DA 20-497 Released: May 7, 2020 OFFICE OF ENGINEERING AND TECHNOLOGY SEEKS COMMENT ON RADWIN LTD’S REQUEST FOR EMERGENCY WAIVER OF SECTION 15.407(A) OF THE RULES FOR UNLICENSED NATIONAL INFORMATION INFRASTRUCTURE DEVICES IN THE 5.15-5.25 GHZ AND 5.725-5.85 GHZ BANDS ET Docket No. 20-128 Comment Date: May 15, 2020 Reply Comment Date: May 20, 2020 On May 1, 2020, RADWIN Ltd. (RADWIN) filed an emergency request for a waiver of Section 15.407(a) of the Commission’s rules to allow the operation of Unlicensed National Information Infrastructure (U-NII) devices in the 5.15-5.25 GHz and 5.725-5.85 GHz bands that emit multiple directional beams at power levels that exceed the limits for point-to-multipoint systems. The Commission’s Office of Engineering and Technology (OET) seeks comment on this request. RADWIN states that the waiver will permit its customers to provide better high-speed broadband service to subscribers so that they can stay connected and access essential services during the COVID-19 pandemic. It states that increased power will provide improved system performance, including capacity and robustness, both of which are key to getting and keeping more of those customers’ end users online at the same time. RADWIN further states that this relief is particularly critical to customers in remote areas, many of whom have limited access to health care during usual conditions and will increasingly rely on telehealth during the current pandemic. Section 15.407(a) of the Commission’s rules permits U-NII devices to operate in the 5.15-5.25 GHz and 5.725-5.85 GHz bands with a maximum conducted power output of one watt (30 dBm) and with an antenna gain of up to 6 dBi, i.e., an EIRP limit of 36 dBm. If an antenna with a maximum directional gain of greater than 6 dBi is used, the conducted power output must be reduced below 30 dBm by the amount in dB that the antenna gain exceeds 6 dBi so that the maximum EIRP does not exceed 36 dBm. Antennas with a gain greater than 6 dBi may be used without a corresponding reduction in conducted power output if operation is limited to fixed point-to-point applications; point-to-multipoint systems are explicitly excluded from this provision. RADWIN is seeking a waiver to permit the operation for a limited time in certain specified areas of point-to-multipoint systems that use multiple sequential beams with up to 28 dBm conducted power output and antenna gains of 20 dBi to produce an EIRP of up to 48 dBm, i.e., 12 dB above the limit. OET seeks comment on the waiver request. OET has concluded that, in order to develop a complete record on the issues presented by this request, this proceeding will be treated, for ex parte purposes, as "permit-but-disclose" in accordance with Section 1.1200(a) of the Commission's rules, subject to the requirements under Section 1.1206(b). Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 CFR §§ 1.415, 1.419, interested parties may file comments and reply comments on or before the dates indicated on the first page of this document. Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS). See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998). § Electronic Filers: Comments may be filed electronically using the Internet by accessing the ECFS: http://apps.fcc.gov/ecfs/. § Paper Filers: Parties who choose to file by paper must file an original and one copy of each filing. If more than one docket or rulemaking number appears in the caption of this proceeding, filers must submit two additional copies for each additional docket or rulemaking number. § Filings can be sent by commercial overnight courier, or by first-class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission’s Secretary, Office of the Secretary, Federal Communications Commission. § Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent to 9050 Junction Drive, Annapolis Junction, MD 20701.U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street, SW, Washington DC 20554 § Effective March 19, 2020, and until further notice, the Commission no longer accepts any hand or messenger delivered filings. This is a temporary measure taken to help protect the health and safety of individuals, and to mitigate the transmission of COVID-19. See FCC Announces Closure of FCC Headquarters Open Window and Change in Hand-Delivery Policy, Public Notice, DA 20-304 (March 19, 2020). https://www.fcc.gov/document/fcc-closes-headquarters-open-window-and-changes-hand-delivery-policy People with Disabilities: To request materials in accessible formats for people with disabilities (braille, large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty). Parties should also send a copy of their filings to Hugh L. Van Tuyl, Office of Engineering and Technology, Federal Communications Commission, Room 7-A162, 445 12th Street, S.W., Washington, D.C. 20554, or by e-mail to Hugh.VanTuyl@fcc.gov. Office of Engineering and Technology contact: Hugh L. Van Tuyl at 202-418-7506. By the Acting Chief, Office of Engineering and Technology -FCC- 2