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Re: [TowerTalk] [WISPA FCC] OT??? High power 2.4 GHz rules change

To: "'John Scrivner'" <>,"'FCC Discussion'" <>
Subject: Re: [TowerTalk] [WISPA FCC] OT??? High power 2.4 GHz rules change
From: "Dan Hammill" <>
Date: Sat, 20 May 2006 23:43:39 -0700
List-post: <>

Thank you for your sentiments towards hams.

As far as I am aware, there is no requirement for hams to use APC on 2.3 &
2.4 GHz.  As an EME (moonbounce) enthusiast who plans to be on 2.3 GHz
someday, Part 97 allows me to use the minimum power necessary to establish
reliable communications (and on shared bands, as restricted by reduced any
limits imposed by the top primary user of the band - typically the
government or military).  If the EME path is degraded to the point that
whatever combinations of TX/RX systems the other station and I may be using
demands a licensed-user legal-limit signal to the antenna feed on my end to
establish a viable connection, then that is the power I would run -
regardless of whether the link is CW, SSB, FM, TV, or digital.  The only
"automatic" control will be the connections linking my ears, eyes,
wattmeter, and RF power knob on the IF radio.  I don't know what you know of
the round-trip EME path, but one would need a rather large dish antenna to
work EME within Part 15 power limits (as in NASA Deep Space Network size).
If you raise unlicensed power levels, the noise floor raises and EME becomes
virtually impossible.  Conversely, if I run legal limit into my 24-foot
dish, aim at the moon on the horizon, and some unlicensed ISP happens to lie
in-between, I guarantee that the ISP will lose, regardless of how much power
he/she may be running.

You also seem to have missed that 2.4 GHz contains an Amateur Satellite
segment.  If you raise unlicensed power levels, any satellite downlinks at
2.4 GHz become degraded due to increased noise floor.

Part 15 devices, by their unlicensed nature, MUST accept interference from
licensed users, and MUST NOT cause interference to licensed users.  To
expect Primary LICENSED users of a frequency band to just roll over and
allow their status to be reduced to that of unlicensed users, with all of
the attendant restrictions, just because the current unlicensed users want
it that way is simply ludicrous.  The ONLY reason you're on 2.4 GHz in the
first place is because of your unlicensed status.  Consequently, you should
expect to be restricted in your operations so that the licensed users will
be able to conduct their normal activities.

Dan  KB5MY 

-----Original Message-----
[] On Behalf Of John Scrivner
Sent: Saturday, May 20, 2006 7:34 AM
To: FCC Discussion
Cc: Principal WISPA Member List;; Amateur 802.11b
Mailing List
Subject: Re: [TowerTalk] [WISPA FCC] OT??? High power 2.4 GHz rules change

I want to first say that I have the utmost respect and admiration for the
Ham community at large and recognize the extensive efforts by this community
to aid us all with emergency communications, research for new innovative
radio technology, technical training, etc.. I know that the Ham community as
a whole do not wish to cause anyone harmful interference in any way and that
they are a good steward of the spectrum they use. With that said I think we
can all appreciate the importance of seeing our collective efforts
represented and addressed in a balanced and positive way within the FCC.

Substantial efforts have been put forth predominantly by the WISP, WiFi and
Municipal wireless industry segments to make 2.4 GHz wireless a platform for
efficient and low-cost broadband delivery. We understand and fully
acknowledge that the Ham community has primary rights in this band. It would
make more logical sense to us to allow unlicensed operations to have
extended power with APC than to eliminate APC for Hams and possibly further
harm the efforts being made by many in the WiFi space to utilize unlicensed
frequencies in a responsible and practical way. I think that as unlicensed
WISP operators we should consider asking the FCC to extend the power rules
to any users in this band, including Part 15,  and take away any primary
license status to anyone who chooses to run the higher power with no APC
requirement. At least those who run with no power level protections would
all be in the same pickle if interference knocks two or more  operators
offline (Part
97 or not). Part 97 operations using APC could retain their primary status
and justifiably cause anyone using higher power to change frequencies or
turn down power to stop the interference.. I see no compelling reason why
Part 97 operations should be granted the right to easily cause harm to Part
15 operations unless the primary licensed status is eliminated for Part 97
and essentially everyone has Part 15 status with higher power rights of use
in this band. Another acceptable option would be to allow commercial use of
this spectrum under the same rules and protections as Part 97 for WISP, WiFi
and Municipal operations. Either option above gives all users a balanced and
level policy framework to operate within. I do think that one of the
requirements for higher power use should be that any operator would be
required to become a licensed radio operator (Ham or other) before the
higher power could be used.
John Scrivner

Marlon K. Schafer (509) 982-2181 wrote:

> Hi All,
> As I'm sure you guys are aware, HAMs are primary users in about half 
> of the 2.4 gig band.  When using APC you can run very high wattage.  I 
> can't remember if it's 100 or 1000.  This is for video as I recall.
> There's a proposal to drop the APC requirement.  As a board member of 
> the Wireless Internet Provider's Association ( I've been 
> asked to ask for your input on the issue.
> WISPs, and other license exempt users, are limited (for all practical
> purposes) to 4 watts for our broadcast sites.  And much of the gear is 
> contention based, so anything that's always on tends to cause great 
> headaches and gnashing of teeth.
> We will likely fight this new proposal but wanted input from the HAM 
> community first.
> Are there people using this ability today?
> What's it used for?
> Any plans for more high power 2.4 gig use?
> Are there any reasons that we shouldn't come out against the proposal 
> to drop the APC requirement?
> Am I missing anything?  Asking the wrong questions etc?
> Thanks all!
> Marlon
> (509) 982-2181                                   Equipment sales
> (408) 907-6910 (Vonage)                    Consulting services
> 42846865 (icq)                                    And I run my own wisp!
> (net meeting)
> _______________________________________________
> FCC mailing list

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