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Re: [802SEC] +++ 10 Day EC Ballot - Reply Comments to the FCC's Incentive Auction Proposal - Docket No. 12-268 +++

It seems to me that this is all yet another process centric debate about the meaning of a more or less continuously changing set of rules wherein no actual good thing is accomplished.

The half life of an 802 filing in a regulatory proceeding in terms of its value (except to archeologists) is on the order of months. Once the regulatory body digests it, along with all the other opinions submitted, it is either influences a rulemaking, or it doesn't, it's either included in a recommendation or it isn't, at which point, for all practical purposes it disappears into the mists of time.

 Fiddling with the how of our internal processes work doesn't improve our impact on regulations.

Nobody not presently involved with 802 who accesses 802 documents on Mentor sees the internal logic of our rules that make us so special, and careful and considerate. The see what they see. So our rules are not protection against being misunderstood.

Standards development under ANSI rules requires certain principles be in place and followed in order to be compliant, to protect contributor's rights and the process.

Regulatory filings don't have the same constraints. If I or my company isn't happy with an 802 filing, I or my company can file on our own behalf directly with the agency, unfiltered by 802 and its rules. So a person or a group always has an alternative means of being heard.

Do these changes matter, no they don't, except insofar as they instigate meaningless contention which continues, never resolving itself, as yet another set of changes appears over the horizon, and the next person takes up the megaphone of compliance to browbeat the rest into submission.

I remain unbrowbeaten, and, while of course, I will comply with whatever silly decision we are finally driven to in order to resolve this controversy, I remain undeterered I my view of its ultimate worth.


John Notor
Sent from my iPhone
Mobile: 1 (408) 799-2738

On Mar 6, 2013, at 11:45 PM, "James P. K. Gilb" <> wrote:


I don't intend to be cute, my apologies if the email came off wrong.  I am being serious about this.

However, I don't understand what specific issues are in the P&P or OM that actually causes insurmountable problems with regards to the document submission.  The requirements are:

- Approved by 2/3 vote of EC (we have been doing this)
- Issued by the Sponsor Chair (adds one step to the process)
- Copied to the Sponsor (already done) and IEEE SA Standards Board Secretary (we don't do this, but perhaps we should?)
- Posted on the website (all .18 submissions already do this as they are on mentor, linked from the IEEE 802 LMSC web site)
- Have a statement on the web site that says the position statements expires in 5 years after issue (not done).

The last one probably needs some tuning.  The implication of any filing is that it is the current IEEE 802 position at the time of filing, and presumably, for the near future.  What good would a communication be if it was no longer valid after it was issued?

So I plead ignorance, please tell me what are the specific problems that I have missed?

James Gilb

On 03/06/2013 10:21 PM, John Notor wrote:
> This is all very cute, but does not really address the issues related
> to regulatory bodies, whose policies and rules about document
> submissions do not revolve around IEEE 802 policies or operating
> procedures.
> A little common sense here would be helpful, and a recognition of
> what influence we've had since the beginning of 802.18 using the
> process to date.
> John
> John Notor Sent from my iPhone Mobile: 1 (408) 799-2738
> On Mar 6, 2013, at 7:48 PM, "James P. K. Gilb" <>
> wrote:
> Mike
> If a position statement has an expiration date, then we need to state
> that in the document.  If it is less than 5 years, then it should say
> so.
> If the position changes, then we need to issue a new position
> statement.
> BTW: Having a timeout on the position statement of some duration (it
> is in the OM and so we can select it) is a good idea for just the
> reason you state.
> James Gilb
> On 03/06/2013 09:04 AM, Michael Lynch wrote:
>> James,
>> Another item that doesn't seem to fit our filings with the FCC or
>> any other regulatory body: they are not position statements or
>> papers and should not have a five year life cycle.
>> "All IEEE 802 LMSC communications to government bodies shall be
>> issued by the IEEE 802 LMSC Chair as the view of IEEE 802 LMSC
>> (stated in the first paragraph of the statement). Such
>> communications shall be copied to the Sponsor and the IEEE-SA
>> Standards Board Secretary and shall be posted on the IEEE 802 LMSC
>> web site. The IEEE 802 LMSC web site shall state that all such
>> position statements shall expire five years after issue."
>> For example what we filed after the January meeting may not be the
>> view of the wireless groups by the time they meet in September. So
>> to have them considered as IEEE 802 position statements or papers
>> doesn't fit their intended purpose. Our views can and sometimes do
>> change in less than a year rather than the five years referenced in
>> the OM.
>> Regards,
>> Mike
>> -----Original Message----- From: James Gilb
>> [] On Behalf Of James P. K. Gilb Sent:
>> Wednesday, March 06, 2013 1:47 AM To: Roger Marks Cc: Michael
>>; Rosdahl;
>> Nikolich; Pat Thaler;
>> Chaplin; Tony Jeffree; Law;
>> <> Kraemer; Bob Heile; Subir;
>> "Buzz paul.nikolich@ATT.NET" <""apurva.mody" SSA)
>> Mody, Lynch <>,
>> J Shellhammer <>,Riegel Maximilian
>> <>,Thompson Geoffrey
>> <>,Everett O. Rigsbee
>> <>,Radhakrishna Canchi
>> <>,John Lemon <>,Paul
>> Nikolich " "> Subject: Re: +++ 10 Day EC Ballot - Reply Comments to
>> the FCC's Incentive Auction Proposal - Docket No. 12-268 +++
>> All

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