Some operators of Fixed Wireless Access (FWA) broadband ISP networks in the UK have expressed concern to ISPreview after Ofcom appeared to toughen their stance on the compliance of related hardware with their rules. Some providers fear this could effectively ban their kit, reduce choice in the market and push up costs.
The issue stems from a speech on “Compliance and Spectrum” that Ofcom’s Enforcement Manager, Ken Johnson, recently gave to the UK Wireless Internet Service Providers Association (UKWISPA) at an event in London during late March 2023. As part of that, Ken highlighted some of the action being planned under the Wireless Telegraphy regulations.
One of Ofcom’s slides touched on the issue of country selection and Dynamic Frequency Selection (DFS). In particular, the slide appeared to suggest that any wireless kit which lets you tell it which country it is in at the time (as some countries might not enforce DFS) may not be legal in the UK. Even if you do NOT change the country away from UK, or turn off DFS. So just the chance that you could change this, may make it a problem.
The issue is that virtually every brand of wireless kit, Ubiquiti, Cambium etc., except for a few like Mimosa (they use GPS+text message based activation to have a good feel for where in the world it is at the time), allows you to choose the country.
Extract from Ofcom’s Slide
The user restrictions in para 4.2.9 of EN 301 893 state that equipment should be so constructed so that equipment (hardware and/or software) shall not be accessible to the user, if changing those settings results in the equipment no longer being compliant with the DFS requirements.
(Example: If you can select a country code that allows DFS to be disabled, the equipment does not meet all the requirements of IR2030 and cannot be used under the licence exemption in the UK).
The regulator also seems to want the Declaration of Conformity (DOC) for each device to specify the firmware version (they don’t currently do this), which is tedious as it could mean that any new firmware release then would not be compliant unless it has a new DOC issued. But this could make tackling 0-day style security flaws or major bugs with rapid software/firmware updates tedious (delays due to bureaucracy), which could conflict with the NCSC’s new security advice (i.e. requires rapid updates).
The measures appear to indicate that Ofcom may be taking a tougher line against importers of related kit (e.g. Ubiquiti). One way around this would be for each vendor to both manufacture and ship a UK-only model of each device, but that would be tricky because most companies create a global model and then adapt it to each country via software/firmware changes. Not every vendor will be able to build a UK-specific model, and that could reduce supply, while also raising equipment costs.
However, a spokesperson for Ofcom told ISPreview that they have a “duty to protect and manage the radio spectrum” and have “not made lots of wireless broadband kit illegal,” but they also added that there are cases where radio equipment does not work properly to the detriment of other spectrum users (e.g. RLAN equipment is attributed to “causing widespread interference to meteorological radar” in the UK).
The regulator’s presentation was thus designed to emphasise how important it is to “exercise due diligence to ensure that equipment is safe and compliant” with their regulations.
A spokesperson for Ofcom said:
“Manufacturers must demonstrate that equipment meets the ‘essential requirements’ set out in the regulations. This is normally achieved by referencing a recognised technical standard. Equipment that meets all elements of an appropriate standard is presumed to meet the ‘essential requirements’.
Manufacturers of RLAN equipment normally reference a technical standard ETSI EN 301 893 V2.1.1 (2017-05). Ofcom has found that in many instances key elements of the standard are not met. Specifically, those that concern the functionality of systems specifically designed to avoid interference to meteorological radar.”
Part of Ofcom’s move to take a tougher line here may reflect that not every manufacturer of related kit has been as willing as some others to engage with the regulator on these issues, or so we’ve heard. At the end of the day, both providers and the regulator appear to have legitimate concerns, but finding common ground on some of these issues could be tricky. Much will depend on the flexibility of vendors when adapting to the changes.
UPDATE 27th April 2023 @ 8:09am
The Chairman of UKWISPA, David Burns, has kindly provided a little extra context on how the wider industry is responding to Ofcom’s measures.
David Burns told ISPreview.co.uk:
“I can confirm that we are pressing the manufacturers to improve their commitment to DFS compliance, as some recent testing suggested that certain equipment did not respond as expected when subjected to radar sources. We are also in constructive discussions with Ofcom and our members to help ensure that radar systems such as the Met Office can operate without disruption.
Our members work tirelessly to help both rural and urban communities to get superfast, Ultrafast and Gigabit broadband in some of the most challenging parts of the UK. We enjoy a great relationship with Ofcom, who have been very supportive in helping to identify and isolate the small amount of FWA equipment that has at times fallen short in some DFS tests.
We continue to work with Ofcom in this matter. Meanwhile, the largest growth areas for WISPs are in projects using frequency bands that are not affected by DFS. These include Band N77 (3.8 to 4.2 GHz) and V-Band (around 60 GHz) which provide huge capacities and are delivering 400 Mbps services in deep rural communities and Gigabit+ speeds in urban and suburban areas.
We expect these speeds to continue to increase in the next 12-months, with FWA re-establishing its position as an anchor technology for Project Gigabit alongside fibre.”
This is quite interesting in the 5Ghz space where there’s lots of P2P and P2MP deployments. Perhaps this will lead to killing off the budget wireless ISPs and leave just those who can afford 60Ghz or P2P microwave equipment.
I’ve seen installations across business parks, not even near an airport, where DFS is triggered frequently. That leads to a 10minute + drop in service each time for connected customers.
I know quite a few wireless ISPs who disable DFS to work around this…
True and legit, but it feels like to me the way Ofcom are doing this will just (as usual) add additional burdens on people and companies doing the right thing (or perhaps put them out of business, so mediocrity and money wins over things well done in some cases, despite the small scale) and those who just buy a kit off amazon and turn it on to get “the wifi in the garden too”. I’ve seen too many of those too and nothing that happens to put them under compliance.
Not to mention that IMHO this will put supplies in pause while manufacturers think about how to comply, meaning no stock available.
this only means that the product chosen has not been calibrated correctly for CCA-ED. Additionally any outdoor equipment ideally should be deployed using zero-wait DFS; where it only bars the triggered channel and can move immediately to another DFS channel without the need to undertake CAC
Was it Zimbabwe country code on Mikrotik giving you access to all channels in 5GHz band?
Ofcom are Sabre-rattling at WISPs about their ‘poor use of spectrum’ yet at the same time are making no efforts whatsoever to deal with CCTV installers such as Farmer’s Eye who throw up UBNT kit that blasts out 80Mhz channel width on Band C without the appropriate license for a 30m PtP hop feeding some CCTV cameras or Sky Q s**ting all over the spectrum with their horrific wireless implementation.
If they actually started being a bit more proactive about spectrum hygiene and engaged properly with the WISP industry rather than just showing up at our industry meetings to wave their d*** about, they might find that their lives got significantly easier.
If you have some technical data about how non-compliant these devices you have cited are, I would encourage you to report it formally.
@RobC +1
It’s easier to do press releases than actually do any actual enforcement.
@spurple
It is not his job to do this it is all on OFCOM.
@10BaseT
And how is that utopia you live in working out for you?
If you can help, then help. If it means OFCOM can spend time and money doing more then that’s a good thing isn’t it? Like all of these bodies they are starved of cash and time on purpose because they act against corporate greed and political donors. I’m no defender of OFCOM but if you’ve already done the work, have the evidence then send it in. Why make their job harder over some idealogical perfect world theory.
Yes they SHOULD have the time and money to do all of this. Yes it IS their job but you have a tiny minnow swimming in a tank with some very very large and wealthy sharks. Sharks that purposely pay off the government through lobbying to under fund and reduce the oversight OFCOM have. If someone can help redress that balance, even a tiny bit, then discouraging them from doing so is stupid.
@PoliticalGenius
No, I haven’t made any research. It is about OFCOM taking easy path and trying to solve just a piece of problem. If they don’t have money to do it properly then they shouldn’t start doing it in the first place.
You can do this with most enterprise kit not just Ubiquiti but wouldn’t class Ubiquiti as enterprise, seems unfair to point them out as an example when this is can be done on so many products.
Fair. They sit squarely in the SMB space.
The bump in price between SMB and full-on enterprise kit is notable.
Just to point out that Band n77 is 3.3-4.2GHz.