Re: [WISPA] Modifications of Parts 2 and 15 of the...
So I guess once a unique connector gets a shelf spot in the local radio shack your radio certification is void and requires a new unique connector to be developed followed by a trip back to the certification lab. I just love the FCC sometimes. I guess the FCC could outlaw the sale of certain connectors to the general public. That would be a good approach...NOT! (see the film Borat for proper use of the pause-NOT punchline) Scriv Jack Unger wrote: Here's one definition that the FCC has used for unique connector. Begin Quote ___ A unique connector is one that is not of a standard type found in electronic supply stores. _ End Quote __ jack Lonnie Nunweiler wrote: I am still wondering what is meant by unique for the connector. I've seen you write that the N connector is NOT allowed. Why is that? Lonnie On 4/26/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote: Under the normal Part-15 rules, the only devices allowed to have a non unique connector are devices labeled for and sold only to professional installers. The problem is, there isn't really a good explanation of what a part-15 professional installer is. What I've been told by the FCC is that the intent is that any device where it's easy to mix and match parts (remember that you could only use specifically certified antennas before 2005) was to only be sold to a pro installer. Literally, it was illegal for a vendor to sell us an ap without also including the cable and antenna for it. To be a pro installer we're supposed to have been manufacturer trained on a specific piece of gear (I was trained on p-com and wmux gear in the bad ol' wpcs days). The reasoning was that it's possible to use a certified combination of radio, cable, and antenna, and STILL exceed the EIRP limits. So we're supposed to have been trained on the device so we'd not accidentally assemble and configure an illegal version of a legal kit. The new rules specifically say that these rules do NOT apply to a device designed for a professional installer. If you're not sure that your device is for a pro installer, look in the manual. If it's got an n connector on it, it should also say that it's only available to professional installers. That rule has been TOTALLY ignored by everyone. We are, as users of this gear day in and day out, assumed to be professional installers so we don't have to buy devices with only unique connectors or buy only in kits (like a Linksys dsl router etc.). Again, I'd LOVE to see a real mix and match capability where we could use anyone's radio with anyone's amp and antenna. But they clearly aren't yet ready to go there. Just to make sure I'm reading this correctly, I've asked for some time with the head of OET (the FCC folks that write these rules). I'll pass along what he says once I'm able to talk to him about it. Hope that helps, 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: Lonnie Nunweiler [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 9:02 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval I saw nothing about an N connector being disallowed. It simply says that the connector(s) must be unique, and my contention is that an N connector is just as unique as a U.FL or RP-SMA. Once something becomes an Industry Standard it sort of loses its uniqueness. Since every system must have an antenna and for maintenance purposes that antenna must be removable. Just try and unsolder an antenna lead while hanging off a tower. I doubt that is their intention and thus they would certainly allow a removable antenna. I do agree that they are worried about the consumer gear and having Joe Schmoe hook up a larger antenna to his Dlink, LinkSys or Zcom consumer router. For the ISP market the rules must have a bit more common sense, and I did see that in the document. I felt it was a very positive step and one that will help the Industry in general. (earlier discussion pruned) -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the...
, 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: Lonnie Nunweiler [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 9:02 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval I saw nothing about an N connector being disallowed. It simply says that the connector(s) must be unique, and my contention is that an N connector is just as unique as a U.FL or RP-SMA. Once something becomes an Industry Standard it sort of loses its uniqueness. Since every system must have an antenna and for maintenance purposes that antenna must be removable. Just try and unsolder an antenna lead while hanging off a tower. I doubt that is their intention and thus they would certainly allow a removable antenna. I do agree that they are worried about the consumer gear and having Joe Schmoe hook up a larger antenna to his Dlink, LinkSys or Zcom consumer router. For the ISP market the rules must have a bit more common sense, and I did see that in the document. I felt it was a very positive step and one that will help the Industry in general. (earlier discussion pruned) -- Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc. FCC License # PG-12-25133 Serving the Broadband Wireless Industry Since 1993 Author of the WISP Handbook - Deploying License-Free Wireless WANs True Vendor-Neutral Wireless Consulting-Training-Troubleshooting FCC Part 15 Certification Assistance for Wireless Service Providers Phone (VoIP Over Broadband Wireless) 818-227-4220 www.ask-wi.com -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the...
- Original Message - From: Jack Unger [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Friday, April 27, 2007 9:25 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the... John, You're being sarcastic here, right? I'd be really surprised to hear that any certification ever was voided because a connector became more available. I'm starting to feel sorry for the poor, old FCC. First off, certain business elements want to eliminate them. Second, certain political interests (controlled by certain business interests) want to control them and determine what rules they make. Third, they regularly get threatened by Congress with reduced budgets. Fourth, their job is to implement the (often vague) laws made by Congress. Fifth, they have to be somewhat vague to try to apply the laws to everyone without pissing off anyone. Sixth, they have to be somewhat specific so their rules don't get challenged in court by the previously mentioned business interests. Seven, their engineers have to be pretty smart to know how wireless really works and what engineering principles to write into regulations. Eight, their lawyers have to be pretty good writers to translate the engineering principles into clearly-written rules and regulations. Nine, they have to craft a website that makes it fairly easy for the public to do business with them. Ten, they have to have pretty thick skin to not get distracted and become vindictive when everyone attacks them. Sheeesh, I never found myself defending the FCC before. Unfortunately, unlicensed does not mean unregulated. Responsible business people (which is what we are) strive to understand the conditions under which the regulatory agency works and strive to interact constructively with the people who work for that agency. I think we've found (and will continue to find) that most of the FCC employees will do what they can to be responsive to our needs if only we will communicate those needs in a clear, responsible, and timely fashion. But I'm probably preaching to the choir here because most WISP-folk already know this stuff and are already playing a constructive role, right? jack There's a reason we call them servants. If they don't like the heat, better find a nice cushy job as a small business startup while trying to defend yourself against a bunch of over-eager regulators. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the, Commission's Rules for unlicensed devices and, equipment approval
Grin It's certainly a fuzzy one. A unique connector was defined a few years back. As I recall, It's one that's not commonly available to the average consumer. It's one of the reasons that the old Orinoco cards had those goofy connectors on them. They had to come up with something that wasn't common. Yet, the FCC still certifies millions of Linksys devices with RPSMA connectors. Go figure. Like I said, I think that the FCC is MOSTLY worried about getting broadband out to people. No harmful interference, and no blasting over the EIRP limits. Other than that, they sure don't seem to care. But if they ever do start to care, I hope to have my network in dang good shape when the man come a callin'. marlon - Original Message - From: Lonnie Nunweiler [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 8:18 PM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval I am still wondering what is meant by unique for the connector. I've seen you write that the N connector is NOT allowed. Why is that? Lonnie On 4/26/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote: Under the normal Part-15 rules, the only devices allowed to have a non unique connector are devices labeled for and sold only to professional installers. The problem is, there isn't really a good explanation of what a part-15 professional installer is. What I've been told by the FCC is that the intent is that any device where it's easy to mix and match parts (remember that you could only use specifically certified antennas before 2005) was to only be sold to a pro installer. Literally, it was illegal for a vendor to sell us an ap without also including the cable and antenna for it. To be a pro installer we're supposed to have been manufacturer trained on a specific piece of gear (I was trained on p-com and wmux gear in the bad ol' wpcs days). The reasoning was that it's possible to use a certified combination of radio, cable, and antenna, and STILL exceed the EIRP limits. So we're supposed to have been trained on the device so we'd not accidentally assemble and configure an illegal version of a legal kit. The new rules specifically say that these rules do NOT apply to a device designed for a professional installer. If you're not sure that your device is for a pro installer, look in the manual. If it's got an n connector on it, it should also say that it's only available to professional installers. That rule has been TOTALLY ignored by everyone. We are, as users of this gear day in and day out, assumed to be professional installers so we don't have to buy devices with only unique connectors or buy only in kits (like a Linksys dsl router etc.). Again, I'd LOVE to see a real mix and match capability where we could use anyone's radio with anyone's amp and antenna. But they clearly aren't yet ready to go there. Just to make sure I'm reading this correctly, I've asked for some time with the head of OET (the FCC folks that write these rules). I'll pass along what he says once I'm able to talk to him about it. Hope that helps, 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: Lonnie Nunweiler [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 9:02 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval I saw nothing about an N connector being disallowed. It simply says that the connector(s) must be unique, and my contention is that an N connector is just as unique as a U.FL or RP-SMA. Once something becomes an Industry Standard it sort of loses its uniqueness. Since every system must have an antenna and for maintenance purposes that antenna must be removable. Just try and unsolder an antenna lead while hanging off a tower. I doubt that is their intention and thus they would certainly allow a removable antenna. I do agree that they are worried about the consumer gear and having Joe Schmoe hook up a larger antenna to his Dlink, LinkSys or Zcom consumer router. For the ISP market the rules must have a bit more common sense, and I did see that in the document. I felt it was a very positive step and one that will help the Industry in general. On 4/26/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote: I certainly DO want to mix and match. Hell, it's going on all over anywhere, they're gonna have to legalize it sooner or later anyway. The mix and match thing is way beyond anyone's ability to enforce it anymore. However, it's still the law and shouldn't be done. This is the specific
Re: [WISPA] Modifications of Parts 2 and 15 of the, Commission's Rules for unlicensed devices and,equipment approval
Right. And my point is, they should be easy to get certified. How do we get the various SBC vendors we use to get their boards certified as non-intentional radiators that can hold intentionally radiating modules? ralph wrote: Laptop=Legal FCC Certified Computing Device SBC=not WRAP=not RB=not -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Scott Reed Sent: Wednesday, April 25, 2007 8:04 PM To: WISPA General List Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and,equipment approval Right, for the transmitter. That is the mPCI card that goes in the laptop. I am talking about the laptop itself. Laptop = SBC = WRAP = RB = ??? Dawn DiPietro 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
Re: [WISPA] Modifications of Parts 2 and 15 of the,C ommission's Rules for unlicensed devices and, equipment approval
I certainly DO want to mix and match. Hell, it's going on all over anywhere, they're gonna have to legalize it sooner or later anyway. The mix and match thing is way beyond anyone's ability to enforce it anymore. However, it's still the law and shouldn't be done. This is the specific clause that applies to us: The professional installation provision of Section 15.203 may not be applied to modules. If it's got an N connector on it, as does most of our gear, it's for professional installation only. This new ruling is clearly aimed at the Dells, HPs, Toshibas etc. of the world. Not at us. If you can find a source at the FCC that'll say otherwise I'd LOVE to hear from them. 90% of the networks out there have changed something that will take them out of compliance, this rule would bring almost all of them back into compliance. 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: Lonnie Nunweiler [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 4:27 PM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval 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
Re: [WISPA] Modifications of Parts 2 and 15 of the, Commission's Rules for unlicensed devices and, equipment approval
Marlon, What does The professional installation provision of Section 15.203 say? and how does this change things? I thought the professional installation only meant that the installer had the knowledge and was allowed by the FCC to determine what antenna and xmitter could work together without the complete assembly being certified as one. To me the exclusion of this only means that again the radio module, firmware, and antenna have to be certified. Thus if the mfg did this with several different antenna then these modules with any of the certified combinations of antenna would be legal. I'm not sure what an N connector has to do with this? The rule says a unique connector. Don't know about you but a u.fl is about as unique as you can get and not for the consumer. Tim - Original Message - From: Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 8:11 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval I certainly DO want to mix and match. Hell, it's going on all over anywhere, they're gonna have to legalize it sooner or later anyway. The mix and match thing is way beyond anyone's ability to enforce it anymore. However, it's still the law and shouldn't be done. This is the specific clause that applies to us: may not be applied to modules. If it's got an N connector on it, as does most of our gear, it's for professional installation only. This new ruling is clearly aimed at the Dells, HPs, Toshibas etc. of the world. Not at us. If you can find a source at the FCC that'll say otherwise I'd LOVE to hear from them. 90% of the networks out there have changed something that will take them out of compliance, this rule would bring almost all of them back into compliance. 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: Lonnie Nunweiler [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 4:27 PM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval 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
Re: [WISPA] Modifications of Parts 2 and 15 of the, Commission's Rules for unlicensed devices and, equipment approval
- Original Message - From: Marlon K. Schafer (509) 982-2181 This new ruling is clearly aimed at the Dells, HPs, Toshibas etc. of the world. Not at us. If you can find a source at the FCC that'll say otherwise I'd LOVE to hear from them. 90% of the networks out there have changed something that will take them out of compliance, this rule would bring almost all of them back into compliance. This is where I don't see that we are any different. What is the difference between an IPAQ, Dell, and SBC's like WRAP, Gateworks, Metro, etc. They are computers, they are base units that a radio module is installed into, they run an OS. Their primary purpose is to be a computer and we the WISP community have used them to become AP's or Clients. My Dell laptop with it's installed minipci radio is a Client. And if I chose to install other software it can be an AP. The only thing I see my laptop from being legal is if I chose to attach a different antenna than what is already there. But if the manufacture of that radio had certified it with say a 24bd grid then I could attach that grid to the laptop and still be legal. Again this is MY wishful understanding of this new rule. Tim -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the, Commission's Rules for unlicensed devices and, equipment approval
I saw nothing about an N connector being disallowed. It simply says that the connector(s) must be unique, and my contention is that an N connector is just as unique as a U.FL or RP-SMA. Once something becomes an Industry Standard it sort of loses its uniqueness. Since every system must have an antenna and for maintenance purposes that antenna must be removable. Just try and unsolder an antenna lead while hanging off a tower. I doubt that is their intention and thus they would certainly allow a removable antenna. I do agree that they are worried about the consumer gear and having Joe Schmoe hook up a larger antenna to his Dlink, LinkSys or Zcom consumer router. For the ISP market the rules must have a bit more common sense, and I did see that in the document. I felt it was a very positive step and one that will help the Industry in general. On 4/26/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote: I certainly DO want to mix and match. Hell, it's going on all over anywhere, they're gonna have to legalize it sooner or later anyway. The mix and match thing is way beyond anyone's ability to enforce it anymore. However, it's still the law and shouldn't be done. This is the specific clause that applies to us: The professional installation provision of Section 15.203 may not be applied to modules. If it's got an N connector on it, as does most of our gear, it's for professional installation only. This new ruling is clearly aimed at the Dells, HPs, Toshibas etc. of the world. Not at us. If you can find a source at the FCC that'll say otherwise I'd LOVE to hear from them. 90% of the networks out there have changed something that will take them out of compliance, this rule would bring almost all of them back into compliance. 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 -- Lonnie Nunweiler Valemount Networks Corporation http://www.star-os.com/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
- Original Message - From: Scott Reed [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 9:22 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval Actually, the SBC is never an intentional radiator. The added card is. As I read, and Tim says the same thing in a later post, we need the SBCs certified the same as laptops. Certified as non-intentional radiators that accept intential radiators that are certified. Isn't that what the presented ruling says can happen? I went back and read some stuff over again... You can certify a module with either a permanently attached antenna, or one with a unique connector to a transmitter module. For instance, it appears that if you built an AMP, for instance, that was AGC type with limiting so that it put out constant power and sideband limitations, OOB limitations, etc, regardless of input, you could certify it with any antenna that lives within the FCC rules for eirp, etc. Of course, the complexity and cost of that would make it into why bother product.Its just that's what it looks like can be done. Yes, it appears you can certify a mini-pci card... with either a permanently attached antenna, or with a unique connector. Exactly how this unique connector is enforced, I don't know. Maybe someone has input on this. It says that the rf shielding that provides compliance must be part of the module, and that the enclosure it's put within (or no enclosure) now makes no difference. Is this unique connector required to be just the connection to the card? Obviously they expect there to be a pigtail, because this is meant to allow outside casing to be ... shall we say... irrelevant to certification. Do all connectors have to be uniqe, or just the one to the transmitter module? Now, as far as SBC's go, I know for a fact that Compex WP54's have passed FCC certification, because i have some assemblies from Compex that were certified with a detachable antenna. Thus, we know of at least one SBC that should be easily put in use. I guess maybe what we need is for Wistron, Ubiquiti, Compex... Maybe someone who does routinely certify assemblies to submit a mini-pci and cpe type antenna for approval under these rules. Or, maybe someone who knows the relevant decisionmakers to ask if we can. Rules do now permit equivalent antenna swaps already, and I saw nothing to prohibit this under these rules. As for the base station / client issue I recall some time back, that it was at least the intention of the FCC to allow the client to use PTP eirp rules while the AP was requierd to remain at the lower PTMP rules. Anyone remember the ultimate outcome of those inquiries? Dawn DiPietro wrote: Scott, The SBC would not be a transmitter without the mPCI wireless card now would it. The SBC would be the host device. Regards, Dawn DiPietro Scott Reed wrote: Right, for the transmitter. That is the mPCI card that goes in the laptop. I am talking about the laptop itself. Laptop = SBC = WRAP = RB = ??? Dawn DiPietro 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
Re: [WISPA] Modifications of Parts 2 and 15 of the, Commission's Rules for unlicensed devices and, equipment approval
Under the normal Part-15 rules, the only devices allowed to have a non unique connector are devices labeled for and sold only to professional installers. The problem is, there isn't really a good explanation of what a part-15 professional installer is. What I've been told by the FCC is that the intent is that any device where it's easy to mix and match parts (remember that you could only use specifically certified antennas before 2005) was to only be sold to a pro installer. Literally, it was illegal for a vendor to sell us an ap without also including the cable and antenna for it. To be a pro installer we're supposed to have been manufacturer trained on a specific piece of gear (I was trained on p-com and wmux gear in the bad ol' wpcs days). The reasoning was that it's possible to use a certified combination of radio, cable, and antenna, and STILL exceed the EIRP limits. So we're supposed to have been trained on the device so we'd not accidentally assemble and configure an illegal version of a legal kit. The new rules specifically say that these rules do NOT apply to a device designed for a professional installer. If you're not sure that your device is for a pro installer, look in the manual. If it's got an n connector on it, it should also say that it's only available to professional installers. That rule has been TOTALLY ignored by everyone. We are, as users of this gear day in and day out, assumed to be professional installers so we don't have to buy devices with only unique connectors or buy only in kits (like a Linksys dsl router etc.). Again, I'd LOVE to see a real mix and match capability where we could use anyone's radio with anyone's amp and antenna. But they clearly aren't yet ready to go there. Just to make sure I'm reading this correctly, I've asked for some time with the head of OET (the FCC folks that write these rules). I'll pass along what he says once I'm able to talk to him about it. Hope that helps, 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: Lonnie Nunweiler [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 9:02 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval I saw nothing about an N connector being disallowed. It simply says that the connector(s) must be unique, and my contention is that an N connector is just as unique as a U.FL or RP-SMA. Once something becomes an Industry Standard it sort of loses its uniqueness. Since every system must have an antenna and for maintenance purposes that antenna must be removable. Just try and unsolder an antenna lead while hanging off a tower. I doubt that is their intention and thus they would certainly allow a removable antenna. I do agree that they are worried about the consumer gear and having Joe Schmoe hook up a larger antenna to his Dlink, LinkSys or Zcom consumer router. For the ISP market the rules must have a bit more common sense, and I did see that in the document. I felt it was a very positive step and one that will help the Industry in general. On 4/26/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote: I certainly DO want to mix and match. Hell, it's going on all over anywhere, they're gonna have to legalize it sooner or later anyway. The mix and match thing is way beyond anyone's ability to enforce it anymore. However, it's still the law and shouldn't be done. This is the specific clause that applies to us: The professional installation provision of Section 15.203 may not be applied to modules. If it's got an N connector on it, as does most of our gear, it's for professional installation only. This new ruling is clearly aimed at the Dells, HPs, Toshibas etc. of the world. Not at us. If you can find a source at the FCC that'll say otherwise I'd LOVE to hear from them. 90% of the networks out there have changed something that will take them out of compliance, this rule would bring almost all of them back into compliance. 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 -- Lonnie Nunweiler Valemount Networks Corporation http://www.star-os.com/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the, Commission's Rules for unlicensed devices and, equipment approval
Please see inline... - Original Message - From: Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 6:00 PM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval Under the normal Part-15 rules, the only devices allowed to have a non unique connector are devices labeled for and sold only to professional installers. The problem is, there isn't really a good explanation of what a part-15 professional installer is. What I've been told by the FCC is that the intent is that any device where it's easy to mix and match parts (remember that you could only use specifically certified antennas before 2005) was to only be sold to a pro installer. Literally, it was illegal for a vendor to sell us an ap without also including the cable and antenna for it. To be a pro installer we're supposed to have been manufacturer trained on a specific piece of gear (I was trained on p-com and wmux gear in the bad ol' wpcs days). The reasoning was that it's possible to use a certified combination of radio, cable, and antenna, and STILL exceed the EIRP limits. So we're supposed to have been trained on the device so we'd not accidentally assemble and configure an illegal version of a legal kit. up to here I agreewith you. The new rules specifically say that these rules do NOT apply to a device designed for a professional installer. If you're not sure that your device is for a pro installer, look in the manual. If it's got an n connector on it, it should also say that it's only available to professional installers. *** From the new rule: 4. 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. In other words it MUST ALWAYS have a unique connector *** This from part 15 says that the unique conector is NOT required if intended for a professional installer The N connector is considered a unique connector Section 15.203 Antenna requirement.An intentional radiator shall be designed to ensure that no antenna other than that furnished by the responsible party shall be used with the device. The use of a permanently attached antenna or of an antenna that uses a unique coupling to the intentional radiator shall be considered sufficient to comply with the provisions of this Section. The manufacturer may design the unit so that a broken antenna can be replaced by the user, but the use of a standard antenna jack or electrical connector is prohibited. This requirement does not apply to carrier current devices or to devices operated under the provisions of Sections 15.211, 15.213, 15.217, 15.219, or 15.221. Further, this requirement does not apply to intentional radiators that must be professionally installed, such as perimeter protection systems and some field disturbance sensors, or to other intentional radiators which, in accordance with Section 15.31(d), must be measured at the installation site. However, the installer shall be responsible for ensuring that theproper antenna is employed so that the limits in this Part are not exceeded. ** That rule has been TOTALLY ignored by everyone. We are, as users of this gear day in and day out, assumed to be professional installers so we don't have to buy devices with only unique connectors or buy only in kits (like a Linksys dsl router etc.). TRUE. all radios are to be sold with cable and antennas Again, I'd LOVE to see a real mix and match capability where we could use anyone's radio with anyone's amp and antenna. But they clearly aren't yet ready to go there. The mix/match can still ONLY be with antennas that were certified with the radio module / firmware. Just to make sure I'm reading this correctly, I've asked for some time with the head of OET (the FCC folks that write these rules). I'll pass along what he says once I'm able to talk to him about it. Thanks, looking forward to response. Hope that helps, 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
Re: [WISPA] Modifications of Parts 2 and 15 of the, Commission's Rules for unlicensed devices and, equipment approval
I am still wondering what is meant by unique for the connector. I've seen you write that the N connector is NOT allowed. Why is that? Lonnie On 4/26/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote: Under the normal Part-15 rules, the only devices allowed to have a non unique connector are devices labeled for and sold only to professional installers. The problem is, there isn't really a good explanation of what a part-15 professional installer is. What I've been told by the FCC is that the intent is that any device where it's easy to mix and match parts (remember that you could only use specifically certified antennas before 2005) was to only be sold to a pro installer. Literally, it was illegal for a vendor to sell us an ap without also including the cable and antenna for it. To be a pro installer we're supposed to have been manufacturer trained on a specific piece of gear (I was trained on p-com and wmux gear in the bad ol' wpcs days). The reasoning was that it's possible to use a certified combination of radio, cable, and antenna, and STILL exceed the EIRP limits. So we're supposed to have been trained on the device so we'd not accidentally assemble and configure an illegal version of a legal kit. The new rules specifically say that these rules do NOT apply to a device designed for a professional installer. If you're not sure that your device is for a pro installer, look in the manual. If it's got an n connector on it, it should also say that it's only available to professional installers. That rule has been TOTALLY ignored by everyone. We are, as users of this gear day in and day out, assumed to be professional installers so we don't have to buy devices with only unique connectors or buy only in kits (like a Linksys dsl router etc.). Again, I'd LOVE to see a real mix and match capability where we could use anyone's radio with anyone's amp and antenna. But they clearly aren't yet ready to go there. Just to make sure I'm reading this correctly, I've asked for some time with the head of OET (the FCC folks that write these rules). I'll pass along what he says once I'm able to talk to him about it. Hope that helps, 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: Lonnie Nunweiler [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 9:02 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval I saw nothing about an N connector being disallowed. It simply says that the connector(s) must be unique, and my contention is that an N connector is just as unique as a U.FL or RP-SMA. Once something becomes an Industry Standard it sort of loses its uniqueness. Since every system must have an antenna and for maintenance purposes that antenna must be removable. Just try and unsolder an antenna lead while hanging off a tower. I doubt that is their intention and thus they would certainly allow a removable antenna. I do agree that they are worried about the consumer gear and having Joe Schmoe hook up a larger antenna to his Dlink, LinkSys or Zcom consumer router. For the ISP market the rules must have a bit more common sense, and I did see that in the document. I felt it was a very positive step and one that will help the Industry in general. On 4/26/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote: I certainly DO want to mix and match. Hell, it's going on all over anywhere, they're gonna have to legalize it sooner or later anyway. The mix and match thing is way beyond anyone's ability to enforce it anymore. However, it's still the law and shouldn't be done. This is the specific clause that applies to us: The professional installation provision of Section 15.203 may not be applied to modules. If it's got an N connector on it, as does most of our gear, it's for professional installation only. This new ruling is clearly aimed at the Dells, HPs, Toshibas etc. of the world. Not at us. If you can find a source at the FCC that'll say otherwise I'd LOVE to hear from them. 90% of the networks out there have changed something that will take them out of compliance, this rule would bring almost all of them back into compliance. 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 -- Lonnie Nunweiler Valemount Networks Corporation http://www.star-os.com/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http
Re: [WISPA] Modifications of Parts 2 and 15 of the...
Here's one definition that the FCC has used for unique connector. Begin Quote ___ A unique connector is one that is not of a standard type found in electronic supply stores. _ End Quote __ jack Lonnie Nunweiler wrote: I am still wondering what is meant by unique for the connector. I've seen you write that the N connector is NOT allowed. Why is that? Lonnie On 4/26/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote: Under the normal Part-15 rules, the only devices allowed to have a non unique connector are devices labeled for and sold only to professional installers. The problem is, there isn't really a good explanation of what a part-15 professional installer is. What I've been told by the FCC is that the intent is that any device where it's easy to mix and match parts (remember that you could only use specifically certified antennas before 2005) was to only be sold to a pro installer. Literally, it was illegal for a vendor to sell us an ap without also including the cable and antenna for it. To be a pro installer we're supposed to have been manufacturer trained on a specific piece of gear (I was trained on p-com and wmux gear in the bad ol' wpcs days). The reasoning was that it's possible to use a certified combination of radio, cable, and antenna, and STILL exceed the EIRP limits. So we're supposed to have been trained on the device so we'd not accidentally assemble and configure an illegal version of a legal kit. The new rules specifically say that these rules do NOT apply to a device designed for a professional installer. If you're not sure that your device is for a pro installer, look in the manual. If it's got an n connector on it, it should also say that it's only available to professional installers. That rule has been TOTALLY ignored by everyone. We are, as users of this gear day in and day out, assumed to be professional installers so we don't have to buy devices with only unique connectors or buy only in kits (like a Linksys dsl router etc.). Again, I'd LOVE to see a real mix and match capability where we could use anyone's radio with anyone's amp and antenna. But they clearly aren't yet ready to go there. Just to make sure I'm reading this correctly, I've asked for some time with the head of OET (the FCC folks that write these rules). I'll pass along what he says once I'm able to talk to him about it. Hope that helps, 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: Lonnie Nunweiler [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 9:02 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval I saw nothing about an N connector being disallowed. It simply says that the connector(s) must be unique, and my contention is that an N connector is just as unique as a U.FL or RP-SMA. Once something becomes an Industry Standard it sort of loses its uniqueness. Since every system must have an antenna and for maintenance purposes that antenna must be removable. Just try and unsolder an antenna lead while hanging off a tower. I doubt that is their intention and thus they would certainly allow a removable antenna. I do agree that they are worried about the consumer gear and having Joe Schmoe hook up a larger antenna to his Dlink, LinkSys or Zcom consumer router. For the ISP market the rules must have a bit more common sense, and I did see that in the document. I felt it was a very positive step and one that will help the Industry in general. (earlier discussion pruned) -- Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc. FCC License # PG-12-25133 Serving the Broadband Wireless Industry Since 1993 Author of the WISP Handbook - Deploying License-Free Wireless WANs True Vendor-Neutral Wireless Consulting-Training-Troubleshooting FCC Part 15 Certification Assistance for Wireless Service Providers Phone (VoIP Over Broadband Wireless) 818-227-4220 www.ask-wi.com -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the...
So once a non standard connector becomes an Industry Standard then you will find it in most supply stores. Also, what sort of supply store? Radio Shack or Electrocomm? Radio Shack might have the N connector, but it is likely suitable for VHF use only. Microwave quality is not mainstream, so does that mean an AP can use a Microwave rated N connector? I would think so. Lonnie On 4/26/07, Jack Unger [EMAIL PROTECTED] wrote: Here's one definition that the FCC has used for unique connector. Begin Quote ___ A unique connector is one that is not of a standard type found in electronic supply stores. _ End Quote __ jack Lonnie Nunweiler wrote: I am still wondering what is meant by unique for the connector. I've seen you write that the N connector is NOT allowed. Why is that? Lonnie On 4/26/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote: Under the normal Part-15 rules, the only devices allowed to have a non unique connector are devices labeled for and sold only to professional installers. The problem is, there isn't really a good explanation of what a part-15 professional installer is. What I've been told by the FCC is that the intent is that any device where it's easy to mix and match parts (remember that you could only use specifically certified antennas before 2005) was to only be sold to a pro installer. Literally, it was illegal for a vendor to sell us an ap without also including the cable and antenna for it. To be a pro installer we're supposed to have been manufacturer trained on a specific piece of gear (I was trained on p-com and wmux gear in the bad ol' wpcs days). The reasoning was that it's possible to use a certified combination of radio, cable, and antenna, and STILL exceed the EIRP limits. So we're supposed to have been trained on the device so we'd not accidentally assemble and configure an illegal version of a legal kit. The new rules specifically say that these rules do NOT apply to a device designed for a professional installer. If you're not sure that your device is for a pro installer, look in the manual. If it's got an n connector on it, it should also say that it's only available to professional installers. That rule has been TOTALLY ignored by everyone. We are, as users of this gear day in and day out, assumed to be professional installers so we don't have to buy devices with only unique connectors or buy only in kits (like a Linksys dsl router etc.). Again, I'd LOVE to see a real mix and match capability where we could use anyone's radio with anyone's amp and antenna. But they clearly aren't yet ready to go there. Just to make sure I'm reading this correctly, I've asked for some time with the head of OET (the FCC folks that write these rules). I'll pass along what he says once I'm able to talk to him about it. Hope that helps, 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: Lonnie Nunweiler [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 9:02 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval I saw nothing about an N connector being disallowed. It simply says that the connector(s) must be unique, and my contention is that an N connector is just as unique as a U.FL or RP-SMA. Once something becomes an Industry Standard it sort of loses its uniqueness. Since every system must have an antenna and for maintenance purposes that antenna must be removable. Just try and unsolder an antenna lead while hanging off a tower. I doubt that is their intention and thus they would certainly allow a removable antenna. I do agree that they are worried about the consumer gear and having Joe Schmoe hook up a larger antenna to his Dlink, LinkSys or Zcom consumer router. For the ISP market the rules must have a bit more common sense, and I did see that in the document. I felt it was a very positive step and one that will help the Industry in general. (earlier discussion pruned) -- Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc. FCC License # PG-12-25133 Serving the Broadband Wireless Industry Since 1993 Author of the WISP Handbook - Deploying License-Free Wireless WANs True Vendor-Neutral Wireless Consulting-Training-Troubleshooting FCC Part 15 Certification Assistance for Wireless Service Providers Phone (VoIP Over Broadband Wireless) 818-227-4220 www.ask-wi.com -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless
[WISPA] Modifications of Parts 2 and 15 of the,Commiss ion’s Rules for unlicensed devices and,equipment app roval
All, I just received this document and thought it might be of some interest to the list. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-56A1.pdf Regards, Dawn DiPietro -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
Am I reading this correctly Does this mean that if a mfg of a mini pci radio gets it certified with different antenna, that it then can be put into ANY base unit and be certified? Please correct me if I'm wrong, but isn't this what we have been asking for? Tim - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 8:36 AM Subject: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval All, I just received this document and thought it might be of some interest to the list. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-56A1.pdf Regards, Dawn DiPietro -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
I read that just about all the way through. It appears we can now certify a mini-pci radio with some specific gain antennas, and use it in any control board. There seems to be some requirement that we demonstrate the software can't or doesn't cause the module to operate outside of certified parameters. The equivalent antenna rules should be helpful here, too. Can someone who communicates with the appropriate people at the FCC get some clarification about certifying gain differences between the PTP antennas and PTMP base station? - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 8:36 AM Subject: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval All, I just received this document and thought it might be of some interest to the list. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-56A1.pdf Regards, Dawn DiPietro -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
It had been discussed on the Part 15 lists for that time and I remember reading an FCC publication about it a while ago. - Mike Hammett Intelligent Computing Solutions http://www.ics-il.com - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 11:04 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval Mike, Where did you get that idea? Regards, Dawn DiPietro Mike Hammett wrote: I thought that was put in to effect a year or two ago. - Mike Hammett Intelligent Computing Solutions http://www.ics-il.com - Original Message - From: Tim Kerns [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 10:54 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval Am I reading this correctly Does this mean that if a mfg of a mini pci radio gets it certified with different antenna, that it then can be put into ANY base unit and be certified? Please correct me if I'm wrong, but isn't this what we have been asking for? Tim - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 8:36 AM Subject: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval All, I just received this document and thought it might be of some interest to the list. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-56A1.pdf Regards, Dawn DiPietro -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
Nope. Not what it says. It's very specific about the antenna AND cabling used. What it means is that if you build a laptop (or some such device) and wish to slap in an atheros vs. prism rf section you can do that without having to recertify the whole shebang. They SPECIFICALLY excluded the professional installer gear on this. That means anything with an n connector is out. 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: Tim Kerns [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 8:54 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval Am I reading this correctly Does this mean that if a mfg of a mini pci radio gets it certified with different antenna, that it then can be put into ANY base unit and be certified? Please correct me if I'm wrong, but isn't this what we have been asking for? Tim - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 8:36 AM Subject: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval All, I just received this document and thought it might be of some interest to the list. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-56A1.pdf Regards, Dawn DiPietro -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
Probably not. :-p Not that I don't want to, but my searching abilities aren't so good. - Mike Hammett Intelligent Computing Solutions http://www.ics-il.com - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 12:04 PM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval Mike, Any chance you could provide a link to the document you are talking about? Regards, Dawn DiPietro Mike Hammett wrote: It had been discussed on the Part 15 lists for that time and I remember reading an FCC publication about it a while ago. - Mike Hammett Intelligent Computing Solutions http://www.ics-il.com - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 11:04 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval Mike, Where did you get that idea? Regards, Dawn DiPietro Mike Hammett wrote: I thought that was put in to effect a year or two ago. - Mike Hammett Intelligent Computing Solutions http://www.ics-il.com - Original Message - From: Tim Kerns [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 10:54 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval Am I reading this correctly Does this mean that if a mfg of a mini pci radio gets it certified with different antenna, that it then can be put into ANY base unit and be certified? Please correct me if I'm wrong, but isn't this what we have been asking for? Tim - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 8:36 AM Subject: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval All, I just received this document and thought it might be of some interest to the list. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-56A1.pdf Regards, Dawn DiPietro -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
- Original Message - From: Jack Unger [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 12:21 PM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval 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. did you read? Come on Jack... Here's paragraph three of the background section: 3. In recent years, manufacturers have developed Part 15 transmitter modules (or “single” modules) that can be incorporated into many different devices. These modules generally consist of a completely self-contained radio-frequency transmitter (transmission system) missing only an input signal source and a power source to make it functional. Once the modules are authorized by the Commission under its certification procedure, they may be incorporated into a number of host devices such as personal computers (PCs) or personal digital assistants (PDAs), which have been separately authorized.2 The completed product generally is not subject to requirements for further certification by the Commission. Therefore, modular transmitters save manufacturers the time and any related expenses that would be incurred if a new equipment authorization were needed for the same transmitter when it is installed in a new device. _ I dunno about you, but if that does not address mini-pci modules on a single board computer, I dunno what would. That's about as clear and specific as they could get! They CLEARLY are talking about rf network devices. It takes no imagination whatsoever to very effectively create mini-pci cards and certify them under these rules. They even state that the 'enclosure' no longer matters, nor does the device the module is connected to, unless it can make the device operate out of bounds.The software, if it uses the drivers from the manufacturer, or elements of the manufacturer's software, that are approved as far as SDR's go, for TPC and DFS, then yes, it obviously complies with this, because those are certified by the chipset manufacturers. And further, they went on to state that this can be applied to a wide array of rf devices... and they address various types of modulation, frequencies, blah blah. We're talking part-15 based networking devices, they're talking walkie talkies, they're talking about a huge array of devices. I see it as sea change, and take that from the language they use. The requirements are: self contained shielding so it's not dependent on enclosure for unintentional radiation control, has its own power control, can be certified separately from the rest of the device. The worst that can happen, is that we submit a mini-pci and antenna combination for certification and it gets rejected, but it appears to me we CAN certify it. As far as the unique connector rule, I don't know how this is interpreted, but every laptop and mini-pci put in it now has the same connector. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
I find reading all these notices very difficult... I think they hire writers just to confuse us Ok, here is my thoughts.. Manufacture A designs and builds a radio card (minipci), and develops the firmware to operate it.They then get FCC certification for this radio, firmware, and (hopefully) several antenna and like. PC manufacture B then purchases this radio and firmware to incorporate into this device. Before, this PC should have been sent for FCC certification with this specific radio, firmware, and like antenna. Now if the PC manufacture wanted to use one from Mfg A or one from Mfg B then they would need to FCC certify each case. Sound familiar? As I read this, the PC manufacture would now only need to put a label stating that this PC has radio with FCC cert # . installed. If this is the case, how do we differ? We use the same firmware and radio combo, the only problem I see is radio manufactures only certify with small db antenna. If they would certify with 14, 19 and 24 db, then I don't see why we would be any different. This rule still needs the unique connector. I also don't see any distinction between being a client or an AP in this rule. I see this rule only as radiation concerns. Tim - Original Message - From: Jack Unger [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 12:21 PM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval 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 bottom line is - I don't think this 2nd Report and Order contains anything that will substantially change the way we do business. jack Tim Kerns wrote: Am I reading this correctly Does this mean that if a mfg of a mini pci radio gets it certified with different antenna, that it then can be put into ANY base unit and be certified? Please correct me if I'm wrong, but isn't this what we have been asking for? Tim - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 8:36 AM Subject: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval All, I just received this document and thought it might be of some interest to the list. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-56A1.pdf Regards, Dawn DiPietro -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc. FCC License # PG-12-25133 Serving the Broadband Wireless Industry Since 1993 Author of the WISP Handbook - Deploying License-Free Wireless WANs True Vendor-Neutral Wireless Consulting-Training-Troubleshooting FCC Part 15 Certification Assistance for Wireless Service Providers Phone (VoIP Over Broadband Wireless) 818-227-4220 www.ask-wi.com -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
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 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
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
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 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
RE: [WISPA] Modifications of Parts 2 and 15 of the,Com mission's Rules for unlicensed devices and,equipment appro val
Laptop=Legal FCC Certified Computing Device SBC=not WRAP=not RB=not -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Scott Reed Sent: Wednesday, April 25, 2007 8:04 PM To: WISPA General List Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and,equipment approval Right, for the transmitter. That is the mPCI card that goes in the laptop. I am talking about the laptop itself. Laptop = SBC = WRAP = RB = ??? Dawn DiPietro 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
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
- Original Message - From: Jack Unger [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 1:33 PM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval Yes, we still need to submit a wireless card, case, power supply, software, and range of antennas to be certified as a system . No, this change means that the CASE, POWER SUPPLY, and associated other hardware that generates the input signal does not need to be certified to build a certified product. This the exact change we need to be able build our own equipment. The motherboard and case are no longer required to build and keep the system compliant and certified. Just the module itself, with chosen antennae. jack -- Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc. FCC License # PG-12-25133 Serving the Broadband Wireless Industry Since 1993 Author of the WISP Handbook - Deploying License-Free Wireless WANs True Vendor-Neutral Wireless Consulting-Training-Troubleshooting FCC Part 15 Certification Assistance for Wireless Service Providers Phone (VoIP Over Broadband Wireless) 818-227-4220 www.ask-wi.com -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
But Jack, they don't have to. Anyone can. - Original Message - From: Jack Unger [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 2:03 PM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval 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 bottom line is - I don't think this 2nd Report and Order contains anything that will substantially change the way we do business. jack Tim Kerns wrote: Am I reading this correctly Does this mean that if a mfg of a mini pci radio gets it certified with different antenna, that it then can be put into ANY base unit and be certified? Please correct me if I'm wrong, but isn't this what we have been asking for? Tim - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 8:36 AM Subject: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval All, I just received this document and thought it might be of some interest to the list. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-56A1.pdf Regards, Dawn DiPietro -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc. FCC License # PG-12-25133 Serving the Broadband Wireless Industry Since 1993 Author of the WISP Handbook - Deploying License-Free Wireless WANs True Vendor-Neutral Wireless Consulting-Training-Troubleshooting FCC Part 15 Certification Assistance for Wireless Service Providers Phone (VoIP Over Broadband Wireless) 818-227-4220 www.ask-wi.com -- WISPA Wireless List: wireless@wispa.org Subscribe
Re: [WISPA] Modifications of Parts 2 and 15 of the, Commission's Rules for unlicensed devices and, equipment approval
Ralph, you hit the mark. The sbc guys need to get their stuff tested and certified. End of story. If some can't do it and others do, they will soon be without sales. That ought to drive them to conform. I can see the domino effect starting. ADI has done a very good thing for us. The pressure is on the other guys now. George ralph wrote: I'm just trying to say that most of these boards have never been certified to even use as a computing device in the US. They could be putting out spurs and harmonics all over the aircraft band or anywhere else. I had an SBC once whose crystal oscillator was putting out a strong signal right on 146.055 MHZ, the input of a local Ham repeater. It shut them completely down until I could get there and shut the computer off. Manufacturer had me pad the crystal with a capacitor. Moved the spur off to who knows where else. Hopefully not to the aircraft distress frequency or something like that. This board was not FCC certified either. I have a Routerboard 153 sitting here on my desk. Nowhere on it is an FCC compliance note about its compliance as an unintentional radiator. -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Mark Koskenmaki Sent: Wednesday, April 25, 2007 10:26 PM To: WISPA General List Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and, equipment approval - Original Message - From: ralph [EMAIL PROTECTED] To: 'WISPA General List' wireless@wispa.org Sent: Wednesday, April 25, 2007 6:42 PM Subject: RE: [WISPA] Modifications of Parts 2 and 15 of the,Commission's Rules for unlicensed devices and,equipment approval Laptop=Legal FCC Certified Computing Device SBC=not WRAP=not RB=not I'm not sure what you're trying to say here... I know that lots of SBC's have been certified within systems, and gettting them certified outside of systems, as unintentional radiators should be... well.. almost trivial. I don't think a WRAP board has been, but then, the WRAP is now obsolete. The various RB / Compex / Gateworks, etc SBC's are nothing but PARTS of already certified systems. The CPU's and other parts are common parts. They'd probably qualify under plain old declaration of compliance rules. -- George Rogato Welcome to WISPA www.wispa.org http://signup.wispa.org/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Modifications of Parts 2 and 15 of the ,Commission’s Rules for unlicensed devices and,equ ipment approval
- Original Message - From: Jack Unger [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, April 25, 2007 8:22 PM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval Mark, I agree with you on many of the points that you've been making recently regarding who should pay (or not pay) for CALEA compliance but with regard to the meaning of these FCC rules modifications, I disagree with virtually all of your opinions. There's nothing wrong with that; we are each entitled to our own opinions. Further, I'm not going to keep debating these points with you. I've stated by beliefs and you've stated yours. Feel free to build and certify your equipment any way that you see fit and believe is legal. The discussion that really counts is the one that you have with the FCC. Please see my comments inline and good luck. jack Well, Jack, I guess we'll ultimately find out what they really mean when when they have to answer questions in plain english. While Im sure you have more experience reading between the lines than I have... or at least desciphering the legalese they put out, I get what I say from reading the document. Then again, don't forget... there's the law of unintended consequences... that they say stuff without realizing how it can be interpreted. Ultimately, who's going to be the one asking them for clarity here? -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/