To reiterate a few points made in last email and add a new important point c)... a) I recommend anyone submitting changes to the table use dBm instead of mW values. This is simply for consistency. The regulatory rules quote all sorts of different definitions of tx power (i.e 'PSD in mW/MHz', 'peak EIRP', 'max dBm'). But if this table is meant as sw (rather than just a reference doc), then I suggest using the same units throughout. b) Yes, Finland should follow the same "ETSI1" values used for most of the other EU countries. EU member states sometimes have minor differences in transposition of the harmonized standards, but it is the harmonized standards that must be used for regulatory conformance and CE Marking/import across all the EU countries. In other words the R&TTE Directive and ETSI EN 301 328 (for 2.4GHz) and EN301 893 (for 5GHz) are "the overriding law for compliance across all the European Community countries (ie allowed tx power, modulations and channels). c) I think the group should review the documentation/comments that accompany the regdbase to explain clearly to implementers... i) Tx power values in the dbase are in EIRP - meaning the device's conducted tx power plus individual device's antenna gain (in 2.4 & 5GHz) must be below the EIRP values in the dbase. If a product simply sets conducted tx power to the value in the dbase and the product has an antenna with positive gain, then end product will (unintentionally) not comply with most countries limits. ii) Implementers must ensure the complete radio device/system passes regulatory compliance and receives radio certification for target countries. Actual antenna gain is taken into account during regulatory compliance testing of the system (hw + sw). Resulting compliant levels can be (IMO must be) programmed into a radio's hw/EEPROM. This prevents possible non-compliance per i). An important aside for this group to understand...it is rare that any radio device can be legally set to the "tx power" value that appears in a countries published rules. Reason is that tx power is just one of many required compliance tests. It is often spurious emissions, harmonics and power spectral density tests that limit the compliant tx power to levels sometimes much lower than the simple "peak EIRP" limit quoted in the rules. My point here is to reiterate the need to educate implementers to take responsibility and understand the complete radio product (hw+sw) must meet regulatory rules. Implementers cannot at all rely on this regdbase to ensure the device maintains compliance with the rules. iii) Can someone please explain if/how antenna gain is entered into sw for a product? This is one possible root for vendors who don't program in compliance test results into their hw to adjust down actual tx power compared to the EIRP values in the regdbase. Michael Green Atheros Communications, Inc. mgreen@xxxxxxxxxxx Desk: +1-781-400-1491 Mobile: +1-508-380-4921 -----Original Message----- From: Pekka Pietikainen [mailto:pp@xxxxxxxxxx] Sent: Friday, May 28, 2010 8:43 AM To: Luis R. Rodriguez Cc: Michael Green; David Quan; linville@xxxxxxxxxxxxx; linux-wireless@xxxxxxxxxxxxxxx Subject: Re: wireless-regdb: FI/CZ updates On Wed, May 26, 2010 at 11:30:37AM -0700, Luis R. Rodriguez wrote: > Pekka, please remove these changes from this patch, you want to make > your patches atomic, with only one purpose to help the review process > easier. You stashed changes to CZ & FI on one... You also switched > from dBm to mW and note how you actually did change the EIRP here for > only one for FI. Please provide a separate set of patches for that for > FI. If you want to switch to mW for all of the entries for FI first do > that, and then on a separate patch make the actual regulatory changes > so this is crystal clear for the review process. Okie Looking at it a bit more probably makes sense to codify the current harmonized EU rules, and then just for each country note that they've actually implemented it in their local legislation (I checked FI, SE and CZ). Everyone should have, but some are pretty slow at this, or have some special national interests... The legislation uses mW, so that's the reason I switched them. For review (first hit on google for the decision number should find the official text), I can do patches once someone has verified, that this is what the legalese actually says: # EU Commission Decision 2009/381/EC (2400 - 2483.5 @ 40), (N/A, 100mW) # 2005/513/EC and 2007/90/EC, 5250 and 5470 can be doubled if TPC is in use (5150 - 5250 @ 40), (N/A, 200mW), NO-OUTDOOR (5250 - 5350 @ 40), (N/A, 100mW), NO-OUTDOOR, DFS (5470 - 5725 @ 40), (N/A, 500mW), DFS ��.n��������+%������w��{.n�����{���zW����ܨ}���Ơz�j:+v�����w����ޙ��&�)ߡ�a����z�ޗ���ݢj��w�f
