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Dear EC Members:
Attached is the final version of the FCC NOI response. It is based on the version “7c”. which includes the changes agreed to by Bob and Roger, and the formatting required for submission. Please review ASAP so that it can be processed by the GPPC prior to uploading via the FCC ECF system on October 2nd. Removal of the document number header is all that is required for submission.
Director, Global Spectrum Strategy
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
I agree with as well. The 802 statement will comply with policy, period. I believe the statement tweaks Roger and Bob agreed to today result in such text.
Since there is a bit of confusion regarding which version is up for approval, I recommend Rich upload the most recent Roger/Bob revision and inform the EC asap.
-------- Original message --------
From: Pat Thaler <000006d722d423ba-dmarc-
Date: 9/20/17 1:33 PM (GMT-05:00)
Subject: Re: [802SEC] +++10 day ECM (early close)+++ FCC NOI Response
I agree as well.
On Wed, Sep 20, 2017 at 10:32 AM, Kennedy, Rich <firstname.lastname@example.org> wrote:
I strongly agree with Adrian on this. We cannot possibly represent every IEEE standard. Just as industries have opposing views on spectrum, the standards that drive their technologies will also. IEEE should be satisfied with the fact that they do drive these industries, allow different opinions under their umbrella, and let the regulators make those decisions.
Director, Global Spectrum Strategy
"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.
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?
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.
At 03:11 PM 9/18/2017 -0700, Pat Thaler wrote:
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 Â 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. "
On Mon, Sep 18, 2017 at 2:37 PM, Roger Marks <email@example.com> wrote:
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.
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 â€œExpanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHzâ€ .
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.Â The deadline for filing is 02 October 2017. Paul has delegated the conduct of the EC electronic ballot to me.
dcn/17/18-17-0114-06-0000-Â as communication to the U.S. Federal Communications Commission, granting the IEEE LMSC chair (or his delegate) editorial license. ieee-802-response-to-fcc-17- 104.docx
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.
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
11 Robert Toner Blvd, Suite 5-301
North Attleboro, MA 02763 USA
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