[FCC] RE : NON-SEQUITUR

Christopher Waid chris at thinkpenguin.com
Wed Sep 9 22:01:03 PDT 2015


On 2015-09-10 12:38 AM, L. D. Pinney wrote:
> Well Mr. Waid You seem to have time to waste reading and posting here
> :)

Excuse me? I've been working at this campaign non-stop for over a month 
now. I've got dozens of reporters, radio shows, and other publicity 
outlets to talk to all while trying to run a company during the day. 
There are all of a small handful of people who are *really* helping with 
this campaign. I can't even see straight at this point. I think I'm 
going to call it quits for tonight.

> 
>                                                                     DA
> 12-459
> 
>                                                            September
> 27, 2012
> 
>                                              Enforcement Advisory No.
> 2012-07
> 
>                              TDWR and U-NII DEVICES
> 
>            Enforcement Bureau Takes Action to Prevent Interference to
> 
>      FAA-Operated Terminal Doppler Weather Radars Critical to Flight
> Safety
> 
>    The Enforcement Bureau recently took action against several
> companies for
>    operating devices that caused interference to Terminal Doppler
> Weather
>    Radars (TDWRs) maintained by the Federal Aviation Administration
> (FAA).
>    TDWR systems operating in the 5600-5650 MHz band are used by the
> FAA to
>    obtain quantitative measurements for gust fronts, wind shear,
> microbursts,
>    and similar information.
> 
>    Investigations conducted by the FCC, the FAA, and the National
>    Telecommunications and Information Administration (NTIA) in several
> areas
>    of the United States and Puerto Rico revealed that much of the
>    interference stems from wireless devices sharing the same band as
> TDWR
>    systems, and operating outdoors in the vicinity of airports at high
>    elevations that are line-of-sight to the TDWR installations and
> most are
>    operating inconsistent with the FCC Part 15 Rules. The Enforcement
> Bureau
>    and the FAA continue to investigate additional areas where
> interference is
>    reported to TDWR systems, and will continue to take appropriate
>    enforcement action as necessary.
> 
>    What do the rules require?
> 
>    Manufacturers, marketers, and users of U-NII devices are hereby
> cautioned
>    that only devices certified under FCC Part 15, Subpart E of the
> Rules may
>    be operated as U-NII devices. For those U-NII devices operating as
> a
>    master device in the 5.25 GHz - 5.35 GHz and 5.47 GHz - 5.725 GHz
> bands, a
>    Dynamic Frequency Selection (DFS) radar detection mechanism must be
>    enabled. A piece of equipment is no longer certified as required
> under the
>    FCC rules if it is installed or configured to defeat DFS, to
> utilize
>    antennas other than those certified for the device, or to make
> other
>    changes that modify the equipment beyond the configuration that has
> been
>    certified. Using uncertified U-NII devices, or certified U-NII
> devices in
>    an unauthorized manner, violates the FCC Part 15 Rules and may
> result in
>    interference to radio communications services critical to public
> safety.
> 
>    Users are also cautioned that operation of the U-NII device must
> not cause
>    harmful interference, and if harmful interference occurs, the
> operation
>    must cease immediately. Furthermore, federal law prohibits willful
> or
>    malicious interference to authorized radio communications.
> 
>    What Should U-NII Operators Do to Comply?
> 
>    Users of U-NII devices must ensure certified devices are installed
> and
>    configured properly. Additionally, if the U-NII devices are
> installed and
>    operating within 35 km of a TDWR system, users are required to take
>    special precautions on the frequency of operation as described in
> the OET
>    Guidance 443999. We caution users of U-NII devices, however, that a
> U-NII
>    device must not cause interference to a TDWR system, regardless of
> the
>    distance between the U-NII device and the TDWR.
> 
>    In fact, operators of U-NII devices under FCC Part 15 Rules must
> not only
>    refrain from causing interference but also must accept interference
> from
>    licensed devices such as the TDWR systems. Any user causing
> interference
>    may be required to cease operating the U-NII device, even if the
> device in
>    use was properly certified and configured, and will not be
> permitted to
>    resume operation until the condition causing the interference has
> been
>    corrected. Even if they avoid or fix any interference problems,
> however,
>    U-NII operators may only operate those devices within authorized
>    frequencies, power limitations, and other technical requirements.
> 
>    Finally, the FCC encourages users of U-NII devices near the TDWR
> systems
>    to register in the voluntary database system discussed in the
> Guidance.
> 
>    What Should Manufacturers and Retailers Do to Comply?
> 
>    As noted above, manufacturers must ensure that U-NII devices
> capable of
>    operating in certain bands have a DFS radar detection mechanism and
> must
>    not have software configurations that allow users to disable the
> features.
>    We also require manufacturers of U-NII devices to remind their
> customers
>    to ensure that the U-NII devices are properly configured and used
> in an
>    authorized manner and that they do not cause interference to TDWRs
> as
>    described in the various guidance documents. Moreover, retailers
> must
>    ensure that the equipment they are marketing complies with FCC
> rules. We
>    will continue to work with manufacturers and retailers to adopt
> tools to
> 
> On Wed, Sep 9, 2015 at 11:35 PM, Christopher Waid
> <chris at thinkpenguin.com> wrote:
> 
>> On 2015-09-08 09:37 PM, Daniel Curran-Dickinson wrote:
>> 
>>> Also to save reading the article if you want to get right to the
>>> enforcement actions:
>> 
>> I don't have the time to read these articles, but if they have any
>> quotes from the FCC in regards to the specific rule changes please
>> let me know.
>> 
>> 
> https://www.fcc.gov/encyclopedia/weather-radar-interference-enforcement
>> [1]
>> 
>> On 2015-09-08 9:26 PM, Daniel Curran-Dickinson wrote:
>> Found the link: It is
>> 
> http://boundless.aerohive.com/technology/why-we-lost-the-weather-radar-channels.html
>> [2]
>> 
>> On 2015-09-08 9:24 PM, Daniel Curran-Dickinson wrote:
>> Oh and the name of the article / blog post is "Why we lost the
>> weather
>> channels" or something close to that.
>> 
>> Regards,
>> 
>> Daniel
>> 
>> On 2015-09-08 9:21 PM, Daniel Curran-Dickinson wrote:
>> While I don't claim to have first hand knowledge is has been
>> reported
>> that yes there were fines and enforcements actions taken on a
>> number of
>> occasions (sorry I don't have link else I'd point you to the person
>> making the claims - I do remember his name is Michael Gast and
>> works for
>> Aerohive AIUI).
>> 
>> Regards,
>> 
>> Daniel
>> 
>> On 2015-09-08 9:07 PM, L. D. Pinney wrote:
>> It's easiest to blame the FCC anyway....they "authorized" the HIGH
>> POWER
>> RADAR in the Unlicensed National Information Infrastructure
>> <https://en.wikipedia.org/wiki/U-NII [3]> Band.
>> 
>> And sure...but where is the "tangible" evidence of such
>> unauthorized
>> modified firmware and operating wifi without DFS and/or on
>> disallowed
>> channels near airports ?? Does the FCC have records as in arrest
>> records and/or fines...or perhaps confiscated
>> equipment....otherwise it
>> is unsubstantiated.
>> 
>> On Tue, Sep 8, 2015 at 7:57 PM, Daniel Curran-Dickinson
>> <daniel at daniel.thecshore.com <mailto:daniel at daniel.thecshore.com>>
>> wrote:
>> 
>> According to the FCC there are people who disagree and were
>> running
>> modified firmware and operating wifi without DFS and/or on
>> disallowed channels near airports, and I really don't buy the
>> whole
>> it's all a big conspiracy of lies argument.
>> 
>> Occam's Razor says that the less convoluted social explanation
>> (that
>> the FCC did indeed find what they say they did and that they
>> are
>> over-reacting to it) wins in the absence of more concrete
>> evidence
>> otherwise.
>> 
>> On 2015-09-08 8:50 PM, L. D. Pinney wrote:
>> 
>> Scare Quotes? ...it's just "sweeps" & "listens" isn't
>> really
>> technical
>> 
>> SO...basically I think (know) that I personally have NO
>> INCENTIVE
>> WHATSOEVER to run my WiFi on those frequencies.
>> Whereas the FCC says otherwise .... it's a NON-SEQUITUR
>> "argument"
>> 
>> On Tue, Sep 8, 2015 at 7:46 PM, Daniel Curran-Dickinson
>> <daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>
>> <mailto:daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>>> wrote:
>> 
>> What's with all the scare quotes?
>> 
>> Regards,
>> 
>> Daniel
>> 
>> On 2015-09-08 8:44 PM, L. D. Pinney wrote:
>> 
>> radar is very directional it "sweeps" with a
>> powerful
>> beam and
>> "listens"
>> for the echos.
>> So...depending on how fast they turn the
>> thing...would
>> be the
>> number of
>> "spikes"
>> Where as distance from the "airport" would
>> "determine"
>> the power
>> level
>> at your home.
>> 
>> On Tue, Sep 8, 2015 at 7:37 PM, Daniel
>> Curran-Dickinson
>> <daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>
>> <mailto:daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>>
>> <mailto:daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>
>> <mailto:daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>>>> wrote:
>> 
>> It's an interesting argument, although I am
>> not
>> sure of the
>> directionality of the radar (i.e. how much
>> goes
>> wide/down
>> vs. up)
>> which is a relevant question to this notion.
>> 
>> Routers are generally non-directional so
>> could
>> get
>> to the radar
>> receiver, so if radar is sufficiently
>> directional
>> to avoid
>> swamping
>> the home wifi then the argument still holds.
>> 
>> I am nowhere near an aiport so I really have
>> no
>> idea what
>> radar does
>> to wifi signals.
>> 
>> Regards,
>> 
>> Daniel
>> 
>> On 2015-09-08 8:25 PM, L. D. Pinney wrote:
>> 
>> Even if this is all true.... my point is
>> one
>> has
>> DISincentive to run
>> WiFi on the same (or nearly) frequency of
>> the
>> TDWR at
>> the local
>> airport...as every time "it" sweeps your
>> place
>> your
>> WiFi would be
>> "swamped" by a signal with HUNDREDS of
>> THOUSANDS of WATTS.
>> Where as the FCC seems to think one has
>> "incentive" to
>> run his
>> WiFi in
>> this "so-called" illegal frequency range.
>> 
>> On Tue, Sep 8, 2015 at 7:03 PM, Daniel
>> Curran-Dickinson
>> <daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>
>> <mailto:daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>>
>> <mailto:daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>
>> <mailto:daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>>>
>> <mailto:daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>
>> <mailto:daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>>
>> <mailto:daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>
>> <mailto:daniel at daniel.thecshore.com
>> <mailto:daniel at daniel.thecshore.com>>>>> wrote:
>> 
>> That makes more sense. The reason I
>> was
>> confused
>> by the
>> 250 part of
>> the number is that I was thinking
>> dBm.
>> 
>> Anyway still doesn't make your point
>> unless you
>> can point to
>> literature that says the guy who
>> said
>> that
>> reflection from
>> clouds is
>> in the same order of magnitude as
>> router
>> output is
>> completely out to
>> lunch. It makes sense to me - no
>> only do
>> you have
>> inverse
>> square
>> round trip over a long distance,
>> clouds
>> are not highly
>> radar reflective.
>> 
>> Regards,
>> 
>> Daniel
>> 
>> On 2015-09-08 2:11 PM, L. D. Pinney
>> wrote:
>> 
>> I can't reply to my post because
>> of
>> some
>> problem with
>> the list.
>> Somehow the Old version got
>> posted...Yes it is 250
>> MILLI watts.
>> 
>> http://transition.fcc.gov/eb/uniitdwr.pdf [4]
>> 
>> http://www.hallikainen.com/FccRules/2014/15/407/ [5]
>> .
>> https://en.wikipedia.org/wiki/U-NII [3]
>> 
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>> 
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> 
> 
> Links:
> ------
> [1] 
> https://www.fcc.gov/encyclopedia/weather-radar-interference-enforcement
> [2]
> http://boundless.aerohive.com/technology/why-we-lost-the-weather-radar-channels.html
> [3] https://en.wikipedia.org/wiki/U-NII
> [4] http://transition.fcc.gov/eb/uniitdwr.pdf
> [5] http://www.hallikainen.com/FccRules/2014/15/407/
> [6] http://lists.prplfoundation.org/cgi-bin/mailman/listinfo/fcc


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