RE: WLAN/ Submissions to FCC
Jim, Thanks for your presentation of unclear parts of the filing.
I have responded in context below.
Chair, IEEE P802.11, Standards WG for Wireless Local Area Networks
Lucent Technologies Nederland B.V.
3431 JZ Nieuwegein
voice phone number: +31 30 6097528 (Time Zone UTC+2)
fax phone number: +31 30 609 7556
> 1) The question has been raised on who IEEE 802 speaks for? In the letter
> submitted to the FCC, it is implied that this is a position of the IEEE
> Computer Society (the letter is submitted on Computer Society letterhead).
> believe the letter to the FCC over-represents the position in the
> Both Judy Gorman and Dick Hollerman have asked this question.
VH--> The letter head's top clearly states the owner of the letterhead: the
The logo of the Computer Society and the IEEE are placed in our letterhead
because we are sponsored by them.
Also, the opening sentence clearly defines the sender:
"IEEE 802, the LAN/MAN Standards Committee ("the Committee") is writing in
regard to ..........)
Further down the letter we consistently use "Committee" to refer to the
> 2) Who can vote on this letter?
VH--> the voting rights of 802.11 and 802 are clearly defined by the rules
> What about minority positions?
VH-->Minorities have the full possibilities to file their own position at
> What voting
> guidelines do we use for these submissions?
VH--> We use the normal majority rule for procedural matters (50 %) However,
at the 802.11 meeting the vote was unanimous, I will publish the result
after closure as it usual parliamentary procedure.
> Since there is not really a
> project within 802 to produce this letter (we do have projects to develop
> standards, but not to develop positions), some people have complained that
> they were not allowed to participate in the voting on this letter. The
> question is have we enlarged the charter of 802 without providing due
> and representation?
VH-->Based on the following quote from the LMSC Operating rules, I believe
we have NOT enlarged the charter:
220.127.116.11 Working Group Chair's Responsibilities
The main responsibility of the Working Group Chair is to produce a draft
standard, recommended practice, or guideline, or to revise an existing
document. The responsibilities include:
c) Maintain liaison with other organizations at the direction of the
Executive Committee or at the discretion of the Working Group Chair with the
approval of the Executive Committee.
> 3) IEEE 802 must be able to defend its standards from rules changes that
> negatively impact 802 standards.
> 4) The IEEE has an EMC Society (chair-Don Heirman) and an IEEE EMCS
> Development Committee (SDCOM-chair Stephen Berger) which has objected to
> being allowed to participate in the development of the 802 position.
VH--> Just to make the sentence unambiguous: Don Heirman agrees with 802.11
filing the current letter and has asked to organise for future liaison.
Stuart Kerry and myself have talked to Steve Berger and have asked him to
come with a proposal.
> point made is whether developing such a position is clearly specified in
> PAR for the project.
VH--> We did specify in the 802.11 PAR that we would be allowed to write to
regulatory agencies. I was convinced that the rules (see above) would
provide me sufficient freedom to do so without having an explicit line on
The PAR requirement would be useless anyway, because a PAR expires as soon
as the SB has approved a standard. The regulatory control is required during
the whole lifetime of the Standard.
> What I would like to do going forward:
> 1) Clearly establish 802 as having the authority to develop industry
> positions on the 2.4GHz band through the development of a project on
> spectral interoperability. We have a study group to do this already in
> 802.15, and I believe we should drive this to develop a "Guide".
VH--> It is a good idea to review the rules and make sure we can continue to
respond to comments requested by regulatory bodies and to submit requests to
provide further expansion of the spectrum for the application of our
devices. The charter should NOT be limited to the 2.45 GHz band.
In view of the availability of 3 working groups needing to work with
spectrum, we need to set-up a specialists group for this type of activity:
e.g. a Tag (thanks for the idea, Ian).
> 2) Review carefully the current two letters currently in ballot in 802.11
> for further submission to the FCC. Unfortunately, time pressure requires
> that inputs be made prior to 4Oct and further comments a month later,
> we will have time to meet again. I am not sure having another "position"
> letter is the best thing to do.
VH-->I will make a further draft of the letters as they would be submitted
(including letterhead showing only one logo: the IEEE 802 logo) and the
formatting usually preferred by the FCC tomorrow.
> Jim Carlo(firstname.lastname@example.org) Cellular:1-214-693-1776 Voice&Fax:1-214-853-5274
> TI Fellow, Networking Standards at Texas Instruments
> Chair, ISO/IEC JTC1/SC6 Telecom and Info Exchange Between Systems
> Chair, IEEE802 LAN/MAN Standards Committee