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[802SEC] re: Reply Comments on 5 GHZ NPRM

Dear Carl,

As you know, this issue has generated a lot of discussion within 
802.16. I have faced a difficult decision on whether to file a 
Procedure 4 motion to block the 802.18 submittal. I am aware that a 
motion to block would, in effect, kill the submission. That's because 
there isn't time to conduct an EC ballot before tomorrow's FCC 

I very much appreciate your reconciliation effort involving the 
addition of a paragraph. I agree that the new text is fully in line 
with recent 802.18 consensus positions. I also recognize that you are 
sticking your neck out in advocating the change, and I appreciate 
your leadership on the issue.

I agree with the view of some 802.16 members that the submittal, even 
as revised, does not fully support their concerns. I accept that, by 
choosing not to attend the 802.18 session in Singapore (the week 
following 802.16's interim in Denver), 802.16 members lost an 
opportunity to participate in the development of the document. In the 
802 process, participation is central. On the other hand, we also say 
that our process is contribution-driven. I believe that some 
non-attendees would have been likely to participate by contribution 
if they were aware that this topic was on the agenda. I would like to 
see 802.18's process be refined to ensure that a list of intended 
topics be provided on the 802.18 reflector in advance of your 
sessions, along with at least an informal Call for Contributions. I 
think that this is particularly critical when 802.18 is meeting 
without the presence of some of the 802 wireless groups.

I'll make an effort to explain to the 802.16 community that they need 
to stay on top of the regulatory issues and be actively engaged with 
802.18. Though we don't agree on all issues, I think that we can 
continue to find a lot of common ground.

Having weighed all the issues, I have decided not to file a motion to 
block the revised submittal. I encourage the SEC, and the 802.16 
membership, to support you on this issue and in your broader efforts 
to forge 802 consensus.



At 2:43 PM -0400 03/09/22, Stevenson, Carl R (Carl) wrote:
>Dear EC members,
>After the approval of 
>18-03-0061-00-0000_802_18_Rep_Cmts_ET-03-122.doc by 802.18, 802.11, 
>and 802.15 in Singapore, and its submittal for the 5 day EC 
>pre-filing review, an issue was raised by a member of 802.16 (who 
>did not attend our meeting in Singapore).
>There has been some discussion amongst the parties, with Roger 
>Marks' participation, and in the interest of addressing the concern 
>expressed by the member of 802.16, I have proposed to add a 
>paragraph, with an appropriate heading to the document as an 
>editorial change. (text follows within ***** lines, with the 1st 
>sentence being the heading)
>The Commission should endeavor to identify additional spectrum for 
>high power outdoor point-point and point-multipoint broadband 
>While we understand that the Commission is bound by the ITU Radio 
>Regulations regarding the bands under consideration in the instant 
>Proceeding, we (consistent with our previously filed comments) share 
>the concerns of the License-Exempt Alliance (LEA) regarding the 
>Commission's assumption of the adequacy of the 100 MHz at 
>5.725-5.825 MHz for higher-power outdoor operations. While "out of 
>scope" in the instant Proceeding, we encourage the Commission to 
>remain committed to finding ways to provide increased capacity for 
>such services through another proceeding.
>I would hasten to point out the following to the members of the EC:
>1)This text is ENTIRELY in harmony/agreement with text on EXACTLY 
>this issue that was contained within the original comments of 802, 
>that were approved at the July Plenary in SFO by 802.18, 802.11, 
>802.15, 802.16, and the EC, and were filed with the FCC. (see
>at 18-20)
>2) There has been no objection from any of the members of 802.18 to 
>the addition of this text (in fact, there has been support expressed 
>by those members of 802.18 who did comment).
>3) The addition of this text would not prejudice the interests of 
>any of the other wireless WGs.
>4) Roger is aware of my intent, and I believe he supports it as an 
>effort to accomodate a concern expressed by one of his members.
>Since the substance of this addition has already been approved and 
>filed with the FCC in our original comments, I consider the addition 
>of this text in an effort to extend the consensus on our reply 
>comments an appropriate editorial modification to the approved 
>Since the filing deadline on this document is midnight, end of Sept. 
>23, EDT, I strongly urge you all to allow this change to go forward. 
>Were it not consistent with our previously filed comments, I would 
>think that the "5 day clock" would need to be reset, but since it IS 
>TOTALLY consistent with what the EC has previously approved, I don't 
>believe that action (which would preclude the filing of the modified 
>document) should be required.
>Respectfully submitted,
>Carl R. Stevenson
>Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group
>610-965-8799 (home office)
>610-712-3217 (fax mailbox)
>610-570-6168 (cellphone)
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