Re: [802SEC] Comments and reply comments to Public Trial of Google TVWS Database
James and all,
The reply comment period for the FCC is often shorter than the initial
comment period, since, after all, the proceeding notification has been
published for some time, so it¹s not so much that the FCC didn¹t give
enough initial notice for public comment. In very complex proceedings,
like the FCC 600 MHz reverse auction proceeding we dealt with recently,
the reply comments require review of a large number of difficult to digest
documents, and the FCC is often open to a request for an extension.
The complications for 802 come when a proceeding, or, for other
international regulators, a consultation, that affects IEEE 802 is
published between 802 plenary or interim meetings, with due dates before
the next scheduled 802 meeting, plenary or interim.
802¹s actual radio regulatory response time between regularly scheduled
meetings is a 30 day meeting notice, at least one 802.18 meeting day,
another day or two for notice to the EC and a 10 day EC ballot, followed
by maybe a day to get the item to the regulatory body. Basically, in big
round numbers, that¹s around 45 days minimum.
We can argue about the 5 day review rule to shorten the time, but when
there is the possibility of some disagreement on the issue, that is not
the reliable approach for most submissions, since it could cost an
additional 5 days, then a 10 day EC ballot to resolve.
For these kinds of regulatory activities, there is no need for 802 to have
a 30 day notice, since most companies who participate in 802 whose
products depend on regulation are usually following the relevant
regulatory activity and have some idea of when the request for comments to
regulations will be published, so the notice is procedural rather than
necessary. No one is harmed by the shorter time period.
On 7/29/14, 11:50 PM, "James P. K. Gilb" <firstname.lastname@example.org> wrote:
>These are not new rules. They are the rules under which we have been
>operating for at least 4 years.
>We may have been ignoring these rules, but it is not correct to say that
>they are new.
>BTW: Since when does the government only allow 20 day responses to any
>proposed rule change? I am not as familiar with the processes as you
>are, but I thought that they needed to give adequate notification.
>On 07/29/2014 12:40 PM, Michael Lynch wrote:
>> Correct, another item that the new rules prevent us, as 802, from
>>commenting on. The member's sponsors will be the ones having to do these
>> Best regards,
>> From: ***** IEEE 802 Executive Committee List *****
>>[mailto:STDS-802-SEC@ieee.org] On Behalf Of John H Notor
>> Sent: Tuesday, July 29, 2014 09:28
>> To: STDS-802-SEC@LISTSERV.IEEE.ORG
>> Subject: [802SEC] Comments and reply comments to Public Trial of Google
>> Released: 07/29/2014. OFFICE OF ENGINEERING AND TECHNOLOGY REQUESTS
>>COMMENT ON THE PUBLIC TRIAL OF GOOGLE, INC.'S TV BAND DATABASE SYSTEM
>>REGISTRATION PROCEDURES. (DA No. 14-1079). (Dkt No 04-186 ). Comments
>>Due: 08/13/2014. Reply Comments Due: 08/19/2014. OET . Contact: Alan
>>Stillwell at (202) 418-2925 or Hugh Van Tuyl (202) 418-7506
>> Comments Date: August 13, 2014
>> Reply comments Date: August 19, 2014
>> Unfortunately, 802.18 won't be able to comment on this, since our first
>>teleconference meeting is scheduled on August 20, due to the 802 P&P 30
>>day notice requirement for meetings.
>> John Notor
>> President/Chief Technologist
>> Notor Research
>> Mobile: 1.408.316.8312
>> Mobile: 1.408.799.2738
>> Web: www.notor.com<http://www.notor.com>
>> ---------- This email is sent from the 802 Executive Committee email
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