"For fixed point to-point transmitters that employ a directional antenna 
gain greater than 23 dBi, a 1 dB reduction in maximum conducted output 
power and maximum power spectral density is required for each 1 dB of 
antenna gain in excess of 23 dBi”

What is the assumed transmitter power? 30dBm?

On Apr 15, 2014, at 3:55 PM, Fred Goldstein <fgoldst...@ionary.com> wrote:

> On 4/15/2014 5:13 PM, Tom DeReggi wrote:
>>  Excellent Summry. Can you clarify.....
>> 
>>  In previous ISM/UNII 5.750-5.850Ghz, the 2 to1 rule was allowed similar to
>>  2.4Ghz, so that 5.8GHZ CPEs in Point-to-MultiPpoint systems could transmit
>>  at PTP EIRP (higher than the AP 36db EIRP limit) as long as it was
>> increased
>>  via antenna gain.  Does that still apply for the new  UNII   5.750-5.850Ghz
>>  rules?
> 
> Under the old "ISM" rules for 5725-5850, there was no EIRP limit for 
> point to point:
> 
> (ii) Systems operating in the 5725-5850 MHz band that are used
>    exclusively for fixed, point-to-point operations may employ
>    transmitting antennas with directional gain greater than 6 dBi without
>    any corresponding reduction in transmitter conducted output power.
> 
> Under the ISM rules for 2400-2483.5 MHz, there is a 1 for 3 rule, so you 
> can keep 2/3 of the EIRP above +36 that comes from antenna gain:
> 
> (i) Systems operating in the 2400-2483.5 MHz band that are used
>    exclusively for fixed, point-to-point operations may employ
>    transmitting antennas with directional gain greater than 6 dBi provided
>    the maximum conducted output power of the intentional radiator is
>    reduced by 1 dB for every 3 dB that the directional gain of the antenna
>    exceeds 6 dBi.
> 
> 
> Under the old U-NII rules for 5725-5825, there was an EIRP limit on 
> point to point that was higher than the +36 dBm limit for point to 
> multipoint.
> 
> For fixed, point-to-point U-NII transmitters
>    that employ a directional antenna gain greater than 23 dBi, a 1 dB
>    reduction in peak transmitter power and peak power spectral density for
>    each 1 dB of antenna gain in excess of 23 dBi would be required.
> 
> So the old EIRP point to point limit under U-NII was +53 dBm.  The FCC 
> proposed making that the new unified rule, but -- WISPA and members to 
> the rescue! -- ended up adopting the ISM "no EIRP limit" instead.  Get 
> those Rocket dishes out... but only above 5725.
> 
> 
> (BTW, "ISM" refers to Part 18 RF heaters.  15.247 is the unlicensed 
> intentional radiators using bands where ISM is the primary user of the 
> frequency, hence the nickname.)
> 
>>  I saw that you inferred that that was not likely allowed for the new
>> outdoor
>>  use of Unii 5.1 Ghz.
> 
> Correct.  The 5150-5250 U-NII-1 segment inherits the old U-NII-3 rule 
> that everybody got around via the ISM rule (boy is that confusing), 
> capping EIRP at +53.  The new 5150-5250 fixed rule:
> 
> For fixed point to-point transmitters that employ a directional antenna 
> gain greater than 23 dBi, a 1 dB reduction in maximum conducted output 
> power and maximum power spectral density is required for each 1 dB of 
> antenna gain in excess of 23 dBi.
> 
>> 
>>> ----- Original Message -----
>>> From: "Fred Goldstein" <fgoldst...@ionary.com>
>>> To: "WISPA General List" <wireless@wispa.org>
>>> Sent: Friday, April 04, 2014 12:25 PM
>>> Subject: [Spam] [WISPA] New FCC rules for 5 GHz bands
>>> 
>>> 
>>>> 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
> 
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