RE: Letter to the FCC by IEEE802
Jim,
I could not find you in the office the plenary, that is why I acted.
See my embedded comments.
Vic
> ----------
> From: Jim Carlo[SMTP:jcarlo@ti.com]
> Sent: Sunday, November 14, 1999 11:44
> To: Hayes, Vic (Vic)
> Cc: IEEE802
> Subject: Letter to the FCC by IEEE802
> Importance: High
>
> <<File: 92658r2_Proposed_Reply_Comments_on_FCC_99-231r1.doc>>
> Vic, I am very concerned with the appropriateness of this letter. We had
> quite a go-around and discussion on whether the other two letters that
> IEEE
> 802 submitted to the FCC had gone through due-process and I believe we
> made
> significant progress by our inviting different parties to hear the
> responses
> before submission. In the end, I felt we had done our job properly.
>
> We still have concerned parties on the prior letters, with an appeal into
> the IEEE, and I do not know what the status of this is.
>
> The problem I have with the letter below:
>
> 1) I was not aware of the fact that the FCC had extended the response time
> for comments. Therefore in a previous note you sent me that there was no
> need to submit additional comments by the IEEE 802. I am concerned that
> interested parties may not have realized that this issue would be
> discussed
> at the 802 meeting.
VH--> My note to 802.11 and yourself just mentioned that no petition to
"extend the time for reply-comments" was needed and that I can save me the
time to write such letter. I have NOT said anything about a letter myself.
Now that the FCC has extended the time, and all people knowing that we had
the meeting, the group felt that failing to file may be proof of
indifference.
I have to follow up on the 802.11 action.
> a) Was the discussion of this letter announced as part of your agenda for
> the 802.11 meeting and when. I probably missed it?
>
VH--> I did not change the original announcement in my agenda after my
decision NOT to make the petition to extend the time:
Send letters to liaison groups and to regulatory agencies as needed, for
example:
FCC NPRM ET Docket No. 99-231
FCC NPRM ET Docket No. 99-42
WRC 2000/2002
There were people in the meeting room from both Proxim, Siemens as well as
Intel. They did not use their option to participate in debate.
> 2) Your updated letter to the FCC is confusing. Do I understand correctly
> that the cover page will not actually be submitted? Therefore the clear
> definition of what is the RAHG Regulatory Ad Hoc group, how many members
> were in this group (I think five members - I'd like a list and their
> companies) to show some balence.
>
VH-->The group that took part in the overall Regulatory work had the
following list of participants (I do not have the times they participated):
Lou Delaverson Motorola
Don Johnson WLAN Consulting (contracted by Lucent)
Denis Kuwahara Boeing
Richard Paine Boeing
Reiner Mim Proxim
Peter Murray NWN
Harry Worstell AT&T
> I believe this should be included in the
> actual letter with the other tallies.
VH--> At the meeting you were of the opinion that such was too much detail.
I agree with that. 802.11 members are sufficiently aware of their rights in
order to vote NO if they disagree.
> 3) What more review does this letter need? Why does it need review by
> Council?
VH--> At the SEC meeting, I felt people wanting to do so, and especially
from a non-company related counsel. I discussed it while on the floor with
Jerry Walker and he said there was a budget to get counsel from a "unbiased"
person. I would have asked my own counsel else.
> We discussed this in the SEC meeting, and the summary was not clear
> on how council could modify an 802 letter.
>
VH--> Editorials are always possible. They can also warn against
undiplomatic phrases.
> As I understand it, the letter,
> after we get it correct, will be circulated to IEEE-USA and IEEE-SA Staff
> for comment and review.
VH--> I was already asking that in my e-mails.
> 4) I would also send the letter, after you update per 2), to Steve Berger
> and Ian Gifford for forwarding to Bluetooth and HomeRF for information.
VH__>Sure
> I will be in Hawaii for the next four days, so you can call me at my room,
> or on my cellular phone. Can you call me at 9:00am on Monday?
VH--> Will be in LA till 6 AM Monday. Las Vegas till Wednesday 4 AM
> Jim Carlo(jcarlo@ti.com) Cellular:1-214-693-1776 Voice&Fax:1-214-853-5274
> TI Fellow, Networking Standards at Texas Instruments
> Chair, ISO/IEC JTC1/SC6 Telecom and Info Exchange Between Systems
> Chair, IEEE802 LAN/MAN Standards Committee
>
> -----Original Message-----
> From: Hayes, Vic (Vic) [mailto:vichayes@lucent.com]
> Sent: Friday, November 12, 1999 3:55 PM
> To: Pribula, Denise IEEE; Sauthoff, Dr. Ned - IEEE-USA VP
> Cc: Rutigliano, Janet; Carlo, Jim TI
> Subject: Request for review by Counsel
> Importance: High
>
>
> Hi Denise,
> Could you please request counsel to review this letter planned for filing
> at
> the FCC for the proceedings in ET Docket 99-231 as Reply-Comments.
>
> The filing date should be November 19, 1999 (FCC delayed the deadline). I
> can make a PDF file of the version Tom approves. I will then have that one
> e-mailed to him for electronic filing.
>
> In addition, I ask Dr. Ned Sauthof to review the contents with the
> IEEE-USA
> policy.
>
> Thanks a lot.
> ----------
> Vic Hayes,
> Chair, IEEE P802.11, Standards WG for Wireless Local Area Networks
> Lucent Technologies Nederland B.V.
> Zadelstede 1-10
> 3431 JZ Nieuwegein
> The Netherlands
> voice phone number: +31 30 6097528 (Time Zone UTC+1)
> fax phone number: +31 30 609 7556
> e-mail: vichayes@lucent.com
> <<92658r2_Proposed_Reply_Comments_on_FCC_99-231r1.doc>>
>