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[Ham-80211] OT??? High power 2.4 GHz rules change

Fri May 19 16:12:43 UTC 2006

A couple of quick comments...

1) The FCC has defined what is means by spread spectrum and how to obtain
APC under Part 97.  

2) DSSS (802.11b) and OFDM (802.11g) do not fit the FCC diffinition of
spread spectrum.

3) Accomplishing APC on DSSS and OFDM types of modulation using the method
of APC that the FCC has defined in Part 97 is a "Practical Impossibility" (a
legal term) and I can assure you that no knowledgable federal attorney is
going to get the government involved in Practical Impossibility litigation.
There is too much case law at stake if they lose and judges almost always
rule against practical impossibility.


PS, just this week finished a contract law seminar from the Defense
Acquisition University (continuing educations requirement for procurement
professionals) that shows just how federal judges are ruling.  IMHO they
would not rule in favor of the government where there is a question of
Practical Impossibility.

-----Original Message-----
From: ham-80211-bounces at lists.tapr.org
[mailto:ham-80211-bounces at lists.tapr.org]On Behalf Of Tim Gorman
Sent: Thursday, May 18, 2006 12:06 PM
To: TAPR Mailing List for Ham Radio Use of 802.11
Subject: Re: [Ham-80211] OT??? High power 2.4 GHz rules change

Contrary to other posts, I can find nothing in any FCC documentation that 
shows they approaced the ARRL about dropping the APC requirement. And since 
this is a public proceeding, it will cost you little to add your comments to

the proceeding at this time. If you do not comment on it and it becomes 
reality *then* you could incur significant legal costs trying to fight the 
isse as a seconcdary user of the spectrum.

I an an amateur radio operator with two Linksys wrt54g wireless routers I
modified the firmware on. I have been looking at purchasing amplifiers to up

their output to establish an omni-directional hubbed network. Amplifiers
moderate power levels are not that expensive. Dropping the APC requirement 
*would* make it easier to implement the current FCC requirements. Meeting 
current requirements would require applications to make use of the 802.11h 
modules in the modified firmware I am using. It *will* require additional 
work over just buying off-the-shelf stuff and using it.

Having said that, I have to tell you I have already posted comments against 
the proposal. After thinking about it a lot I came to the conclusion that
*is* the technological path to follow to limit spectrum pollution, be it 
pollution in the Part 15 or Part 97 arena. Hams are supposed to engineer 
their equipment based on sound engineering practice and judgment. 
Implementing APC *is* exhibiting sound engineering practice and judgment. 
While you can argue that philosophically amateurs will implement APC on
own without it being in the rules, pragmatically that is not the case. The 
ARRL in their proposal admits this by basically saying APC, as formulated by

the FCC, is too hard for amateurs to do. Basically, that is a crock. 
Conceptually, it is easy to do in any FHSS system. It is hard to do in a
system because trying to identify signal strengths of narrow band signals is

difficult in a DSSS system. But I'm sure some DSP processing could handle 

Anyway, as you can see there are probably lots of varying views on this 
subject. You need to think your position through and put in your comments, 
while I think it is past the comment date, I think the FCC will still accept

comments as long as they aren't actively in the process of analyzing them.

tim ab0wr

On Wednesday 17 May 2006 11:03, 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
> 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 (www.wispa.org) I've been asked
> 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)
> www.odessaoffice.com/wireless
> www.odessaoffice.com/marlon/cam
> _______________________________________________
> ham-80211 mailing list
> ham-80211 at lists.tapr.org
> https://lists.tapr.org/cgi-bin/mailman/listinfo/ham-80211

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