Re: [802SEC] Letter Ballot on new P&P for Coexistence - Reminder
Stuart and SEC,
Here are Roger's comments.
From: Roger B. Marks [mailto:firstname.lastname@example.org]
Sent: Monday, August 16, 2004 2:24 PM
To: Shellhammer, Stephen J
Cc: email@example.com; firstname.lastname@example.org
Subject: Re: [802SEC] Letter Ballot on new P&P for Coexistence -
I vote Disapprove. I believe that, because this proposal remains
ambiguous, it's very hard to see what we may be doing here. We could
end up with some very unhappy consequences. This is reminding me of
what some governments do with telecom regulation: write some mandates
using general language and leave it to some agency or the courts to
figure out what they meant. The result is a bonanza for lawyers and
consultants, but it doesn't do a lot of good for the technologists.
In our case, who is going to be left to figure it all out?
Here are some specific comments. They are not as thorough and refined
as I would like, but time is short. I may edit them, or add to them,
(a) The language does not define coexistence or Coexistence
Assurance. This leaves everyone who needs to make a judgement on this
(including the Working Group and the EC) little guidance in knowing
what is expected. This can be a big problem. I expect that
development of CA document is going to significantly delay new
standards from going to Working Group ballot, while participants look
around to figure out who is going to fund the consultants required to
prepare a CA document. Unless we are clear in what is required, this
barrier could easily turn into a blockade to new standards.
(b) The proposed Procedure talks about "Coexistence with 802 wireless
standards in unlicensed bands." This would, literally, apply only to
approved standards, not to drafts or projects in process, but this
should be made more explicit so no one needs to guess. Also, it's not
clear whether we need to coexist with every device that may be built
to the standard, or to just the devices that already exist. For
example, in some cases, 802 standards would allow devices in many
frequency bands. Is it necessary to show coexistence in bands where
no such devices exist? Are we trying to coexist with the standards or
Also, the limitation to "unlicensed bands" is fuzzy; in general, both
licensed and unlicensed devices may be allowed in a band.
To address these points, it might be better to replace the heading
"Coexistence with 802 wireless standards in unlicensed bands" with
"Coexistence with unlicensed wireless devices based on 802
standards." Also, in the proposed Procedure, "The CA document shall
address coexistence with all relevant 802 wireless standards in the
unlicensed bands" should be replaced with "The CA document shall
address coexistence with unlicensed wireless devices based on 802
(b) Likewise, the meaning of "The working group should include other
users of the target band(s) in their analysis." is not fully clear.
Now are we trying to coexist with "users" instead of either "devices"
(d) The wording "The CA document shall accompany the draft on all
wireless working group letter and sponsor ballots" is ambiguous. Does
"wireless" modify "working group" or "ballots"? Better to just change
"wireless" to "relevant".
(e) The last line ("The working group makes the determination on
whether the coexistence necessary for the standard or amendment has
been met.") is inappropriate unless "working group" is replaced by
(f) Editorially, the references to Procedure 2 and Procedure 11 are
no longer appropriate, given the current P&P format.
>IEEE 802 SEC,
> This is a reminder that the EC letter ballot on new P&P
>for coexistence closes in a little over a week. See attached.
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