To File your Comments to reverse the FCC March Rule Making on Proceeding 13-49
The law to change 5.725 GHz to 5.85 GHz emission levels is already in force!
WISPA, Cambium Networks, Mimosa and JAB Wireless have filed
Petitions for Reconsideration on behalf of the WISP Industry to reverse this ruling
and convince the FCC that this rule change is a grave mistake!
As a WISP using this frequency, it is your obligation to your business, your family, your employees and your customers to put down your harnesses and write a letter to the FCC before August 14th
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.
If you don’t think it will impact your business, take the 5 GHz Survey
It will change your mind!
Read other WISP Comments and the Petitions for Reconsideration
Enter Proceeding Number 13-49
Write a letter to the FCC, preferably on your company letterhead
Use economic impact estimates from numbers you entered in the survey
Mention the “Trickle Down Effects” it may have on your community, it’s businesses, schools and consumers. See important bullet points below.
Upload your letter to the FCC website by August 14th
Enter Proceeding Number 13-49
Encourage all other WISPs and other users of the band to do the same
May the Force be With US!
Steve Coran and I met with staffs of 4 of the 5 FCC Commissioners on July 21st. These are points we made:
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.
Points to Make
ET Docket No. 13-49
- 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.
- Petitions for reconsideration filed on June 2, 2014 by WISPA, Cambium Networks, Mimosa Networks and JAB Wireless
- 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
- 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
- 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
- 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 allows only two 20-MHz sectors instead of four in a typical configuration
- to compensate, WISPs would need to add significantly more infrastructure at great cost in areas where towers may not be available
- 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.
- PROVIDE SPECIFIC COST INFORMATION – equipment, tower lease fees, lost income
- 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
- TDWR facilities are at least 75 MHz away therefore they were never affected by OOBE from Section 15.247 equipment.
- FCC’s new security software rules should address interference problems that might arise from illegal use of equipment.
- 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
Join us at WISPAPALOOZA 2014 in Las Vegas, Oct. 11th – 18th
866-317-2851 Ext. 101 WISPA Office
260-622-5774 Direct Line
rharnish <at> wispa.org
admins <at> wispa.org (Rick and Trina)