Re: [802SEC] +++ 10 Day EC Ballot - Reply Comments to the FCC's Incentive Auction Proposal - Docket No. 12-268 +++
I guess if we put it in a footnote or at the end of the document, perhaps
after the signature, maybe with a reference to the 802 P&P (or OM)
requirement, the expiration date would not confuse the regulatory body.
I don't remember seeing an expiration date on a submission to any of the
usual regulatory suspects from other entities filing, but it doesn't mean
it can't be done.
The FCC recently did a "refresh" proceeding, on the wireless microphone
issues in the TV Band, where it requested commenters to update their
filings in the matter.
John
John Notor
President/Chief Technologist
Notor Research
Mobile: 1.408.799.2738
Skype: 1.408.457.1814
On 3/7/13 9:46 AM, "Pat Thaler" <pthaler@BROADCOM.COM> wrote:
>Generally, an expiry date on a document ensures that it goes away at some
>point even if it isn't replaced. It doesn't mean that it will always be
>valid for that long. For example, some of our drafts and all IETF IDs
>have an expiration date but they often are replaced with a new draft
>before it expires.
>
>I don't think we send out a position statement expecting to contradict
>it 6 months later. Yes we may refine it and send out a new statement
>before 5 years. New information or new participation might change our
>views more radically, but it isn't what we expect when we send a
>statement out. It would undermine the usefulness of a position statement
>if we sent it out with a very short expiration.
>
>Regards,
>Pat
>
>-----Original Message-----
>From: Michael Lynch [mailto:MJLynch@mjlallc.com]
>Sent: Wednesday, March 06, 2013 9:04 AM
>To: James P. K. Gilb; Roger Marks
>Cc: EC List (STDS-802-SEC@LISTSERV.IEEE.ORG); John_DAmbrosia@dell.com;
>jrosdahl@ieee.org Rosdahl; p.nikolich@ieee.org Nikolich; Pat Thaler;
>clint.chaplin@gmail.com Chaplin; Tony Jeffree; David_Law@ieee.org Law;
>bkraemer@ieee.org <bkraemer@ieee.org> Kraemer; Bob Heile;
>subirdas21@gmail.com Subir; "Buzz paul.nikolich@ATT.NET"
><""apurva.mody"@baesystems.com SSA) Mody,freqmgr@ieee.org Lynch
><freqmgr@ieee.org>,shellhammer@ieee.org J Shellhammer
><shellhammer@ieee.org>,Riegel Maximilian
><maximilian.riegel@nsn.com>,Thompson Geoffrey <thompson@ieee.org>,Everett
>O. Rigsbee <BRigsBieee@comcast.net>,Radhakrishna Canchi
><Radhakrishna.Canchi@kyocera.com>,John Lemon <jlemon@ieee.org>,Paul
>Nikolich " ">
>Subject: RE: +++ 10 Day EC Ballot - Reply Comments to the FCC's Incentive
>Auction Proposal - Docket No. 12-268 +++
>
>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 [mailto:jpgilb@gmail.com] On Behalf Of James P. K. Gilb
>Sent: Wednesday, March 06, 2013 1:47 AM
>To: Roger Marks
>Cc: Michael Lynch; EC List (STDS-802-SEC@LISTSERV.IEEE.ORG);
>John_DAmbrosia@dell.com; jrosdahl@ieee.org Rosdahl; p.nikolich@ieee.org
>Nikolich; Pat Thaler; clint.chaplin@gmail.com Chaplin; Tony Jeffree;
>David_Law@ieee.org Law; bkraemer@ieee.org <bkraemer@ieee.org> Kraemer;
>Bob Heile; subirdas21@gmail.com Subir; "Buzz paul.nikolich@ATT.NET"
><""apurva.mody"@baesystems.com SSA) Mody,freqmgr@ieee.org Lynch
><freqmgr@ieee.org>,shellhammer@ieee.org J Shellhammer
><shellhammer@ieee.org>,Riegel Maximilian
><maximilian.riegel@nsn.com>,Thompson Geoffrey <thompson@ieee.org>,Everett
>O. Rigsbee <BRigsBieee@comcast.net>,Radhakrishna Canchi
><Radhakrishna.Canchi@kyocera.com>,John Lemon <jlemon@ieee.org>,Paul
>Nikolich " ">
>Subject: Re: +++ 10 Day EC Ballot - Reply Comments to the FCC's Incentive
>Auction Proposal - Docket No. 12-268 +++
>
>All
>
>With regards to item 3), unfortunately, there is some overlap between the
>OM and the P&P.
>
>The P&P requires:
> - 2/3 approval for public statements
> - Public statements are only issued by the Chair.
>
>Both of these are in subclauses that can only be added to, hence these
>requirements come from AudCom and it is highly unlikely we can change
>them.
>
>As for "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.", we can and
>probably should change that in some fashion.
>
>IMHO, it would be nice to have a single area on the web site that does
>contain EC positions so that we don't contradict ourselves or issue the
>same position twice.
>
>I also agree with Roger that the argument that the OM was not followed in
>the past does not mean that it should not be followed now.
>
>James Gilb
>
>On 03/04/2013 11:38 AM, Roger Marks wrote:
>> On 2013/03/04, at 12:08 PM, Michael Lynch wrote:
>>
>>> Roger,
>>>
>>> 1. If you find the 2nd sentence of paragraph 11 unintelligible then
>>>please propose new wording.
>>>
>> Maybe it was intended to be two sentences, like this:
>>
>> "In light of this proposal we would like to emphasize the importance of
>>ensuring that the entire spectrum under channel 51 will continue to be
>>utilized by licensed, unlicensed, wireless microphones or TV operation.
>>IEEE 802 Standards for operation in TVWS have been and are being
>>developed to minimize interference to DTV reception in compliance with
>>FCC rules."
>>
>> I don't know the intent since I did not participate.
>>> 2. You may not be aware of the issues that have been occurring with
>>>regards to the EC reflector. Therefor it seemed that there was no other
>>>way to guarantee that this email would ever reach the intended audience
>>>other than to use the private list. I'm adding the reflector to this
>>>response. Let's see if it will work this week. My last several attempts
>>>to use it ended up with messages not being delivered. At Paul's request
>>>I was in contact with the SA and they were not able to resolve the
>>>matter. In that case last week the use of the private list was agreed
>>>to by Paul and with the tight timeline that this ballot is on it seemed
>>>best to use it to better guaranty being received by the EC..
>>>
>> I don't see your message in the archive. Maybe this response will end
>>up there.
>>> 3. Paul did very clearly authorize me to conduct this ballot. Do
>>>you feel that there was another reference other than 8.2 that should
>>>have been used or, that under 8.2, he is not authorized to delegate to
>>>someone else the role of conducting a ballot? The reference to 8.2 was
>>>also used on the very recent comments on the FCC's 3.5 GHz NPRM without
>>>objection by anyone. In reviewing 8.2 I see nothing that prevents the
>>>Sponsor Chair from delegating the function of communicating with
>>>governmental bodies. On the other hand if the Sponsor Chair is the only
>>>one who can communicate with governmental organizations then indeed he
>>>should be the sole point of contact for all communications to and from
>>>the FCC, Ofcom, ITU, etc. Maybe the OM needs to be revised (again) to
>>>make it clear that this role can be delegated?
>>>
>> I agree that the issue I've raised could have been applied to past
>> ballots as well. Still, the precedent of ignoring the OM doesn't
>> invalidate the OM. 8.2 doesn't specify who conducts the ballot, but it
>> does state who needs to issue the statement (though the meaning of
>> "issue" might be debated). There are also some specific post-ballot
>> elements of 8.2.1 that I suspect have not been observed in the past
>> ("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.")
>>
>> Roger
>>
>>> Best regards,
>>>
>>> Mike
>>>
>>> From: Roger Marks [mailto:r.b.marks@ieee.org]
>>> Sent: Monday, March 04, 2013 9:46 AM
>>> To: Michael Lynch
>>> Cc: John_DAmbrosia@dell.com; jrosdahl@ieee.org; p.nikolich@ieee.org;
>>> pthaler@broadcom.com; gilb@ieee.org;clint.chaplin@gmail.com;
>>> tony@jeffree.co.uk; David_Law@ieee.org; bkraemer@ieee.org;
>>> bheile@ieee.org; subirdas21@gmail.com;apurva.mody@baesystems.com;
>>> freqmgr@ieee.org; shellhammer@ieee.org; maximilian.riegel@nsn.com;
>>> Geoffrey Thompson; Everett O. (Buzz) Rigsbee; Canchi, Radhakrishna;
>>> John Lemon; Paul Nikolich (paul.nikolich@ATT.NET)
>>> Subject: Re: +++ 10 Day EC Ballot - Reply Comments to the FCC's
>>> Incentive Auction Proposal - Docket No. 12-268 +++
>>>
>>> Mike,
>>>
>>> I have a few editorial and procedural comments.
>>>
>>> (1) The second sentence of paragraph 11 is unintelligible.
>>>
>>> (2) Conducting a ballot by circulation to a closed email list does not
>>>meet the requirement of OM 4.1.2: "Provision shall be made for the IEEE
>>>802 LMSC membership to observe and comment on Sponsor electronic
>>>ballots. All comments from those who are not members of the Sponsor
>>>shall be considered."
>>>
>>> (3) Since the language indicates OM Subclause 8.2, then the elements
>>>of 8.2.1(b) apply. In particular: "All IEEE 802 LMSC communications to
>>>government bodies shall be issued by the Sponsor Chair..."
>>>
>>> Roger
>>>
>>>
>>>
>>> On 2013/03/02, at 12:10 PM, Michael Lynch wrote:
>>>
>>>
>>> Dear EC,
>>>
>>> During the January wireless interim meeting in Vancouver 802.18 began
>>>work on a response to the FCC's 3.5 GHz NPRM proceeding. It was not
>>>possible to complete the response at that meeting so a series of
>>>conference calls were announced to complete the work. Two calls, one on
>>>January 24th and the second on January 31st, were used to complete the
>>>document Doc. 18-12-0109-06. The document was approved by 802.18 by a
>>>vote of 5 yes, 0 no and 1 abstention, submitted to and approved by the
>>>EC and filed with the FCC.
>>>
>>> During the discussion of any other business the group decided to
>>>continue to have the Thursday evening calls during the period of
>>>February 7th to March 14th. The positive result of that action was the
>>>approval on February 28th of proposed reply comments to the FCC's
>>>"Incentive Auction" proposal (Docket No. 12-268). This takes advantage
>>>of the FCC having extended the reply comment date to March 12th.
>>>
>>> I have asked Paul to allow me to conduct a ten day EC email ballot to
>>>approve submitting the reply comments (Doc. 18-13-0016-06-0000) to the
>>>FCC.
>>>
>>> Paul's response to my request is:
>>>
>>> "I will authorize a 10 day EC email ballot, to be conducted by Mike
>>>Lynch, for the following motion."
>>>
>>> Motion:
>>>
>>> "To approve, under OM Subclause 8.2, document 18-13-0016-06-0000
>>>subject to the early close provision of OM Subclause 4.1.2.."
>>>
>>> Moved: Mike Lynch
>>>
>>> Seconded: Apurva Mody
>>>
>>> Link to the document:
>>>
>>> https://mentor.ieee.org/802.18/dcn/13/18-13-0016-06-0000-draft-reply-
>>> comments-to-fcc-tv-band-incentive-auction-nprm.doc
>>>
>>> Reply comments are to be submitted to the FCC by March 12, 2013.
>>>
>>> The ballot will start March 2nd and end on March 11th, 2013.
>>>
>>> I am using the "private list" since once again there seems to be an
>>>issue with either delay or non-delivery when using the EC reflector.
>>>This has also impacted the 802.18 reflector.
>>>
>>> Best regards,
>>>
>>> Mike
>>> +1.972.814.4901
>>>
>>
>>
>
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