| John, all
I looked back and found the original 3350 request for comment from Nov 13, 2013, and the minutes , so unless something changed, no comment is necessary. I did not see that 802 addressed the Spectrum Bridge or other issues as far as I can tell.
When companies that are involved are following or submitting their own responses that is an on going process of business, I do think however, that technologies change, 802 sometimes does not respond because a group may be a study group yet to become a WG etc, or approval for a new sub group under an existing WG.
So, circumstances may change as to whether 802 itself, which is not entity based, may want to respond in a way they couldn’t before to a short period reply time. We have more and more groups involved with new standards, some new WG , etc. So can it be that although the original time frame which was enough, and interest from WG’s could have been none on a specific subject, but now in a short period of time, becomes important based on new status within 802 that although not responded to before, there could be an interest in answering a later regulatory call for comment within the 30 day window?
I am sure you know more than I do, it is just a thought, and it maybe good to have a path for an exception than not. Sincerely, Nancy
On Jul 30, 2014, at 7:45 AM, John H Notor <gnu@notor.com> wrote: 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.
John
John Notor
President/Chief Technologist
Notor Research
Mobile: 1.408.316.8312
Mobile: 1.408.799.2738
Web: www.notor.com
On 7/29/14, 11:50 PM, "James P. K. Gilb" <gilb@ieee.org> wrote:
Mike
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.
Thanks
James Gilb
On 07/29/2014 12:40 PM, Michael Lynch wrote:
John,
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
filings.
Best regards,
Mike
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
TVWS Database
FYI,
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
https://apps.fcc.gov/edocs_public/attachmatch/DA-14-1079A1.docx
https://apps.fcc.gov/edocs_public/attachmatch/DA-14-1079A1.pdf
https://apps.fcc.gov/edocs_public/attachmatch/DA-14-1079A1.txt
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
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>
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