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[802SEC] Request for extension of reply comment deadline for the FCC 5 GHz U-NII Revision NPRM, ET 13-49

Dear EC,


As all of you are aware IEEE 802 filed Comments in the current FCC 5GHz proceeding. The next step in the this process is to review all of the other filings in order to create and then to create and file Reply Comments.


At this moment there are 67 filings with a total of 940 pages. The IEEE 802 comments seem typical and account for 42 of those pages, while others, such as from the Wi-Fi Alliance, account for 49 pages. Included amongst the filings are some Ex Parte fillings (5) and Letters (7), as well as the NPRM itself and the FCC Commissioners’ comments.


Because of the nature of the IEEE 802 work process it is unlikely that we can review, create and approve Reply Comments by the FCC’s prescribed date of 24 June. IEEE 802, as will other organizations, need more time to review the comments and draft a cogent and carefully worded Reply Comments. It is for that purpose that the attached request for an extension of time has been created for Paul to file with the Commission.


I am not aware of a process in the IEEE 802 rules that allows for us to respond quickly to this matter. The attached document simply asks the FCC to extend the time for creating Reply Comments. There are two proposed extensions, one for 15 days and the other for 30 days. Personally I prefer the latter since it would allow IEEE 802 to take the results of the review and create Reply Comments during the July Plenary in Geneva.


What I am asking the EC to do is to allow Paul to file the attached request for an extension of time in order for IEEE 802 to develop Reply Comments. I am open to suggestions for how to accomplish approving this letter. Could we apply the five day review period as the approval method?


Glad to discuss,




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Attachment: draft_request_extension_of_FCC_reply_comments_deadline_ET 13-49.docx
Description: draft_request_extension_of_FCC_reply_comments_deadline_ET 13-49.docx