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Re: [802SEC] +++ 10-day EC Email Ballot +++ EC motion on 802.11 response to FCC docket 15-47


Sorry for the delay in responding to this ballot. It took me a little while to go over all the discussion points on this thread. I echo with what Apurva, Roger and Ben have said.

The document also  says “Where regulatory restrictions, such as exclusion zones, lead to problems that have no possible technical solution, the size of the potential market is the only decision

factor the community can use to assess the viability of an opportunity” whereas we do not say  what IEEE 802 would like to see on exclusion zone issue.  Towards that I liked Rich’s suggestion on adding

“IEEE 802 will continue to monitor progress towards resolving the exclusion zone and FSS protection limitations, and will re-evaluate our position as conditions dictate”.

It would be good if we return this to  802.11/15 REG group and allow them for another round of discussions.  OTH, if it delays a timely response, WG  can communicate to FCC

directly since  it does not require an EC approval motion as pointed out by Roger.  


Therefore I vote disapprove.






From: [] On Behalf Of Stephens, Adrian P
Sent: Thursday, June 04, 2015 10:37 AM
Subject: [802SEC] +++ 10-day EC Email Ballot +++ EC motion on 802.11 response to FCC docket 15-47


Dear 802 EC,


Whereas IEEE 802.11 has approved (In the WG: Y:47 N:0 A:2) the following motion: “To approve document 11-15/683r2 as our comments in FCC 15-47, and forward to the IEEE 802 EC, for approval and transmittal to the FCC.”


Move that EC approves transmission of document 11-15/683r2 ( to the FCC as a letter in response to FCC docket 15-47, granting the LMSC Chair editorial license.



Moved:   Stephens

Seconded: Rosdahl


Start of ballot: 2015-06-04

Close of ballot: 2015-06-14, 23:59 UTC-12


Early close: As required in subclause 4.1.2 'Voting rules' of the IEEE 802 LAN/MAN Standards Committee (LMSC) Operations Manual, this is notice that, to ensure the release is provided in a timely manner, this ballot may close early once sufficient responses are received to clearly decide a matter.      

Sufficient responses to clearly decide this matter will be based on the required majority for a motion under subclause 7.1.1 'Actions requiring approval by a majority vote' item (h), 'Other motions brought to the floor by members (when deemed in order by the Sponsor Chair)' of the IEEE 802 LAN/MAN Standards Committee (LMSC) Policies and Procedures.



Background information and rationale on specific form of motion


1.       The motion made at the EC telecon on 2015-06-02 was modified from the motion made in 802.11,  by the addition of a sentence intended to clarify possible future intentions.  The sentence was suggested by the 802.11 REG SC chair,  based on discussion he had with various parties after approval of the WG motion.  Time ran out on the telecon.

2.       There was an email thread on the EC reflector,  abstracted as below…

a.        Apurva: “It would be better if IEEE 802 provides constructive suggestions to the FCC

b.      Roger: “I propose to add the following at the end of the introductory "COMMENTS OF IEEE 802" paragraph?     "Other standards developed under IEEE 802 may be more suitable for adaptation and use under CBRS rules."”

c.       Ben: “I do not think Roger's addition addresses Apurva's concern, which is that the message lacks a positive suggestion. … I would advocate rewording so it is clear the concerns from 802 are not uniquely 802.11 WG's concerns.”


I have given some thought to the role of the EC in communications from a WG concerning that WG to an external body.   The LMSC rules require that such communications pass through EC for motion at 2/3 approval.   The LMSC rules do not limit what the EC can do with that document.


But, I believe we should limit what the EC attempts to do with such a document.  IMHO,  it should limit its actions to editorial corrections and clarifications.   If it fails to approve a document,  then comments on its substantive comment could be sent back to the WG,  so that the WG can adjust the document,  and send it back for approval.  Recent experience with the DSRC report confirms to me that this is the way we should handle such matters.


I believe that attempting to modify the substantive (i.e., non-editorial) content in the EC perilously moves its role away from keeper of the process into technical judge and jury.


Given these beliefs and the history recited above, I have moved the original motion as approved by 802.11.  If the motion is defeated,  I will collect comments to be sent to 802.11 for consideration in a subsequent attempt to communicate with the FCC.


Also,  I would like to see the Chair’s Guidelines provide clarification to bound and streamline this process in future.  But that is another debate.


On the specific changes requested,  I think both the changes proposed are essentially harmless.  But I think both are out of scope (i.e., not relevant) in a response originated by the 802.11 WG specific to WLAN,  which is the scope of this communication.


Notwithstanding the above discussion,  I did modify the motion from that presented to the WG, to add the “, granting the LMSC Chair editorial license”.   I believe this should always be present,  because I wouldn’t want to insist the LMSC Chair sent an uncorrected liaison where he,  e.g.,  spots a speeling misteak at the last moment.



Best Regards,




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