Re: [WISPA] Modifications of =?WINDOWS-1252?Q?_Parts_2_and_15_of_the, Commis?= sion’s Rules for unlicensed d evices and, equipment approval

2007-04-25 Thread Lonnie Nunweiler

The software can allow non FCC modes as long as there is an option to
select FCC modes and not exceed either the power or frequency spectrum
limits while properly selected.

It would be a mistake to require the OS code to limit for FCC and US
operation.  The code can be changed and any number of things can be
done to make the unit operate outside of FCC requirements, plus this
is a world market and not everybody falls under FCC requirements.  In
fact the majority of people are in the category that is not FCC
scrutinized.

The point should be that the unit is certified to meet FCC
requirements if the user selects the US country code.  Just the same
as it would meet FCC requirements if they used a certified radio and a
certified antenna.  It really is up to the user to have a proper
radio, antenna and select the proper country code.

Government bodies can dictate all they want, but in the end it is up
to the individual to remain in compliance, and if they decide to
ignore certain things, then what does it really matter what the regs
demand that everybody else do?

This whole situation should come down to what is best for the majority
of the users who will operate responsibly and not make it more
difficult for the good guys while trying to force the bad guys to
comply.  It should be pretty obvious by now that some people will
ignore whatever rule you make, so why punish everybody?

The FCC seemed pretty pleased with the innovation that is happening
and the adoption of wireless for getting to the hard to reach users.
They seem to be wanting this trend to continue, and the loosening up
on certification requirements is a very good step that will encourage
even more of what everybody wants.

I do not think the FCC are trying to add roadblocks but rather are
attempting to encourage people to do it right and they seem to be
making it easier for that to happen. It is a very positive thing they
have done.




Lonnie

On 4/25/07, Jack Unger [EMAIL PROTECTED] wrote:

Scott,

I believe that your comments are substantially correct.

The main problem that I see with building our own equipment is that very
few (if any) manufacturers of modular wireless cards have certified them
with a range of usable external WISP-grade antennas. I don't think this
2nd Report and Order changes that. Also, remember that the software used
must limit operation of the complete system only to those frequencies
and power levels that are legal in the U.S.

jack


Scott Reed wrote:
 I haven't read it really well and I have not yet looked up the
 referenced sections of Part 15, but I read the part that is not about
 split modular to be the part the refers to a PC.  And I read it that
 if the PC is certified to have radio cards AND the radio card is
 certified with an antenna, then that PC, radio card and antenna can be
 used.

 So, if that is true, then Tim may be on the right track.  Jack is right,
 not any base, but I would read it that any certified base is doable.
 I have often wondered how it works for laptops, but hadn't bothered to
 find it.  This makes sense.  Ubiquiti certifies the CM9 card with a set
 of antennae.  Dell certifies the laptop for a radio card.  Putting a CM9
 in Dell's laptop is fine as long as it connects to an antenna, using the
 proper cable, that was certified with the CM9.

 Therefore, if MT can get an RBxxx board certified as a base unit, we
 should be able to use a CM9 in that RBxxx with the proper antenna and be
 good.  The gotcha here is those sections of Part 15 I have not yet
 followed up on.  I am not sure what the professional installer stuff
 is about.

 What am I missing or is this good news?

 Jack Unger wrote:
 Tim,

 I read the 2nd Report and Order and I don't see where it is saying
 that a certified mini PCI radio can be put into any base unit.

 I think what the FCC is doing is:

 1. Providing eight criteria that clarify the definition of what a
 legal modular assembly is.

 2. Allowing some flexibility regarding on-module shielding, data
 inputs, and power supply regulation.

 3. Clarifying the definition of what a split modular assembly is.

 4. Defining the (somewhat flexible) requirements that a split
 modular assembly must meet.

 Although a motherboard will certainly contain an operating system, I
 don't think that a mini PCI radio plugged into any motherboard meets
 the FCC's definition of a split modular assembly. I think the FCC
 considers a split modular assembly to be where circuitry that today
 would be contained on a single modular assembly is (now or in the
 future) split between two different physical assemblies. This
 splitting allows more equipment design flexibility because one
 transmitter control element (the new term that the FCC formerly
 called the module firmware) could theoretically be interfaced with
 and control more than one radio front end (the amplifier and
 antenna-connecting) section.

 Of course, that's just my interpretation. I'll bet others could add
 more detail. The 

Re: [WISPA] Modifications of =?WINDOWS-1252?Q?_Parts_2_and_15_of_the, Commis?= sion’s Rules for unlicensed d evices and, equipment approval

2007-04-25 Thread Lonnie Nunweiler

I'm curious how a Linux with madwifi is binary certified yet MT or
StarOS are not?  They all use Linux and have drivers traceable to
Atheros, just as the madwifi group code is.

Lonnie

On 4/25/07, Doug Ratcliffe [EMAIL PROTECTED] wrote:

Ok,

I can see several things in this ruling.  It's of course referring to
consumer installed PCI/USB/miniPCI(we sell retail boxed laptop wireless
cards for consumer install).  Well, these cards are certified SEPARATE from
the computer itself, so Netgear, Dlink, Linksys can have a wide range of
antenna options.  So why don't all of the vendors get together to get the
SR2/SR5/SR9/CM9/Senao cards certified with say the most popular antenna
options (Rootennas, grid dishes, etc) as if they were consumer installed
cards for laptops, NOT for WISPs.  But that would give our usage of it
because nothing stops us from sticking a Linksys ad-hoc wireless card on the
rooftop of a building and broadcasting wireless from a PC.  EVEN a Linux
box - look at MadWIFI - binary drivers to keep FCC certification.  And
MadWIFI lets your Linux box be a FCC certified AP.

Now that leaves the software itself, Mikrotik/StarOS to modular certify
their software with those cards.  Or switch back to a standardized FCC
certified firmware binary.

I can see this ruling being out there because Dell / HP / Compaq might be
nervous about losing their overall FCC cert on pre-installed wireless cards.
As computer system builders we've all been using modular certifications for
years:  FCC certified case, motherboard, video card, modem, etc.  Add FCC
certified wireless cards to that mix and guess what - now you've got a
computer capable of being an access point, and being FCC certified by
default. Use RP-SMA instead of N-Male for the connector rules.  Get some
certified antennas (and I think there's probably already a list of certified
antennas for use with Ubiquiti's cards), and now you've got FCC certified
WISP equipment.

- Original Message -
From: Scott Reed [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Wednesday, April 25, 2007 5:29 PM
Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's
Rules for unlicensed devices and,equipment approval


 And look as I might, I have trouble find what antennae the card vendor
 is certified with.

  From other discussions, I would ask a couple of additional questions.
 If we assume we can find a mPCI card that has WISP usable antennae in
 its certification then:
 1) Couldn't someone just get an RBxxx or WRAP or whatever SBC certified
 as a base unit and we could put the card in it?
 2) If an SBC is certified without an enclosure, is it still certified if
 it is in a box?

 Here is what I am thinking.  If we would get  an SBC certified bare as a
 base unit then we could use it with various cards in whatever enclosure
 we want to use.  The FCC seems to be interested in RF noise being
 emitted.  I don't think there are very many enclosures that increase the
 RF output, so if a bare SBC is certified, putting it in a box shouldn't
 negate the certification.  That would be like saying I can't put my
 laptop in a suitcase if the laptop is powered on.

 If this is the case, getting some of the equipment many of  us use in
 our operations certified may not be as hard as once thought.  And if we
 can show the mPCI makers the advantage of including some of the antennae
 we use in their certifications, we may be able to legally use a lot more
 equipment.

 Jack Unger wrote:
  Scott,
 
  I believe that your comments are substantially correct.
 
  The main problem that I see with building our own equipment is that
  very few (if any) manufacturers of modular wireless cards have
  certified them with a range of usable external WISP-grade antennas. I
  don't think this 2nd Report and Order changes that. Also, remember
  that the software used must limit operation of the complete system
  only to those frequencies and power levels that are legal in the U.S.
 
  jack
 
 
  Scott Reed wrote:
  I haven't read it really well and I have not yet looked up the
  referenced sections of Part 15, but I read the part that is not about
  split modular to be the part the refers to a PC.  And I read it
  that if the PC is certified to have radio cards AND the radio card is
  certified with an antenna, then that PC, radio card and antenna can
  be used.
 
  So, if that is true, then Tim may be on the right track.  Jack is
  right, not any base, but I would read it that any certified base
  is doable.
  I have often wondered how it works for laptops, but hadn't bothered
  to find it.  This makes sense.  Ubiquiti certifies the CM9 card with
  a set of antennae.  Dell certifies the laptop for a radio card.
  Putting a CM9 in Dell's laptop is fine as long as it connects to an
  antenna, using the proper cable, that was certified with the CM9.
 
  Therefore, if MT can get an RBxxx board certified as a base unit,
  we should be able to use a CM9 in that RBxxx 

Re: [WISPA] Modifications of =?WINDOWS-1252?Q?_Parts_2_and_15_of_the, Commis?= sion’s Rules for unlicensed d evices and, equipment approval

2007-04-25 Thread Lonnie Nunweiler

I guess you have to define what unique means.  You can buy U.FL or
RP-SMA connectors from just as many outlets as you can a N connector,
maybe even more, since N connectors are more Industrial and the U.FL
and RP-SMA have become consumer items.

Lonnie


On 4/25/07, Dawn DiPietro [EMAIL PROTECTED] wrote:

Scott,

In order for the system to be certified it must include the modular
transmitter and the antenna. If you did not include these parts what
would you be certifying exactly?

As quoted from said document;

The modular transmitter must comply with the antenna requirements of
Section 15.203
and 15.204(c). The antenna must either be permanently attached or employ
a unique
antenna coupler (at all connections between the module and the antenna,
including the
cable). Any antenna used with the module must be approved with the
module, either at
the time of initial authorization or through a Class II permissive
change. The
professional installation provision of Section 15.203 may not be
applied to modules.

Regards,
Dawn DiPietro


Scott Reed wrote:
 And look as I might, I have trouble find what antennae the card vendor
 is certified with.

 From other discussions, I would ask a couple of additional questions.
 If we assume we can find a mPCI card that has WISP usable antennae in
 its certification then:
 1) Couldn't someone just get an RBxxx or WRAP or whatever SBC
 certified as a base unit and we could put the card in it?
 2) If an SBC is certified without an enclosure, is it still certified
 if it is in a box?

 Here is what I am thinking.  If we would get  an SBC certified bare as
 a base unit then we could use it with various cards in whatever
 enclosure we want to use.  The FCC seems to be interested in RF noise
 being emitted.  I don't think there are very many enclosures that
 increase the RF output, so if a bare SBC is certified, putting it in a
 box shouldn't negate the certification.  That would be like saying I
 can't put my laptop in a suitcase if the laptop is powered on.

 If this is the case, getting some of the equipment many of  us use in
 our operations certified may not be as hard as once thought.  And if
 we can show the mPCI makers the advantage of including some of the
 antennae we use in their certifications, we may be able to legally use
 a lot more equipment.
 Jack Unger wrote:
 Scott,

 I believe that your comments are substantially correct.

 The main problem that I see with building our own equipment is that
 very few (if any) manufacturers of modular wireless cards have
 certified them with a range of usable external WISP-grade antennas. I
 don't think this 2nd Report and Order changes that. Also, remember
 that the software used must limit operation of the complete system
 only to those frequencies and power levels that are legal in the U.S.

 jack


 Scott Reed wrote:
 I haven't read it really well and I have not yet looked up the
 referenced sections of Part 15, but I read the part that is not
 about split modular to be the part the refers to a PC.  And I read
 it that if the PC is certified to have radio cards AND the radio
 card is certified with an antenna, then that PC, radio card and
 antenna can be used.

 So, if that is true, then Tim may be on the right track.  Jack is
 right, not any base, but I would read it that any certified base
 is doable.
 I have often wondered how it works for laptops, but hadn't bothered
 to find it.  This makes sense.  Ubiquiti certifies the CM9 card with
 a set of antennae.  Dell certifies the laptop for a radio card.
 Putting a CM9 in Dell's laptop is fine as long as it connects to an
 antenna, using the proper cable, that was certified with the CM9.

 Therefore, if MT can get an RBxxx board certified as a base unit,
 we should be able to use a CM9 in that RBxxx with the proper antenna
 and be good.  The gotcha here is those sections of Part 15 I have
 not yet followed up on.  I am not sure what the professional
 installer stuff is about.

 What am I missing or is this good news?

 Jack Unger wrote:
 Tim,

 I read the 2nd Report and Order and I don't see where it is saying
 that a certified mini PCI radio can be put into any base unit.

 I think what the FCC is doing is:

 1. Providing eight criteria that clarify the definition of what a
 legal modular assembly is.

 2. Allowing some flexibility regarding on-module shielding, data
 inputs, and power supply regulation.

 3. Clarifying the definition of what a split modular assembly is.

 4. Defining the (somewhat flexible) requirements that a split
 modular assembly must meet.

 Although a motherboard will certainly contain an operating system,
 I don't think that a mini PCI radio plugged into any motherboard
 meets the FCC's definition of a split modular assembly. I think
 the FCC considers a split modular assembly to be where circuitry
 that today would be contained on a single modular assembly is (now
 or in the future) split between two different physical
 assemblies. This splitting 

Re: [WISPA] Modifications of =?WINDOWS-1252?Q?_Parts_2_and_15_of_the, Commis?= sion’s Rules for unlicensed d evices and, equipment approval

2007-04-25 Thread Lonnie Nunweiler

Why were you waiting for that one?  It sounds like you do NOT want to
mix and match to suit the job.

You can mix and match, you just have to make sure that the
transmitters you mix are certified with the antennas you use.
Certified is certified.  It does not matter that you have other types
in use.  Imagine if you could not mix and match, since that would mean
you could not use Alvarion and Tranzeo on the same tower, which is
certainly not the intent.  Since you can clearly mix different systems
on a tower then it also holds that you can mix different transmitters
with a system.  Just keep each one meeting the proper requirements and
you should be OK.

The new regs are not regulating your entire network as a whole, but
rather are wanting individual parts to be proper.

Lonnie

On 4/25/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote:

THAT's the one I've been waiting for.

This pretty much rules out any intent what so ever that WE can use this to
mix and match transmitters.

Marlon
(509) 982-2181
(408) 907-6910 (Vonage)Consulting services
42846865 (icq)WISP Operator since 1999!
[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



- Original Message -
From: Dawn DiPietro [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Wednesday, April 25, 2007 2:58 PM
Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's
Rules for unlicensed devices and,equipment approval


 Scott,

 In order for the system to be certified it must include the modular
 transmitter and the antenna. If you did not include these parts what would
 you be certifying exactly?

 As quoted from said document;

 The modular transmitter must comply with the antenna requirements of
 Section 15.203
 and 15.204(c). The antenna must either be permanently attached or employ a
 unique
 antenna coupler (at all connections between the module and the antenna,
 including the
 cable). Any antenna used with the module must be approved with the module,
 either at
 the time of initial authorization or through a Class II permissive change.
 The
 professional installation provision of Section 15.203 may not be applied
 to modules.

 Regards,
 Dawn DiPietro


 Scott Reed wrote:
 And look as I might, I have trouble find what antennae the card vendor is
 certified with.

 From other discussions, I would ask a couple of additional questions.  If
 we assume we can find a mPCI card that has WISP usable antennae in its
 certification then:
 1) Couldn't someone just get an RBxxx or WRAP or whatever SBC certified
 as a base unit and we could put the card in it?
 2) If an SBC is certified without an enclosure, is it still certified if
 it is in a box?

 Here is what I am thinking.  If we would get  an SBC certified bare as a
 base unit then we could use it with various cards in whatever enclosure
 we want to use.  The FCC seems to be interested in RF noise being
 emitted.  I don't think there are very many enclosures that increase the
 RF output, so if a bare SBC is certified, putting it in a box shouldn't
 negate the certification.  That would be like saying I can't put my
 laptop in a suitcase if the laptop is powered on.

 If this is the case, getting some of the equipment many of  us use in our
 operations certified may not be as hard as once thought.  And if we can
 show the mPCI makers the advantage of including some of the antennae we
 use in their certifications, we may be able to legally use a lot more
 equipment.
 Jack Unger wrote:
 Scott,

 I believe that your comments are substantially correct.

 The main problem that I see with building our own equipment is that very
 few (if any) manufacturers of modular wireless cards have certified them
 with a range of usable external WISP-grade antennas. I don't think this
 2nd Report and Order changes that. Also, remember that the software used
 must limit operation of the complete system only to those frequencies
 and power levels that are legal in the U.S.

 jack


 Scott Reed wrote:
 I haven't read it really well and I have not yet looked up the
 referenced sections of Part 15, but I read the part that is not about
 split modular to be the part the refers to a PC.  And I read it that
 if the PC is certified to have radio cards AND the radio card is
 certified with an antenna, then that PC, radio card and antenna can be
 used.

 So, if that is true, then Tim may be on the right track.  Jack is
 right, not any base, but I would read it that any certified base is
 doable.
 I have often wondered how it works for laptops, but hadn't bothered to
 find it.  This makes sense.  Ubiquiti certifies the CM9 card with a set
 of antennae.  Dell certifies the laptop for a radio card.  Putting a
 CM9 in Dell's laptop is fine as long as it connects to an antenna,
 using the proper cable, that was certified with the CM9.

 Therefore, if MT can get an RBxxx board certified as a base unit, we