On 4/15/2014 6:39 PM, Tom DeReggi wrote: > Fred, > > Ok, so in summary.... > > A WISP Internet Provider is an "Information Service" and does not collect or > charge USF. And that end-to-end Internet Information Service solution is > composed of 3 In-line components, working togeather as one..... > > 1. Wireless last mile (provider me) > 2. Fiber-based Metro IP transport (provider A) > 3. IP transit (provider B) > > And the sole purpose and use of the Metro-IP Transport link is to deliver > "information Services" to the End User, as a part of the solution..
Information Services are the higher layer payload of telecommunications. When the telecommunications itself is provided as a service, it's a telecommunications service. And that's subject to USF. That you are using it to deliver an information service is none of their business. Be thankful, when you think about it. > So, you are saying..... Under that Circumstance, the Metro IP tranport layer > can not be claimed as a "wholesale Component" of an "Information Service", > and WISPs must consider themselves an End User of telecommunications > Services, and be subject to USF and Taxation on that circuit, because > Metro-IP Data services are considered Telecommunications services, > regardless of how they might be used. There is no "wholesale component" rule. The "telecommunications component" of a vertically-integrated information service is no longer subject to USF. > > Tom DeReggi > RapidDSL & Wireless, Inc > IntAirNet- Fixed Wireless Broadband > > > ----- Original Message ----- > From: "Fred Goldstein" <fgoldst...@ionary.com> > To: <wireless@wispa.org> > Sent: Tuesday, April 15, 2014 5:55 PM > Subject: [Spam] Re: [WISPA] New FCC rules for 5 GHz bands > > >> 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 >> >> _______________________________________________ >> Wireless mailing list >> Wireless@wispa.org >> http://lists.wispa.org/mailman/listinfo/wireless > _______________________________________________ > Wireless mailing list > Wireless@wispa.org > http://lists.wispa.org/mailman/listinfo/wireless > -- 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
