Taiwan's Ministry of Transportation and Communications revised its
frequency allocation rules [1], specifically opening up 5.15 GHz ~
5.25 GHz and 5.6 GHz ~ 5.65 GHz for U-NII applications, as well as
explicitly mentioning U-NII applications and DFS requirements for
the related frequency ranges.
LP0002 [2], the technical standard for low power radio devices, hasn't
been updated,though work is under way. The NCC, Taiwan's equivalent of
the US FCC, has explicitly [3][4] allowed certification under the newest
FCC Part 15E limitations, though unwanted emissions must still conform
to LP0002 sections 2.7 ~ 2.8:
- 5150 MHz ~ 5250 MHz is not restricted to indoor usage.
- 5250 MHz ~ 5350 MHz and 5470 MHz ~ 5725 MHz devices should have DFS
capabilities, and conform to latest FCC radar standards.
- 5250 MHz ~ 5350 MHz without DFS capabilities are limited to indoor
usage, under current LP0002 restrictions.
In addition, large channels across multiple U-NII bands are allowed
under the same rules as FCC KDB 644545 [5].
This patch updates the regulatory rules for Taiwan (TW) to reflect the
changes noted above, and corrects transmit power limits for 5470 MHz ~
5725 MHz. In addition, the format of the rules has been modified:
- List band boundaries, instead of channel boundaries, and add AUTO-BW
for adjacent bands.
- List maximum transmit power using mW instead of dBm. This is easier
to find from the related documents.
[1] http://www.motc.gov.tw/websitedowndoc?file=post/201411171137330.doc&filedisplay=Table+of+radio+frequency+allocation.doc
[2] http://www.ncc.gov.tw/english/show_file.aspx?table_name=news&file_sn=681
[3] http://www.rheintech.com/our-blog/item/585-taiwan-ncc-opens-5150-5250-mhz-for-wireless-devices
[4] Proposal #10312260 (p.6, Chinese),
http://www.etc.org.tw/_library/K00/%E9%9B%BB%E4%BF%A1%E7%B5%82%E7%AB%AF%E8%A8%AD%E5%82%99%E5%AF%A9%E9%A9%97/1031223_nccqa56.pdf
[5] Proposal #10202205 (p.3, Chinese),
http://www.etc.org.tw/_library/K00/%E4%BD%8E%E5%8A%9F%E7%8E%87%E8%A8%AD%E5%82%99%E5%AF%A9%E9%A9%97/1020221_nccqa50.pdf
Signed-off-by: Chen-Yu Tsai <[email protected]>
---
Hi everyone,
First of all, I am _not_ a regulatory or wireless expert, nor is my
field of work related, unless you count deploying access points as
related.
Last week I bought and deployed a new "Tri-band" 802.11ac wireless
router, and it was using channels 36~44, which previously was not
available in Taiwan. After asking around, a friend at the vendor
said that Taiwan recently opened up that part of the spectrum.
Unfortunately, [4][5] are Q&As transcripts with the regulatory body.
I cound only find them in Chinese. Suffice to say, Taiwan's NCC
follows the FCC closely whenever possible when it comes to wireless
stuff.
As such, I also looked at the US rules. It seems they are using
"peak power spectral density" instead of "peak power output".
I believe this is wrong. My crude understanding is the former
is the amount of power in a single chunk of the complete channel,
while the latter is the actual power put out by the transmitter.
The former would be used to enforce a more uniform power distribution
over the wireless channel, while the later actually limits transmission
power, and thus range.
Regards
ChenYu
---
db.txt | 20 ++++++++++++++------
1 file changed, 14 insertions(+), 6 deletions(-)
diff --git a/db.txt b/db.txt
index 809cd3c..f1c110d 100644
--- a/db.txt
+++ b/db.txt
@@ -1117,12 +1117,20 @@ country TT: DFS-FCC
(5490 - 5730 @ 160), (24), DFS
(5735 - 5835 @ 80), (30)
-country TW: DFS-JP
- (2402 - 2472 @ 40), (30)
- (5270 - 5330 @ 40), (17), DFS
- (5490 - 5590 @ 80), (30), DFS
- (5650 - 5710 @ 40), (30), DFS
- (5735 - 5835 @ 80), (30)
+# Source:
+# Table of Frequency Allocations of Republic of China (Taiwan) / Nov 2014:
+# http://www.motc.gov.tw/websitedowndoc?file=post/201411171137330.doc& \
+# filedisplay=Table+of+radio+frequency+allocation.doc
+# LP0002 / 28 Jun 2011:
+# http://www.ncc.gov.tw/english/show_file.aspx?table_name=news&file_sn=681
+# (section 3.10.1, 4.7)
+#
+country TW: DFS-FCC
+ (2400 - 2483.5 @ 40), (1000 mW)
+ (5150 - 5250 @ 80), (1000 mW), AUTO-BW
+ (5250 - 5350 @ 80), (250 mW), DFS, AUTO-BW
+ (5470 - 5725 @ 160), (250 mW), DFS, AUTO-BW
+ (5725 - 5850 @ 80), (1000 mW), AUTO-BW
country TZ:
(2402 - 2482 @ 40), (20)
--
2.1.4
On Thu, Jul 9, 2015 at 11:15 PM, Seth Forshee
<[email protected]> wrote:
> On Wed, Jul 08, 2015 at 11:07:20AM +0800, Chen-Yu Tsai wrote:
>> > Thanks. I think there should be a written document about what the
>> > rules should be like, or what is expected:
>> >
>> > 1. WiFi channel boundaries or band boundaries
>> > 2. peak output power or peak power spectral density
>> >
>> > In http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000856.html
>> > you mentioned the software is smart enough to work out how to combine
>> > different bands and what channels to use, so I see no reason to explicitly
>> > chop up contiguous spectrum, unless there are explicit rules forbidding
>> > combined use of bands with different regulatory rules. AFAIK the FCC
>> > only requires one to satisfy all rules when usage crosses band boundaries.
>> >
>> > http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000857.html
>> > also raises a similar question.
>
> I was really commenting about the transmit power updates in your patch.
> I just compared the frequency changes to the documentation you linked to
> and those do look okay to me.
I see.
>> >> I would however consider an update for 5.15-5.25 GHz and 5.6-5.65 GHz
>> >> provided that there's official documentation to substantiate the change.
>> >> I unfortunately cannot read Chinese, so I would need some assistance to
>> >> confirm the documentation.
>> >
>> > I could possibly ask around, though I'm not optimistic. The "official"
>> > documents are just transcripts from NCC hosted Q&A sessions regarding
>> > the latest regulations. Proposals/questions are submitted by vendors,
>> > and the NCC responds and puts together an aggregated transcript.
>>
>> Just got off the phone with the NCC. Their position is, spectrum allocation
>> is not within their purview, but the Ministry of Transportation and
>> Communications. As noted in the patch, they have already opened up the
>> spectrum to U-NII and low power radio usage. What remains is that the
>> NCC revise its testing standards. Until then, their position is that,
>> since their testing standards are modeled after FCC standards, vendors
>> can just test under FCC standards, then convert the reports into LP0002
>> format, and cite the FCC test report.
>>
>> There is no formal English version of the Q&A transcript, at least not
>> until some foreign testing body requests it. The person in charge just
>> asked me to translate it myself...
>
> If you send a patch which updates only the frequencies I would likely
> apply that after allowing a week or so for others to either ack or nack
> it (and running the stuff you linked to through google translate and
> seeing if I could make any sense of the output).
Got it.
> I think the power updates are probably based on a misunderstanding, and
> may not even be completely correct. For the most part after they've been
> converted to EIRP (eirp = 10 * log10(mW)) they don't turn out to be
> substantially different than what we have now. I think the value in
> 5250-5350 MHz is probably incorrect however. Based on my quick skim of
> the document you linked to it should be 50 mW rather than 250. 50 mW
> also roughly matches to the 17 dBm which is in the database today,
> whereas 250 mW is closer to 24 dBm.
Yes. About the first part, it seems dbparse.py converts values in mW
into EIRP anyway. However I don't think EIRT equals "peak power spectral
density".
About the second part, yes the current values match the ones in LP0002.
However as I stated, the regulatory body has explicitly allowed certifying
under the latest FCC rules, which effectively raises the limits from
50 mW to 250 mW.
> My suggestion would be update the frequencies but not the existing
> transmit power limits, unless you discover that any of the power limits
> are definitely incorrect.
I'll split up the patch into 3:
1. Add the new 5150 - 5250 frequency band, using current LP0002
limits if any, otherwise FCC limits.
2. Tweak frequency boundaries for the remaining bands to make
them contiguous and properly reflect the regulations rather
than the WiFi channel frequencies.
3. Update power limits and DFS requirements to latest FCC standards.
Each patch will then explain why and how the regulations changed
along with references, in English if available.
You can then decide on whether to merge all three or just the first
two.
Regards
ChenYu
On Wed, Jul 8, 2015 at 4:54 AM, Seth Forshee <[email protected]> wrote:
> On Tue, Jul 07, 2015 at 04:07:15PM +0800, Chen-Yu Tsai wrote:
>> Taiwan's Ministry of Transportation and Communications revised its
>> frequency allocation rules [1], specifically opening up 5.15 GHz ~
>> 5.25 GHz and 5.6 GHz ~ 5.65 GHz for U-NII applications, as well as
>> explicitly mentioning U-NII applications and DFS requirements for
>> the related frequency ranges.
>>
>> LP0002 [2], the technical standard for low power radio devices, hasn't
>> been updated,though work is under way. The NCC, Taiwan's equivalent of
>> the US FCC, has explicitly [3][4] allowed certification under the newest
>> FCC Part 15E limitations, though unwanted emissions must still conform
>> to LP0002 sections 2.7 ~ 2.8:
>>
>> - 5150 MHz ~ 5250 MHz is not restricted to indoor usage.
>>
>> - 5250 MHz ~ 5350 MHz and 5470 MHz ~ 5725 MHz devices should have DFS
>> capabilities, and conform to latest FCC radar standards.
>>
>> - 5250 MHz ~ 5350 MHz without DFS capabilities are limited to indoor
>> usage, under current LP0002 restrictions.
>>
>> In addition, large channels across multiple U-NII bands are allowed
>> under the same rules as FCC KDB 644545 [5].
>>
>> This patch updates the regulatory rules for Taiwan (TW) to reflect the
>> changes noted above, and corrects transmit power limits for 5470 MHz ~
>> 5725 MHz. In addition, the format of the rules has been modified:
>>
>> - List band boundaries, instead of channel boundaries, and add AUTO-BW
>> for adjacent bands.
>>
>> - List maximum transmit power using mW instead of dBm. This is easier
>> to find from the related documents.
>>
>> [1] http://www.motc.gov.tw/websitedowndoc?file=post/201411171137330.doc&filedisplay=Table+of+radio+frequency+allocation.doc
>> [2] http://www.ncc.gov.tw/english/show_file.aspx?table_name=news&file_sn=681
>> [3] http://www.rheintech.com/our-blog/item/585-taiwan-ncc-opens-5150-5250-mhz-for-wireless-devices
>> [4] Proposal #10312260 (p.6, Chinese),
>> http://www.etc.org.tw/_library/K00/%E9%9B%BB%E4%BF%A1%E7%B5%82%E7%AB%AF%E8%A8%AD%E5%82%99%E5%AF%A9%E9%A9%97/1031223_nccqa56.pdf
>> [5] Proposal #10202205 (p.3, Chinese),
>> http://www.etc.org.tw/_library/K00/%E4%BD%8E%E5%8A%9F%E7%8E%87%E8%A8%AD%E5%82%99%E5%AF%A9%E9%A9%97/1020221_nccqa50.pdf
>>
>> Signed-off-by: Chen-Yu Tsai <[email protected]>
>> ---
>>
>> Hi everyone,
>>
>> First of all, I am _not_ a regulatory or wireless expert, nor is my
>> field of work related, unless you count deploying access points as
>> related.
>>
>> Last week I bought and deployed a new "Tri-band" 802.11ac wireless
>> router, and it was using channels 36~44, which previously was not
>> available in Taiwan. After asking around, a friend at the vendor
>> said that Taiwan recently opened up that part of the spectrum.
>>
>> Unfortunately, [4][5] are Q&As transcripts with the regulatory body.
>> I cound only find them in Chinese. Suffice to say, Taiwan's NCC
>> follows the FCC closely whenever possible when it comes to wireless
>> stuff.
>>
>> As such, I also looked at the US rules. It seems they are using
>> "peak power spectral density" instead of "peak power output".
>> I believe this is wrong. My crude understanding is the former
>> is the amount of power in a single chunk of the complete channel,
>> while the latter is the actual power put out by the transmitter.
>> The former would be used to enforce a more uniform power distribution
>> over the wireless channel, while the later actually limits transmission
>> power, and thus range.
>
> I certainly don't qualify as a regulatory expert either. But the rules
> you're proposing to change came from Qualcomm Atheros, and I do have
> considerable confidence in their regualtory expertise. Therefore I'd
> want an ack from QCA before I'd consider applying this patch.
Thanks. I think there should be a written document about what the
rules should be like, or what is expected:
1. WiFi channel boundaries or band boundaries
2. peak output power or peak power spectral density
In http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000856.html
you mentioned the software is smart enough to work out how to combine
different bands and what channels to use, so I see no reason to explicitly
chop up contiguous spectrum, unless there are explicit rules forbidding
combined use of bands with different regulatory rules. AFAIK the FCC
only requires one to satisfy all rules when usage crosses band boundaries.
http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000857.html
also raises a similar question.
> I would however consider an update for 5.15-5.25 GHz and 5.6-5.65 GHz
> provided that there's official documentation to substantiate the change.
> I unfortunately cannot read Chinese, so I would need some assistance to
> confirm the documentation.
I could possibly ask around, though I'm not optimistic. The "official"
documents are just transcripts from NCC hosted Q&A sessions regarding
the latest regulations. Proposals/questions are submitted by vendors,
and the NCC responds and puts together an aggregated transcript.
Regards
ChenYu
On Wed, Jul 22, 2015 at 3:56 PM, Chen-Yu Tsai <[email protected]> wrote:
> On Wed, Jul 22, 2015 at 3:40 PM, Chen-Yu Tsai <[email protected]> wrote:
>> On Thu, Jul 9, 2015 at 11:15 PM, Seth Forshee
>> <[email protected]> wrote:
>>> On Wed, Jul 08, 2015 at 11:07:20AM +0800, Chen-Yu Tsai wrote:
>>>> > Thanks. I think there should be a written document about what the
>>>> > rules should be like, or what is expected:
>>>> >
>>>> > 1. WiFi channel boundaries or band boundaries
>>>> > 2. peak output power or peak power spectral density
>>>> >
>>>> > In http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000856.html
>>>> > you mentioned the software is smart enough to work out how to combine
>>>> > different bands and what channels to use, so I see no reason to explicitly
>>>> > chop up contiguous spectrum, unless there are explicit rules forbidding
>>>> > combined use of bands with different regulatory rules. AFAIK the FCC
>>>> > only requires one to satisfy all rules when usage crosses band boundaries.
>>>> >
>>>> > http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000857.html
>>>> > also raises a similar question.
>>>
>>> I was really commenting about the transmit power updates in your patch.
>>> I just compared the frequency changes to the documentation you linked to
>>> and those do look okay to me.
>>
>> I see.
>>
>>>> >> I would however consider an update for 5.15-5.25 GHz and 5.6-5.65 GHz
>>>> >> provided that there's official documentation to substantiate the change.
>>>> >> I unfortunately cannot read Chinese, so I would need some assistance to
>>>> >> confirm the documentation.
>>>> >
>>>> > I could possibly ask around, though I'm not optimistic. The "official"
>>>> > documents are just transcripts from NCC hosted Q&A sessions regarding
>>>> > the latest regulations. Proposals/questions are submitted by vendors,
>>>> > and the NCC responds and puts together an aggregated transcript.
>>>>
>>>> Just got off the phone with the NCC. Their position is, spectrum allocation
>>>> is not within their purview, but the Ministry of Transportation and
>>>> Communications. As noted in the patch, they have already opened up the
>>>> spectrum to U-NII and low power radio usage. What remains is that the
>>>> NCC revise its testing standards. Until then, their position is that,
>>>> since their testing standards are modeled after FCC standards, vendors
>>>> can just test under FCC standards, then convert the reports into LP0002
>>>> format, and cite the FCC test report.
>>>>
>>>> There is no formal English version of the Q&A transcript, at least not
>>>> until some foreign testing body requests it. The person in charge just
>>>> asked me to translate it myself...
>>>
>>> If you send a patch which updates only the frequencies I would likely
>>> apply that after allowing a week or so for others to either ack or nack
>>> it (and running the stuff you linked to through google translate and
>>> seeing if I could make any sense of the output).
>>
>> Got it.
>>
>>> I think the power updates are probably based on a misunderstanding, and
>>> may not even be completely correct. For the most part after they've been
>>> converted to EIRP (eirp = 10 * log10(mW)) they don't turn out to be
>>> substantially different than what we have now. I think the value in
>>> 5250-5350 MHz is probably incorrect however. Based on my quick skim of
>>> the document you linked to it should be 50 mW rather than 250. 50 mW
>>> also roughly matches to the 17 dBm which is in the database today,
>>> whereas 250 mW is closer to 24 dBm.
>>
>> Yes. About the first part, it seems dbparse.py converts values in mW
>> into EIRP anyway. However I don't think EIRT equals "peak power spectral
>> density".
>
> Sorry, this part applies to the US rules, not part of this patch.
I just realized that what I misunderstood as PSD was the fact that no one
had updated the power limits of U-NII-1 for the US. I've added such a patch
to my series.
Sorry for the noise.
>> About the second part, yes the current values match the ones in LP0002.
>> However as I stated, the regulatory body has explicitly allowed certifying
>> under the latest FCC rules, which effectively raises the limits from
>> 50 mW to 250 mW.
>>
>>> My suggestion would be update the frequencies but not the existing
>>> transmit power limits, unless you discover that any of the power limits
>>> are definitely incorrect.
>>
>> I'll split up the patch into 3:
>>
>> 1. Add the new 5150 - 5250 frequency band, using current LP0002
>> limits if any, otherwise FCC limits.
>>
>> 2. Tweak frequency boundaries for the remaining bands to make
>> them contiguous and properly reflect the regulations rather
>> than the WiFi channel frequencies.
>>
>> 3. Update power limits and DFS requirements to latest FCC standards.
>>
>> Each patch will then explain why and how the regulations changed
>> along with references, in English if available.
>>
>> You can then decide on whether to merge all three or just the first
>> two.
>>
>>
>> Regards
>> ChenYu
On Wed, Jul 08, 2015 at 11:07:20AM +0800, Chen-Yu Tsai wrote:
> > Thanks. I think there should be a written document about what the
> > rules should be like, or what is expected:
> >
> > 1. WiFi channel boundaries or band boundaries
> > 2. peak output power or peak power spectral density
> >
> > In http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000856.html
> > you mentioned the software is smart enough to work out how to combine
> > different bands and what channels to use, so I see no reason to explicitly
> > chop up contiguous spectrum, unless there are explicit rules forbidding
> > combined use of bands with different regulatory rules. AFAIK the FCC
> > only requires one to satisfy all rules when usage crosses band boundaries.
> >
> > http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000857.html
> > also raises a similar question.
I was really commenting about the transmit power updates in your patch.
I just compared the frequency changes to the documentation you linked to
and those do look okay to me.
> >> I would however consider an update for 5.15-5.25 GHz and 5.6-5.65 GHz
> >> provided that there's official documentation to substantiate the change.
> >> I unfortunately cannot read Chinese, so I would need some assistance to
> >> confirm the documentation.
> >
> > I could possibly ask around, though I'm not optimistic. The "official"
> > documents are just transcripts from NCC hosted Q&A sessions regarding
> > the latest regulations. Proposals/questions are submitted by vendors,
> > and the NCC responds and puts together an aggregated transcript.
>
> Just got off the phone with the NCC. Their position is, spectrum allocation
> is not within their purview, but the Ministry of Transportation and
> Communications. As noted in the patch, they have already opened up the
> spectrum to U-NII and low power radio usage. What remains is that the
> NCC revise its testing standards. Until then, their position is that,
> since their testing standards are modeled after FCC standards, vendors
> can just test under FCC standards, then convert the reports into LP0002
> format, and cite the FCC test report.
>
> There is no formal English version of the Q&A transcript, at least not
> until some foreign testing body requests it. The person in charge just
> asked me to translate it myself...
If you send a patch which updates only the frequencies I would likely
apply that after allowing a week or so for others to either ack or nack
it (and running the stuff you linked to through google translate and
seeing if I could make any sense of the output).
I think the power updates are probably based on a misunderstanding, and
may not even be completely correct. For the most part after they've been
converted to EIRP (eirp = 10 * log10(mW)) they don't turn out to be
substantially different than what we have now. I think the value in
5250-5350 MHz is probably incorrect however. Based on my quick skim of
the document you linked to it should be 50 mW rather than 250. 50 mW
also roughly matches to the 17 dBm which is in the database today,
whereas 250 mW is closer to 24 dBm.
My suggestion would be update the frequencies but not the existing
transmit power limits, unless you discover that any of the power limits
are definitely incorrect.
Thanks,
Seth
On Wed, Jul 8, 2015 at 10:51 AM, Chen-Yu Tsai <[email protected]> wrote:
> On Wed, Jul 8, 2015 at 4:54 AM, Seth Forshee <[email protected]> wrote:
>> On Tue, Jul 07, 2015 at 04:07:15PM +0800, Chen-Yu Tsai wrote:
>>> Taiwan's Ministry of Transportation and Communications revised its
>>> frequency allocation rules [1], specifically opening up 5.15 GHz ~
>>> 5.25 GHz and 5.6 GHz ~ 5.65 GHz for U-NII applications, as well as
>>> explicitly mentioning U-NII applications and DFS requirements for
>>> the related frequency ranges.
>>>
>>> LP0002 [2], the technical standard for low power radio devices, hasn't
>>> been updated,though work is under way. The NCC, Taiwan's equivalent of
>>> the US FCC, has explicitly [3][4] allowed certification under the newest
>>> FCC Part 15E limitations, though unwanted emissions must still conform
>>> to LP0002 sections 2.7 ~ 2.8:
>>>
>>> - 5150 MHz ~ 5250 MHz is not restricted to indoor usage.
>>>
>>> - 5250 MHz ~ 5350 MHz and 5470 MHz ~ 5725 MHz devices should have DFS
>>> capabilities, and conform to latest FCC radar standards.
>>>
>>> - 5250 MHz ~ 5350 MHz without DFS capabilities are limited to indoor
>>> usage, under current LP0002 restrictions.
>>>
>>> In addition, large channels across multiple U-NII bands are allowed
>>> under the same rules as FCC KDB 644545 [5].
>>>
>>> This patch updates the regulatory rules for Taiwan (TW) to reflect the
>>> changes noted above, and corrects transmit power limits for 5470 MHz ~
>>> 5725 MHz. In addition, the format of the rules has been modified:
>>>
>>> - List band boundaries, instead of channel boundaries, and add AUTO-BW
>>> for adjacent bands.
>>>
>>> - List maximum transmit power using mW instead of dBm. This is easier
>>> to find from the related documents.
>>>
>>> [1] http://www.motc.gov.tw/websitedowndoc?file=post/201411171137330.doc&filedisplay=Table+of+radio+frequency+allocation.doc
>>> [2] http://www.ncc.gov.tw/english/show_file.aspx?table_name=news&file_sn=681
>>> [3] http://www.rheintech.com/our-blog/item/585-taiwan-ncc-opens-5150-5250-mhz-for-wireless-devices
>>> [4] Proposal #10312260 (p.6, Chinese),
>>> http://www.etc.org.tw/_library/K00/%E9%9B%BB%E4%BF%A1%E7%B5%82%E7%AB%AF%E8%A8%AD%E5%82%99%E5%AF%A9%E9%A9%97/1031223_nccqa56.pdf
>>> [5] Proposal #10202205 (p.3, Chinese),
>>> http://www.etc.org.tw/_library/K00/%E4%BD%8E%E5%8A%9F%E7%8E%87%E8%A8%AD%E5%82%99%E5%AF%A9%E9%A9%97/1020221_nccqa50.pdf
>>>
>>> Signed-off-by: Chen-Yu Tsai <[email protected]>
>>> ---
>>>
>>> Hi everyone,
>>>
>>> First of all, I am _not_ a regulatory or wireless expert, nor is my
>>> field of work related, unless you count deploying access points as
>>> related.
>>>
>>> Last week I bought and deployed a new "Tri-band" 802.11ac wireless
>>> router, and it was using channels 36~44, which previously was not
>>> available in Taiwan. After asking around, a friend at the vendor
>>> said that Taiwan recently opened up that part of the spectrum.
>>>
>>> Unfortunately, [4][5] are Q&As transcripts with the regulatory body.
>>> I cound only find them in Chinese. Suffice to say, Taiwan's NCC
>>> follows the FCC closely whenever possible when it comes to wireless
>>> stuff.
>>>
>>> As such, I also looked at the US rules. It seems they are using
>>> "peak power spectral density" instead of "peak power output".
>>> I believe this is wrong. My crude understanding is the former
>>> is the amount of power in a single chunk of the complete channel,
>>> while the latter is the actual power put out by the transmitter.
>>> The former would be used to enforce a more uniform power distribution
>>> over the wireless channel, while the later actually limits transmission
>>> power, and thus range.
>>
>> I certainly don't qualify as a regulatory expert either. But the rules
>> you're proposing to change came from Qualcomm Atheros, and I do have
>> considerable confidence in their regualtory expertise. Therefore I'd
>> want an ack from QCA before I'd consider applying this patch.
>
> Thanks. I think there should be a written document about what the
> rules should be like, or what is expected:
>
> 1. WiFi channel boundaries or band boundaries
> 2. peak output power or peak power spectral density
>
> In http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000856.html
> you mentioned the software is smart enough to work out how to combine
> different bands and what channels to use, so I see no reason to explicitly
> chop up contiguous spectrum, unless there are explicit rules forbidding
> combined use of bands with different regulatory rules. AFAIK the FCC
> only requires one to satisfy all rules when usage crosses band boundaries.
>
> http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000857.html
> also raises a similar question.
>
>> I would however consider an update for 5.15-5.25 GHz and 5.6-5.65 GHz
>> provided that there's official documentation to substantiate the change.
>> I unfortunately cannot read Chinese, so I would need some assistance to
>> confirm the documentation.
>
> I could possibly ask around, though I'm not optimistic. The "official"
> documents are just transcripts from NCC hosted Q&A sessions regarding
> the latest regulations. Proposals/questions are submitted by vendors,
> and the NCC responds and puts together an aggregated transcript.
Just got off the phone with the NCC. Their position is, spectrum allocation
is not within their purview, but the Ministry of Transportation and
Communications. As noted in the patch, they have already opened up the
spectrum to U-NII and low power radio usage. What remains is that the
NCC revise its testing standards. Until then, their position is that,
since their testing standards are modeled after FCC standards, vendors
can just test under FCC standards, then convert the reports into LP0002
format, and cite the FCC test report.
There is no formal English version of the Q&A transcript, at least not
until some foreign testing body requests it. The person in charge just
asked me to translate it myself...
Regards
ChenYu
On Wed, Jul 22, 2015 at 3:40 PM, Chen-Yu Tsai <[email protected]> wrote:
> On Thu, Jul 9, 2015 at 11:15 PM, Seth Forshee
> <[email protected]> wrote:
>> On Wed, Jul 08, 2015 at 11:07:20AM +0800, Chen-Yu Tsai wrote:
>>> > Thanks. I think there should be a written document about what the
>>> > rules should be like, or what is expected:
>>> >
>>> > 1. WiFi channel boundaries or band boundaries
>>> > 2. peak output power or peak power spectral density
>>> >
>>> > In http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000856.html
>>> > you mentioned the software is smart enough to work out how to combine
>>> > different bands and what channels to use, so I see no reason to explicitly
>>> > chop up contiguous spectrum, unless there are explicit rules forbidding
>>> > combined use of bands with different regulatory rules. AFAIK the FCC
>>> > only requires one to satisfy all rules when usage crosses band boundaries.
>>> >
>>> > http://lists.infradead.org/pipermail/wireless-regdb/2015-July/000857.html
>>> > also raises a similar question.
>>
>> I was really commenting about the transmit power updates in your patch.
>> I just compared the frequency changes to the documentation you linked to
>> and those do look okay to me.
>
> I see.
>
>>> >> I would however consider an update for 5.15-5.25 GHz and 5.6-5.65 GHz
>>> >> provided that there's official documentation to substantiate the change.
>>> >> I unfortunately cannot read Chinese, so I would need some assistance to
>>> >> confirm the documentation.
>>> >
>>> > I could possibly ask around, though I'm not optimistic. The "official"
>>> > documents are just transcripts from NCC hosted Q&A sessions regarding
>>> > the latest regulations. Proposals/questions are submitted by vendors,
>>> > and the NCC responds and puts together an aggregated transcript.
>>>
>>> Just got off the phone with the NCC. Their position is, spectrum allocation
>>> is not within their purview, but the Ministry of Transportation and
>>> Communications. As noted in the patch, they have already opened up the
>>> spectrum to U-NII and low power radio usage. What remains is that the
>>> NCC revise its testing standards. Until then, their position is that,
>>> since their testing standards are modeled after FCC standards, vendors
>>> can just test under FCC standards, then convert the reports into LP0002
>>> format, and cite the FCC test report.
>>>
>>> There is no formal English version of the Q&A transcript, at least not
>>> until some foreign testing body requests it. The person in charge just
>>> asked me to translate it myself...
>>
>> If you send a patch which updates only the frequencies I would likely
>> apply that after allowing a week or so for others to either ack or nack
>> it (and running the stuff you linked to through google translate and
>> seeing if I could make any sense of the output).
>
> Got it.
>
>> I think the power updates are probably based on a misunderstanding, and
>> may not even be completely correct. For the most part after they've been
>> converted to EIRP (eirp = 10 * log10(mW)) they don't turn out to be
>> substantially different than what we have now. I think the value in
>> 5250-5350 MHz is probably incorrect however. Based on my quick skim of
>> the document you linked to it should be 50 mW rather than 250. 50 mW
>> also roughly matches to the 17 dBm which is in the database today,
>> whereas 250 mW is closer to 24 dBm.
>
> Yes. About the first part, it seems dbparse.py converts values in mW
> into EIRP anyway. However I don't think EIRT equals "peak power spectral
> density".
Sorry, this part applies to the US rules, not part of this patch.
> About the second part, yes the current values match the ones in LP0002.
> However as I stated, the regulatory body has explicitly allowed certifying
> under the latest FCC rules, which effectively raises the limits from
> 50 mW to 250 mW.
>
>> My suggestion would be update the frequencies but not the existing
>> transmit power limits, unless you discover that any of the power limits
>> are definitely incorrect.
>
> I'll split up the patch into 3:
>
> 1. Add the new 5150 - 5250 frequency band, using current LP0002
> limits if any, otherwise FCC limits.
>
> 2. Tweak frequency boundaries for the remaining bands to make
> them contiguous and properly reflect the regulations rather
> than the WiFi channel frequencies.
>
> 3. Update power limits and DFS requirements to latest FCC standards.
>
> Each patch will then explain why and how the regulations changed
> along with references, in English if available.
>
> You can then decide on whether to merge all three or just the first
> two.
>
>
> Regards
> ChenYu
On Tue, Jul 07, 2015 at 04:07:15PM +0800, Chen-Yu Tsai wrote:
> Taiwan's Ministry of Transportation and Communications revised its
> frequency allocation rules [1], specifically opening up 5.15 GHz ~
> 5.25 GHz and 5.6 GHz ~ 5.65 GHz for U-NII applications, as well as
> explicitly mentioning U-NII applications and DFS requirements for
> the related frequency ranges.
>
> LP0002 [2], the technical standard for low power radio devices, hasn't
> been updated,though work is under way. The NCC, Taiwan's equivalent of
> the US FCC, has explicitly [3][4] allowed certification under the newest
> FCC Part 15E limitations, though unwanted emissions must still conform
> to LP0002 sections 2.7 ~ 2.8:
>
> - 5150 MHz ~ 5250 MHz is not restricted to indoor usage.
>
> - 5250 MHz ~ 5350 MHz and 5470 MHz ~ 5725 MHz devices should have DFS
> capabilities, and conform to latest FCC radar standards.
>
> - 5250 MHz ~ 5350 MHz without DFS capabilities are limited to indoor
> usage, under current LP0002 restrictions.
>
> In addition, large channels across multiple U-NII bands are allowed
> under the same rules as FCC KDB 644545 [5].
>
> This patch updates the regulatory rules for Taiwan (TW) to reflect the
> changes noted above, and corrects transmit power limits for 5470 MHz ~
> 5725 MHz. In addition, the format of the rules has been modified:
>
> - List band boundaries, instead of channel boundaries, and add AUTO-BW
> for adjacent bands.
>
> - List maximum transmit power using mW instead of dBm. This is easier
> to find from the related documents.
>
> [1] http://www.motc.gov.tw/websitedowndoc?file=post/201411171137330.doc&filedisplay=Table+of+radio+frequency+allocation.doc
> [2] http://www.ncc.gov.tw/english/show_file.aspx?table_name=news&file_sn=681
> [3] http://www.rheintech.com/our-blog/item/585-taiwan-ncc-opens-5150-5250-mhz-for-wireless-devices
> [4] Proposal #10312260 (p.6, Chinese),
> http://www.etc.org.tw/_library/K00/%E9%9B%BB%E4%BF%A1%E7%B5%82%E7%AB%AF%E8%A8%AD%E5%82%99%E5%AF%A9%E9%A9%97/1031223_nccqa56.pdf
> [5] Proposal #10202205 (p.3, Chinese),
> http://www.etc.org.tw/_library/K00/%E4%BD%8E%E5%8A%9F%E7%8E%87%E8%A8%AD%E5%82%99%E5%AF%A9%E9%A9%97/1020221_nccqa50.pdf
>
> Signed-off-by: Chen-Yu Tsai <[email protected]>
> ---
>
> Hi everyone,
>
> First of all, I am _not_ a regulatory or wireless expert, nor is my
> field of work related, unless you count deploying access points as
> related.
>
> Last week I bought and deployed a new "Tri-band" 802.11ac wireless
> router, and it was using channels 36~44, which previously was not
> available in Taiwan. After asking around, a friend at the vendor
> said that Taiwan recently opened up that part of the spectrum.
>
> Unfortunately, [4][5] are Q&As transcripts with the regulatory body.
> I cound only find them in Chinese. Suffice to say, Taiwan's NCC
> follows the FCC closely whenever possible when it comes to wireless
> stuff.
>
> As such, I also looked at the US rules. It seems they are using
> "peak power spectral density" instead of "peak power output".
> I believe this is wrong. My crude understanding is the former
> is the amount of power in a single chunk of the complete channel,
> while the latter is the actual power put out by the transmitter.
> The former would be used to enforce a more uniform power distribution
> over the wireless channel, while the later actually limits transmission
> power, and thus range.
I certainly don't qualify as a regulatory expert either. But the rules
you're proposing to change came from Qualcomm Atheros, and I do have
considerable confidence in their regualtory expertise. Therefore I'd
want an ack from QCA before I'd consider applying this patch.
I would however consider an update for 5.15-5.25 GHz and 5.6-5.65 GHz
provided that there's official documentation to substantiate the change.
I unfortunately cannot read Chinese, so I would need some assistance to
confirm the documentation.
Thanks,
Seth