Re: [802SEC] FCC wants help defining broadband
Would it be possible to submit a short response that says this is an important issue where IEEE 802 should have input but 3 and a half weeks isn't enough time to develop a concensus response and we request an extension?
Pat
-----Original Message-----
From: ***** IEEE 802 Executive Committee List ***** [mailto:STDS-802-SEC@ieee.org] On Behalf Of Mike Lynch
Sent: Friday, August 21, 2009 8:58 AM
To: STDS-802-SEC@LISTSERV.IEEE.ORG
Subject: Re: [802SEC] FCC wants help defining broadband
Paul,
Yes, this is a topic that 802.18 should be interested in. We developed
initial comments to the FCC during the May interim but they did not address
the definition of broadband. Indeed we found the initial NOI (09-51) to be
extremely complex (more than 60 questions). The 802.18 response to GN Docket
09-51 and can be found at:
http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_documen
t=6520220911
During the July plenary 802.18 took a very quick look at the large number of
responses to 09-51 and decided to wait until the FCC came out with a further
request for comments. With all of the comments that they have received we
felt that it could take until Q4 before they ask for further comments. This
request is not that further request for comments but is focused on a single
definition that is not agreed even within the Federal government.
The short comment cycle makes any response from 802.18 difficult. If 802.18
is to develop and file comments there are two options:
1) I announce a conference call today for next week, most likely Tuesday
but not later than Wednesday. The 802.18 voters and representatives from the
802 WGs would have to have their positions prepared and be ready to develop
the definition on that call. Those comments would have to be sent to the EC
for a 5 day review by Thursday so that they could be filed with the FCC by
CoB on 31 August.
The reply comment cycle is not practical unless we plan for a conference
call on 2 September. Participants would have had to review the comments and
be ready to develop the reply comments on that call.
The main problem as I see it is the 802 WGs not having time to develop their
positions. I do not believe that the comment preparation should be limited
to wireless only.
2) 802.18 develops comments at the September interim. This gives time for
all interested 802 WGs to develop a view and be ready to develop the
comments/reply comments at the interim. The output would be filed with the
FCC after the EC review. This has happened previously as the FCC realized
that our meeting cycle and their comment cycle are often not in sync.
I am very open to other proposals on how to proceed.
Regards,
Mike
-----Original Message-----
From: ***** IEEE 802 Executive Committee List *****
[mailto:STDS-802-SEC@ieee.org] On Behalf Of Paul Nikolich
Sent: Friday, August 21, 2009 08:55
To: STDS-802-SEC@LISTSERV.IEEE.ORG
Subject: [802SEC] FCC wants help defining broadband
Mike,
Is responding to the FCC's request regarding the definition of broadband
something the 802.18 participants would be interested in addressing?
See the 20 August public notice.
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-1842A1.pdf
Regards,
--Paul
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