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I think that the relevant rule is in subclause 9.2:
"The CSD statement shall be reviewed and approved by the WG and the Sponsor as part of the approval process for the following:
• Forwarding the PAR to NesCom
The rule does not differentiate between new and revised PARs.
As 802.11ax predates the current CSD document, it uses the format of the CSD document under which it was approved (i.e., a 5 C).
IMHO: Any submission of a PAR that goes to NesCom requires CSD review and approval by the WG and the Sponsor.
It may be that WG to determines that despite the change of scope, the answers to original CSD stand, unmodified. If so, the WG should state that.
It may be, however, that the CSD/5C explicitly referred to the original band frequencies and so the WG should modify and approve the CSD (can be done by WG ballot) to match the new work.
IMHO, YMMV, etc.
PS: While a PAR that provides no new functionality does not require a CSD, an amendment clearly does. As does a change to the PAR of an amendment. Again, IMHO.