Electronic Communications Act, 2005 (Act No. 36 of 2005) Regulations Radio Frequency Spectrum Amendment Regulations, 2021 Part IX - Annexures Annexure B Reasons Document for the Annexure B of the Radio Frequency Spectrum Regulations 2015 - December 2021 6. Application-Specific Submissions 6.6 WAS/RLANS

 

The reference for the band 5150-5250 MHz was ITU-R M.1652 while band 5250-5350 MHz and 5470-5725 MHz referenced CEPT/ERC/REC 70-03, ECC/DEC/(04)08, ITU-R M.1652 and ITU Res 229 (WRC-03)

 

The band 5150-5250 MHz had Channel Access Mechanism (Frame Based Equipment / Load Based Equipment) as an additional requirement, while band 5250-5350 MHz and 5470-5725 had DFS, TPC, and Channel Access Mechanism (Frame Based Equipment / Load Based Equipment) as additional requirements.

 

AMCHAM Proposed that the reference CEPT/ERC/REC 70-03 be removed for the bands 5150-5250 MHz, 5250-5350 MHz, and 5470-5725 MHz and be replaced by an ECC/DEC/(04)08.

 

Globalstar supports the Authority’s proposal to allow indoor deployments of WAS/RLANS with a power limit of 20 dBm in the 5150-5250 MHz band and further strongly argues and cautions against any future amendment that would allow the high-powered outdoor deployment.

 

IEEE802 MAN suggested the deployment of RLAN in the band 5150-5250MHz to be allowed for outdoor deployment.

 

WAPA is concerned by the reduction in allowable EIRP for outdoor WAS & RLAN applications from 1W/30dBm to 500mW/27dBm in the absence of Transmit Power Control (TPC) being employed in the band 5470-5725MHz. TPC is currently unsupported by most equipment deployed in the field by WAPA’s members, and the cost of replacement would impose a considerable economic burden on their members.

 

Bitco & WAPA is concerned by the addition of a Dynamic Frequency Selection (DFS) requirement for the band 5470-5725MHz, DFS functionality is currently unsupported by most equipment deployed in the field and recommends it be recalled because it will introduce additional hardware costs and the DFS technology may cause significant degradation of service.

 

WI-FI Alliance encourages the Authority to allow RLANs operating bands 5150-5250 MHz, 5250-5350 MHz, and 5470-5725 MHz to be considered for outdoor usage.

 

Furthermore, WI-FI Alliance recommends the Authority to allow License-Exempt Device in the 6 GHz Band (5925-7125 MHz) and extend it for RLAN/WLAN in preparation for the next Wi-Fi generation(s).

 

Telkom recommends that the notes from REC 70-03 that specify the maximum e.i.r.p. density limits in Column C be added to the RFSAR for the band 2400-2483.5 MHz, 5150-5250 MHz, 5250-5350 MHz, and 5470-5725 MHz.

 

Telkom requests clarity on what “Frame-based equipment/loadbased equipment” in Column E is, in the band 5150-5250 MHz and 5470-5725 MHz.

 

The Authority notes the proposal to remove the reference CEPT/ERC/REC 70-03 and replace it with ECC/DEC/(04)08 , however the Authority maintains that reference CEPT/ERC/REC 70-03 already contains the Decision ECC/DEC/(04)08, therefore referencing CEPT/ERC/REC 70-03, means the Decision is implied.

 

The Authority notes the submission regarding the power limit and outdoor deployment of WAS/RLANS in the 5150-5250 MHz band, however the Authority updated the power limit to 23 dBm in accordance with the prescribed performance standard SANS 301 893.

 

The Authority notes the submission about the reduced power in the absence of TPC and the addition of DFS for WAS/RLANS operating in the band 5470-5725 MHz, however TPC and DFS are not new requirements as they have always been requirements within the prescribed performance standard SANS 301 893.

 

The Authority notes the recommendation about allowing outdoor deployment of RLAN in the band 5150-5250MHz and 5250-5350 however, based on numerous interference complaints caused by the unauthorized outdoor deployment, the Authority maintained the position allowing only indoor deployment in those bands.

 

The Authority notes the recommendation to allow License-Exempt device in the 6 GHz Band (5925-7125 MHz) and extend it for RLAN/WLAN however the Authority wishes to advise that currently the band is assigned to licensees as contained in the National Radio Frequency Plan 2018.

 

The Authority notes the submission of including the power spectral density limits in the RFSAR for the bands 2400-2483.5 MHz, 5150-5250 MHz, 5250-5350 MHz, and 5470-5725 MHz, however power spectral density and other essential requirements as contained within the prescribed standards SANS 300 328 and SANS 301 893 still need to be complied with, and their exclusion in the RFSAR does not imply that they are not a requirement for conformance.

 

The Authority notes the submission requesting clarity for the terms “Frame-based equipment/load-based equipment” in Column E.

Frame based equipment is an equipment where the transmit/receive structure is not demand-driven but has fixed timing.

Load based equipment is an equipment where the transmit/receive structure is demand-driven.