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[802SEC] Request for 7-day review of IEEE 802.11 WG Communication to FCC - Doc: 11-15/0683r5

Dear EC members,


I am responding as described in this email  to the failure of the EC motion on the question, “Move that EC approves transmission of document 11-15/683r2 ( to the FCC as a letter in response to FCC docket 15-47, granting the LMSC Chair editorial license.


I hereby request a “Sponsor member” review of document

as an IEEE 802.11 WG communication to the FCC under the procedure in 8.2.2 the IEEE LMSC OM:


8.2.2 Sponsor subgroup communications with government bodies


a) Sponsor subgroup communications with government bodies shall not be released without prior approval by 75% of the Sponsor subgroup. Such communications may proceed unless blocked by a Sponsor vote. For statements not presented for review in a sponsor meeting, Sponsor members shall have a review period of at least five days; if, during that time, a motion to block it is made, release of the statement will be withheld until a letter ballot of the Sponsor is held to determine if it is approved.


b) Sponsor subgroup communications shall be identified in the first paragraph as the view of only the Sponsor subgroup and shall be issued by the Sponsor subgroup(s) Chair(s) and

shall include the Sponsor Chair in the distribution. Such statements shall not bear the IEEE, the IEEE-SA, or IEEE 802 LMSC logos.”


The cited procedure states that the review period should be at least 5 days.   As there is a long weekend coming up for many,  I am indicating a review period of 7 days, ending midnight UTC-12 on 2015-07-08.


The submission deadline to the FCC is Wednesday July 15th,  so any EC actions related to this need to take place during the Monday EC plenary (July 13th) (I have requested an agenda slot as a contingency).   No action of the EC will be necessary if no motion to block is made.


This modified communication has not yet been approved by 802.11.   I am anticipating a motion to approve the document as reviewed by the EC at the 802.11 WG Monday plenary.

The 802.11 WG motion will be essentially identical to: “Approve transmission of document 11-15/683r5 to the FCC as a letter in response to FCC docket 15-47, granting the 802.11 WG chair editorial license”.


I would be astonished if such a motion was not approved in the WG, hence my presumption in asking for the EC to review this updated document now.


Compared to the document that has already been reviewed,  the following changes have been made:

1.       The initial paragraph makes it clear this is a communication from the 802.11 Working Group

2.       A new final sentence has been added: “IEEE 802.11 will continue to monitor progress towards resolving the exclusion zone and FSS protection limitations, and will re-evaluate our position as conditions dictate.”


A redline is attached for your convenience.  This shows as tracked changes the changes between R2 (approved by the WG and motioned originally in the WG) and R5,  which is the subject of the current review.


The submission responds to comments received during the EC ballot as follows:


Apurva wrote:  “I feel that this Document should be the position of the 802.11 / 802.15 Working Groups. So I am okay if this is sent out as a Liaison from IEEE 802.11 / 802.15 Regulatory Standing Committee or the Working Groups but not as an IEEE 802 LMSC Position.” (excerpt)

The updated document represents only an 802.11 WG position.

(I should add that Apurva also had disagreements with technical content.  You can see his full argument here:


Subir wrote: “Subir: "Towards that I liked Rich’s suggestion on adding

“IEEE 802 will continue to monitor progress towards resolving the exclusion zone and FSS protection limitations, and will re-evaluate our position as conditions dictate”.

It would be good if we return this to  802.11/15 REG group and allow them for another round of discussions.  OTH, if it delays a timely response, WG  can communicate to FCC

directly since  it does not require an EC approval motion as pointed out by Roger."”

1)      The text cited above has been added to the updated document

2)      The updated document represents only an 802.11 WG position


Pat wrote: “Pat: "My  vote is Approve if the “continue to monitor progress” text is added. Disapprove otherwise"”

That text has been added.


Roger wrote: “Roger: "The statement under discussion is very narrowly drawn toward an 802.11 position. If it were reformatted as an 802.11 communication in accordance with 8.2.2 and presented for five-day review, I would not move to block it."” (excerpt)

(The rest of his response is here:

We are presenting this as an 802.11 position for 5-day review.


I believe these comments have been addressed in the draft sent to review in a manner that is consistent with at least one of the alternatives (where present) requested in the comment.



Best Regards,




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