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Re: [802SEC] +++ 10-day EC Email Ballot +++ Scope change of IEEE 802.24 and process for adding Task Groups for new areas of interest


I disagree that the distinguishing factor about what 802.18 handles is whether the radiation is intentional radiation from the MDI. It's the Radio Regulatory TAG and the same organizations (e.g. FCC) that regulates sending radio signals for a purpose often also handles the regulation of unintentional interference and of susceptibility. 

We have dealt with some EMI regulatory issues in the past (before the creation of 802.18). That area has been pretty stable and we haven't needed interaction on it since the creation of 802.18, but if there was a rule making change coming up where we wanted to comment. I expect that would fall under 802.18 because it is radio and they would be the place to work out any internal differences of opinion between our accidental and on purpose emitters before sending a communication.  (Vehicular and industrial may have different needs regarding EMI but there already seems to be an understanding of what they need and no current call to have government communications on the subject.)

On the other hand, in the past we had some comments/interaction regarding optical emitters (compliance with eye safety) and if that were to come up again, it wouldn't be an 802.18 matter because it isn't radio even though it is about signal at the MDI. Since it is different governmental bodies there isn't an argument that we would be more influential operating through existing 802.18 relationships for it and since we only have one WG working on optical transmission, there is no need to coordinate WG positions. 

Regarding something like the timing requirement I mentioned, I don't expect we would do something about that as it is already established and we think we can live with the current value. But if there were a proposed change to make it much shorter, we might choose to comment. We don't need to comment on everything, but if and when something arises where we see a need to communicate with a non-radio regulatory or a government agency, a WG has the right to send such a communication unless it is blocked in the 5-day review. 

I agree that such communications should be able to come from a WG when it is an issue that applies primarily to just that WG. My point was that under our rules WGs have that option. There is nothing that says that all regulatory or government communication needs to go through 802.18 or through some other TAG. There is just a mechanism to allow the EC to block sending in a case where the EC has a problem with the communication. It should stay that way. 


-----Original Message-----
From: Geoff Thompson [] 
Sent: Friday, May 23, 2014 1:16 PM
To: Pat Thaler
Subject: Re: [802SEC] +++ 10-day EC Email Ballot +++ Scope change of IEEE 802.24 and process for adding Task Groups for new areas of interest


I would argue that any relationships we are likely to have with other agencies is far different.
802.18 interacts with agencies concerning what is direct emitted by an implementation of the standard at the (Air) MDI.

In almost all other contexts, our relationship with a regulatory agency is as a subsystem element.
(Your example of "the amount of time that it takes for back-up cameras to become operational" is an appropriate citation here)

I don't see it as being appropriate for 802 to go to a regulatory agency on that issue.
It is up to our customers to agree on the portion of that time to allocate to us in the systems design.
They can do that independently, in 802 or they can do it in SAE or some other trade group.
It is then their problem (as it always has been) to get those requirements harmonized world-wide.

I see no value in jumping into those fights other than to say:
	"Yeah, we do a piece of that system and those guys are right"

I see no value to 802 for doing that sort of thing.
OTOH, we should certainly welcome reports from our customers on what the regulators are doing to them that affects our standards.
Those communications can certainly be handled by our members who have a dog in those fights as liaison reports.

Having those communications come into a TAG rather than the WG which is actually working on the problem is probably a bad idea.


On May 23, 2014, at 12:16 PMPDT, Pat Thaler <pthaler@BROADCOM.COM> wrote:

> Michael and Adrian,
> 802.18 is the Radio Regulatory TAG. It is chartered to communicate with regulatory and governmental bodies on radio regulatory matters, e.g. spectrum.
> There are regulatory and governmental bodies that deal with matters other than radio regulatory which impact IEEE 802 standards. For example, Energy Efficiency (Energy Star in the US), safety, automotive requirements (e.g. there is a requirement for the amount of time that it takes for back-up cameras to become operational after starting the car), Smart Grid.

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