Re: Rules change ballot; addition of Procedure 10: communicationwith government bodies
> Dear SEC and 802 members
>
>At the July 2000 plenary the 802 Sponsor Executive Committee (SEC)
>agreed to initiate a rules change ballot to add Procedure 10 in our
>operating rules.
>
>"Procedure 10 PROCEDURE FOR COMMUNICATION WITH GOVERNMENT BODIES
I vote No.
I have both grammatical and fundamental concerns, as enclosed.
Roger
First, I agree with Tony's suggestions but would like to propose some
editorial alternatives:
>Procedure 10 PROCEDURE FOR COMMUNICATION WITH GOVERNMENT BODIES
>
>o IEEE 802 position statements
> - Communications with government bodies shall not be released
>without prior approval of the Executive Committee.
> - All communications shall be sent under the signature of the
>LMSC Chair as the position of IEEE 802 (stated in the first
>paragraph) and shall be copied to the SEC and the IEEE SA
> Standards Board Secretary and shall be posted on the IEEE 802
>web site and reviewed after 5 years.
IEEE 802 position statements shall be identified in the first
paragraph as the position of IEEE 802 and shall bear the signature of
the LMSC Chair. They shall be copied to the SEC and the IEEE-SA
Standards Board Secretary. They shall be posted on the IEEE 802 web
site and reviewed after 5 years.
>o Working group position statements
> - Communications with government bodies shall shall not be
>released without prior approval by a majority of the working group
>and review by the Executive Committee.
- Working Group communications with government bodies shall not be
released without prior approval by a majority of the Working Group
and review by the SEC.
> - All communications shall be sent under the signature of the
>Working group Chair(s) as the position of the working group(s)
>(stated in the first paragraph) and shall include the LMSC Chair
>in the communication distribution list.
Working Group position statements shall be identified in the first
paragraph as the position of the Working Group and shall bear the
signature of the Working Group Chair. The LMSC Chair shall be
included the distribution list.
>o Incoming liaison letters to Executive Committee members shall be
>sent, as a minimum to the LMSC Chair.
SEC members receiving incoming liaison letters shall forward a copy
to the LMSC Chair.
>o Informal communications are encouraged but should not imply that
>they are a formal position of the IEEE 802 or of the working group
>
>o Proposed position statements that need to be authored by other
>IEEE entities shall not be forwarded to the IEEE SA Standards Board
>Secretary for further processing without prior approval of the
>Executive Committee."
Change "IEEE SA" to "IEEE-SA".
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Now, my fundamental concerns, starting with the sentences as
editorially revised above:
>Procedure 10 PROCEDURE FOR COMMUNICATION WITH GOVERNMENT BODIES
Problem: What is a government body? What about, for example, ITU,
which is an international body with some authority and of which
governments are the members?
I suggest adding this opening sentence: "These procedures apply to
communications with government agencies of any kind, including
organizations comprised of government representatives."
>They shall be posted on the IEEE 802 web site and reviewed after 5 years.
Problem: This is too vague. What exactly happens after five years?
I suggest: "They shall be posted on the IEEE 802 web site with the
notice that all such statements shall expire after five years. The
LMSC Vice Chair shall ensure that expired position statements are
removed from the web site."
>Working Group communications with government bodies shall not be
>released without prior approval by a majority of the Working Group
>and review by the Executive Committee.
Problem: The "review" by the ExCom is too vague. Can the ExCom stop
the letter or not?
Problem: A majority vote of the Working Group is too slim for a vote
of this significance.
I suggest: "Working Group communications with government bodies shall
not be released without prior approval by a 75% majority of the
Working Group. Such communications may proceed unless blocked by an
SEC vote. For a letter not presented for review in an SEC meeting,
SEC members shall have a review period of at least five days; if,
during that time, a motion to block it is made, release of the letter
will be withheld pending completion of the vote."
>Working Group position statements shall be identified in the first
>paragraph as the position of the Working Group and shall bear the
>signature of the Working Group Chair.
Too weak: it doesn't limit broader claims or implied claims of support.
I suggest: "Working Group position statements shall be identified in
the first paragraph as the position of only the Working Group and
shall bear the signature of the Working Group Chair. Such statements
may not bear the IEEE or IEEE 802 logos."
>SEC members receiving incoming liaison letters shall forward a copy
>to the LMSC Chair.
I suggest: "SEC members receiving incoming liaison letters from
government bodies shall forward a copy to the LMSC Chair."
>o Informal communications are encouraged but should not imply that
>they are a formal position of the IEEE 802 or of the working group
Way too vague. Whom are we encouraging to submit these informal
communications? And with what limitations? This sentence could result
in a member writing to a regulatory agency and saying, for example,
"While this is not the formal position of IEEE 802, I suspect that it
is the position of the large majority of the members." And that
member could claim that the 802 rules encouraged him to write the
letter.
I suggest: "Informal communications by Working Group officials and
designated representatives are permitted, but no communication,
formal or informal, shall imply the support of IEEE 802 or its
subsidiaries unless the position is properly taken under these rules."