Re: [802SEC] Fwd: P802.16g Disapproval Notification
I think there could be some grounds for saying that the comments
supporting a negative ballot must be entered through MyBallot. The SB OM
says of Do Not Approve votes (188.8.131.52): "This vote must be accompanied
by one or more specific objections with proposed resolution in
sufficient detail in legible form...." One could argue that to
"accompany" a negative ballot, the comment needs to be entered in
MyBallot. There is text later that implies that the sponsor is obligated
to consider all comments received by the close of ballot: (184.108.40.206) "The
Sponsor is only obligated to consider comments that are received with
ballots and other comments that are received by the close of ballot."
and (220.127.116.11) "The Sponsor shall make a reasonable attempt to resolve
all comments, objections, and negative votes that are accompanied by
comments." and "Comments received before the close of ballot from
persons who are not in the balloting group, including from the mandatory
coordination entities, require acknowledgement sent to the commenter and
shall be presented to the comment resolution group for consideration." I
guess one could take the position that a comment is only "received" when
it arrives in MyBallot but that is a bit more of a stretch.
So I understand your position that you were required to consider all
comments and couldn't prohibit people from sending them in outside
MyBallot, it seems like for future ballots you could at least require
that all disapprove with comment comments be entered through MyBallot.
From: ***** IEEE 802 Executive Committee List *****
[mailto:STDS-802-SEC@ieee.org] On Behalf Of Roger B. Marks
Sent: Saturday, June 09, 2007 12:43 AM
Subject: Re: [802SEC] Fwd: P802.16g Disapproval Notification
Thanks for taking a look at the details. I appreciate another
I don't agree that failure to discourage amounts to encouraging. I don't
control the voters. Obviously, I'll make a stronger effort in the future
to encourage people to use myBallot. But the only way I can see to
definitively make that work is to simply say that I'll refuse to accept
comments otherwise. I have been always been under the impression (based
on my reading of the IEEE-SA rules, and on what I have learned from
experienced people over the years) that I don't have the right to do
that. Am I wrong?
I could say the following: "You are strongly encouraged to submit
through myBallot; otherwise, we will still accept your comments, but
approval of the resulting ballot may be jeopardized." This may motivate
some people. Others may ignore the advice simply because they are
accustomed to comment tools that are much more effective and convenient
than myBallot. But the major problem is with Disapprove voters. If they
are really opposed to progression of the draft, then this position
provides them an incentive to bypass myBallot and thereby block progress
at RevCom. In other words, I can't count on Disapprove voters to follow
my words of encouragement.
I've used the myBallot process only a few times, far fewer than you
have. I believe that the method by which I addressed the back-door
comments was basically equivalent to what we did in the pre-myBallot
days. I think that was a transparent process. But I recognize now that
RevCom has gotten used to the myBallot way of doing things and now has
adjusted to a different view.
We'll adjust too. But I still feel caught in procedural ambiguity. I
understand that the Operations Manual says "the Sponsor shall make a
reasonable attempt to resolve all comments." To my knowledge, it doesn't
say anything about dismissing non-myBallot comments. But I think that
perhaps this is what RevCom is telling me I have to do.
This is why I say that I feel either direction is risky.
On Jun 9, 2007, at 12:53 AM, Tony Jeffree wrote:
> Roger -
> What I find somewhat mystifying is why you chose to allow these voters
> to submit comments directly rather than via MyBallot. I hear your
> words about not having encouraged the practice, but failure to
> discourage it comes to the same thing as encouraging it.
> It isn't uncommon to have to enter a small number of comments received
> after the ballot has closed (when MyBallot is no longer available for
> use by the ballot group), but when that is necessary, the "rogue
> comment" mechanism can be used by you (or your designee) to add such
> comments to the comment database, thus making the process as
> transparent as possible, both in the eyes of RevCom and the balloters.
> However, at least in my experience, it is unusual to have to handle
> more than a handful of comments that way.
> Having read the RevCom comments, particularly the ones that indicate
> they were having difficulty understanding exactly what was being
> presented to them, I am not at all surprised that they bounced the
> At 06:17 09/06/2007, Roger B. Marks wrote:
>> To: 802.16 Reflector
>> cc: 802 EC Reflector
>> I have unfortunate news to report on P802.16g.
>> On 26 April, after three Sponsor Ballot recirculations and a 99%
>> approval ratio (136 Approve, 2 Disapprove), I submitted P802.16g/D9
>> to RevCom:
>> Yesterday, the approval request was rejected by the IEEE-SA Standards
>> Board, upon RevCom's advice.
>> To the best of my understanding, the core reason for the rejection
>> was that some of voters submitted comments directly to the Working
>> Group instead of using the IEEE-SA's myBallot system. This was partly
>> related to the unresolved comments of the two disapprove voters:
>> This issue was raised by several RevCom members prior to the meeting.
>> Phillip Barber (the Task Group Chair) and I prepared responses to
>> those comments for RevCom consideration, arguing that the WG did
>> follow documented procedures and, because it was required to address
>> all comments, had little choice in how to proceed:
>> I participated by telephone in the RevCom meeting of 6 June to
>> discuss these issues but was unable to reverse the opinion.
>> [I would like to add that the RevCom administrator responded to the
>> research in our response by indicating that 802.16-07/012r4 seems to
>> have not been included in the second recirculation; if so, it was
>> likely due to an accidental omission on my part, for which I assume
>> responsibility. However, RevCom at no time raised this issue in its
>> deliberations, so it does not appear to have directly affected the
>> During the RevCom meeting, I requested advice as to what kind of
>> approach we could follow to assure that we satisfy RevCom's concerns.
>> When no clear answer arose, I requested assignment of a RevCom
>> "mentor" to provide feedback and assurance that our future steps will
>> be satisfactory. Geoff Thompson volunteered.
>> The formal notice of disapproval is below, and at:
>> I am pleased to see that it provides some explicit directions on how
>> we can proceed: "The Sponsor must conduct a recirculation ballot to
>> show all unresolved comments associated with negative votes, and
>> their responses, to the ballot group. The Sponsor is encouraged to
>> input all comments and responses into the myBallot system for ease of
>> submittal package review by RevCom. The Sponsor shall inform the
>> ballot group that the myBallot system must be used as the mechanism
>> for ballot comment submission."
>> The middle sentence may be the most challenging. Based on my
>> understanding of the software, I am not currently aware of any way to
>> input comments and responses into the myBallot system prior to a
>> recirc. I have inquired with IEEE-SA staff as to whether they can
>> arrange a way to do so.
>> RevCom does not hold conference call meetings during the summer, so
>> the next chance for RevCom review of this draft is 26 September. This
>> delay will cause pain to the interesting parties. Since the base
>> standard will by then be more than three years old, it appears that
>> we may need to address the rule prohibiting amendments after three
>> years. There are some exceptions to the rule, but I don't fully
>> understand the language in the IEEE-SA Standards Board Operations
>> Manual, so further research will be required.
>> I'm copying the IEEE 802 EC so that other Working Groups will be
>> aware of this problem. Working Groups receiving comments outside the
>> myBallot system will need to decide whether to address those comments
>> or to ignore them. I am concerned that they will face risk either
>> way. In any case, it would certainly be wise to make an effort, in
>> your Sponsor Ballot cover letters, to steer your voters toward the
>> use of myBallot.
>> Roger B. Marks <email@example.com>
>> NextWave Broadband Inc.
>> Chair, IEEE 802.16 Working Group on Broadband Wireless Access
>> <http:// WirelessMAN.org>
>> Begin forwarded message:
>>> From: firstname.lastname@example.org
>>> Date: June 8, 2007 09:59:57 AM MDT
>>> To: email@example.com
>>> Subject: P802.16g Disapproval Notification
>>> 8 June 2007
>>> Roger Marks
>>> NextWave Broadband, Inc.
>>> 4040 Montview Blvd
>>> Denver, CO 80207
>>> cc: Paul Nikolich, C/LM Liaison
>>> Richard Snyder, MTT Liaison
>>> Michael Kipness, Program Manager
>>> William Ash, Program Manager
>>> Kim Breitfelder, Manager-Standards Editing and Production
>>> Geoff Thompson, RevCom mentor
>>> RE: NEW P802.16g/D9 (C/LM + MTT) IEEE Standard for Local and
>>> Metropolitan Area Networks - Part 16: Air Interface for Fixed and
>>> Mobile Broadband Wireless Access Systems - Amendment 3: Management
>>> Plane Procedures and Services
>>> Dear Roger,
>>> I must inform you that P802.16g was disapproved as a new amendment
>>> to IEEE Std 802.16-2004 by the IEEE-SA Standards Board on 7 June
>>> The Sponsor must conduct a recirculation ballot to show all
>>> unresolved comments associated with negative votes, and their
>>> responses, to the ballot group. The Sponsor is encouraged to input
>>> all comments and responses into the myBallot system for ease of
>>> submittal package review by RevCom.
>>> Sponsor shall inform the ballot group that the myBallot system must
>>> be used as the mechanism for ballot comment submission. Geoff
>>> Thompson will be the RevCom mentor to the Sponsor.
>>> David L. Ringle
>>> Manager - IEEE-SA Governance, Policy & Procedures IEEE Standards
>>> Activities Department
>>> 445 Hoes Lane
>>> Piscataway, NJ 08854
>>> TEL: +1 732 562 3806
>>> FAX: +1 732 875 0524
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