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RE: [802SEC] +++Approve Response to FCC FNPRM

Thank you Vic for this consideration of my Members comments. As I said
in my Approve with comments, the dissenters in the WG had the
opportunity to make comments, and indeed had a further opportunity
earlier this week in your positing of the updated letter to the 802.11


- Stuart

Attached is my vCard for Contact Information:

-----Original Message-----
From: Hayes, Vic (Vic) []
Sent: Friday, August 10, 2001 06:38
Cc: 802.0 reflector
Subject: RE: [802SEC] +++Approve Response to FCC FNPRM


I have looked at the comments from your e-mail and have accommodated
what we could without making any technical change.


Vic Hayes
Agere Systems Nederland B.V., formerly Lucent Technologies Zadelstede
1-10 3431 JZ  Nieuwegein, the Netherlands
Phone: +31 30 609 7528 (Time Zone UTC + 2)
FAX: +31 30 609 7498

-----Original Message-----
From: Stuart J. Kerry []
Sent: 29 July, 2001 2:09 AM
Subject: RE: [802SEC] +++Approve Response to FCC FNPRM

Mr. Chairman,

After posting to the 802.11 membership the request to review the
aforementioned FCC FNPRM letter as modified, I feel that my abstain vote
at the Closing SEC meeting in Portland should now be overturned to
Approve, for this ballot.

The justification for this judgment is that an overwhelming majority of
the 802.11 membership did not respond to the email reflector pole,
requiring dissenters to voice their views. This maybe shows a lack of
interest, but I feel more importantly, in the satisfaction of the

Those 3 members that did comment, I judge could have their wishes
fulfilled by Vic accommodating their observations into the final version
of this letter. This being over and above Vic's goal to make the Radio
Regulatory group charter, and formation of said group quickly. Which I
whole heartedly support and encourage it be done with hast.

I would also point out to the membership that there are further chances
in the FNPRM process that could accommodate other improvements. It is
imperative now that IEEE 802 shows the ever increasing strength of the
membership and the successful adoption of these standards and
technologies in the marketplace.

Finally, in approving it, I would like to see the final version with
those 3 members wishes included before it is sent. I look forward to
Vic's final edits.

- Stuart J. Kerry
Chair, IEEE 802.11 Wireless Local Area Networks Working Group

Received Comments:

1)   Victoria Poncini:

The only portion of this letter I oppose is section 2.2.1 the last
sentence in paragraph 4 of this section. IEEE doc: 01/391-r7 fails to
provide data value needed for the limitation we are suggesting. The
recommendation to limit the spectral power density for digital systems
is not defined.  There appears to be a place holder of "dBm/MHz" with no
recommended limitation to make the power density equivalent to that of
other 2.4 GHz devices.  I'm assuming that testing was done, or
calculations were made and there is a numeric value "the committees"
would recommend for use by the newer digital systems.  Am I way off on
this? Have I missed something in the document? I think we (the IEEE
committees) should provide the FCC with a recommended value and the
rationale (with data) to back it up.

2)   Sean Coffey:

In response to your request for 802.11 feedback on the letter to be sent
to the FCC, I feel I still have not been given enough information to
make an informed decision, as indicated below. I am unsure about what
the letter to be sent is.  However, I'm very sure that the process is
extremely unsatisfactory.

I am still unclear as to exactly what changes have been made, and are to
be made.  I basically agree with the document 391r7 as circulated.  In
particular, it contains entries on both (I) the need for peak power
limitations, and (II) a request for a waiver for the new frequency
hopping rules.  I feel that both of these are extremely important and I
am FOR such a letter. However, is this really what we are voting on?  At
the Portland meeting there was a last minute change, by 802.15, to the
then-current draft, 391r6, involving deleting one section.  It was not
clear to the membership what we were voting on, and the matter was ruled
out of order.  I was told by Vic Hayes during this discussion that the
deleted section was 2.2.1, i.e., the section dealing with peak power
limitations.  If this is the change, then I am AGAINST the letter.

However, 391r7 appears to indicate that it is section 2.2.2 that has
been dropped, which would be fine.  Which is it? More generally, I would
like to go on record as saying that the process by which we put together
letters to the FCC  is extremely unsatisfactory, and has come to the
stage where formal protests need to be considered.  I do not think that
it is acceptable that major changes can be made to important documents
minutes before they are voted on; I do not think it is acceptable that
the very text of the document to be voted on is unclear to members who
have followed the process with due diligence; I do not think it is
acceptable that the procedure allows, in effect, some groups within 802
to make last-minute changes that are then presented as a fait accompli
to 802.11.

This is not the first time issues related to the RR group have appeared.
In the Monterey meeting, a document was issued from the group that
contained a highly prejudicial and tendentious assertion that affected
the work then going on in Task Group g; no notice of this comment was
given before 802.11 was asked to vote on the document, and no notice was
given to TGg.  The final version of the document containing the
assertion was not available in advance.

Concerns were raised by many people during the Portland meeting about
the need for the output of the RR group to be debated adequately in
802.11, and for the process to be reformed. Unfortunately the chair of
the RR group does not appear to have taken these concerns seriously, at
least up to this point. Again, I find this unsatisfactory.

3)   David Hytha: (Opposed)

The letter needs one simple but important item to be acceptable: We have
to define what should be the interference framework which governs
adaptive hopping.  Description: The FCC is moving away from detailed
standards specific rules but some definition of interference conditions
may be necessary to referee the multiple users in the band.  A framework
that does this IS EXPECTED of the IEEE as the widest represented group.

Vic Hayes's Retort to David Hytha:

I am sorry to hear your comments at this late stage of the game. We can
only make minor changes to the document. I have sent several e-mails to
the regulations, dot 11, dot 15 and dot 16 reflectors requesting input
as well I made an announcement at the May meeting. If you have
contributions to make, please provide them in time in future. We can use
your talent very well.

What we now have is the best we could get.

David Hytha's Retort to Vic Hayes:

These comments were all made in Portland by several people including
myself but were not included.  My concern is that the FCC looks to the
IEEE to come up with a solution that will serve the broadest possible
number of standards.  Our response has not addressed the key issue of
how do you measure or adapt to interference without standards specific
responses. The question is left unanswered.

Further Retort by Vic Hayes to David Hytha:

Sorry David, you are still not specific in what you wanted to add. I do
not recollect a submission from you. Nor do I recollect any oral input
during the 2 meetings of the regulatory group you attended (Tuesday
10:30 AM and Tuesday 3:30 PM). Peter and Denis, you were secretary and
were there all the time, do you recollect any input from David that we
missed? However, as said before, there is no way we can add anything
other than editorial in the material.

-----Original Message-----
X-Sybari-Space: 00000000 00000000 00000000 00000000
From:     Jim Carlo []
Sent:     Sunday, July 15, 2001 19:11
To:  IEEE802
Subject:  [802SEC] +++Approve Response to FCC FNPRM

Issue date: 15Jul2001Closing Date: 28Jul2001
Moved By: Roger Marks
Second By: Vic Hayes
Move: to submit document RR-01-012 as Comments to FNPRM 99-231. Objects
between square brackets are subject to change to reflect the reality.
Document RR-01-012 r0 contains the items between square brackets, worked
out according to the actions taken in the WGs and the SEC. It also has
taken the effect of the dot15 amendment into consideration. Revision
marks can be made visible. This is the version that will be submitted by
Vic Hayes and I (note both Vic and I will send the document together - I
will add my coordinates). The attached zip file contains document
11-01-391 r7. This is the version according to the motion to amend made
in dot 15 Wireless working group Chairs are expected to poll their
groups on these comments within 10 days.


Vic Hayes
Agere Systems Nederland B.V., formerly Lucent Technologies Zadelstede
1-10 3431 JZ  Nieuwegein, the Netherlands
Phone: +31 30 609 7528 (Time Zone UTC + 2)
FAX: +31 30 609 7498

Attached is my vCard for Contact Information:

Stuart J. Kerry.vcf