Regulatory AlertHi All,
I thought that the DFS requirement on 5.3 gig gear was only for new
equipment certification. Turns out that even existing product lines when
sold as new have to be modified. Example: You have a 3 year old Trango or
Motorola 5.3 gig system and you want to add a new customer. The new radio
will have to have DFS capabilites or they can't make/sell it to you, even
though it's the same hardware as the device certified 3 years ago.
This comes from an html exchange with Rashmi Doshi. He's with the FCC and
in charge of such things rules etc. I've put rd: in front of his comments.
laters,
marlon
----- Original Message -----
From: Rashmi Doshi
To: Marlon K. Schafer ; [EMAIL PROTECTED]
Cc: Julius Knapp ; Bruce Romano
Sent: Tuesday, July 03, 2007 3:01 PM
Subject: RE: Regulatory Alert
Marlon:
rd: I see you are keeping us on our toes!
rd: Some answers to your questions:
Just to make sure I'm perfectly clear on this. A product, that was
certified under the old rules, can no longer be sold under those rules in
the USA?
rd: It is correct that if the product was certified under the old rules, it
cannot be sold unless it was upgraded to include the DFS and TPC
requirements.
Any new gear, not just new certifications, has to meet the new rules as of
July 20th of this year. No grandfather clause is in place for product lines
we're already using?????? I know we can still use them, but we have to also
be able to buy new radios and replace bad units.
rd: Yes all the new gear has to meet these requirements. This transition
actually started last year, so your manufacturers should have been informing
you since July 20, 2006 of their plans for migration. We have allowed
options for repairing bad units. However, these must be controlled by the
manufacturers and not be made freely available. In general if the bad units
are shipped and the manufacturer replaces with a like unit this is typically
allowed in the US.
As I read this, I'd not, after July 20, 2007, be able to buy the same radios
I use in parts of my network today. I'll, instead, have to change to
whatever the new replacement product line will be and either replace all
customer gear or run two parallel networks, one old and dying due to lack of
replacement parts, and one new one. Even though the "old" network is only
months old. Is this correct?
rd: The situation will depend on the approach the manufacturer takes in
handling the situation. This transition has been in the rules for the last
3 years, so it should not be any surprise to anyone. In fact, all the
products or changes to products in this band were required to implement the
new requirements starting last year. A number of manufacturers have been
able to upgrade their products through software changes to meet the new
requirements. In those cases they can sell the new units as upgraded to
meet the requirements. In some cases they have chosen to remove the
operation in the impacted band. I understand some people are able to run
"hybrid" networks.
rd: I hope these answers your questions. Have a happy 4th of July!
rd: Rashmi Doshi
From: Marlon K. Schafer [mailto:[EMAIL PROTECTED]
Sent: Tuesday, July 03, 2007 11:32 AM
To: Rashmi Doshi; [EMAIL PROTECTED]
Cc: Julius Knapp; Bruce Romano
Subject: Re: Regulatory Alert
Hiya Rashmi!
How the heck are you these days! Long time no talk.
Just to make sure I'm perfectly clear on this. A product, that was
certified under the old rules, can no longer be sold under those rules in
the USA? Any new gear, not just new certifications, has to meet the new
rules as of July 20th of this year. No grandfather clause is in place for
product lines we're already using?????? I know we can still use them, but
we have to also be able to buy new radios and replace bad units.
As I read this, I'd not, after July 20, 2007, be able to buy the same radios
I use in parts of my network today. I'll, instead, have to change to
whatever the new replacement product line will be and either replace all
customer gear or run two parallel networks, one old and dying due to lack of
replacement parts, and one new one. Even though the "old" network is only
months old. Is this correct?
Thank you and have a great 4th of July!
marlon
----- Original Message -----
From: Rashmi Doshi
To: [EMAIL PROTECTED] ; [EMAIL PROTECTED]
Cc: Julius Knapp ; Bruce Romano
Sent: Monday, July 02, 2007 2:53 PM
Subject: FW: Regulatory Alert
Marlon:
Your inquiry was forwarded to me to reply.
The information in the notice included in your email is correct. According
to section 15.37 (l) of our rules, "UNII equipment operating in the 5.25 -
5.35 GHz band that are imported or marketed on or after July 20, 2007 shall
comply with the DFS and TPC requirements section 15.407." Thus, if the
Trango products listed in the email do not meet the appropriate DFS and TPC
requirements, they cannot be marketed, distributed or sold after that date
for operation in the 5.25 - 5.35 GHz band.
I hope this clarifies the requirement.
Thanks,
Rashmi Doshi, PhD
Chief, FCC Laboratory Division
From: Marlon K. Schafer [mailto:]
Sent: Fri 6/29/2007 6:15 PM
To: John Seaman
Cc: Robert Cannon; Julius Knapp
Subject: Re: Regulatory Alert
John,
Please double-check this. I think the rule only applies to NEW product
offerings. Pulling your 5.3 gig products off the shelf should NOT be
needed. We'd certainly not appreciate the move as we have some 5.3 gig gear
out there and need the ability to add new customers when the need arises.
Bob or Julie, can either of you shed any light on this?
thanks!
marlon
----- Original Message -----
From: John Seaman
To: [EMAIL PROTECTED]
Sent: Thursday, June 28, 2007 4:51 PM
Subject: Regulatory Alert
Dear Marlon ,
We wanted to let you know that a new FCC regulation is going into effect
July 20, 2007 that will affect operators' ability to deploy wireless
equipment in the United States in the UNII band. As a result of this
regulatory change, several Trango products are affected.
The new FCC regulation impacts the sale of wireless equipment operating in
the 5.25-5.35 GHz band. On July 20, 2007 only products that support radar
detection as specified by the FCC in the 5.25-5.35 GHz band can be imported
or marketed. Per our understanding, 5.3 GHz units which were purchased
prior to July 20, 2007 can still be deployed and previously deployed
networks that utilize 5.3 GHz are grandfathered in and do not require DFS
upgrades after the FCC deadline. The following document on the FCC website
describes the rules and has additional links:
http://www.fcc.gov/oet/ea/presentations/files/oct06/Oct_06-DFS_Equipment_Authorization-AL.pdf
To comply with the FCC regulation, after July 20, 2007 Trango Broadband
Wireless will no longer sell wireless systems in the United States which
operate in the 5.25-5.35 GHz bands unless the system employs Dynamic
Frequency Selection (DFS) and Transmit Power Control (TPC). Trango is
working on new products which employ DFS/TPC and will begin shipping these
systems once FCC approval is obtained.
Beginning July 20, 2007, the following Trango Broadband products will still
be available but will only support operation in the 5.725 to 5.85 GHz ISM
Band:
M5830S-AP
M5830S-AP-EXT
M5830S-SU
M5830S-SU-EXT
Atlas5010-INT
Atlas5010-EXT
TLINK-10
TLINK-10-EXT
This change will be implemented through new firmware which will be
pre-loaded on all units (listed above) shipping from Trango starting on July
20. The new firmware will not allow the operator to select a band of
operation in the 5.3 GHz band.
The M5300S-FSU (5.3 GHz FOX SU) does not support 5.8 GHz operation and will
not be shipping within the United States beginning July 20, 2007. We have
M5300S-FSU units in stock and ready to ship if you are interested in beating
the July 20th deadline. However, supply is limited and stock will be
allocated on a first-come-first-serve basis.
The new TrangoLINK-45 is a 45 Mbps multi-band point-to-point bridge which
employs DFS for legal operation in the 5.3 and 5.4 GHz bands (as well as 5.8
GHz). This product is currently undergoing FCC certification and will be
available for shipment in the United States as soon as FCC approval is
obtained. Availability date for a DFS-enabled point-to-multipoint system
will be announced at a later date.
If you have any questions or concerns about this regulatory change, please
feel free to contact any of the Trango sales or support representatives.
Please see http://www.trangobroadband.com/howtobuy/domestic_sales.shtml for
complete contact information.
Thanks and best regards,
John Seaman
Sales Director
Trango Broadband Wireless
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