[wireless-regdb] wireless-regdb: Regulatory rules for Hong Kong (HK)

[wireless-regdb] wireless-regdb: Regulatory rules for Hong Kong (HK)

[tavio.wong]

Hello,

According to section 2.1(b) of [1], the allowed peak output power in different bands is higher than currently defined in db.txt. I see that the rules for HK have not been updated since 2014. Since I don't understand sections 2.2 and 2.3, is there any reason for limiting the output power other than that the information is outdated?

If not, I propose the rules for HK be updated as follows [section 2.1(a) also requires that 5.15-5.35 GHz be restricted to indoor use]:

country HK: DFS-ETSI
	(2402 - 2482 @ 40), (36)
	(5170 - 5250 @ 80), (23), AUTO-BW, NO-OUTDOOR
	(5250 - 5330 @ 80), (23), DFS, AUTO-BW, NO-OUTDOOR
	(5490 - 5710 @ 160), (30), DFS
	(5735 - 5835 @ 80), (36)

Thank you for your consideration.

[1] https://www.ofca.gov.hk/filemanager/ofca/en/content_401/hkca1039.pdf

[2] https://git.kernel.org/pub/scm/linux/kernel/git/sforshee/wireless-regdb.git/tree/db.txt?id=7f7a9f7bc6011b072b5427eced1ff19261764e95#n751

Best regards,
Tavio

_______________________________________________
wireless-regdb mailing list
wireless-regdb@lists.infradead.org
http://lists.infradead.org/mailman/listinfo/wireless-regdb

Re: [wireless-regdb] wireless-regdb: Regulatory rules for Hong Kong (HK)

[Seth Forshee]

On Wed, Mar 15, 2023 at 02:37:16PM +0000, tavio.wong wrote:
> Hello,
> 
> According to section 2.1(b) of [1], the allowed peak output power in different bands is higher than currently defined in db.txt. I see that the rules for HK have not been updated since 2014. Since I don't understand sections 2.2 and 2.3, is there any reason for limiting the output power other than that the information is outdated?
> 
> If not, I propose the rules for HK be updated as follows [section 2.1(a) also requires that 5.15-5.35 GHz be restricted to indoor use]:

Thanks for the proposed updates. I have a few adjustments to suggest,
below.

> country HK: DFS-ETSI
> 	(2402 - 2482 @ 40), (36)

Here and in other rules I'd suggest adjusting the ranges based on the
regulations rather than aligning them based on wifi channels. So here
use 2400 - 2483.5 instead, etc.

> 	(5170 - 5250 @ 80), (23), AUTO-BW, NO-OUTDOOR
> 	(5250 - 5330 @ 80), (23), DFS, AUTO-BW, NO-OUTDOOR
> 	(5490 - 5710 @ 160), (30), DFS

This range actually extends to 5725 MHz. But since the subsequent range
has looser restrictions, we can do what we've done with some other
countries and extend the rule to 5730 MHz to allow use of channel 144.

The document references the technical requirements from the FCC rules
for 5150-5350 and 5470-5725 MHz, which requires TPC when the EIRP is
over 500 mW. The 5250-5350 MHz rule should be okay, but the 5470-5725
MHz rule needs to have the max EIRP lowered to 500 mW (27 dBm).

Thanks,
Seth

> 	(5735 - 5835 @ 80), (36)
> 
> Thank you for your consideration.
> 
> [1] https://www.ofca.gov.hk/filemanager/ofca/en/content_401/hkca1039.pdf
> 
> [2] https://git.kernel.org/pub/scm/linux/kernel/git/sforshee/wireless-regdb.git/tree/db.txt?id=7f7a9f7bc6011b072b5427eced1ff19261764e95#n751
> 
> Best regards,
> Tavio
> 
> _______________________________________________
> wireless-regdb mailing list
> wireless-regdb@lists.infradead.org
> http://lists.infradead.org/mailman/listinfo/wireless-regdb

_______________________________________________
wireless-regdb mailing list
wireless-regdb@lists.infradead.org
http://lists.infradead.org/mailman/listinfo/wireless-regdb

Re: [wireless-regdb] wireless-regdb: Regulatory rules for Hong Kong (HK)

[tavio.wong]

Thanks for the feedback.

I have adjusted the rules as follows based on your suggestions and further research on FCC rules:

country HK: DFS-ETSI
	(2400 - 2483.5 @ 40), (30)
	(5150 - 5250 @ 80), (23), AUTO-BW, NO-OUTDOOR
	(5250 - 5350 @ 80), (23), DFS, AUTO-BW, NO-OUTDOOR
	(5470 - 5725 @ 160), (24), DFS
	(5725 - 5850 @ 80), (30)

1. The ranges have been adjusted to align with HK regulations.

2. For 2400-2483.5 MHz, max power is set to 1 W (30 dBm) based on [1] 47 CFR 15.247(b)(3).

3. For 5470-5725 MHz, max power is set to 250 mW (24 dBm) based on [2] 47 CFR 15.407(a)(2).

4. For 5725-5850 MHz, max power is set to 1 W (30 dBm) based on [3] 47 CFR 15.407(a)(3)(i).

5. 5725-5730 MHz (Channel 144) is already covered by the last range (5725-5850 MHz) so no changes are necessary.

I have also cross-checked the limits to make sure they don't exceed those in the rules for US. The only difference in limits is in 5250-5350 MHz where HK regulations further restrict it to 200 mW (23 dBm).

One last suggestion: I noticed 6 GHz band is allowed for outdoor use at a max of 14 dBm (Section 3.2 of [4]) though it's only for licensed devices. Can it also be added to the rules as below?
	(5925 - 6425 @ 160), (14)

Thanks again for your time.

[1] https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-C/subject-group-ECFR2f2e5828339709e/section-15.247#p-15.247(b)(3)

[2] https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-E/section-15.407#p-15.407(a)(2)

[3] https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-E/section-15.407#p-15.407(a)(3)(i)

[4] https://www.ofca.gov.hk/filemanager/ofca/en/content_401/hkca1081.pdf

Best Regards,
Tavio

------- Original Message -------
On Wednesday, March 22nd, 2023 at 01:12, Seth Forshee <sforshee@kernel.org> wrote:


> On Wed, Mar 15, 2023 at 02:37:16PM +0000, tavio.wong wrote:
> 
> > Hello,
> > 
> > According to section 2.1(b) of [1], the allowed peak output power in different bands is higher than currently defined in db.txt. I see that the rules for HK have not been updated since 2014. Since I don't understand sections 2.2 and 2.3, is there any reason for limiting the output power other than that the information is outdated?
> > 
> > If not, I propose the rules for HK be updated as follows [section 2.1(a) also requires that 5.15-5.35 GHz be restricted to indoor use]:
> 
> 
> Thanks for the proposed updates. I have a few adjustments to suggest,
> below.
> 
> > country HK: DFS-ETSI
> > (2402 - 2482 @ 40), (36)
> 
> 
> Here and in other rules I'd suggest adjusting the ranges based on the
> regulations rather than aligning them based on wifi channels. So here
> use 2400 - 2483.5 instead, etc.
> 
> > (5170 - 5250 @ 80), (23), AUTO-BW, NO-OUTDOOR
> > (5250 - 5330 @ 80), (23), DFS, AUTO-BW, NO-OUTDOOR
> > (5490 - 5710 @ 160), (30), DFS
> 
> 
> This range actually extends to 5725 MHz. But since the subsequent range
> has looser restrictions, we can do what we've done with some other
> countries and extend the rule to 5730 MHz to allow use of channel 144.
> 
> The document references the technical requirements from the FCC rules
> for 5150-5350 and 5470-5725 MHz, which requires TPC when the EIRP is
> over 500 mW. The 5250-5350 MHz rule should be okay, but the 5470-5725
> MHz rule needs to have the max EIRP lowered to 500 mW (27 dBm).
> 
> Thanks,
> Seth
> 
> > (5735 - 5835 @ 80), (36)
> > 
> > Thank you for your consideration.
> > 
> > [1] https://www.ofca.gov.hk/filemanager/ofca/en/content_401/hkca1039.pdf
> > 
> > [2] https://git.kernel.org/pub/scm/linux/kernel/git/sforshee/wireless-regdb.git/tree/db.txt?id=7f7a9f7bc6011b072b5427eced1ff19261764e95#n751
> > 
> > Best regards,
> > Tavio
> > 
> > _______________________________________________
> > wireless-regdb mailing list
> > wireless-regdb@lists.infradead.org
> > http://lists.infradead.org/mailman/listinfo/wireless-regdb

_______________________________________________
wireless-regdb mailing list
wireless-regdb@lists.infradead.org
http://lists.infradead.org/mailman/listinfo/wireless-regdb

Re: [wireless-regdb] wireless-regdb: Regulatory rules for Hong Kong (HK)

[Seth Forshee]

On Wed, Mar 22, 2023 at 03:14:41PM +0000, tavio.wong wrote:
> Thanks for the feedback.
> 
> I have adjusted the rules as follows based on your suggestions and further research on FCC rules:
> 
> country HK: DFS-ETSI
> 	(2400 - 2483.5 @ 40), (30)
> 	(5150 - 5250 @ 80), (23), AUTO-BW, NO-OUTDOOR
> 	(5250 - 5350 @ 80), (23), DFS, AUTO-BW, NO-OUTDOOR
> 	(5470 - 5725 @ 160), (24), DFS
> 	(5725 - 5850 @ 80), (30)
> 
> 1. The ranges have been adjusted to align with HK regulations.
> 
> 2. For 2400-2483.5 MHz, max power is set to 1 W (30 dBm) based on [1] 47 CFR 15.247(b)(3).
> 
> 3. For 5470-5725 MHz, max power is set to 250 mW (24 dBm) based on [2] 47 CFR 15.407(a)(2).
> 
> 4. For 5725-5850 MHz, max power is set to 1 W (30 dBm) based on [3] 47 CFR 15.407(a)(3)(i).
> 
> 5. 5725-5730 MHz (Channel 144) is already covered by the last range (5725-5850 MHz) so no changes are necessary.
> 
> I have also cross-checked the limits to make sure they don't exceed those in the rules for US. The only difference in limits is in 5250-5350 MHz where HK regulations further restrict it to 200 mW (23 dBm).

Since explicit power limits are given I think we should be able to use
those. The reference to the US rules probably refers to other
requirements. So for 3 we can use 27 dBm and for 4 we can use 36 dBm.

> 
> One last suggestion: I noticed 6 GHz band is allowed for outdoor use at a max of 14 dBm (Section 3.2 of [4]) though it's only for licensed devices. Can it also be added to the rules as below?
> 	(5925 - 6425 @ 160), (14)

Yes, we could do it this way, or use the 24 dBm limit with NO-OUTDOOR.

Thanks,
Seth

> 
> Thanks again for your time.
> 
> [1] https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-C/subject-group-ECFR2f2e5828339709e/section-15.247#p-15.247(b)(3)
> 
> [2] https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-E/section-15.407#p-15.407(a)(2)
> 
> [3] https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-E/section-15.407#p-15.407(a)(3)(i)
> 
> [4] https://www.ofca.gov.hk/filemanager/ofca/en/content_401/hkca1081.pdf
> 
> Best Regards,
> Tavio

_______________________________________________
wireless-regdb mailing list
wireless-regdb@lists.infradead.org
http://lists.infradead.org/mailman/listinfo/wireless-regdb

Re: [wireless-regdb] wireless-regdb: Regulatory rules for Hong Kong (HK)

[tavio.wong]

On Sunday, April 16th, 2023 at 8:00 AM, Seth Forshee <sforshee@kernel.org> wrote:
> On Wed, Mar 22, 2023 at 03:14:41PM +0000, tavio.wong wrote:
> 
> > Thanks for the feedback.
> > 
> > I have adjusted the rules as follows based on your suggestions and further research on FCC rules:
> > 
> > country HK: DFS-ETSI
> > (2400 - 2483.5 @ 40), (30)
> > (5150 - 5250 @ 80), (23), AUTO-BW, NO-OUTDOOR
> > (5250 - 5350 @ 80), (23), DFS, AUTO-BW, NO-OUTDOOR
> > (5470 - 5725 @ 160), (24), DFS
> > (5725 - 5850 @ 80), (30)
> > 
> > 1. The ranges have been adjusted to align with HK regulations.
> > 
> > 2. For 2400-2483.5 MHz, max power is set to 1 W (30 dBm) based on [1] 47 CFR 15.247(b)(3).
> > 
> > 3. For 5470-5725 MHz, max power is set to 250 mW (24 dBm) based on [2] 47 CFR 15.407(a)(2).
> > 
> > 4. For 5725-5850 MHz, max power is set to 1 W (30 dBm) based on [3] 47 CFR 15.407(a)(3)(i).
> > 
> > 5. 5725-5730 MHz (Channel 144) is already covered by the last range (5725-5850 MHz) so no changes are necessary.
> > 
> > I have also cross-checked the limits to make sure they don't exceed those in the rules for US. The only difference in limits is in 5250-5350 MHz where HK regulations further restrict it to 200 mW (23 dBm).
> 
> 
> Since explicit power limits are given I think we should be able to use
> those. The reference to the US rules probably refers to other
> requirements. So for 3 we can use 27 dBm and for 4 we can use 36 dBm.

OK.

> 
> > One last suggestion: I noticed 6 GHz band is allowed for outdoor use at a max of 14 dBm (Section 3.2 of [4]) though it's only for licensed devices. Can it also be added to the rules as below?
> > (5925 - 6425 @ 160), (14)
> 
> 
> Yes, we could do it this way, or use the 24 dBm limit with NO-OUTDOOR.

I guess I will leave it this way for now so that the band is usable in both indoor and outdoor settings.

Based on the latest discussion, I have updated the rules as below:

# Source:
# https://www.ofca.gov.hk/filemanager/ofca/en/content_401/hkca1039.pdf (2.4 GHz and 5 GHz)
# https://www.ofca.gov.hk/filemanager/ofca/en/content_401/hkca1081.pdf (6 GHz)
country HK: DFS-ETSI
        (2400 - 2483.5 @ 40), (36)
        (5150 - 5250 @ 80), (23), AUTO-BW, NO-OUTDOOR
        (5250 - 5350 @ 80), (23), DFS, AUTO-BW, NO-OUTDOOR
        (5470 - 5725 @ 160), (27), DFS
        (5725 - 5850 @ 80), (36)
        (5925 - 6425 @ 160), (14)

If the rules look fine to you, I will try to submit a patch for this change.

Thanks for your time and your help!

Regards,
Tavio

> 
> Thanks,
> Seth

_______________________________________________
wireless-regdb mailing list
wireless-regdb@lists.infradead.org
http://lists.infradead.org/mailman/listinfo/wireless-regdb

Re: [wireless-regdb] wireless-regdb: Regulatory rules for Hong Kong (HK)

[Seth Forshee]

On Sun, Apr 16, 2023 at 04:14:19PM +0000, tavio.wong wrote:
> 
> On Sunday, April 16th, 2023 at 8:00 AM, Seth Forshee <sforshee@kernel.org> wrote:
> > On Wed, Mar 22, 2023 at 03:14:41PM +0000, tavio.wong wrote:
> > 
> > > Thanks for the feedback.
> > > 
> > > I have adjusted the rules as follows based on your suggestions and further research on FCC rules:
> > > 
> > > country HK: DFS-ETSI
> > > (2400 - 2483.5 @ 40), (30)
> > > (5150 - 5250 @ 80), (23), AUTO-BW, NO-OUTDOOR
> > > (5250 - 5350 @ 80), (23), DFS, AUTO-BW, NO-OUTDOOR
> > > (5470 - 5725 @ 160), (24), DFS
> > > (5725 - 5850 @ 80), (30)
> > > 
> > > 1. The ranges have been adjusted to align with HK regulations.
> > > 
> > > 2. For 2400-2483.5 MHz, max power is set to 1 W (30 dBm) based on [1] 47 CFR 15.247(b)(3).
> > > 
> > > 3. For 5470-5725 MHz, max power is set to 250 mW (24 dBm) based on [2] 47 CFR 15.407(a)(2).
> > > 
> > > 4. For 5725-5850 MHz, max power is set to 1 W (30 dBm) based on [3] 47 CFR 15.407(a)(3)(i).
> > > 
> > > 5. 5725-5730 MHz (Channel 144) is already covered by the last range (5725-5850 MHz) so no changes are necessary.
> > > 
> > > I have also cross-checked the limits to make sure they don't exceed those in the rules for US. The only difference in limits is in 5250-5350 MHz where HK regulations further restrict it to 200 mW (23 dBm).
> > 
> > 
> > Since explicit power limits are given I think we should be able to use
> > those. The reference to the US rules probably refers to other
> > requirements. So for 3 we can use 27 dBm and for 4 we can use 36 dBm.
> 
> OK.
> 
> > 
> > > One last suggestion: I noticed 6 GHz band is allowed for outdoor use at a max of 14 dBm (Section 3.2 of [4]) though it's only for licensed devices. Can it also be added to the rules as below?
> > > (5925 - 6425 @ 160), (14)
> > 
> > 
> > Yes, we could do it this way, or use the 24 dBm limit with NO-OUTDOOR.
> 
> I guess I will leave it this way for now so that the band is usable in both indoor and outdoor settings.
> 
> Based on the latest discussion, I have updated the rules as below:
> 
> # Source:
> # https://www.ofca.gov.hk/filemanager/ofca/en/content_401/hkca1039.pdf (2.4 GHz and 5 GHz)
> # https://www.ofca.gov.hk/filemanager/ofca/en/content_401/hkca1081.pdf (6 GHz)
> country HK: DFS-ETSI
>         (2400 - 2483.5 @ 40), (36)
>         (5150 - 5250 @ 80), (23), AUTO-BW, NO-OUTDOOR
>         (5250 - 5350 @ 80), (23), DFS, AUTO-BW, NO-OUTDOOR
>         (5470 - 5725 @ 160), (27), DFS
>         (5725 - 5850 @ 80), (36)
>         (5925 - 6425 @ 160), (14)
> 
> If the rules look fine to you, I will try to submit a patch for this change.

Sorry, just noticed that I hadn't responded.

That looks fine. I'd suggest also slightly tweaking the bands like this:

        (5470 - 5730 @ 160), (27), DFS
        (5730 - 5850 @ 80), (36)

We do this for some other countries so that channel 144 is usable, and
since 5470-5725 is more restrictive than 5725-5850 it doesn't pose any
problems.

Please go ahead and submit a patch!

Thanks,
Seth

_______________________________________________
wireless-regdb mailing list
wireless-regdb@lists.infradead.org
http://lists.infradead.org/mailman/listinfo/wireless-regdb