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Re: [802SEC] +++10 day ECM (early close)+++ FCC NOI Response



Roger:

I think the policy is embodied in IEEE-SA procedures.  The -SASB Operations Manual has long included a requirement for a disclaimer philosophically consistent with the IEEE policy you detailed below.  In In SASB Ops Man, 5.1.3, somewhat different text is detailed:

"this document solely represents the views of name of group and does not necessarily represent a position of either the IEEE or the IEEE Standards Association.

Obviously, the required text is not the same, but the disclaimer of clearly stating the statement does not represent the positions of superior organizations is the same.  The biggest gap I see in the SA rule is it doesn’t point out something like the “other Organizational Units” in the disclaimer.  The IEEE language is written for an IEEE Organizational Unit (e.g., inside IEEE, that would mean IEEE-SA, Computer Society, etc.), but the spirit certainly would apply to any recognized group within IEEE.  The IEEE-SA rule extends things down to Sponsors and WGs.  I guess it would be appropriate for ProCom to review the SASB Ops Man text and harmonize current IEEE policy if deemed necessary.  

BTW, I agree with you about the statement of other groups disagreeing not being required by the policy, and would be impractical to verify that there is an opposing position.

—Bob

On Sep 20, 2017, at 8:53 AM, Roger Marks <r.b.marks@ieee.org> wrote:

Paul,

I found what I believe is the documentation you mentioned <https://www.ieee.org/documents/ieee_policies.pdf>.

What's new about that policy that conflicts with our existing procedures? How will policy changes be embodied in IEEE-SA and 802 procedures?

I did see this:

The name of the Organization Unit responsible for the Public Policy Position Statement shall be included in the Statement, along with the date of its approval by the governing body. Each organizational unit position statement shall also contain the following disclaimer at the close of the formal statement and before any background or attached materials: “This statement was developed by the [insert name of IEEE organizational unit] and represents the considered judgment of a group of IEEE members with expertise in the subject field. The positions taken by [insert name of IEEE organizational unit] do not necessarily reflect the views of IEEE or its other Organizational Units.”

I did not see anything about a need to "clearly acknowledge that other technologies have different and conflicting and/or competing interests."

Roger

On September 20, 2017 at 9:37:47 AM, paul.nikolich (paul.nikolich@att.net) wrote:

Roger,

Yes, see IEEE policy, section 15.

Regards,

--Paul

-------- Original message --------
From: Roger Marks <r.b.marks@ieee.org>
Date: 9/20/17 11:01 AM (GMT-05:00)
Subject: Re: [802SEC] +++10 day ECM (early close)+++ FCC NOI Response

Paul,

Bob and I agreed on a revision of section VIII and turned our proposal over to Rich to decide how he wants to proceed. I'm not planning any further editing.

I do, however, question the detailed edit that you are proposing. The LMSC Policies and Procedures ("Accepted by SASB 12 June 2014") says:

Subgroup public statements shall be identified in the first paragraph of the public statement as being specifically the position of the subgroup. These statements shall be issued by the subgroup Chair and shall include the Sponsor Chair in the distribution. Such statements shall not bear the IEEE, the IEEE-SA, or the Sponsor logos.

Is a new IEEE-SA procedure in place?

Roger




On September 20, 2017 at 6:06:57 AM, Paul Nikolich (paul.nikolich@att.net) wrote:

Rich, Bob, Roger and All,

The guidance I received from Gordon Day, the chair of the IEEE Global Public Policy Committee, yesterday is as follows: 
"If 802 or SA is to submit a response to the NOI, I think that, at a minimum, the document must prominently state that it is responding only from the perspective of 802's technical domain (appropriately described) and clearly acknowledge that other technologies have different and conflicting and/or competing interests.  It can't be seen as a position representing all of IEEE."

I consider Gordon's recommendation an editorial change and recommend we include language to that effect in the opening Introduction section.  Bob and Roger, since you'll be working on wording tweaks today, please add the language.  Also, add a signature from me as the 802 LMSC Chairman.  Thank you.

Regards,

--Paul

------ Original Message ------
From: "Richard Kennedy" <rkennedy1000@gmail.com>
Cc:
Sent: 9/19/2017 12:47:59 AM
Subject: Re: [802SEC] +++10 day ECM (early close)+++ FCC NOI Response

I would appreciate it. Paul wants unanimity.

On Sep 18, 2017 6:41 PM, "Roger Marks" <r.b.marks@ieee.org> wrote:
Bob,

I had no intention to weaken any coexistence statement and would prefer that you be happy with the result. Is the issue in VIII? I moved words around because I couldn't understand the text. Want to work offline to find better wording?

Thanks,

Roger

On Sep 18, 2017, 8:06 PM -0600, Bob Heile <bheile@ieee.org>, wrote:
Hi Rich

I  must vote no with the changes proposed by Roger and Pat. What both propose substantially waters down the real potential to achieve meaningful coexistence and the statement that coexistence may be a real problem. I much prefer the language be left as it was in which case I would vote approve.

Regards

Bob


At 03:11 PM 9/18/2017 -0700, Pat Thaler wrote:
Rich,

Overall, the text looks good. However, I've consulted with some of my wireless colleagues and we have concerns that some of the content is premature.

Specifically, in III, it is too early to take higher power levels completely off the table with "limits  equal to the U-NII-1 band". Therefore, we would prefer "with limits equal to the current 5 GHz U-NII rules as appropriate." That leaves open the potential for 4 W EIRP in circumstances where it technically justifiable.Â

Also, while the challenges of protecting incumbents are different in the different bands, we think the bands should be addressed as they are able. Lower power and/or indoor only use may mitigate the concerns in U-NII-6 and UNII-8 bands so we aren't comfortable with the suggestion to addess U-NII-5 and U-NII-7 first. We suggest this replacement for the last sentence in III: "Therefore the bands should be released as soon as possible for each band. "

Regards,
Pat

On Mon, Sep 18, 2017 at 2:37 PM, Roger Marks <r.b.marks@ieee.org> wrote:
Rich,

I vote Approve, but please consider my attached suggestions for improvement. Most are strictly editorial, but some are more substantive; for example, I believe that Footnote 2 contains an erroneous reference.

Regards,

Roger


On September 15, 2017 at 4:53:03 PM, Kennedy, Rich (rich.kennedy@hpe.com) wrote:

Dear EC members,

Â

On Thursday, the 14th of September the IEEE 802.18 Radio Regulatory Technical Advisory Group approved an input document to the FCC Notice of Inquiry entitled “Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz†.

Â

The vote in the TAG was 15/0/0.

Â

I would now like to proceed to the motion in respect to this submission I am seeking an early close (see below), as this is a somewhat urgent matter, as Paul has been instructed to run this response through the IEEE BoD Global Public Policy Committee process, which will take some time.  The deadline for filing is 02 October 2017. Paul has delegated the conduct of the EC electronic ballot to me.

Â

Motion

======

Â

Approve https://mentorieee.org/802.18/dcn/17/18-17-0114-06-0000-ieee-802-response-to-fcc-17-104.docx as communication to the U.S. Federal Communications Commission, granting the IEEE LMSC chair (or his delegate) editorial license.

Â

Moved by: Rich Kennedy, on behalf of the TAG

Seconded by: Adrian Stephens

Â

Start of ballot: Friday 15 September 2017

End of ballot: Monday 24 September 2017 AOE

Â

Early close: As required in subclause 4.1.2 'Voting rules' of the IEEE 802 LAN/MAN Standards Committee (LMSC) Operations Manual, this is notice that, to ensure the release is provided in a timely manner, this ballot may close early once sufficient responses are received to clearly decide a matter. Sufficient responses to clearly decide this matter will be based on the required majority for a motion under subclause 7.1.1 'Actions requiring approval by a majority vote' item (h), 'Other motions brought to the floor by members (when deemed in order by the Sponsor Chair)' of the IEEE 802 LAN/MAN Standards Committee (LMSC) Policies and Procedures.

Â

Thank you.

Â

Rich Kennedy

Â

Director, Global Spectrum Strategy

Â

Board Director, Dynamic Spectrum Alliance

Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group

Chair Emeritus, IEEE 802.11af WLAN in TVWS

Chair, Wi-Fi Alliance Spectrum & Regulatory Task Group

Â

rich.kennedy@hpe.com

(737) 202-7014

Â
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Bob Heile, Ph.D

Director of Standards, Wi-SUN Alliance
Chair, IEEE 802.15 Working Group on Wireless Specialty Networks
Chair IEEE 2030.5 Working Group for Smart Energy Profile 2
Co-Chair IEEE P2030 Task Force 3 on Smartgrid Communications

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