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Re: [802SEC] Motion on OfCom Consultation, filing due 22 July, 2016


I vote Disapprove.

My concern is that the document presumes in several places that the term “Wi-Fi”, as used in the consultation, means “Wi-Fi®” However, it’s my understanding that it doesn’t. The consultation says:

In this document we use the term Wi-Fi throughout because it is by far the most common WLAN/RLAN application and is widely understood by both industry stakeholders and consumers - but the discussion is also relevant to all other variations of WLAN/RLAN technology (e.g. LTE/LAA etc.).

Since the response uses the term “Wi-Fi” differently than does the consultation, if should explain that usage and contrast it to that of the consultation. Here is some text where it matters:

*Slide 5 asks for “Wi-FI” to “be treated as an de facto incumbent, and should be afforded the protection all of its adherents expect and deserve.” This has two very different meanings depending on whether Wi-Fi is Wi-Fi® or all “variations of WLAN/RLAN technology (e.g. LTE/LAA etc.)”.
*Slide 6 worries about the “entry into the spectrum dominated by Wi-Fi for 20 years, of other technologies”. As far as I know, the technologies of interest are all “variations of WLAN/RLAN technology”, so they are not “other technologies”, according to the consultation.
*Side 10 says “Wi-Fi has become the dominant wireless Internet access technology”. Is this intended to include all “variations of WLAN/RLAN technology”?

There are also a lot of grammatical errors that need to be cleaned up, which I’m sure you will take care of after approval of the motion. I would suggest that you rephrase “The trend in new Internet connected devices is only wireless connectivity,” because I don’t think it’s clear. Surely that’s not the only trend in Internet connected devices.



On 2016Jul 14, at 7:56 AM, Holcomb, Jay <> wrote:

Dear EC Members,
Paul has delegated to Rich Kennedy to conduct an EC electronic ballot on the following motion. To ensure this motion is decided well before the 22 July 2016 Ofcom filing deadline I'm announcing an 'early close' to this ballot (see below).
802 EC motion per 802 OM 8.2 Procedure for communication with government bodies:
Move to approve the responses to the 13/05/2016 Ofcom  consultation (see as defined in document which contain the 802.18 approved (5/0/0) responses, instructions for uploading to Ofcom webpage and granting the 802.18 chair editorial license. 
Mover: Rich Kennedy, Seconder: Adrian Stephens
Start of ballot:  July 14, 2016
End of ballot: July 14 + 10 days or sooner per Early Close provisions
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.
On behave of Rich Kennedy, Chair of IEEE 802.18
Jay R. Holcomb
IEEE 802.18 Vice Chair 
R&D Spectrum Regulatory
2111 N Molter Road 
Liberty Lake, WA 99019 
509/891-3281, -3896 fax 
509/979-3625 cell
Knowledge to Shape Your Future
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