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[802SEC] IEEE-USA/CCIP statement on "Accelerating Advanced BroadbandDeployment in the US"




Dear SEC:

I'd like to bring to your attention a report that, I understand, is 
under consideration as a possible "entity position statement" of 
IEEE-USA, the U.S. Activities wing of IEEE. The report, on 
"Accelerating Advanced Broadband Deployment in the US," was developed 
by the IEEE-USA's Committee on Communications and Information Policy 
(CCIP) <http://www.ieeeusa.org/committees/CCIP>. I've been looking at 
a version of the report dated 12-31-02. I am not going to forward the 
report to the reflector right now, because CCIP doesn't seem to have 
released it. I do not know know if this is the final CCIP output; if 
not, it is considered quite close to final. In general, I am finding 
it difficult to learn much about the deliberations of CCIP. I am not 
a member. There is, in principle at least, an opportunity to be an 
"Internet Corresponding Member" 
<http://www.ieeeusa.org/committees/CCIP/index.html#participation>, 
but I have not received a response to the application I submitted 
well over a month ago.

This report follows the June 2002 CCIP-sponsored "IEEE-USA Workshop 
on U.S. National Policy for Accelerating Broadband Deployment" 
<http://www.ieeeusa.org/conferences/broadband>. Note that most of the 
public information on the topic was generated BEFORE the workshop. 
Afterwards, an IEEE-USA press release 
<http://www.ieeeusa.org/releases/2002/062402pr.html> said "The 
exchange of ideas created policy issues that IEEE-USA will use to 
establish policies on broadband deployment. A formal position 
statement is expected within the year." See also an _Institute_ 
article <http://www.spectrum.ieee.org/INST/oct02/fbroadband.html>. 
CCIP is scheduled to next meet on Monday 27 Jan.

Without forwarding the report, I'd like to quote from it to give you 
the flavor:

========
*compared to the efforts of several other countries the pace of 
broadband deployment in the US has been painfully slow. Truly 
scalable (gigabit) broadband networks are not being seriously 
considered at policy levels, much less rapidly deployed in the US.

* In response to this situation, the IEEE-USA in June 2002 held a 
Workshop with the objective to: "Explicitly Include Gigabit Ethernet 
over Fiber (GEF) Technologies in the US Policy Debate on Accelerating 
Broadband Deployment."

* This IEEE-USA initiative was motivated also by the fact that its 
sister organization, the IEEE Standards Association (IEEE-SA), is a 
designated national standards body and a world leader in voluntary 
consensus standards making

*the potential exists for accelerating broadband deployment through 
industry-standard gigabit Ethernet networks over fiber optic media 
(IEEE 802.3* Gigabit Ethernet over fiber -- GEF -- networks) 
especially as they are complemented by compatible IEEE 802 wireless 
technologies.

* The infrastructure for a GEF network is built using products from 
multiple manufacturers that are "plug and play" (i.e., interoperable 
and interchangeable) in compliance with IEEE Ethernet standards.  As 
a result, these inputs are highly competitive, surprisingly cost 
effective, and widely available today.

* Recommendation 1
Policymakers must ensure that IEEE 802.3, Gigabit Ethernet over fiber 
(GEF) technologies complemented by IEEE 802 wireless technologies be 
fully considered and fairly evaluated for a prominent role in 
accelerating broadband deployment in the US.

End Notes
* IEEE 802.3, a Working Group of IEEE 802, has worldwide recognition 
as the Ethernet standardization leader.
* The IEEE 802 LAN/MAN Standards Committee encompasses many evolving 
wired and wireless local and metropolitan area network technologies. 
Access standards complementary to IEEE 802.3 are being developed in 
IEEE 802 Working Groups: 802.11, Wireless Local Area Networks 
("Wi-Fi"), 802.16, Broadband Wireless Access (BWA); and 802.17, 
Resilient Packet Ring (RPR);" and 802.20, Mobile Broadband Wireless 
Access (MBWA).
========

Personally, I am concerned with a number of aspects of this report. 
In particular, the strong focus throughout on "Gigabit Ethernet over 
Fiber" seems to me to appeal to a rather narrow constituency rather 
than to a broad consensus. Aside from the narrowness of the 
technology, I think that the insistence on Gbit/s as the right rate 
for broadband access is considerably higher than most people would 
suggest. I also have a number of specific concerns with the text, 
including some very significant recommendations that I have not 
quoted.

I don't see CCIP, or IEEE-USA, soliciting input on this document. I 
don't understand their procedures well enough to know whether they 
plan to solicit comment. However, I think it might be a good idea for 
802 to consider submitting comments anyway. It is my understanding 
that any IEEE-USA position statement would need to follow Section 15 
of the IEEE Policies <http://www.ieee.org/about/whatis/policies>. 
Subclause 15.1 includes this language: "However, recognizing that 
IEEE objectives are best pursued when concerted, consensus positions 
can be articulated, organizational units are encouraged to seek 
common ground for expression of their views by submitting proposed 
organizational unit position statements for approval at the highest 
level within the IEEE appropriate to the issues involved and their 
position within the IEEE." So, perhaps IEEE-USA ought to seek to 
include 802 or IEEE-SA in their deliberations.

I am interested in the views of SEC members. Do you think that 802 
ought to speak up on this issue? Do you think an 802 consensus view 
would differ from those of the draft? Should we ask to review and 
comment on the draft? I don't think I'm alone in my concerns, but I 
wonder if I'm in the majority or minority.

Regards,

Roger