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In one sense it does not matter what we believe because it seems that the IEEE BoD GPCC has already determined that IEEE 802 public policy statements do need to be reviewed by GPCC.
However, it is worthwhile understanding if GPCC have the authority to make that determination under the current rules.
You are suggesting they do not because IEEE 802 is not an organizational unit. As I understand it, you are basing this assertion on I-107 Part 6 of the IEEE By-Laws. I would note that poor drafting of this clause makes it somewhat ambiguous. Your interpretation seems to be that only Major Boards listed in I-103 are organizational units. I read it differently. My interpretation of this part is that it is just saying that the Board of any of the Major Boards listed in I-103 is a Committee of IEEE under NY law, and it does not define an organizational unit
There is evidence for my understanding of the definition of organizational unit elsewhere in the By-Laws. For example:
I-107 Part 1) Definition. An IEEE organizational unit is a subset of the entire IEEE membership that has been formed to carry out particular educational, geographic, professional, technical, or other appropriate activities of interest and service to those who are members of that organizational unit as permitted by law
I-107 Part 5) Structure. An organizational unit may contain other organizational units.
I-100 Part 4) … or an IEEE organizational unit (such as a Chapter, Section, or Society).
I-303 Part 2) … Major Boards and their organizational units may …
… <and many more>
The bottom line is that IEEE 802 is almost certainly an organizational unit, and that the NOI response to the FCC is almost certainly a Public Policy Position Statement (given it is going to a government entity). Therefore GPCC probably do have the authority to review the NOI response. That said, I believe we should ask them to give IEEE 802 authority to issue a Public Policy Position Statement without GPCC review
Resend in HTML format in the hope that numbering and formatting won’t be deleted ...
I don’t believe that IEEE 802 is an ‘IEEE Organizational Unit’. Relevant text from the IEEE Constitution and Bylaws <https://www.ieee.org/documents/ieee_constitution_and_bylaws.pdf> below.
I-107. Organizational Units Defined; Hierarchy, Structure and Membership Types
6. Boards. The board of any organizational unit, referred to as Major Boards listed in IEEE Bylaw I-303, shall be deemed to be a Committee of IEEE within the meaning of the New York Not-for-Profit Corporation Law."
I-303. Major Boards
2. Major Boards. The IEEE Board of Directors establishes the following Major Boards:
IEEE Educational Activities Board (EAB)
IEEE Member and Geographic Activities Board (MGAB)
IEEE Publication Services and Products Board (PSPB)
IEEE Standards Association (IEEE-SA)
IEEE Technical Activities Board (TAB)
IEEE United States of America (IEEE-USA)
These organizational units shall implement programs intended to serve and benefit IEEE members, the engineering and scientific community, and the general public. Programs of Major Boards that have a close relationship to the missions of other Major Boards shall be coordinated with those organizational units. The Board of Directors shall approve the charters, objectives, and mission statements of each such Major Board.
From: Andrew Myles (amyles) [mailto:firstname.lastname@example.org]
Sent: 21 September 2017 06:04
Subject: RE: Sponsors public statements
Let me start by noting that I believe it is generally inappropriate and impractical for IEEE-SA or IEEE to review positions of IEEE 802 on topics clearly within the scope of IEEE 802.
That said, it appears the IEEE BoD GPCC believe they need to be involved in some sort of review process for IEEE 802 external positions on public policy matters. The clear evidence of this position is the direction to Paul that the NOI be sent to IEEE BoD GPCC for review and approval.
I suspect this belief is probably justified by Section 15.4 B) of the IEEE Policies related to IEEE Organizational Unit Public Policy Position Statements.
A Public Policy Position Statement is defined below. I suspect a liaison on regulatory matters to a government organisation is reasonably regarded as a public policy matter. In this case an NOI to the FCC is almost certainly a Public Policy Position Statement. As an aside, I suspect a liaison to a standards development organisation is probably not a Public Policy Position Statement in most circumstances.
1. DEFINED: An IEEE Organizational Unit Public Policy Position Statement is a statement of the position of an IEEE Organizational Unit on a matter of public policy that falls within its recognized geographic, technical or business scope
A key definition is IEEE Organizational Unit. This is defined in Section 15.4 B) as a formally constituted body within IEEE that has an approved Charter and/or scope and has a formal place within the hierarchical structure of IEEE. It seems likely that IEEE 802 is an IEEE Organizational Unit.
The Section 15.4 B then defines an approval process that effectively requires approval by IEEE BoD GPCC. This is consistent with what is happening in this case.
3. Prior to being issued, all Organizational Unit Public Policy Position Statements shall be reviewed by the IEEE Global Public Policy Committee using criteria outlined in Section 15.6 of IEEE Policies, and any issues arising from that review must be resolved.
While these appear to be the rules, I disagree with them and suggest that IEEE 802 ask IEEE-SA to ask the IEEE BoD to change them urgently!
One of the key positive attributes of standards development in IEEE-SA is that we let a thousand flowers bloom. Sometimes those flowers are red, sometimes white and sometimes they are weeds, but that is OK because we let the others decide what is best. Other in this context is usually the market , but it can also be governments.
Although it would not be ideal of two or more IEEE OUs to submit contradictory inputs into a public policy process, the fact that it is possible is what makes IEEE great. The key to making this work is to ensure that it is made very clear that the inputs only represent the views of the particular IEEE OU.
On a more practical note, the review criteria in Section 15.6 just seems to add unnecessary delay rather than any significant value in most cases, particularly in the context of IEEE 802 which has a long record of responsible action. If it is deemed to be really important for IEEE BoD GPCC to undertake this review on every Public Policy Position Statement, maybe IEEE 802 could be given a license for the review to occur post submission?
From: ***** IEEE 802 Executive Committee List ***** [mailto:STDS-802-SEC@ieee.org] On Behalf Of Law, David
Sent: Thursday, 21 September 2017 2:25 AM
Subject: [802SEC] Sponsors public statements
Dear EC members,
Since there has been some discussion of public statements from Sponsors I'd like to share my thoughts.
Subclause 5.1.3 'Statements to external bodies' of the IEEE-SA Standards Board Operations manual <http://standards.ieee.org/develop/policies/opman/sect5.html#5.1.3> states that a '... Sponsor shall have policies and procedures in place concerning the creation and handling of public statements ...'. I believe we do in subclause 8.3.1 'Sponsor public statements' of the IEEE 802 LAN/MAN Standards Committee (LMSC) Policies and Procedures.
It states that 'Each statement shall clearly identify the group creating this statement in its opening paragraph, and shall include in that paragraph, or a footnote thereto, the exact sentence that "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."'. We need to make sure we do this.
It states 'Upon issuance of all such public statements, electronic copies shall be sent to the Secretary of the IEEE-SA Standards Board and to the Secretary of the IEEE-SA BOG.'. Both of these positions are held by Konstantinos Karachalios, so by CCing him I believe that requirement can be met.
It also states 'These procedures shall also conform both to the IEEE-SA procedures as administered by the IEEE-SA Board of Governors (BOG) and set forth in subclause 6.5 of the IEEE Standards Association Operations Manual and to the rules in Section 15 of the IEEE Policies.
On review of subclause 6.5 'Position statements' <http://standards.ieee.org/develop/policies/sa_opman/sect6.html#6.5> of the IEEE-SA Operations Manual, it seems to relate to position statements representing the IEEE Standards Association which I don't believe we are doing here.
On review of section 15 of the IEEE Policies <https://www.ieee.org/documents/ieee_policies.pdf>, it seems to relate to position statements representing the IEEE which I don't believe we are doing here.
I do note subsection 15.11 'OU Public Policy Processes and Operations' which states 'Consistent with applicable IEEE Bylaws and Policies, IEEE Organizational Units may establish internal requirements and processes regulating their public policy communications and the related activities of their subordinate Organizational Units.'. This seems to be what subclause 6.5 'Position statements' of the IEEE-SA Operations Manual and subclause 5.1.3 'Statements to external bodies' of the IEEE-SA Standards Board Operations manual do.
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