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[Fwd: [802SEC] IEEE-USA/CCIP statement on "Accelerating Advanced Broadband Deployment in the US"]

Dear All,

I have attached a draft position statement from the IEEE-USA regarding
"Accelerating Broadband Deployment".  I have several serious concerns
about this position statement that I wish to bring to your attention.

1) I am very concerned about the process that was apparently used to
develop this statement.  I am not familiar with the workings of the 
but it appears that they do not subscribe to the policy of "openness" that
is inherent in the procedures of the IEEE-SA. In particular, I believe that
this positition statement was drafted without any input or advice from the
IEEE-SA, the IEEE 802 LMSC, or the IEEE 802.3 Working Group, yet
the subject matter of the statement is of significant concern to all of 

2) The statement places a heavy emphasis on the application of standards
developed in the IEEE 802.3 Working Group, specifically the Gigabit
Ethernet standard, IEEE Std 802.3z-1998.  As the chairman of the body
that developed this standard, as one of the authors of the standard, as
one of the inventors of the technology, and one of the leading experts in
the field, I find it unfathomable that I was neither consulted on the 
nor made aware of its development, nor given a chance to review it. This is
not a case of a wounded ego, as I believe that none (or at best a very 
selection) of the other experts who participated in the development of
IEEE Std 802.3z-1998 were consulted either.  This should give everyone
serious doubts as to the credibility of the analysis behind this statement.

3) As further evidence of the lack of coordination and communication with
the relevant experts, the statement completely ignores the current projects
in the IEEE 802.3 Working Group related to the subject.  In particular,
the statement makes no mention of the IEEE P802.3ah project, which
concerns Ethernet in the First Mile, the application of Ethernet technology
to subscriber access networks, specifically for the purpose of accelerating
the deployment of advanced broadband services. This project is hardly
a secret, and has been in development for over two years.  By completely
neglecting this work, the position statement omits key findings of the 
and presents obsolete information.

4) Interestingly enough, the statement acknowledges the expertise of the
IEEE 802.3 Working Group and the IEEE 802 LMSC. How the group
that drafted this statement can simultaneously acknowledge and ignore
these bodies of experts is beyond me. I am very concerned that the statement
will be interpretted as representing the position of these bodies. This
must not be allowed to occur without their advice and informed consent.

I believe that the IEEE-SA, the IEEE 802 LMSC, and the IEEE 802.3
Working Group should have the opportunity to review and comment on
this statement before it is issued by the IEEE-USA.  It appears that the
audience for the statement is intended to include US Government departments
and agencies such as the FCC, DoJ and FTC, and that the statement attempts
to influence US national policy on the subject.  This is a non-trivial 

As I have no direct contact with the hierarchy of the IEEE-USA, I call upon
the individuals addressed on this email to assist me. I do not know the 
timeframe for release of the statement, nor do I know the current status of
the statement.  Please help me answers these questions, and help me find a
way to ensure that the relevant bodies of experts within the IEEE-SA are

Howard Frazier
Chair, IEEE 802.3z Gigabit Ethernet Task Force (ret)
Chair, IEEE 802.3ah EFM Task Force
Member, IEEE-SA Standards Board

-------- Original Message --------

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) . 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" 
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" 
. Note that most of the 
public information on the topic was generated BEFORE the workshop. 
Afterwards, an IEEE-USA press release 
 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 . 
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 

* 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 

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 . 
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.