I notice that the FCC issued a $10,000 fine to Ayustar in San Juan 
about a year ago.  I hope they got the message.

It just might be that the FCC and NTIA were a little fast in making 
5600-5650 part of the Part 15 bands.  Sure, licensed equipment can be 
used without a license (vis. 3650) but that's a pretty 
straightforward violation.  On the other hand, it would be better to 
have access to that band, including the 30 MHz guard bands that the 
NTIA presentation shows as being needed, at least near the TDWRs.

And that's the rub:  There are 45 TDWRs, and a lot of places nowhere 
near them.  Sensing has not proven reliable.  But a GPS/database 
approach is costly.  Maybe the best compromise is to take 5570-5680 
and take it out of Part 15, or limit Part 15 use to indoor low power 
only (like 5150-5250).  Then the 110 MHz at risk can be made 
available under Part 90, as nonexclusive light licensing.  The 
license would have to specify its frqeuencies area of operation, and 
follow rules that avoid TDWR interference.  So if it's within say 10 
miles of a TDWR, it would need the 30 MHz spacing, and if within some 
larger radius, it would need less spacing, and if way far from one of 
them, it could operate within the TDWR band.  In exchange for this, 
we should ask for higher power limits, perhaps the same as on 
5725-5850 ISM, for places where it wouldn't interfere with TDWR (say 
if it's both >30 MHz and > 20 km away, or >100 km away).  This could 
be done with a map of both TDWR and any other protected radars.

At 2/9/2011 01:59 PM, Jack Unger wrote:
>On 2/9/2011 9:49 AM, Marlon K. Schafer wrote:
> > The proper fix for this problem is a visit from the enforcement guys, and a
> > nasty fine for repeat offenders.
><jau> Joint FAA/FCC Enforcement teams have been out for a long time 
>but this is
>a VERY costly solution and likely not sustainable in this era of shrinking
>budgets. That's why it's better to solve this problem before 
>enforcement becomes
>the option of (costly) last resort. WISPA has suggested to the FCC that they
>better PUBLICIZE enforcement actions and they are considering that.
> > After that, what would be so hard about using sensing and DFS (done right
> > this time) to cause systems near the radars to notch out the 110mhz of
> > spectrum while not bothering anyone else?
><jau> This is much more difficult that it sounds. The wireless 
>industry has been
>working for over a year (manufacturers, chip makers, etc.) to do 
>this and has so
>far been unable to come up with an acceptable technical solution. 
>The effort is
>on hold at the moment.
> > The radar systems are well known, should be an easy signal to detect.
><jau> They are not so easy to detect. New radar waveforms come into 
>use. Radars
>go on and off-line. Wireless systems can't sit around all day just listening;
>they have real world traffic to handle. Again, the best minds in the industry
>have so far failed to figure out an acceptable solution.
> > The radios already tend to send a LOT of data back and forth, radio name,
> > signal levels, speed, language, channel used etc. etc. etc.  Certainly any
> > radio that turns on could sense for 30 seconds, if it detects a TDWR signal
> > at a certain threshold, then report than back to the AP and the AP could
> > then lock out the needed channels for that particular location.
><jau> You are more than welcome to volunteer to join the wireless "Industry
>Group" engineering team that has been addressing this issue for the 
>last year.
>I'll be happy to introduce you to the team leader so you can sign up to
>contribute your engineering advice.
> > This should be able to be done via a firmware upgrade to any legacy or new
> > hardware out there.
><jau> Well, the manufacturers are not stepping up to develop new 
>firmware. This
>is one of the frustrations that the FCC feels.
> > Cheap, relatively easy, fixes the problem and does NOT take away 110mhz of
> > newly acquired spectrum from the rest of the country.
><jau>I would welcome your help to reach out to and motivate the 
>manufacturers to
>do this. Let me know when you are ready to start your outreach program.
> > A quick note on PR.  The operator(s) there has run foot loose and 
> fancy free
> > with the rules for as long as I can remember.  Perhaps it's time to fine
> > them at a high enough level that it puts them out of business?  Kind of a 3
> > strikes your out thing.
><jau> Yep. Sounds right.
>
>jack
>
> > marlon
> >

  --
  Fred Goldstein    k1io   fgoldstein "at" ionary.com
  ionary Consulting              http://www.ionary.com/
  +1 617 795 2701 



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