Resent with Permission. If you are using 5GHz For your Backhauls or to connect Clients this is very important to read. This will Put a lot of Small Wisps out of business especially if you have a large Rural coverage area.
Gary Phillips STE Wireless Inc Purpose: Call To Action to support WISPA, Cambium, JAB Wireless and Mimosa’s Petitions for Reconsideration – File Comments to the FCC on Petition 13-49 Deadline: August 14th (SEE Bullet Points at the bottom of this email) Subject: <http://apps.fcc.gov/ecfs/document/view?id=7521096518> FCC First Report and Order in the Matter of Revision of Part 15 of the Commission’s Rules to Permit Unlicensed National Information Infrastructure (U-NII_ Devices in the 5 GHz Band (ET Docket No. 13-49) ATTENTION: ALL WISPS, Manufacturers, Integrators THAT USE THE 5725-5850 MHz BAND (Pass this on to school systems, county government and other industry users of this band) This email is a request to all WISPs and other entities that use the 5725-5850 MHz band. On March 31st, the FCC adopted new rules for the 5 GHz bands. While WISPA petitioned successfully to retain unlimited gain antennas, the FCC adopted more stringent out-of-band emission limits by eliminating Section 15.247 rules and placing all new equipment under Section 15.407. Currently, most 5.725-5.850 MHz equipment operates under Section 15.247 rules. In two years, Section 15.247 equipment will no longer be legal to manufacture. Requiring all new equipment to be certified under Section 15.407 has SEVERE ramifications for the WISP Industry. Section 15.407 equipment will be much more expensive (will need expensive additional filters) and will operate on fewer channels (will have to stay away from the band edges). That’s why WISPA is putting out a CALL TO ACTION, to encourage all WISPs and others who use this band to file FCC comments supporting the Petitions of Reconsideration filed by WISPA, Cambium Networks, Mimosa Networks and JAB Wireless. Below are links to the First Report and Order and all of the Petitions for Reconsideration. Please review the seven points that are listed below the links and choose the point (or points) that you feel are the most significant and that have the most impact your WISP operation. Discuss those points in your FCC Comments. <http://apps.fcc.gov/ecfs/document/view?id=7521096518> FCC First Report and Order in the Matter of Revision of Part 15 of the Commission’s Rules to Permit Unlicensed National Information Infrastructure (U-NII_ Devices in the 5 GHz Band (ET Docket No. 13-49) <http://apps.fcc.gov/ecfs/document/view?id=7521161202> Wireless Internet Service Providers Association Petition for Reconsideration <http://apps.fcc.gov/ecfs/document/view?id=7521159860> Cambium Networks, LTD. Petition for Reconsideration <http://apps.fcc.gov/ecfs/document/view?id=7521162209> Mimosa Networks, Inc. Petition for Reconsideration <http://apps.fcc.gov/ecfs/document/view?id=7521159748> JAB Wireless, Inc. On July 21st, Steve Coran, telecommunications counsel for WISPA and Rick Harnish, Executive Director of WISPA met with key staff people for Commissioners Clyburn, Rosenworcel, O’Reilly and Chairman Wheeler. We stressed the importance of reconsidering this change in the rules. We followed these meetings with a meeting with the staff of the Office of Engineering and Technology (OET). We emphasized the following points: 1. We thanked the Commission for preserving unlimited gain antennas in this band 2. We explained how the new restrictions on out-of-band emissions (Section 15.407) would cause severe consequences for the WISP Industry and for many other industries, including Oil/Gas, School Systems, Aggregate Processors, Food Processors, County Governments and many more. 3. We explained how many rural communities only source of Broadband is fed by this “Workhorse” band and would possibly go dark and/or service levels (capacity) would be compromised by the this change in rules, which would affect link distance, useable frequencies and capacity. 4. We also explained how the new rules would cause manufacturers to add filtering to the radios, which would not only cost much more to produce, but would decrease the available spectrum from 125 MHz to 45 MHz due to a 40 MHz filter needed on both ends of the band. 5. We explained that this decrease in useable spectrum would limit the ability for Wisps to use more than two sectors for Point to Multi-Point use and would cause a decrease in potential capacity to the consumers. 6. We explained that the lower power/smaller antenna option to comply with the rules would cause some consumers to entirely lose their service due to distance limitations. We also explained that consumers who have had service for many years, would not understand why they would either lose service or would now have to pay for a new installation (new more expensive radio) which would have less capacity and speed. 7. We explained that many rural communities are fed by long distance PTP links in this band, which would not be possible with these new rules or would cause operators to have to build more towers at approximately $50,000 per tower, in order to retain service to these communities. This would cause undue hardship on the operators and the consumers served by these links. In some cases, the demographics of the communities would prevent the operator from investing in more towers and radios in order to retain service to these communities. We now encourage everyone to file comments supporting all of the above petitions for reconsideration. The FCC and OET encouraged Steve and I to have operators file comments explaining the economic impact of these rule changes, examples of long distance links which would be impossible to make, given the rules changes, and other hardships the new rule will impose upon your business. Please put your comments on your company letterhead. Below are links to file your documents or comments. You can read previous comments at <http://apps.fcc.gov/ecfs/comment_search/paginate?pageSize=100> http://apps.fcc.gov/ecfs/comment_search/paginate?pageSize=100 * <http://apps.fcc.gov/ecfs/upload/begin?filedFrom=E> Submit a Filing Use to upload letter containing your comments (Highly Encouraged) Proceeding No: 13-49 * <http://apps.fcc.gov/ecfs/hotdocket/list> Submit a Filing (Express) – Use for quick comments in text format Proceeding No: 13-49 Start the letter with the following: Marlene H. Dortch, Secretary Federal Communications Commission 445 Twelfth Street, S.W. Washington, D.C. 20554 Re: Revision of Part 15 of the Commission’s Rules to Permit Unlicensed National Information Infrastructure (U-NII) Devices in the 5 GHz Band, ET Docket No. 13-49 Comments in Support of Petition for Reconsideration of WISPA, Cambium, Mimosa Networks and JAB Dear Ms. Dortch, Thank you very much for your attention to this very important matter. We will continue to be engaged on this issue and will report back to the membership with any further requests for action or details. See the Points to Make below: Points to Make ET Docket No. 13-49 Background 1. FCC Order of April 1 preserved unlimited gain antennas for point-to-point use in 5725-5850 MHz band, but eliminated ability of devices to continue to be certified under Section 15.247. After two years, no more Section 15.247 equipment will be sold. All new equipment must be certified under Section 15.407. 2. Petitions for reconsideration filed on June 2, 2014 by WISPA, Cambium Networks, Mimosa Networks and JAB Wireless a. almost all WISPs (and other industries as well) use Section 15.247 equipment in this band for long-distance point-to-point backhaul and most also use the band for point-to-multipoint communications (that includes a point-to-point uplink) to deliver broadband to distant end-users in rural areas i. other backhaul technologies not available or not affordable ii. only unlicensed band that allows unlimited gain antennas for point-to-point use b. all petitioners expressed similar concerns about effect of FCC rule change requiring equipment to be certified under the more restrictive out-of-band emission (OOBE) requirements of Section 15.407 Points to Emphasize 1. FCC underestimated what the impact of allowing only tight OOBE equipment would be on device performance and cost and how that would negatively affect the ability of rural Americans to receive broadband [and VoIP] service a. two ways to comply with tighter OOBE requirements, both are unacceptable: i. reducing transmit power or antenna gain which drastically reduces link distance [Cambium and JAB presented report that showed 65% loss] ii. incorporating new filtering adds $300 to price of a $249 radio, and also reduces useable portion of band from 125 MHz to 45 MHz 1. allows only two 20-MHz sectors instead of four in a typical configuration b. to compensate, WISPs would need to add significantly more infrastructure at great cost in areas where towers may not be available c. on existing towers, the number of available channels (sectors) that could be co-located would be significantly reduced while simultaneously, the distance and the number of customers that each sector could cover would be substantially less. d. PROVIDE SPECIFIC COST INFORMATION – equipment, tower lease fees, lost income 1. There is no evidence of interference to TDWRs or to any other service ever being caused by OOBE from legally operating Section 15.247 equipment b. TDWR facilities are at least 75 MHz away therefore they were never affected by OOBE from Section 15.247 equipment. c. FCC’s new security software rules should address interference problems that might arise from illegal use of equipment. d. LIMITING OUT-OF-BAND EMISSIONS WILL NOT ALLEVIATE A PROBLEM CAUSED BY SECTION 15.247 OR SECTION 15.407 EQUIPMENT BEING ILLEGALLY MODIFIED TO OPERATE IN A FREQUENCY RANGE (USUALLY 5600-5650 MHZ) WHERE IT HAS NOT BEEN CERTIFIED BOTTOM LINE: Eliminating the flexibility to allow devices to continue to be certified under Section 15.247 was entirely unnecessary and will significantly harm ability of many rural WISP customers to continue to receive broadband and voice services <http://www.wispapalooza.net/> Join us at WISPAPALOOZA 2014 in Las Vegas, Oct. 11th – 18th Respectfully, Rick Harnish Executive Director WISPA 260-622-5699 Cell 866-317-2851 Ext. 101 WISPA Office 260-622-5774 Direct Line Skype: rick.harnish. <mailto:[email protected]> [email protected] <mailto:[email protected]> [email protected] (Rick and Trina) -------------- next part -------------- An HTML attachment was scrubbed... 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