[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