When the FCC Knocks on Your Door

By Jim Wagner

May 16, 2002

According to the jumble of guidelines concerning wireless communications that are commonly known as Part-15 of FCC rules concerning digital transmissions, almost any ISP that offers wireless broadband services could be operating an illegal system.

Fledgling wireless Internet service providers (WISPs), most of them long-time dial-up service providers, usually look to experts for advice when deploying fixed wireless systems over unlicensed 2.4 GHz spectrum.

Finding the right mix of equipment requires an exacting game plan because local demographics and terrestrial nuances demand unique network designs. Usually it's a good idea to work with the experts that put together Wi-Fi systems for a living. Many 2.4 GHz and 5.8 GHz Wi-Fi equipment makers offer free training seminars that have sales representatives and engineers available to recommend the best methods of deploying different wireless technologies.

But what do would-be WISP operators do they're given inaccurate information? What do you do when the Federal Communications Commission (FCC) comes knocking on your door asking to see your Wi-Fi system to make sure it complies with Part-15 of its rules?

"Huh? Part-15? What's that?" you say.

While many operators are familiar with FCC policy governing the use and deployment of equipment and systems in unlicensed spectrum, many don't understand the ramifications for failing to comply with the rules.

Using unlicensed spectrum automatically opens your WISP business to FCC scrutiny. The Commission, tasked with weeding out wireless systems interfering with licensed spectrum holders, check to make sure everything is certified and in compliance with the rules.

For non-believers, Sect. 15.29 of Part-15 rules [.PDF - 337.4K] make this very clear:

The party responsible for the compliance of any device subject to this Part shall promptly furnish to the Commission or its representatives such information as may be requested concerning the operation of the device, including a copy of any measurements made for obtaining an equipment authorization or demonstrating compliance with the regulations."

Michael Anderson, PDQLink Wireless DSL chief information officer, says many new wireless service providers are unaware of the complexities of FCC rules that call for separate certification of both equipment and the overall wireless network.

"Most WISP operators look at the back of a piece of equipment, see the FCC label and say, 'all right, looks good, I'll buy it,' and put it in their network," Anderson said. "What many don't realize is that the system, in its entirety, even down to the length of cable and the addition of a pigtail, has to be certified. Anything that changes the characteristics of the radio has to be certified."

Backward compatibility?

The process for Part-15 compliance is confusing. In fact, one could go so far as to say that the FCC rules governing Wi-Fi systems are overly restrictive and unyielding in their failure to allow for compromise.

The FCC's top officials, engineers, and inspectors seem to be in agreement—although they won't go on the record as saying so.

The addition, removal or modification of any piece of hardware immediately decertifies a system, no matter if it's a new amplifier or shortening a cable run by 10 feet. Modifications change dB levels, which affect the overall signal signature of the system. While the ideas behind the rules make some sense, their rigid, literal enforcement is more open to question.

It's no stretch of the imagination to contend that most WISP operators are providing wireless broadband services in violation of the FCC's Part-15 rules right now because the wording of Part-15 rules is inflexible. The rules explicitly require specific measures for cable connections to antennas and even the number of pigtails in a certain system—no deviations are allowed.

"Why not allow for a certain amount of dB loss before the system is no longer certified?" Anderson said. "Make the wording say, 'cable lengths up to 20 feet' instead of just 'cable lengths of 20 feet' so that a professional installer can make some changes without worrying about being illegal."

Another element of Part-15 rules that defies explanation—When one manufacturer applies for FCC certification of an antenna, the antenna is certified only for this specific equipment maker. Any other manufacturer has to apply for FCC certification on the same antenna separately, even though in some cases the two antennas were made on the same production line at the same time.

Unfortunately, there's no quick fix to the rules, as amendments take years to process through the FCC bureaucracy—the latest amendment to Part-15 is a perfect example. It was originally proposed back in 1999, so any overhaul of Part-15 rules might not happen any time soon.

Reprinted from ISP-Planet.

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