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[802SEC] EC Motion for 5 day EC electronic ballot

To immediately and urgently conduct a 5 day EC electronic ballot to
approve the attached document 18-04-0056-00-00 (TV Band NPRM Comments)
as an 802 Document, authorizing Carl Stevenson and Michael Lynch to
make necessary non-substantive editorial cleanups and formatting
changes, and to file the document with the FCC on behalf of IEEE 802
in a timely fashion. (NOTE: the filing deadline is Nov. 30, 2004 and
additionally, we need time to do the editorial cleanups and final
Formatting for filing.)

Moved:  Carl R. Stevenson
Seconded: Jerry Upton

Information for the EC:

The attached document was approved *unanimously* by 802.18 with broad
representation by voting members of 802.18 from both 802 as well as the
licensed incumbent services which future 802 wireless standards would,
by FCC rule and the ITU Radio Regulations, be required to protect from
harmful interference as a condition for access to the spectrum in question.

There are currently *NO* 802 wireless standards operating in the band in
question (the TV broadcast bands), so the recommendations in this document
would impose NO additional constraints on existing 802 wireless standards.

Any future 802 wireless standards desiring to operate in the band in
*will* be *required* by the FCC to afford the incumbent licensed services
protection from harmful interference.

(The standard to be developed by 802.22, under the scope of its PAR, is
specifically intended to operate in the TV broadcast bands, using cognitive
radio techniques to protect the incumbent licensed services from harmful

This document was reviewed by an ad hoc group from 802.11 (none of the other
Wireless WG Chairs responded to an invitation for review).

Any future 802 wireless standard proposing to use the TV bands under the
proposed by the FCC would, by definition, be required to operate on a
non-interfering basis to the incumbent licensed services.

Additionally, the attached document is a delicately crafted, yet fair,
compromise, based on UNPRECEDENTED cooperation between the "traditional"
802 community and licensed incumbents, some of whom have gained voting
membership, and others who have met the attendance requirements at this
session and will gain voting membership at the March plenary.

These folks came to OUR table to work cooperatively with us in an effort
to avoid conflict over the FCC's proposal to allow unlicensed devices to
operate *in spectrum for which they hold licenses and have legal rights to
protection from harmful interference*.

After months of cooperative work, NOT filing the comments that were mutually
Agreed between the RR-TAG and these incumbents will severely damage the
cooperative working relationship that has been forged between the incumbents
and "traditional 802 participants" and will almost certainly result in their
withdrawing from their attempts to work cooperatively with us and make our
prospects of gaining access to the spectrum.

Finally, since IEEE 802.18 requested, and was granted, an extension of time
in the
comment period, which the FCC granted - something that they normally don't
do - on
the basis that we had all of the incumbents at the table working
with us to bring a broad industry consensus position to the FCC, it will
certainly *trash* 802's reputation with the FCC if we do not deliver this
by the Nov. 30 filing deadline established by the extension of time that was
at our request - a relationship that we have worked hard to cultivate and
has been
very productive.

Carl R. Stevenson (outgoing Chair, IEEE 802.18 RR-TAG)
Michael Lynch, Interim Chair, IEEE 802.18 RR-TAG

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18-04-0056-00-0000_Comments_ to_TV_Band_NPRM.doc