It actually looks like I was totally wrong, you haven’t been able to do it 
since this FCC Declaratory Ruling in 2008:
https://apps.fcc.gov/edocs_public/attachmatch/DOC-284286A1.pdf


From: Hass, Douglas A. 
Sent: Wednesday, June 10, 2015 4:54 PM
To: af@afmug.com 
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz



I disagree that you could split hairs that way. Blocking a method has the 
effect of blocking content, which is all that someone needs to show.

El jun. 10, 2015 4:52 PM, Josh Reynolds <j...@spitwspots.com> escribió:
You're a lawyer now? :)

For the record, blocking a delivery method != blocking content.

Josh Reynolds
CIO, SPITwSPOTS
www.spitwspots.com<http://www.spitwspots.com>

On 06/10/2015 12:02 PM, Ken Hohhof wrote:
You are not allowed to block legal content. Period.

If you rate limit it, you could perhaps claim it is reasonable network 
management, but “no throttling” is another of the 3 bright line rules.

Remember one of the 2 or 3 actual cases of “bad behavior” cited for justifying 
all this was Comcast interfering with Bit Torrent back in something like 2007, 
and they weren’t even outright blocking it.

As far as being sued, a customer could file a complaint with the FCC, rather 
than pursuing civil damages, likely that is the way they would go since all 
they have to do is fill in a form on the FCC website.

My guess is the FCC will be much more interested in pursuing complaints from 
the likes of Netflix, Cogent and Level3 against the likes of Comcast, Verizon 
and Time Warner. Unless you piss off John Oliver. So it might just be like the 
BBB, they just send you the complaint and let you figure out what to do with 
it. That reminds me, I need to check if we are supposed to be registering a 
contact to receive Open Internet Order complaints, that kind of rings a bell, 
but maybe I’m confusing it with having a DC registered agent for CPNI 
complaints if you file Form 499.

The other factor on your side is the customer might not want to complain to the 
FCC if their reasons for using Bit Torrent are not exactly legal or moral. And 
customers wanting to torrent legitimate content, like maybe Linux ISOs, will 
probably just use another method and not have a cow over it.


From: Josh Reynolds<mailto:j...@spitwspots.com>
Sent: Wednesday, June 10, 2015 2:46 PM
To: af@afmug.com<mailto:af@afmug.com>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

I'll say this again: After consulting with no less than 3 legal firms who 
specialize in communications/fcc law, we are in the clear. I'm not going to get 
into a debate about the legality of this because (A) I'm not a lawyer and (B) 
neither are you. We have been told that subscribers agree to the restrictions 
on our network when they sign a contract. The language is the same used for 
commercial services.

Yes, the restriction applies to all torrent traffic.

Josh Reynolds
CIO, SPITwSPOTS
www.spitwspots.com<http://www.spitwspots.com>

On 06/10/2015 11:37 AM, Josh Luthman wrote:
IMO your only concern should be getting sued. Anyone that's torrenting stuff 
probably doesn't have the money for a lawyer to do that.

Do you do any CIR connections for businesses? Do you block them?


Josh Luthman
Office: 937-552-2340
Direct: 937-552-2343
1100 Wayne St
Suite 1337 3
Troy, OH 45373

On Wed, Jun 10, 2015 at 3:35 PM, Josh Reynolds 
<j...@spitwspots.com<mailto:j...@spitwspots.com>> wrote:
And after that based on the legal advice we have received from no less than 3 
Communications Lawyers

Josh Reynolds
CIO, SPITwSPOTS
www.spitwspots.com<http://www.spitwspots.com>

On 06/10/2015 09:41 AM, Ken Hohhof wrote:
And you can legally do it until this Friday.

From: Josh Reynolds<mailto:j...@spitwspots.com>
Sent: Wednesday, June 10, 2015 12:10 PM
To: af@afmug.com<mailto:af@afmug.com>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz


We have been blocking torrents as a network protection measure for over 6 years 
using various DPI and behavioral detection systems, and its in our AUP. We have 
never lost a customer or even had a complaint because of it.

On Jun 10, 2015 4:56 AM, Mathew Howard mailto:mhoward...@gmail.com wrote:
Agreed. I don't even want to think about how many calls we would have to deal 
with if blocked VPNs... and torrents for that matter.

On Wed, Jun 10, 2015 at 7:10 AM, Mike Hammett 
<af...@ics-il.net<mailto:af...@ics-il.net>> wrote:
Yes and blindly killing things is a terrible practice.



-----
Mike Hammett
Intelligent Computing Solutions
http://www.ics-il.com

[http://www.ics-il.com/images/fbicon.png]<https://www.facebook.com/ICSIL>[http://www.ics-il.com/images/googleicon.png]<https://plus.google.com/+IntelligentComputingSolutionsDeKalb>[http://www.ics-il.com/images/linkedinicon.png]<https://www.linkedin.com/company/intelligent-computing-solutions>[http://www.ics-il.com/images/twittericon.png]<https://twitter.com/ICSIL>

Midwest Internet Exchange
http://www.midwest-ix.com

[http://www.ics-il.com/images/fbicon.png]<https://www.facebook.com/mdwestix>[http://www.ics-il.com/images/linkedinicon.png]<https://www.linkedin.com/company/midwest-internet-exchange>[http://www.ics-il.com/images/twittericon.png]<https://twitter.com/mdwestix>
________________________________
From: "Paul McCall" <pa...@pdmnet.net<mailto:pa...@pdmnet.net>>
To: af@afmug.com<mailto:af@afmug.com>
Sent: Tuesday, June 9, 2015 11:12:43 PM

Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz


Rory, how do you “kill torrents”? technically,



And, aren’t there a lot o legitimate programs that use torrents as the 
distribution method?



From: Af [mailto:af-boun...@afmug.com<mailto:af-boun...@afmug.com>] On Behalf 
Of Rory Conaway
Sent: Monday, June 08, 2015 3:54 PM
To: af@afmug.com<mailto:af@afmug.com>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz



If you have file sharers on there for example, I’ve seen XM radios drop to 
10Mbps or less (another reason we kill torrents). If you watch the modulation 
levels when that happens, you will also see them drop as the CPU load goes up.



Rory



From: Af [mailto:af-boun...@afmug.com<mailto:af-boun...@afmug.com>] On Behalf 
Of Josh Luthman
Sent: Monday, June 08, 2015 12:46 PM
To: af@afmug.com<mailto:af@afmug.com>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz



PS in the run queue? That certainly isn't load, there's no way an XM radio can 
do 20+.





Josh Luthman
Office: 937-552-2340
Direct: 937-552-2343
1100 Wayne St
Suite 1337
Troy, OH 45373



On Mon, Jun 8, 2015 at 3:41 PM, Bill Prince 
<part15...@gmail.com<mailto:part15...@gmail.com>> wrote:

I'm with Rory. It depends a lot on the traffic, and and what role it may be 
playing (backhaul, AP, or SM). This is just a 1 day snapshot of one in SM role.

[X]


bp

<part15sbs{at}gmail{dot}com>



On 6/8/2015 12:34 PM, Josh Luthman wrote:

SSH into every single AP and it says 0.00 or 0.01. I used to graph it way back 
(maybe 5.3 days?) and I never saw it deviate. This is definitely all XM gear.





Josh Luthman
Office: 937-552-2340
Direct: 937-552-2343
1100 Wayne St
Suite 1337
Troy, OH 45373



On Mon, Jun 8, 2015 at 3:27 PM, Rory Conaway 
<r...@triadwireless.net<mailto:r...@triadwireless.net>> wrote:

I would have to se your data, mine does not support that.







Sent from fromm phone where I type with a single digit so please excuse 
shortcuts or typos.



Rory Conaway

Triad Wireless


-------- Original message --------
From: Josh Luthman 
<j...@imaginenetworksllc.com<mailto:j...@imaginenetworksllc.com>>
Date: 06/08/2015 3:26 PM (GMT-05:00)
To: af@afmug.com<mailto:af@afmug.com>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

If that was the case why are the loads of every radio 0.01 or less?





Josh Luthman
Office: 937-552-2340
Direct: 937-552-2343
1100 Wayne St
Suite 1337
Troy, OH 45373



On Mon, Jun 8, 2015 at 3:22 PM, Rory Conaway 
<r...@triadwireless.net<mailto:r...@triadwireless.net>> wrote:

To prove my point further, if you do throughput testing with Ubiquity in ptmp 
mode, you will find with xm radios, cpu load affects modulation levels. I 
haven't tested xw radios yet but I believe the threshold is just higher and 
probably justifies 30mhz but it's going to be close.







Sent from fromm phone where I type with a single digit so please excuse 
shortcuts or typos.



Rory Conaway

Triad Wireless


-------- Original message --------

From: Rory Conaway <r...@triadwireless.net<mailto:r...@triadwireless.net>>
Date: 06/08/2015 3:16 PM (GMT-05:00)
To: af@afmug.com<mailto:af@afmug.com>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

The pps and cpu load absolutely is another variable you need to take into 
acount, especially with 400 and 526mhz atheros processors that are also running 
polling. Ignore it as part of your overall strategy and you could be wasting 
spectrum. If your ap never exceeds 80mbps, why do you want 30mhz channels. 
Sarcasm aside, does that help you understand my point.







Sent from fromm phone where I type with a single digit so please excuse 
shortcuts or typos.



Rory Conaway

Triad Wireless


-------- Original message --------
From: Josh Reynolds <j...@spitwspots.com<mailto:j...@spitwspots.com>>
Date: 06/08/2015 2:17 PM (GMT-05:00)
To: af@afmug.com<mailto:af@afmug.com>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

I think we are having two different conversations, and I have no idea what you 
are talking about right now.

What we were discussing has to do with channel sizes, epmp, and ubiquiti. In 
particular, why UBNT 40mhz isn't any better than 30mhz in terms of efficiency.

This part of the discussion has nothing at all to do with any theories on PPS 
you may have, other than those you have tried to inject into this discussion.

On Jun 8, 2015 10:07 AM, Rory Conaway 
<r...@triadwireless.net<mailto:r...@triadwireless.net>> wrote:

Excopt that as was mentioned before, the s/n ratio goes down and if you aren't 
hitting the limits of the physical layer in 20MHz, why do it?







Sent from fromm phone where I type with a single digit so please excuse 
shortcuts or typos.



Rory Conaway

Triad Wireless


-------- Original message --------
From: Josh Reynolds <j...@spitwspots.com<mailto:j...@spitwspots.com>>
Date: 06/08/2015 12:43 PM (GMT-05:00)
To: af@afmug.com<mailto:af@afmug.com>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

I can assure you that on radios connected in a ptp config or small ptmp, that 
you will see more throughput on the 30mhz channel given a noise floor of -97 
and signals in the mid -50s, even with nothing connected on the other side of 
the radios.

Its an efficiency issue.

On Jun 8, 2015 8:13 AM, Mathew Howard 
<mhoward...@gmail.com<mailto:mhoward...@gmail.com>> wrote:

I kind of does, the way I understood it, that bottleneck limited you from 
really being able to do anything beyond what a 30mhz channel could support.

Now that I think about it, I have seen 40mhz perform better than 30mhz... but 
yes, that was because of RF problems, and neither one was doing anything close 
to what it would with a good link.



On Mon, Jun 8, 2015 at 11:09 AM, Josh Reynolds 
<j...@spitwspots.com<mailto:j...@spitwspots.com>> wrote:

That is a bottleneck in the system, but not relevant as far as this discussion 
goes. That has nothing to do with the 30/40MHz channel efficiency per say.

On Jun 8, 2015 8:03 AM, Rory Conaway 
<r...@triadwireless.net<mailto:r...@triadwireless.net>> wrote:

The limitation on the older xm radios was pps. When you added a lot of small 
packets and airmax, you could drop down to as low as 40Mbps. In the real world 
in ptmp mode. We planned for 50mhz per AP with eveything g taken into account.







Sent from fromm phone where I type with a single digit so please excuse 
shortcuts or typos.



Rory Conaway

Triad Wireless


-------- Original message --------
From: Josh Reynolds <j...@spitwspots.com<mailto:j...@spitwspots.com>>
Date: 06/08/2015 11:59 AM (GMT-05:00)
To: af@afmug.com<mailto:af@afmug.com>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

This. Thought it was pretty obvious but I guess I assumed too much out of some 
on this list ;)

On Jun 8, 2015 7:33 AM, Jeremy 
<jeremysmi...@gmail.com<mailto:jeremysmi...@gmail.com>> wrote:

I think he is talking about using 40MHz channels on the older M series, that 
didn't have gig ports. It was my understanding that the processor would get 
taxed as well on a 40MHz channel, making 30MHz actually work better.



On Mon, Jun 8, 2015 at 9:24 AM, Josh Luthman 
<j...@imaginenetworksllc.com<mailto:j...@imaginenetworksllc.com>> wrote:

Ubnt and epmp have gig ports.

Josh Luthman
Office: 937-552-2340
Direct: 937-552-2343
1100 Wayne St
Suite 1337
Troy, OH 45373

On Jun 8, 2015 11:20 AM, "Josh Reynolds" 
<j...@spitwspots.com<mailto:j...@spitwspots.com>> wrote:

I don't know how epmp does it.

For UBNT, a 30mhz channel is just a "fat" 20mhz channel in the atheros chip. 
Single operation. For a 40mhz channel, it's really two 20s, meaning radio 
operations are ran twice. Loss in efficiency, also marred by the lack of 
gigabit port.

On Jun 8, 2015 7:13 AM, Mathew Howard 
<mhoward...@gmail.com<mailto:mhoward...@gmail.com>> wrote:

I've never seeing much difference in performance on the ubnt M series between 
30mhz and 40mhz channels, so yes, I would say that is true... but I'm not sure 
how much applies to ePMP - they do have a much a faster processor and on a 
software level they are very different.

So far, I have been running all of our ePMP APs on 20mhz channels and PTP links 
on 40mhz or 20mhz, depending on how much capacity they need. I haven't really 
seen much need to go down to 10mhz channels with ePMP.



On Mon, Jun 8, 2015 at 8:43 AM, Shayne Lebrun 
<sleb...@muskoka.com<mailto:sleb...@muskoka.com>> wrote:

I seem to recall that with the M series, at least, a 30 mhz channel works 
'better' than a 40 because the 40 is really two 20 mhz channels bonded 
together, where a 30 mhz channel is a 30 mhz channel.

-----Original Message-----
From: Af [mailto:af-boun...@afmug.com<mailto:af-boun...@afmug.com>] On Behalf 
Of Rory Conaway
Sent: Saturday, June 6, 2015 8:32 PM
To: af@afmug.com<mailto:af@afmug.com>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

I'm not that familiar with the ePMP's yet but I can tell you some things that 
we saw with Ubiquiti. One is that channel width does not scale with bandwidth 
that that Atheros chipset. For example, 40MHz channels rarely hit their 
theoretical maximum due to a variety of factors, noise, lower s/n, processor 
limitations, etc... Second, 20MHz channels seem to be the sweet spot but even 
with GPS sync, you have to deal with reflections. Third, 10MHz channels have 
more overhead as a percentage of total capacity and don't handle a lot of users 
well (above 40 for example with the older 400MHz chipsets. I'm starting to 
deploy XW radios with the 520MHz processors but everything is 20MHz now so I 
don't have a comparison). We did see peaks of 32Mbps with some customers on 
10MHz channels but that's non-peak times. In peak times, we were seeing 8Mbps 
when more users were online.

Rory


-----Original Message-----
From: Af [mailto:af-boun...@afmug.com<mailto:af-boun...@afmug.com>] On Behalf 
Of Craig House
Sent: Saturday, June 06, 2015 5:20 PM
To: af@afmug.com<mailto:af@afmug.com>

Subject: [AFMUG] EPMP 10 mhz vs 20mhz

We have deployed 6 towers to begin our new EPMP network and 4 of those towers 
have a full cluster of 2.4 90 degree EPMP sectors. They are configured with ACS 
turned off now because in several cases they all ended up on the same or very 
close to the same channel. I have Front back designations and non overlapping 
channels set up on all towers. I have tried 40 mhz 20 mhz and now 10mhz 
channels and while the customer stability has gotten better the more I play 
with settings I have kind of hit a point I dont know what else to try. I have 
some that the uplink quality will vary wildly from 100% to 0%. Most have gotten 
better since I went to a 10mhz channel. Most of the customers get 12MB -30mb 
down in the wireless link test but the uplinks are as bad as .17. What is the 
cause of this poor uplink quality? Is it interfernece? My one 5ghz AP does not 
have this problem but even with noise many of these customers have -50 signals 
and oddly enough the ones with the great signals seem to be the ones that have 
the poorest link tests on the up link side. I also have customes with -65 or 
-72 signals that get 5MB up on the same sectors? Im scratching my head a bit on 
what the fix is for this? Should I leave ACS on and change everything to 10mhz 
channels? Will a full cluster with ACS on work all on the same channel?
I'm used to FSK where you pick your channel and any channels that are adjacent 
will cause problems with connected SM's. So am I just applying old knowledge to 
a technology that it doesn't apply to?

Craig


Douglas A. Hass
Associate
312.786.6502
d...@franczek.com

Franczek Radelet P.C.

300 South Wacker Drive
Suite 3400
Chicago, IL 60606
312.986.0300 - Main
312.986.9192 - Fax
www.franczek.com
www.wagehourinsights.com
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