicitly define the
802.15.1, 802.15.2, 802.15.3, 802.15.4 projects.
2) section 2.1, paragraph 1.  Typo; 801.11 should be 802.11

>From Bob Heile: WG vote at plenary meeting was 18-0-2 as amended.

>From Stuart Kerry: Mr. Chairman,
After posting to the 802.11 membership the request to review the
aforementioned FCC FNPRM letter as modified, I feel that my abstain vote at
the Closing SEC meeting in Portland should now be overturned to Approve, for
this ballot.

The justification for this judgment is that an overwhelming majority of the
802.11 membership did not respond to the email reflector pole, requiring
dissenters to voice their views. This maybe shows a lack of interest, but I
feel more importantly, in the satisfaction of the letter.

Those 3 members that did comment, I judge could have their wishes fulfilled
by Vic accommodating their observations into the final version of this
letter. This being over and above Vic's goal to make the Radio Regulatory
group charter, and formation of said group quickly. Which I whole heartedly
support and encourage it be done with hast.

I would also point out to the membership that there are further chances in
the FNPRM process that could accommodate other improvements. It is
imperative now that IEEE 802 shows the ever increasing strength of the
membership and the successful adoption of these standards and technologies
in the marketplace.

Finally, in approving it, I would like to see the final version with those 3
members wishes included before it is sent. I look forward to Vic's final

- Stuart J. Kerry
Chair, IEEE 802.11 Wireless Local Area Networks Working Group

Received Comments:

1)	Victoria Poncini:

The only portion of this letter I oppose is section 2.2.1 the last sentence
in paragraph 4 of this section. IEEE doc: 01/391-r7 fails to provide data
value needed for the limitation we are suggesting. The recommendation to
limit the spectral power density for digital systems is not defined.  There
appears to be a place holder of “dBm/MHz” with no recommended limitation to
make the power density equivalent to that of other 2.4 GHz devices.  I’m
assuming that testing was done, or calculations were made and there is a
numeric value “the committees” would recommend for use by the newer digital
systems.  Am I way off on this? Have I missed something in the document? I
think we (the IEEE committees) should provide the FCC with a recommended
value and the rationale (with data) to back it up.

2)	Sean Coffey:

In response to your request for 802.11 feedback on the letter to be sent to
the FCC, I feel I still have not been given enough information to make an
informed decision, as indicated below. I am unsure about what the letter to
be sent is.  However, I’m very sure that the process is extremely

I am still unclear as to exactly what changes have been made, and are to be
made.  I basically agree with the document 391r7 as circulated.  In
particular, it contains entries on both (I) the need for peak power
limitations, and (II) a request for a waiver for the new frequency hopping
rules.  I feel that both of these are extremely important and I am FOR such
a letter.
However, is this really what we are voting on?  At the Portland meeting
there was a last minute change, by 802.15, to the then-current draft, 391r6,
involving deleting one section.  It was not clear to the membership what we
were voting on, and the matter was ruled out of order.  I was told by Vic
Hayes during this discussion that the deleted section was 2.2.1, i.e., the
section dealing with peak power limitations.  If this is the change, then I
am AGAINST the letter.

However, 391r7 appears to indicate that it is section 2.2.2 that has been
dropped, which would be fine.  Which is it?
More generally, I would like to go on record as saying that the process by
which we put together letters to the FCC  is extremely unsatisfactory, and
has come to the stage where formal protests need to be considered.  I do not
think that it is acceptable that major changes can be made to important
documents minutes before they are voted on; I do not think it is acceptable
that the very text of the document to be voted on is unclear to members who
have followed the process with due diligence; I do not think it is
acceptable that the procedure allows, in effect, some groups within 802 to
make last-minute changes that are then presented as a fait accompli to

This is not the first time issues related to the RR group have appeared.  In
the Monterey meeting, a document was issued from the group that contained a
highly prejudicial and tendentious assertion that affected the work then
going on in Task Group g; no notice of this comment was given before 802.11
was asked to vote on the document, and no notice was given to TGg.  The
final version of the document containing the assertion was not available in

Concerns were raised by many people during the Portland meeting about the
need for the output of the RR group to be debated adequately in 802.11, and
for the process to be reformed. Unfortunately the chair of the RR group does
not appear to have taken these concerns seriously, at least up to this
point. Again, I find this unsatisfactory.

3)	David Hytha: (Opposed)

The letter needs one simple but important item to be acceptable:
We have to define what should be the interference framework which governs
adaptive hopping.  Description: The FCC is moving away from detailed
standards specific rules but some definition of interference conditions may
be necessary to referee the multiple users in the band.  A framework that
does this IS EXPECTED of the IEEE as the widest represented group.

Vic Hayes’s Retort to David Hytha:

I am sorry to hear your comments at this late stage of the game. We can only
make minor changes to the document.
I have sent several e-mails to the regulations, dot 11, dot 15 and dot 16
reflectors requesting input as well I made an announcement at the May
meeting. If you have contributions to make, please provide them in time in
future. We can use your talent very well.

What we now have is the best we could get.

David Hytha’s Retort to Vic Hayes:

These comments were all made in Portland by several people including myself
but were not included.  My concern is that the FCC looks to the IEEE to come
up with a solution that will serve the broadest possible number of
standards.  Our response has not addressed the key issue of how do you
measure or adapt to interference without standards specific responses. The
question is left unanswered.

Further Retort by Vic Hayes to David Hytha:

Sorry David, you are still not specific in what you wanted to add. I do not
recollect a submission from you. Nor do I recollect any oral input during
the 2 meetings of the regulatory group you attended (Tuesday 10:30 AM and
Tuesday 3:30 PM).
Peter and Denis, you were secretary and were there all the time, do you
recollect any input from David that we missed?
However, as said before, there is no way we can add anything other than
editorial in the material.

Bob Grow: Approve with editorial comments.
1.  3rd paragraph of letter, "support" -> "supports" similar verb agreement
problems in: 1. "operate" -> "operates", last paragraph of 2.2.1 "propose"
-> "proposes", 3. "welcome" -> "welcomes",
2.  "Committee" is defined as LMSC, yet it is also used for 802.11.
References to WGs should be "committee", two occurrences observed in 1.4.
3.  2.1.1  First line -- space on wrong side of comma.
4.  page 4 footnote, "3Comm" should be "3Com"
5.  signatures "WirelessPersonal" -> "Wireless Personal"
Issue date: 15Jul2001Closing Date: 28Jul2001
Moved By: Roger Marks
Second By: Vic Hayes
Move: to submit document RR-01-012 as Comments to FNPRM 99-231. Objects
between square brackets are subject to change to reflect the reality.

Document RR-01-012 r0 contains the items between square brackets, worked out
according to the actions taken in the WGs and the SEC. It also has taken the
effect of the dot15 amendment into consideration. Revision marks can be made
visible.This is the version that will be submitted by Vic Hayes and I (note
both Vic and I will send the document together - I will add my coordinates).

The attached zip file contains document 11-01-391 r7. This is the version
according to the motion to amend made in dot 15

Wireless working group Chairs are expected to poll their groups on these
comments within 10 days.

Vic Hayes
Agere Systems Nederland B.V., formerly Lucent Technologies
Zadelstede 1-10
3431 JZ  Nieuwegein, the Netherlands
Phone: +31 30 609 7528 (Time Zone UTC + 2)
FAX: +31 30 609 7498