Early last month we reported on the adoption of new rules intended to beef up Wi-Fi operations across the country. Thanks to a notice in the Federal Register, we now know that those new rules (with one exception) will take effect on June 2, 2014. That starts a 12-month transition period (beginning with the June 2 effective date) by the end of which applications for certification of 5 GHz devices must meet the new and modified rules. IMPORTANT: Equipment manufacturers and operators who, prior to the effective date, installed outdoor U-NII-3 band systems that don’t comply with the new EIRP limits have until July 2, 2014 to file waiver requests. Not a big deal – the FCC has signaled it intends to grant these.
The one aspect of the new rules that is not subject to the effective date is Section 15.407(j). That section requires anybody “deploying an aggregate total of more than one thousand outdoor access points within the 5.15-5.25 GHz band” to first submit a letter to the Commission acknowledging that they will have to take corrective action should harmful interference to licensed services in the band occur. Since that submission requirement is, in the parlance of the hilariously-named Paperwork Reduction Act (PRA), an “information collection”, it must first be run past the Office of Management and Budget. That process, which generally takes four-six months or so, has also been initiated by a separate Federal Register notice.
PRA notices often contain curious nuggets, and this one is no exception. Again, Section 15.407(j) requires the preparation of a letter acknowledging responsibility for correcting interference. That’s what, maybe two-three paragraphs long, at most. And while we are loath to discourage the creative spirit, this type of letter appears ideal for a totally mechanistic, boilerplate approach. But the FCC’s “estimated time per response” for each respondent is a staggering 32 hours – that’s four full eight-hour days. Anyone charging by the hour for the preparation of such letters may want to make note of that estimate for future billing purposes.
Section 15.407(j) won’t take effect until OMB has signed off on it and the FCC has published a follow-up notice reporting on that. Check back here for updates.