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Re: [802SEC] +++ 10-day ECM – Early Close +++ Approval of comments on FCC NPRM for Section 7, Expediting of rules for new technologies due by 21 May 2018

Hi Roger,

Thanks for the inputs and understand your concerns.  The point in the comments made about the end rules still need to have the integrity (and proper due diligence) all are use too, may touch a little bit of what you bring up.


You caught us on the KDB needs expanded out and will do some editorial on expanding the further definition of new is needed in the rule, which is exactly why it was mentioned.  As seen with many KDBs, they are to go beyond, add to, FCC interpretation and further detail on a subject, not to replace the rule, why the KDB was mentioned, to add to. 





From: Roger Marks <>
Sent: Tuesday, 15 May, 2018 09:56
To: Holcomb, Jay <>;
Subject: Re: [802SEC] +++ 10-day ECM – Early Close +++ Approval of comments on FCC NPRM for Section 7, Expediting of rules for new technologies due by 21 May 2018




I vote Disapprove.


Here are some concerns:


(1) I cannot understand much of the proposed text. For example, I have trouble parsing: 'However, what if there are additional circumstances, for example, would shifting an existing technology to a new area of spectrum that is unique or significant be considered "New” technology?'

(2) The acronym "KDB" should be expanded but, in any case, I don't believe that providing examples of what is "new" would replace the need to define it.

(3) Having reviewed the FCC NPRM, I am troubled by some of the dissenting Commissioner's concerns. Some of these are addressed in the draft, but I worry about "Incumbents today are vulnerable to upstarts tomorrow.  The rules proposed here—under the guise of spurring innovation—will give anyone threatened by change the ability to oppose what is novel and the right to stonewall progress." It seems that the proposed rules place requirements on the "new" petitioner but none on those opposing.

(4) The only real implication on the FCC that I can see in the proposed rules is that it would be "obligated to take some concrete action within one year that advances the development and use" once newness is ascertained. To me, it doesn't seem very effective to set up a deadline to do something without any clarity about what it is.


I don't plan to change my vote, but I do suggest you consider an editorial review.







On May 11, 2018 at 1:25:49 PM, Holcomb, Jay ( wrote:

Dear EC Members,


I would like to announce the start of an EC motion on comments to the FCC NPRM on Section 7 (GN 18-22, FCC 18-18).  The FCC filing deadline is 21 May 2018 so there is only 8 days to finish the ballot to meet this.


All, please respond before 19 May if possible, so we can meet the FCC deadline. 


More on what the NPRM is about:

In this Notice of Proposed Rulemaking (NPRM), the Commission proposes guidelines and procedures to implement section 7 of the Communications Act of 1934, as amended. 47 U.S.C. § 157 (Communications Act § 7).  By this action, the Commission aims to ensure that new technologies and services that serve the public interest can develop and be made available to the public on a timely basis


Paul has delegated the conduct of the EC electronic ballot on the following motion to me and approved the corresponding early close.


This EC motion is per 802 OM 7.2 Procedure for communication with government bodies.


Motion: Move to approve the comments in; to FCC’s NPRM on Section 7 (FCC GN Docket No. 18-22). With the chair of 802.18 to have editorial privileges and for submission to the FCC by 21 May 2018.


Approved in the RR-TAG: 13/0/0


Mover:    Jay Holcomb

Seconder: Bob Heile


Start of ballot: 11 May 2018

Close of ballot: 21 May 2018 (though need by 19 May to meet FCC deadline)


Paul Nikolich has agreed to an early close.  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.



Jay Holcomb

Itron, Inc.

IEEE 802.18 Chair



for reference, the FCC NPRM:

Some comments filed already



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