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Re: [802SEC] +++ 10 Day EC Ballot - Comments to the European Union Radio Spectrum Policy Group +++


I agree with Roger and vote Disapprove but would switch to Approve if his comments are incorporated.

I agree also with his first two points and take no position on the 3rd (i.e., if the draft was properly approved by 802.18).

In that case, postponing a meeting to the next day, I think we should discuss that as a rules clarification.

James Gilb

On 04/17/2013 02:24 PM, Michael Lynch wrote:
Dear EC,

As approved by the IEEE 802.18 RR-TAG during a pre-announced
conference call the RR-TAG approved Document 18-13-0047-06 as a
response to the European Union Radio Spectrum Regulatory Group (EU
RSPG). The document was approved by a vote of 7 yes, 0 no and 0
abstentions and will, with necessary edits and formatting changes
made by the IEEE 802.18 chair, be forwarded to the EU RSPG.

The next scheduled Thursday conference call will be on April 19th to
deal with a response to FCC Docket 13-49, on 5GHz U-NIII and Part 15

I have asked Paul to allow me to conduct a ten day EC email ballot to
approve submitting the comments (Document 18-13-0047-06) to the EU

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."

Paul also asked that I provide the full EC the same background
material that I provide to him. So I will "cut and paste" that data
here just prior to the actual motion.

"As mentioned in an earlier email IEEE 802.18 held two conference
calls to deal with an unforeseen consultation from the European Union
Radio Spectrum Regulatory Group. I feel that for your benefit more
background would be useful.

At the RR-TAG closing Plenary on March 21st we made the customary
motions for conference calls and, based on a known document soon to
be forthcoming from the FCC, set a date of April 19th to review and
respond to that document. The minutes reflecting that can be found on
IEEE 802.18's Mentor web site as Document 18-13-0039-00.

However, as happens in the regulatory world, another request for
comments was forwarded to the RR-TAG. This one was from the European
Union Radio Spectrum Policy Group. While the document is watermarked
"Draft" in the introduction to that document it states:


The following draft Opinion on Strategic Challenges facing Europe in
addressing the Growing Spectrum Demand for Wireless Broadband has
been agreed for public consultation by the RSPG at its plenary
meeting on 20 February 2013.

It must be noted that this draft Opinion, particularly its annexes
dealing with the identification of frequency bands with potential for
wireless broadband are work in progress. The RSPG has not taken any
final decision with respect to recommending particular portions of
spectrum for wireless broadband and welcomes in this regard any
feedback from stakeholders on the proposals in the draft Opinion and
its annexes.

Following the public consultation and based also on the comments
received, the RSPG plans to finalise the draft Opinion and its
annexes, and present them at the next RSPG plenary meeting for

I am providing you with this data since some may say that we (802)
are providing comments on a "draft" document. Indeed the EU RSPG
plans an using those comments in their final document. Based on the
experience of some in the RR-TAG we may still have be able to comment
further in this proceeding.

The need for this call was submitted to 802.18 by the 802.11 chair,
Bruce Kraemer, on March 22nd. John Notor, the 802.18 vice-chair, sent
the announcement of the April 11th conference call to consider the EU
RSPG consultation to the RR-TAG reflector on March 26th. The meeting
was opened as announced on April 11th but while we had a quorum the
meeting was recessed until April 12th. The reason for the recess was
an overlap with another meeting that would have taken a number of key
participants out of the 802.18 meeting.

On April 12th the meeting resumed and lasted approximately 1.5 hours.
The minutes from that meeting are attached for your review. There was
extensive discussion and resulted in the document (18-13-0047-06)
being approved 7/0/0. Those present are reflected in the attached
minutes. There is one error in the minutes, that being the correct
email for Ron Porat of Broadcom which is<> and not . I think that the error is of a "cut and paste"

The approval of this contribution was a result of the continuing
RR-TAG's Thursday conference calls. Now that I have given you all of
this useful (or not) background please let me move to the request for
the motion.


"To approve, under OM Subclause 8.2, document 18-13-0047-06 subject
to the early close provision of OM Subclause 4.1.2.."

Moved: Mike Lynch

Seconded: Bruce Kraemer

Link to the document:

 Comments are to be submitted to the EU RSPG by April 29th, 2013.

The ballot will start April 17th and end on April 26th.


Mike +1.972.814.4901

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