Thank you for the nice summary, Fred!!!
Josh Luthman Office: 937-552-2340 Direct: 937-552-2343 1100 Wayne St Suite 1337 Troy, OH 45373 On Fri, Apr 4, 2014 at 12:25 PM, Fred Goldstein <fgoldst...@ionary.com>wrote: > On Monday, the FCC formally adopted a First Report and Order (FCC 14-30) > in ET Docket 13-49, revision of Part 15 U-NII rules. The actual R&O > text was released later in the week. For the most part, it came out > well for WISPs. Some rules have been tightened to reduce the chance of > interference to radar, especially TDWR, but more spectrum has been > opened to outdoor use. Note that this was not the final word on 13-49. > It focused on the U-NII-1 band (5150-5250) and U-NII-3 band > (5725-5825). The proposed new U-NII-2B and U-NII-4 bands were not > addressed. Those are more controversial and await a later R&O. > > Key changes that were announced: > > The 5725-5850 ISM band (Rules Part 15.247) was essentially merged with > U-NII-3 (15.407). The upper band edge of U-NII-3 was moved from 5825 to > 5850 to match ISM. Wideband digital operation was removed from ISM, > limiting 15.247 operation on that band to frequency hopping spread > spectrum (narrowband) and the FH portion of hybrid devices. As of one > year after publication in the Federal Register, no new 15.247 wideband > devices will be type-approved for that band, and sale and importation > must stop in two years. Existing devices may continue to be used. > > The WISP community did dodge a bullet here, as the new U-NII-3 rules are > closer to the ISM rules than to the old U-NII rules. In particular, the > proposal to limit EIRP of fixed point-to-point links to +53 dBm, the old > U-NII-3 limit which did not apply to ISM, was not adopted. Fixed > point-to-point U-NII-3 operation can still have unlimited antenna gain > with 1 watt transmitter power. Some of the credit goes to WISPA, who is > acknowledged in the Order. (Cambium too, while its former parent > Motorola Solutions was on the wrong side.) Power spectral density rules > were also modified to a favorable outcome. The old U-NII-3 rules > required 20 MHz bandwidth for full power. The new rules are closer to > ISM's, requiring a minimum 6 dB bandwidth of only 500 kHz for full > power. Point to multipoint EIRP is still capped at +36 dBm. So there > is little lost in the new rules, although the new type approval > procedures will be just a bit harder than the old ones. > > The second major area of change was the U-NII-1 band, 5150-5250. This > had been limited to indoor only use with a +17 dBm power limit. > Globalstar, the low-earth-orbit satellite, is the primary user here, > using it for backhaul (not handset) uplinks, and while LEOsats in > general did not catch on as the FCC had expected when the old rule was > written in 1997, Globalstar did not want its background noise level to > be impacted. A deal was worked out that is still pretty good. > > Under the new rules, outdoor operation is now allowed, and the rules > there are based on the old U-NII-3 rules. So the power limit is 1 watt, > and access points may have up to 6 dB gain without lowering power (i.e., > a +36 dBm EIRP cap). Point-to-point links may have up to 23 dB gain > without lowering power (i.e., a +53 dBm EIRP cap). "Mobile and portable > client devices" in that band are capped at 250 mW (+24) with 6 dB gain > (i.e., a +30 dBm EIRP cap). There is no explicit rule for fixed client > devices, like WISP CPE, so it appears to be treated as portable, as the > definition of "fixed, point-to-point" explicitly excludes > "point-to-multipoint systems". This could be rather limiting and might > merit a little ex parte discussion with the Friendly Candy Company. The > rule was written with WiFi access points (is CableWiFi messing up the > spectrum in your neighborhood too?) in mind. > > In order to protect Globalstar, outdoor U-NII-1 access points have to be > sure their EIRP more than 30 degrees above the horizon does not exceed > +21 dBm. This seems pretty easy, unless say you're doing a steep > point-to-point shot upwards at a skycraper. Another rule requires > operators who install more than 1000 outdoor U-NII-1 APs to notify (by > letter) the FCC and acknowledge that they will take corrective action if > it does interfere with licensed users. So the average WISP won't be > affected but big cable-style or city-wide deployments could have to notify. > > Minor changes were made for U-NII-2 (5250-5350 and 5470-5725), were DFS > is required. The radar test procedures were slightly changed. A very > useful rule change is that DFS hopping no longer has to be uniform. The > radio can operate on a selected first-choice frequency until it detects > radar, and then hop to a selected alternative, etc. So band planning is > now legally possible on the DFS bands. Note that proposals to create a > geographic database for U-NII frequencies (like TVWS), as an alternative > to radar sensing, were rejected. > > Type approval for all U-NII equipment now requires that it be locked to > US specifications, so that users can't just turn off DFS or operate > outside of authorized frequencies. Manufacturers can choose the method > for enforcing how only approved software upgrades can be installed. > Certain upgrades of existing gear will be permitted for two years > without meeting all of the new rules, but not afterwards. > > So it seems to me that UBNT and Cambium gear should be all good to go on > the new frequencies pretty quickly, as they are U-NII approved. I don't > think MikroTik is (it's apparently ISM, not DFS approved here, unless > they've recently gotten it), so their radios will need new approval, and > the more restrictive software, in order to stay on sale here after two > years, let alone operate on the newly-authorized outdoor frequencies. > > All told the rules are a positive outcome. Congratulations to everyone > who helped influence the FCC. > > -- > Fred R. Goldstein k1io fred "at" interisle.net > Interisle Consulting Group > +1 617 795 2701 > > _______________________________________________ > Wireless mailing list > Wireless@wispa.org > http://lists.wispa.org/mailman/listinfo/wireless >
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