Re: [802SEC] Comments and reply comments to Public Trial of Google TVWS Database
I remember a conversation in the last Wireless Chairs meeting in San Diego
where the it was asserted, with some force, that the RR-TAG is subject to
the 30 day notice rule for teleconference meetings (here I mean meetings
where the RR-TAG plans to vote on approval of an output document for EC
for review, not ad hoc or other non-voting meetings).
The bottom line here, if the rules read as you say, is that all EC members
need to accept this as the policy, and the discussion should drop off the
radar going forward.
I believe the RR-TAG has usually operated with a 10 day meeting notice,
based on my experience as a member since July 2002, but if the rule is 5
day notice, then that’s fine. The RR-TAG P&P, admittedly out of date,
simply refers to the 802 P&P for the notice rule.
Thanks for the clarification.
On 7/30/14, 9:00 AM, "James P. K. Gilb" <firstname.lastname@example.org> wrote:
>The 30 day rule is to ensure openness in the standards development
>process. It is found in:
> - IEEE 802 LMSC P&P, clause 6.0 Meetings for the Sponsor
> - IEEE 802 LMSC WG P&P, clause 10 Meetings for WGs.
>However, TAGs, which don't do standards development, are specifically
>excluded from this requirement in the IEEE 802 LMSC P&P, subclause 5.5
>Technical Advisory Groups (TAGs), item e), which states:
>"e) Between plenary and interim meetings, the TAG Chair is empowered to
>schedule teleconference meetings to allow the TAG to conduct business as
>required, provided that the date and time of the teleconference and
>agenda are published on the TAG website and e-mail reflector at least 5
>days before the meeting."
>This is from our current P&P, as approved by AudCom. This rule has also
>been in there for quite some time.
>So, if 802.18 wants to schedule a teleconference, the notice is 5 days
>after posting to the reflector and the website. I am confused why Mike
>thought the 30 day rule applied to TAGs.
>30 days applies to the Sponsor and WGs, but not TAGs.
>On 07/30/2014 07:45 AM, John H Notor 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
>> 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
>> 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
>> regulations will be published, so the notice is procedural rather than
>> necessary. No one is harmed by the shorter time period.
>> 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" <email@example.com> 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
>>> 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.
>>> James Gilb
>>> 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
>>>> 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
>>>> TVWS Database
>>>> 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:
>>>> 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
>>>> teleconference meeting is scheduled on August 20, due to the 802 P&P
>>>> 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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