Apologies, the below is long. Therefore, here’s the executive summary (generated by me, Arguable Intelligence, or lack therof, not machine-based AI) :
- SA ballot comment resolution isn’t delegated by the LMSC under the superior rules – it is overseen – the superior rules actually delegate directly to
the WG or WG subgroup.
- WG ballot process is defined completely within the WG. WG ballot comment resolution isn’t managed or even delegated by the LMSC.
- Only the WG ops manual levels (sometimes) specify the CRG voting and process. It seems that is where the change would be – so I need guidance as to
what LMSC level document (and where) the rules discussion would focus on.
- I personally believe that the CRG’s decisions are always subject to review and vote by the full and original ballot pool – via the recirculation process
– satisfying the requirement that the process be consistent with the SA ballot process, which does the same.
(more detail below)
-george
Ben – one wrinkle here. I believe that Geoff has only referred to a change in the process for working group ballots. I do not believe he is proposing any change to SA ballot comment resolution (I believe
he says he would like to see something for the SA ballot, but doesn’t know what he’d do). Geoff, please correct me if I am wrong, because this may involve either the LSMC Ops manual or the P&Ps.
Second, some corrections - Ben, you state that the “The SDG” (which you say is the LMSC) “is responsible for resolving comments.” – I assume you are talking about for SA ballot here. This isn’t strictly correct.
For the SA ballot, while the standards board ops manual puts oversight responsibility for the SA ballot process on the standards committee (shall ensure), it actually does the delegation to a level below the standards committee – it isn’t a delegation of the
LMSC – and says it is either the WG or a subgroup of the WG. Having the CRG be at the WG (or subgroup of the WG) level isn’t just ‘provided for’ as an option, it is mandated.
Working Group ballot process, on the other hand, is defined completely within the working group. The LMSC isn’t involved comment resolution or administration of the ballot. We review at the point where we
consider progressing to SA ballot. For WG procedures, Section 11 of the WG P&Ps state that the process ‘should be consistent’ with (paraphrasing) the process used at the SA ballot level (which means the LMSC does some oversight, but doesn’t reach into the
CRG process, which is still at the WG or WG subgroup level). WG ops manuals in some cases provide more detail on the precise process, which may vary from WG to WG.
I believe Geoff’s proposal below is “I propose that adoption of a comment resolution is taken by a vote of the members of the current draft balloting group participating in the vote (nominally those members
attending the comment resolution meeting).”
I’m not sure where this would show up in the documents – it doesn’t seem to fit anywhere in the WG P&Ps.
There isn’t an “adoption of a comment resolution” mentioned in the LMSC-level or WG P&P level rules that I can find. Sometimes WG Ops manuals, provide for approval of comment resolution by a 75% vote of
the CRC, e.g., the 802.15 ops manual at 5.5, or the 802.11 ops manual at 3.9.4 (which specifies the accelerated process after conditional approval to SA ballot). I note that 5.2 in the ops manual forms up a CRC with membership that may be different from
the full WG ballot pool, however, it is meant to be representative – not complete – something different than what I think Geoff is suggesting. However, in general, comment resolutions may be adopted by consensus of the CRG individually or in bulk, and differ
even at the subgroup level – but I personally think this is of no consequence to the superior rules.
The reason I believe this is that the CRG’s consensus is ultimately checked by the ballot group on any recirculation, so the full and original ballot pool always has the opportunity to adopt the new changes
– to reject or comment on anything the CRG does to change the draft, or on any rejection of a ‘must be satisfied’ comment. Consensus doesn’t mean unanimity, and any member of the ballot pool is free to comment on unsatisfied negative comments, providing an
opportunity to explain their position and a vote. If a participant in the ballot pool drops out, then that is on them – you can’t force someone to remain engaged. If new participants enter the working group voter pool over the course of the ballot, they
are generally not in the ballot pool. So, the ballot pool is the same with the exception that people may disengage at their own choice.
As I understand Geoff’s suggestion, it may be appropriate for WGs to consider whether more detail or additional rules are needed in the WG ops manuals. Perhaps I am completely off base and something different
is meant. We can discuss whether there is something needed at the LMSC level, but need specific guidance as to what change is sought to which section of which document have a useful discussion in the rules meeting.
George Zimmerman, Ph.D.
President & Principal
CME Consulting, Inc.
Experts in Advanced PHYsical Communications
310-920-3860
From: n81147@xxxxxxxxx <n81147@xxxxxxxxx>
Sent: Monday, July 6, 2026 3:37 AM
To: George Zimmerman <george@xxxxxxxxxxxxxxxxxxxx>; STDS-802-LMSC@xxxxxxxxxxxxxxxxx
Subject: Re: [802-LMSC] PROPOSED RULES CHANGE
Hi George, Geoff,
I understand the process as it is currently defined by rules and find it unambiguous. The SDG is responsible for resolving comments. The SDG, in our case the LMSC, delegates that to the working groups as provided for in the superior rules. The WGs may
then delegate that to a subset of the WG, e.g. the task group, task force, or a specific CRG. In both WG 15 and 11 the OM is clear, and sufficiently flexible to allow some adaptation. For example, both wireless WGs OMs specify that during a duly constituted
session (plenary or interim), the task group assigned the project is responsible for comment resolution and to approve resolutions on behalf of the WG; in WG15 during a session. The OMs allow for the WG to create a CRG, with specified membership, which is
empowered to resolve comments and approve resolutions on behalf of the WG.
I do not understand the problem with the current flow-down that you are seeking to solve. This process has, in most cases, worked very well for quite some time in WG 15. If a majority of the WG doesn't wish to empower a CRG, then the motion to form one
will fail. In my 20 ish years of 802.15, I am aware of only once that a motion to form a CRG has failed. Eliminating this option, which streamlines the process without any negative effect on the quality of the draft in most cases, because once in a blue
moon it isn't more efficient, is a bad idea IMO. In the event a CRG fails to reach the required consensus, the responsibility, the responsibility reverts to the WG more or less as you propose (with a slight difference).
I see several issues created by Geoff's proposal.
For SA ballot the ballot group is different than for WG ballots on the draft. IMO this is a positive feature, not a bug. If I understand Geoff's proposal, the only way to approve comment resolutions is to have consensus of all voters in the WG that were
in the WG ballot series pool. Some of those voters may have ceased participation. Once the draft is submitted to SA ballot, that pool has completed it's task. The SA ballot "restarts" the draft review and refinement. Again IMO this "restart" is a good
thing. If we remove the option for the WG to delegate to a dedicated CRG or to a task group/task force, we may create significant delays, especially in the later ballots where it it is possible with the current method to conduct multiple recirculation ballots
between sessions. Again, for WG 15, in the vast majority of projects (all but 1 that I can recall), this has had only positive outcomes. Geoff's proposal would either restrict recirculations to one every 2 months, or add a minimum 10 day WG electronic ballot
to approve comment resolutions so as to begin a recirculation. I see no benefit.
Note that under the present OMs for the wireless WGs, the WG is not required to delegate comment resolution. In the event that the normal approach fails, the WG may revert to pretty close to what Geoff is proposing, with no change to WG P&Ps, or the OM,
at least for the wireless groups (I have not recently looked at .1 and .3 OMs.
In practice, WG 11 and WG 15 use the delegation differently at times. Again I think this is a feature, not a bug. There are quite a few practical differences between the two WGs. Providing the WG and WG chair flexibility to adapt to the needs of a project
is a good thing. A one size fits all projects approach is not optimal.
FWIW. Perhaps I am not understanding the problem you perceive.
Best regards
Ben
On 7/3/2026 9:43 AM, George Zimmerman wrote:
Geoff – I will add this to the agenda. As this is regarding the WG P&Ps, and our main item of business is to get the LMSC P&Ps ready to submit to Audcom, it will be after that item on the agenda. We may not get to it.
What would be useful would be to understand just what the proposed text change to the working group P&Ps would be, and whether, in fact, the WG P&Ps (or other LMSC level document is the appropriate place. In looking for the right section of a document to prepare, it appears that the details of CRGs are not covered at the LMSC level and are either referred up to SASB documents or down to WG Ops manuals.
I have provided some background below to help you and others prepare for a discussion.
-george
Background:
(all) 802 WG P&Ps:
Comment resolution groups are not currently mentioned in the working group P&Ps.
Section 11, refers to the comment resolution process, stating, “Comment resolution, recirculations, etc. should be consistent with Standards Committee ballot rules and 5.4.3.2 of the IEEE-SA Standards Board Operations Manual (SASB OM).”
I note that 5.4.3.2 of the SASB OM does not cover comment resolution. It only covers Voting on the ballot. Comments are in 5.4.3.3 of the SASB OM. This leaves the actual conduct of WG ballot comment resolution less securely linked to the superior rules than the voting itself is, since LMSC ballot rules don’t cover comment resolution either.
Specifically regarding membership & voting in a CRG, the best I can find is that CRGs are treated as a subgroup of the working group (see SASB OM 5.4.3 below), and, as such, under section 5 of the working group P&Ps, “Any resolution of a subgroup shall be subject to confirmation by the Working Group, unless previously or otherwise delegated to the subgroup.” Therefore, the working group voters all have the ability to overrule any resolution of the CRG. It would seem that other than that the ballot group of a particular WG ballot might be the fixed-in-time sample of the WG membership (and the current WG membership may differ) the WG membership has the right to approve or modify any action of the CRG.
SASB OM:
The SASB OM (in 5.4.3 Conduct of the standards balloting process) states: “The Standards Committee shall ensure that comment resolution occurs via a comment resolution group, which is either the Working Group or a subgroup of the Working Group.”
WG Ops Manuals
CRG procedures are generally found in the individual WG ops manuals, where the working group has decided to codify them. See, for example, section 3.9 of the 802.11 ops manual, or section 5.5 of the 802.15 ops manual.
George Zimmerman, Ph.D.
President & Principal
CME Consulting, Inc.
Experts in Advanced PHYsical Communications
310-920-3860
From: thompson@xxxxxxxx <thompson@xxxxxxxx>
Sent: Thursday, July 2, 2026 9:46 PM
To: George Zimmerman <george@xxxxxxxxxxxxxxxxxxxx>
Cc: stds-802-lmsc@xxxxxxxxxxxxxxxxx
Subject: PROPOSED RULES CHANGE
George-
As we discussed briefly...
I would like to propose discussion of a rules change with respect to comment resolution of negative votes on Working Group Ballot.
The current situation is that adoption of a comment resolution is taken by a vote of current Working Group voters participating in the vote.
I believe that it is proper to change the rule because the voting body for the motion MAY be significantly different (but often is not) from the voting body for the draft.
I propose that adoption of a comment resolution is taken by a vote of the members of the current draft balloting group participating in the vote (nominally those members attending the comment resolution meeting).
I would like to apply the same sort of criteria to SA ballot but I haven't fully figured out what that would be. So I am content to consider just WGB at this time.
Please put this on the agenda for discussion at the rules meeting. It we get an agreement in principle then we'll draft text to go into a formally proposed change to the rules for the next time.
Best regards and sincerely,
Geoff Thompson
EC Member Emeritus
Life Senior Member
+1.540.227.0059
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