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pozar
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FCC compliance in the field

The FCC is currently becoming more active on deployments that are not complying with Part 15 of the R&R. This month they posted this Q&A ...

https://apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?id=39498&switch=P

that focuses on software changes that can bring devices out of compliance. For instance, running outside of the Part 15 bands or at more than power level that would be allowed. (I have a slightly dated paper on power levels that can be seen at http://www.lns.com/papers/part15/)

How is UBNT going to react to this increased awareness of the FCC's concern about devices that can be modified in the field so that they can be operated outside of the FCC's R&R?

Tim
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pozar
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Re: FCC compliance in the field

BTW... An example of the FCC going after a particular WISP can be seen in this Notice of Apparent Liability ...
http://www.fcc.gov/Daily_Releases/Daily_Business/2011/db0211/DA-11-273A1.pdf
Seems that Utah Broadband in Salt Lake City has been fined $25,000 "for apparently willfully and repeatedly violating sections 301 and 302(b) of the Act, and sections 15.1(b) and 15.1(c) of the Rules." with a Ubiquiti XtremeRange5 radio in turning of DFS, operating outside of Part 15 frequencies and running beyond the power limits imposed by Part 15.
Tim
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Re: FCC compliance in the field

"for apparently willfully and repeatedly violating sections 301 and 302(b) of the Act, (...)


says it all
it was misconfigured, they've been warned, and they failed to fix it...
sounds like how it should be
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Re: FCC compliance in the field

That pretty much does say it all. Well above the max EIRP and on illegal channels near an airport, you're just asking for it.
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Re: FCC compliance in the field

Wow! These guys are apparently fairly
inept. Not only were they cited for
disabling DFS (near an active airport),
but they were cited for choosing illegal
frequencies to avoid the radar after
they were told to change them.

And even after the FCC had found the
site, they continued to use high-gain
antennas apparently over EIRP.

How bad is that? Dave
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Re: FCC compliance in the field


How is UBNT going to react to this increased awareness of the FCC's concern about devices that can be modified in the field so that they can be operated outside of the FCC's R&R?
Three things here....

FIRST.................
With one exception I know of, all the WISPs that have been found in violation was because:
1) There were interfering with TDWR - (Airport) Terminal Doppler Weather Radar. When the FAA starts seeing weird wagon wheel spokes on the radar screen, they know its co-channel interference.

2) The FCC locates the emitters, takes reading, and comes back a day later. If the interference is still there, the FCC assumes it was not a "work-in-progress" turning up the radios for the first time, rather a continuous operation - thus the "willful" and "repeated" part of the judgment.

3) As the radios are not certified for operation in UNII-1 and UNII-2 (both upper and lower) - thus the radios were "operating outside of the authorized frequency" and "operating a radio not certified" for operation on those frequencies.

4) The radios were exceeding the allowed EIRP and allowed antenna gain.

All of those issues could have been avoided if the radios were professionally installed, where the FCC recognizes "professional" as an install should know what it and isn't legal.

BTW that one exception was a WISP running third-party coax that the radio wasn't certified for, but that's a moot point now as you are now allowed to use third-party coax and antennas.

So what is UBNT going to do about it? Nothing...it's not their problem.

SECOND.................
5.8 Gig UBNT radios are only certified for UNII-3 operation. What can UBNT do about this? Nothing at the moment. The freeze on deploying UNII-1 and UNII-2 gear has been in effect for several years, waiting for the FCC to begin discussing decide how to write new rules. A few months ago, that discussion is now proceeding and the next step is to come up with the rules, and after that its now in the radio manufactures' hand. So UBNT is in a holding pattern for now.

THIRD.................
The FCC is aggressively pushing the dis-allowance of radios that can be configured to operate outside of the U.S. frequencies. Not even the U.S. installer is supposed to have access to the non-U.S. country code setting. How will UBNT deal with this? Hard to say. You could install a GPS receiver on *every radio* to insure it's can operate under U.S. law. Any other approach would have too many loop-holes and too many unintended results.
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Re: FCC compliance in the field

Wow! These guys are apparently fairly
inept. Not only were they cited for
disabling DFS (near an active airport),
but they were cited for choosing illegal
frequencies to avoid the radar after
they were told to change them.

And even after the FCC had found the
site, they continued to use high-gain
antennas apparently over EIRP.

How bad is that? Dave


vary vary bad... "say like elmer fudd"
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Re: FCC compliance in the field

Seems like the FCC steps in only when your bothering another user on that spectrum. They're not going to go out "looking" for people misbehaving. And to add to the fact, if your given a WARNING first, why not take it and fix it? Must be hell of a lot cheaper than $25,000.

There is also a list of Airports using that part of the 5Ghz spectrum, there isn't many in the US. It's not like "every" airport is using it.
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pozar
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Re: FCC compliance in the field

I may have not made my orginal post very clear. There are two issues here in my post.
1] The problem with Part 15 devices being installed so they operate outside of Part 15. (Operator is responsible)
2] The issue that equipment as marketed and sold in the US has the ablity to be easily configured and operated outside of Part 15 regulations. (Manufacture is responsible)
Item 1 should be of less concern to UBNT as item 2. With Part 15, the FCC tried to put more of the responsiblity of the operation of these devices on the manufacture, hence, no license, certification and the restriction of what can be marketed and sold in the US. Rumors I am hearing from the direction of the FCC is they will, in the future, require manufactures to disable the ablity to operate devices outside of Part 15 requirements. This would be a part of the certification requirements. The FCC may grandfather currently certified devices.
It would be interesting to see comments from UBNT on what they see coming down the road in this matter and how they will react to it.
Regarding the fact that devices can be installed to operate outside of Part 15 such as mixing and matching antennas and radios, the FCC has restricted this and frankly I am still amazed that the FCC has not put their foot down on this more on the individual sale of antennas seperate from radios. Radios and antennas are to be certified as a package.
I also find it a bit strange that UBNT can have a little check box on a web page for the device that says you are complying with the local regulations when the radio has no idea what kind of antenna or deployment (point-to-point vs. point-to-multipoint) you are doing. In each case there are different EIRP requirments.
My guess is that a high percentage of the outdoor deployments exceed what is restricted to for EIRP as many folks just deploy and don't even calculate what the TPO should be.
Tim
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pozar
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Re: FCC compliance in the field

The FCC has really no resources in pro-active inspections. I have been a broadcast engineer from th 70s through the 90s. In the early part of that period, I would get an inspection about every two or three years. This just doesn't happen now. They only time the FCC goes out is in response to a public safety or FAA request.
These guys were not the smartest cookies in operating they way the NOL describes. I am surprised the FCC didn't bump up this fine even more for interfering with the FAA facility. You really have to be this bad to have the FCC come calling. Of course, this isn't to say you shouldn't be following the rules. On top of the fine, you really don't want your operation taken down by the FCC ordering you. This could affect your bottom line as well.
Tim
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Re: FCC compliance in the field

This is the tip of two icebergs.

One is the ability of anybody to make
radio settings that put it out of
compliance for any specific country.
I feel sure Ubiquiti is scrambling to
find a strategy for this before there
is an FCC cease-and-desist order.

The second is Part 15 'intentional
radiators'. This relies on voluntary
compliance, because the FCC has
no way to police this much equipment.
That requires some level of knowledge
and also an interest in complying.

If the FCC can't depend on proper
installation or even good intentions,
they are in a bind; do they just give
up, or do they make this a licensed
band (for higher-powered equipment)?

If the FCC is very lucky, scare tactics
like big fines may improve compliance.
But those 'hobbyists' may not care. Dave
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Re: FCC compliance in the field

See: ubnt.com/forum/showthread.php?t=29613

Anyone else see FCC KDB #594280?

apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?id=39498&switch=P


Where I ran across this was following up on the post about the WISP that was fined (XR5 running in 5.6GHz affecting RADAR). Seems a logical part of the FCC 'stepping it up a notch' to keep everyone in line. If only the factory controls certain configuration parameters... in theory then certain bad behaviors won't be available 'out of the box' (not that anyone would ever figure out what the 'other' country codes are and use them innapropriately).


Sorry, it's been a long day... when I say 'logical' I mean in a government sense... it seems like the next step they would take. Not that it is the best step: just the next step in the progression.

I was wondering the same thing about Linux when I read it. What the heck do you do with all the WRT variants? Again, your right on with that... there should be some heads knocked together on the enforcement. If it takes some $25K fines to do it then go for it - and get ANYONE who violates the rules ('govt included).


As with many things the government touches it will most likely be done in a fashion that will inconvenience the majority of law abiding folks because of the incompetent actions of a few. That just my cynical (or is that experienced?) side talking.

For example, the radios will have to be locked down in a way that the 'compliance mode' and other country codes won't be on the menu... one method being some sort of 'product activation code' that is country specific. A big question at that point still being what to do with all of the Linux distros - make them illegal?

As for the $25K fine, make it bigger, get some attention drawn - wake some people up. There are many radars, they are public record - and they are safety critical. As a citizen I expect some enforcement when safety is involved.

Dave is right on with this one - something must be done before a cease-and-desist hits.
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Re: FCC compliance in the field

Radios and antennas are to be certified as a package.
No way...We fought tooth and nail to get that restriction removed.
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Re: FCC compliance in the field

Dave is right on with this one - something must be done before a cease-and-desist hits.

The way it looks to me is that the system is working pretty well the way it is. We have one case of some dip-schitt who was interfering with Radar with his illegal configuration. That problem was remedied by the FCC because there was an impact from the illegal activity.

Next time some asshole interferes with Radar the FCC will be even better able to handle the situation because of the experience they have with this one jackass.

Meanwhile the other 8.9 million law abiding citizens across the face of the globe can continue to enjoy the benefits of testing the hardware to determine the most effective legal configurations for our communications needs.

No new laws or restrictions are needed. The existing laws and restrictions were easily able to solve the problem with this one single jackass who could not pay attention.
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Re: FCC compliance in the field

'full power' you may not have read
the FCC post. It says very clearly
that a radio may not have a feature
like a country selection that would
allow it to operate illegally. This
amounts to an 'existing law'.

If Ubiquiti does not comply, that
means the FCC could order a halt
to distribution. If it does comply,
that means it will have vastly
more complex distribution issues. Dave
No disclaimer. Nothing to sell. I need to fix that.
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Re: FCC compliance in the field

Why does it need to be vastly different?
Register an account online. Enter your country of operation and radio serial number. Get back an unlock key.
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Re: FCC compliance in the field

'full power' you may not have read
the FCC post.

No, I had not.

Edit - I'm gonna have to change my screen name to "Holi Stoli".
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Re: FCC compliance in the field


Register an account online. Enter your country of operation and radio serial number. Get back an unlock key.
k
All that means is "some dip-schitt" is going to say he's in Argentina to get an unlock code for U.S. operation.
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Re: FCC compliance in the field

We really need to see Ubiquiti get certified for the WorldWide Band
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Re: FCC compliance in the field

All that means is "some dip-schitt" is going to say he's in Argentina to get an unlock code for U.S. operation.

More then likely UBNT will be forced to preset the country code on units sold in the US. Then unless you know how to change it you are stuck with it. Just like the mac address, UBNT knows the commands in the telnet shell to permanently change the mac address and many other things,you just need to know the commands. And I guarantee you they will not give them to you!
Most equipment comes this way. I used to work pretty close with ZCOM who made a lot of the OEM gear for Tranzeo, Netgear, and a list of other companies and I knew how to change the code via telnet or console, but the commands to do that was very restricted as to who knew them. Tranzeo or Netgear did not even know them to my knowledge. I could also use commands to change the mac address and several other characteristics of the radio like max Tx power.
I also have the hidden commands to change the max Tx power and a slew of other things on the Proxim CX-1 and EX-1 radios. DO NOT ASK ME BECAUSE I WILL NOT TELL YOU.

Well, I would tell you how to change the mac address but not the max Tx or anything that would effect the gears legality.
If I had to guess this is what they will do.
And those sub routines/commands will not be in the SDK or they will be pre-compiled like the driver portion (required by Atheros) and if the modules are not present when compiled in will not work.
I would assume when they release the next version of firmware it will look at the country code and automatically hard code it in, if it is set to compliance it will assume US or go to a mode that requires a code from UBNT to set it in and function.
Wait and see, I will bet you this is how it will go down!
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