Re: [WISPA] Brief report from FCC visit
Steve Stroh wrote: Mark: You're overlooking one critical difference between PCs and Wireless systems. PCs are UNintentional radiators, with radiated power levels that are very, very low. Wireless systems are intentional radiators, at significant power levels, and through unintended mixing, have the potential to disrupt other communications systems, including critical systems like public safety. This is a very real fear of the FCC, borne out over nearly 100 years of experience now with the evolution of wireless technology. These things DO happen, and having a proliferation of unlicensed systems out there with significant power levels (EIRP) can cause havoc. When a WISP slaps together a system, do they hook it up to a spectrum analyzer to insure that substantially all the radiated energy is contained within the desired band? No, they don't. When a WISP slaps together a certified system do they hook it up to a spectrum analyzer? Do they spot check their existing equipment with a spectrum analyzer? Faulty/failing hardware is where most of the real interference issues are going to come from. Well, that and every crappy cordless phone/baby monitor/microwave oven... Sam Tetherow Sandhills Wireless Um, the FCC is getting innovation and advancement - look at Clearwire. When there weren't Clearwire, NextWave, Sprint Nextel and ATT actively deploying Broadband Wireless Internet Access, the FCC needed WISPs. Now they've got those big players starting to deploy and they can point to them as a success story for Broadband Wireless Internet Access. Thanks, Steve On Feb 16, 2007, at Feb 16 11:38 PM, wispa wrote: I'd say that that's probable. Further, I'd say that at least 75% of those who did or do not don't even know about it. Especially, if you're a non- wireless ISP, exactly why would you know about it? Wireless guys are more likely to have some knowlege of the FCC.. non-wireless... The FCC is foreign and irrelevant to them. If the government officials take it personal, we're doomed. We're all doomed. If they see things as must get them under our control then there's no longer any good going to happen. It becomes adversary vs adversary. Let me predict that form 445 will get perhaps HALF that response. Again, who's even going to know? I think that's the wrong approach, and along with you, I sincerely doubt it can be gotten past a regulatory body. I suggested component, rather than assembly certification. This way there IS a responsible party. The maker of the equipment is responsible if it is not within spec, and the user is responsible if the user fails to follow the rules concerning EIRP and out of band emissions. Look, there's GOOD precedent for this. Do any of you remember when PC's had to be FCC certified? In the FCC's own terminology - in their own words, even - assemblies using normally compliant parts can be considered compliant and require only a DoC, or Declaration of Conformity. No testing needed. For instance, the SAME mini-pci card the FCC wants certified as an assembly with a WRAP board is perfectly legal to stuff into a laptop with nothing other than a DoC by the maker of the laptop! The only thing this would require... is some specific guidelines from the FCC for component certification by the manufacturer, and the ability for us to file DoC with the FCC for obviously legal assemblies that obviously comply with the intentional radiator standards, because we file for combinations of parts with CERTIFIED behavior and it would be almost simplistic to both do and oversee. So, WOULD I file DoC's on the parts combinations I'd like to use, and then sticker them so * I * am responsible for those? Of course. If Wistron Neweb wants to sell 500K CM-9's let them certify their behavior. Let PacWireless certify the patterns and gain of thier antennas. Let Ubiquiti certify the behavior of SR-9's and SR-2's. It makes little sense to test, retest, re-retest over and over and over, the same basic parts to the same standards. If Wistron's mini-pci fails to perform as spec'd, is it the fault of ... Builder X, who certified the assembly? Or the fault of Wistron? If PacWireless antennas are sold as 21 db gain and are really 27, is that the fault of Builder X or PacWireless? If accountability is what they want, THIS IS IT. Again, the grey area you talk about concerning the use of identical parts of a different brand is actually resolved, from a regulatory viewpoint, rather than being gray. THIS I would argue, not that individual unknown parts be assembled and then magically declared conforming. Like it's going to matter if the case is made of aluminum, steel, or stainless, and whether it's 6X8 or 16X12 as to whether the EIRP, out of band emissions, and so on, meet the legal requirements. Of course it does not. Again, this process of using compliant parts with a DoC on file would be a great way to solve ALL of this. The FCC
Re: [WISPA] Brief report from FCC visit
Tom DeReggi wrote: ! --- SNIP --- 4) We discussed the option for self/group effort to certifying gear combinations. It won't be an option that will be viable. It must be a Manufacturer that applied for equipment certification, as there must be an accountable/responsible/liable party. A group applying for certification, would have to take liabilty and prove their ability to be able to be accountable. I'm not the police and not going to tell you what to use, but any way you slice it, make your own StarOS / Mikrotik gear is illegal (non-certified) in the US. The only way to not be illegal, is to buy it from a manufacturer that has certified their combination, or you become a manufacturer yourself and apply for certification of your combination. The fact that XYZ certified the combination, does not make your combination certified. UNLESS you convince XYZ to be responsible and liable for the compliance of the gear that you bought elsewhere. A MPCI card and antenna is not enough to be a certified system. There are other components involved like Main boards and cases, and testing gear during the QC stage to verify compliance. So are you saying that a PCMCIA card with software and internal antenna is not certified? No one has yet to answer this question for me. Is it legal for Best Buy to sell DLink/Linksys/Netgear/Belkin/... pcmcia cards for laptops? What about USB dongles? If they are legal how is they can certify a card and drivers, but we can't certify a minipci with software? Sam Tetherow Sandhills Wireless ! --- SNIP --- -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Brief report from FCC visit
Sam Tetherow wrote: So are you saying that a PCMCIA card with software and internal antenna is not certified? No one has yet to answer this question for me. Is it legal for Best Buy to sell DLink/Linksys/Netgear/Belkin/... pcmcia cards for laptops? What about USB dongles? If they are legal how is they can certify a card and drivers, but we can't certify a minipci with software? If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. -- 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] Brief report from FCC visit
George Rogato wrote: Sam Tetherow wrote: So are you saying that a PCMCIA card with software and internal antenna is not certified? No one has yet to answer this question for me. Is it legal for Best Buy to sell DLink/Linksys/Netgear/Belkin/... pcmcia cards for laptops? What about USB dongles? If they are legal how is they can certify a card and drivers, but we can't certify a minipci with software? If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. Then if DLink can certify a PCMCIA card with drivers for use with any SBC (a laptop). Then why are people saying we cannot certify a CM9 and a RouterOS drivers and a couple of antennas (Rootenna, PW dish, etc) and then slap them into any SBC? Sam Tetherow Sandhills 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] Brief report from FCC visit
If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. That would be uncertified. This is not a debatable point. This would be taking a consumer device, which is built to permit self-installation into a device for which the FCC says there must be a professional installation. These are the most confusing parts of the rules for novices, but basically if you are installing for another end user, you are assumed to be professional, which actually imposes certain liabilities and responsibilities on you. Further, this would void the certification EVEN if it still met the manufacturer specs because, for better of worse, only the OEM manufacturer can self-certify antenna changes. George, you were in the room at the FCC with me when they told us this so you know it. It is impossible to forget since Marlon pounded them about for most of the meeting but they would not budge that only a manufacturer can pick and chose additional antennas and then only antennas of equal or less power AND with similar specs (relative to emissions on sidelobs, etc.). Really all that was done in that ruling was to make the permissive change rules more simple. None of this was done for the protection of the manufacturers, but rather to make sure the FCC had one throat to choke. Patrick Leary AVP WISP Markets Alvarion, Inc. o: 650.314.2628 c: 760.580.0080 Vonage: 650.641.1243 [EMAIL PROTECTED] -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:24 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit Sam Tetherow wrote: So are you saying that a PCMCIA card with software and internal antenna is not certified? No one has yet to answer this question for me. Is it legal for Best Buy to sell DLink/Linksys/Netgear/Belkin/... pcmcia cards for laptops? What about USB dongles? If they are legal how is they can certify a card and drivers, but we can't certify a minipci with software? If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. -- 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/ This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals computer viruses(190). This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals computer viruses(42). This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals computer viruses. This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals computer viruses(84). This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals computer viruses. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
RE: [WISPA] Brief report from FCC visit
And lately my nights are filled with the goodnight show ___ Marty Dougherty CEO Roadstar Internet Inc. [EMAIL PROTECTED] 703-554-6620 www.roadstarinternet.com -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Patrick Leary Sent: Monday, February 19, 2007 11:59 AM To: WISPA General List Subject: RE: [WISPA] Brief report from FCC visit You must not have little kids like I do! They got me up nice and early at 6:30 AM today. I would not know recognize a weekend morning without Sagwa or Clifford the Big Red Dog. Patrick -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:49 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit First off Patrick, we will be going to the carpet in a few minutes when I get my thoughts collected. I just woke up an hour ago and am sometimes a little sluggish in the early hours. 2nd, Dlink, Linksys and Netgear all have antennas listed on their sites for use with their units. I may be wrong, but I would ass u me that they have been certified. But do your due diligense and check first to make sure. :) George Patrick Leary wrote: If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. That would be uncertified. This is not a debatable point. This would be taking a consumer device, which is built to permit self-installation into a device for which the FCC says there must be a professional installation. These are the most confusing parts of the rules for novices, but basically if you are installing for another end user, you are assumed to be professional, which actually imposes certain liabilities and responsibilities on you. Further, this would void the certification EVEN if it still met the manufacturer specs because, for better of worse, only the OEM manufacturer can self-certify antenna changes. George, you were in the room at the FCC with me when they told us this so you know it. It is impossible to forget since Marlon pounded them about for most of the meeting but they would not budge that only a manufacturer can pick and chose additional antennas and then only antennas of equal or less power AND with similar specs (relative to emissions on sidelobs, etc.). Really all that was done in that ruling was to make the permissive change rules more simple. None of this was done for the protection of the manufacturers, but rather to make sure the FCC had one throat to choke. Patrick Leary AVP WISP Markets Alvarion, Inc. o: 650.314.2628 c: 760.580.0080 Vonage: 650.641.1243 [EMAIL PROTECTED] -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:24 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit Sam Tetherow wrote: So are you saying that a PCMCIA card with software and internal antenna is not certified? No one has yet to answer this question for me. Is it legal for Best Buy to sell DLink/Linksys/Netgear/Belkin/... pcmcia cards for laptops? What about USB dongles? If they are legal how is they can certify a card and drivers, but we can't certify a minipci with software? If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. -- 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/ This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals computer viruses(190). This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals computer viruses(43). This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals computer viruses
OT RE: [WISPA] Brief report from FCC visit
:) Nothing like cuddling up with the girls while they are still in their footy PJs. Of course, the dog likes to pile in too. Patrick -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Marty Dougherty Sent: Monday, February 19, 2007 9:03 AM To: 'WISPA General List' Subject: RE: [WISPA] Brief report from FCC visit And lately my nights are filled with the goodnight show ___ Marty Dougherty CEO Roadstar Internet Inc. [EMAIL PROTECTED] 703-554-6620 www.roadstarinternet.com -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Patrick Leary Sent: Monday, February 19, 2007 11:59 AM To: WISPA General List Subject: RE: [WISPA] Brief report from FCC visit You must not have little kids like I do! They got me up nice and early at 6:30 AM today. I would not know recognize a weekend morning without Sagwa or Clifford the Big Red Dog. Patrick -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:49 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit First off Patrick, we will be going to the carpet in a few minutes when I get my thoughts collected. I just woke up an hour ago and am sometimes a little sluggish in the early hours. 2nd, Dlink, Linksys and Netgear all have antennas listed on their sites for use with their units. I may be wrong, but I would ass u me that they have been certified. But do your due diligense and check first to make sure. :) George Patrick Leary wrote: If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. That would be uncertified. This is not a debatable point. This would be taking a consumer device, which is built to permit self-installation into a device for which the FCC says there must be a professional installation. These are the most confusing parts of the rules for novices, but basically if you are installing for another end user, you are assumed to be professional, which actually imposes certain liabilities and responsibilities on you. Further, this would void the certification EVEN if it still met the manufacturer specs because, for better of worse, only the OEM manufacturer can self-certify antenna changes. George, you were in the room at the FCC with me when they told us this so you know it. It is impossible to forget since Marlon pounded them about for most of the meeting but they would not budge that only a manufacturer can pick and chose additional antennas and then only antennas of equal or less power AND with similar specs (relative to emissions on sidelobs, etc.). Really all that was done in that ruling was to make the permissive change rules more simple. None of this was done for the protection of the manufacturers, but rather to make sure the FCC had one throat to choke. Patrick Leary AVP WISP Markets Alvarion, Inc. o: 650.314.2628 c: 760.580.0080 Vonage: 650.641.1243 [EMAIL PROTECTED] -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:24 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit Sam Tetherow wrote: So are you saying that a PCMCIA card with software and internal antenna is not certified? No one has yet to answer this question for me. Is it legal for Best Buy to sell DLink/Linksys/Netgear/Belkin/... pcmcia cards for laptops? What about USB dongles? If they are legal how is they can certify a card and drivers, but we can't certify a minipci with software? If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. -- 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/ This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals computer viruses(190). This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals computer viruses(43
Re: [WISPA] Brief report from FCC visit
On Mon, 19 Feb 2007 09:25:19 -0600, Sam Tetherow wrote Steve Stroh wrote: When a WISP slaps together a system, do they hook it up to a spectrum analyzer to insure that substantially all the radiated energy is contained within the desired band? No, they don't. When a WISP slaps together a certified system do they hook it up to a spectrum analyzer? Do they spot check their existing equipment with a spectrum analyzer? Faulty/failing hardware is where most of the real interference issues are going to come from. Well, that and every crappy cordless phone/baby monitor/microwave oven... You hit it. We don't check everything we put up. For that matter, the manufacturers don't check them all either. They merely test the prototype and the rest are assumed good. The certified component idea would put the onus on the various manufacturers to assure that ongoing QC would keep things compliant. Mark Koskenmaki Neofast, Inc Broadband for the Walla Walla Valley and Blue Mountains 541-969-8200 -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Brief report from FCC visit
No little kids here. Mine are all grown. One is the admin for OregonFAST.net and the other 2 are pc techs here as well. 2 of them are actually owners of this business. My wife mentioned having another but at 49, I'm thinking thats not a good thing. George Patrick Leary wrote: You must not have little kids like I do! They got me up nice and early at 6:30 AM today. I would not know recognize a weekend morning without Sagwa or Clifford the Big Red Dog. Patrick -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:49 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit First off Patrick, we will be going to the carpet in a few minutes when I get my thoughts collected. I just woke up an hour ago and am sometimes a little sluggish in the early hours. 2nd, Dlink, Linksys and Netgear all have antennas listed on their sites for use with their units. I may be wrong, but I would ass u me that they have been certified. But do your due diligense and check first to make sure. :) George Patrick Leary wrote: If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. That would be uncertified. This is not a debatable point. This would be taking a consumer device, which is built to permit self-installation into a device for which the FCC says there must be a professional installation. These are the most confusing parts of the rules for novices, but basically if you are installing for another end user, you are assumed to be professional, which actually imposes certain liabilities and responsibilities on you. Further, this would void the certification EVEN if it still met the manufacturer specs because, for better of worse, only the OEM manufacturer can self-certify antenna changes. George, you were in the room at the FCC with me when they told us this so you know it. It is impossible to forget since Marlon pounded them about for most of the meeting but they would not budge that only a manufacturer can pick and chose additional antennas and then only antennas of equal or less power AND with similar specs (relative to emissions on sidelobs, etc.). Really all that was done in that ruling was to make the permissive change rules more simple. None of this was done for the protection of the manufacturers, but rather to make sure the FCC had one throat to choke. Patrick Leary AVP WISP Markets Alvarion, Inc. o: 650.314.2628 c: 760.580.0080 Vonage: 650.641.1243 [EMAIL PROTECTED] -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:24 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit Sam Tetherow wrote: So are you saying that a PCMCIA card with software and internal antenna is not certified? No one has yet to answer this question for me. Is it legal for Best Buy to sell DLink/Linksys/Netgear/Belkin/... pcmcia cards for laptops? What about USB dongles? If they are legal how is they can certify a card and drivers, but we can't certify a minipci with software? If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. -- 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] Brief report from FCC visit
Hi George, 49 here also, when do you turn 50? -Dee Alaska Wireless Systems 1(907)240-2183 Cell 1(907)349-2226 Fax 1(907)349-4308 Office www.akwireless.net - Original Message - From: George Rogato [mailto:[EMAIL PROTECTED] To: WISPA General List [mailto:[EMAIL PROTECTED] Sent: Mon, 19 Feb 2007 13:06:43 -0900 Subject: Re: [WISPA] Brief report from FCC visit No little kids here. Mine are all grown. One is the admin for OregonFAST.net and the other 2 are pc techs here as well. 2 of them are actually owners of this business. My wife mentioned having another but at 49, I'm thinking thats not a good thing. George Patrick Leary wrote: You must not have little kids like I do! They got me up nice and early at 6:30 AM today. I would not know recognize a weekend morning without Sagwa or Clifford the Big Red Dog. Patrick -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:49 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit First off Patrick, we will be going to the carpet in a few minutes when I get my thoughts collected. I just woke up an hour ago and am sometimes a little sluggish in the early hours. 2nd, Dlink, Linksys and Netgear all have antennas listed on their sites for use with their units. I may be wrong, but I would ass u me that they have been certified. But do your due diligense and check first to make sure. :) George Patrick Leary wrote: If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. That would be uncertified. This is not a debatable point. This would be taking a consumer device, which is built to permit self-installation into a device for which the FCC says there must be a professional installation. These are the most confusing parts of the rules for novices, but basically if you are installing for another end user, you are assumed to be professional, which actually imposes certain liabilities and responsibilities on you. Further, this would void the certification EVEN if it still met the manufacturer specs because, for better of worse, only the OEM manufacturer can self-certify antenna changes. George, you were in the room at the FCC with me when they told us this so you know it. It is impossible to forget since Marlon pounded them about for most of the meeting but they would not budge that only a manufacturer can pick and chose additional antennas and then only antennas of equal or less power AND with similar specs (relative to emissions on sidelobs, etc.). Really all that was done in that ruling was to make the permissive change rules more simple. None of this was done for the protection of the manufacturers, but rather to make sure the FCC had one throat to choke. Patrick Leary AVP WISP Markets Alvarion, Inc. o: 650.314.2628 c: 760.580.0080 Vonage: 650.641.1243 [EMAIL PROTECTED] -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:24 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit Sam Tetherow wrote: So are you saying that a PCMCIA card with software and internal antenna is not certified? No one has yet to answer this question for me. Is it legal for Best Buy to sell DLink/Linksys/Netgear/Belkin/... pcmcia cards for laptops? What about USB dongles? If they are legal how is they can certify a card and drivers, but we can't certify a minipci with software? If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. -- 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/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Brief report from FCC visit
in 12 more months :) W.D.McKinney wrote: Hi George, 49 here also, when do you turn 50? -Dee Alaska Wireless Systems 1(907)240-2183 Cell 1(907)349-2226 Fax 1(907)349-4308 Office www.akwireless.net - Original Message - From: George Rogato [mailto:[EMAIL PROTECTED] To: WISPA General List [mailto:[EMAIL PROTECTED] Sent: Mon, 19 Feb 2007 13:06:43 -0900 Subject: Re: [WISPA] Brief report from FCC visit No little kids here. Mine are all grown. One is the admin for OregonFAST.net and the other 2 are pc techs here as well. 2 of them are actually owners of this business. My wife mentioned having another but at 49, I'm thinking thats not a good thing. George Patrick Leary wrote: You must not have little kids like I do! They got me up nice and early at 6:30 AM today. I would not know recognize a weekend morning without Sagwa or Clifford the Big Red Dog. Patrick -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:49 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit First off Patrick, we will be going to the carpet in a few minutes when I get my thoughts collected. I just woke up an hour ago and am sometimes a little sluggish in the early hours. 2nd, Dlink, Linksys and Netgear all have antennas listed on their sites for use with their units. I may be wrong, but I would ass u me that they have been certified. But do your due diligense and check first to make sure. :) George Patrick Leary wrote: If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. That would be uncertified. This is not a debatable point. This would be taking a consumer device, which is built to permit self-installation into a device for which the FCC says there must be a professional installation. These are the most confusing parts of the rules for novices, but basically if you are installing for another end user, you are assumed to be professional, which actually imposes certain liabilities and responsibilities on you. Further, this would void the certification EVEN if it still met the manufacturer specs because, for better of worse, only the OEM manufacturer can self-certify antenna changes. George, you were in the room at the FCC with me when they told us this so you know it. It is impossible to forget since Marlon pounded them about for most of the meeting but they would not budge that only a manufacturer can pick and chose additional antennas and then only antennas of equal or less power AND with similar specs (relative to emissions on sidelobs, etc.). Really all that was done in that ruling was to make the permissive change rules more simple. None of this was done for the protection of the manufacturers, but rather to make sure the FCC had one throat to choke. Patrick Leary AVP WISP Markets Alvarion, Inc. o: 650.314.2628 c: 760.580.0080 Vonage: 650.641.1243 [EMAIL PROTECTED] -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:24 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit Sam Tetherow wrote: So are you saying that a PCMCIA card with software and internal antenna is not certified? No one has yet to answer this question for me. Is it legal for Best Buy to sell DLink/Linksys/Netgear/Belkin/... pcmcia cards for laptops? What about USB dongles? If they are legal how is they can certify a card and drivers, but we can't certify a minipci with software? If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. -- 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/ -- 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: OT RE: [WISPA] Brief report from FCC visit
Yeah, I'm just on the tail end of that time with my kids...they still like to be tucked though. It's great being a Daddy! -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Patrick Leary Sent: Monday, February 19, 2007 12:13 PM To: WISPA General List Subject: OT RE: [WISPA] Brief report from FCC visit :) Nothing like cuddling up with the girls while they are still in their footy PJs. Of course, the dog likes to pile in too. Patrick -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Marty Dougherty Sent: Monday, February 19, 2007 9:03 AM To: 'WISPA General List' Subject: RE: [WISPA] Brief report from FCC visit And lately my nights are filled with the goodnight show ___ Marty Dougherty CEO Roadstar Internet Inc. [EMAIL PROTECTED] 703-554-6620 www.roadstarinternet.com -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Patrick Leary Sent: Monday, February 19, 2007 11:59 AM To: WISPA General List Subject: RE: [WISPA] Brief report from FCC visit You must not have little kids like I do! They got me up nice and early at 6:30 AM today. I would not know recognize a weekend morning without Sagwa or Clifford the Big Red Dog. Patrick -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:49 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit First off Patrick, we will be going to the carpet in a few minutes when I get my thoughts collected. I just woke up an hour ago and am sometimes a little sluggish in the early hours. 2nd, Dlink, Linksys and Netgear all have antennas listed on their sites for use with their units. I may be wrong, but I would ass u me that they have been certified. But do your due diligense and check first to make sure. :) George Patrick Leary wrote: If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. That would be uncertified. This is not a debatable point. This would be taking a consumer device, which is built to permit self-installation into a device for which the FCC says there must be a professional installation. These are the most confusing parts of the rules for novices, but basically if you are installing for another end user, you are assumed to be professional, which actually imposes certain liabilities and responsibilities on you. Further, this would void the certification EVEN if it still met the manufacturer specs because, for better of worse, only the OEM manufacturer can self-certify antenna changes. George, you were in the room at the FCC with me when they told us this so you know it. It is impossible to forget since Marlon pounded them about for most of the meeting but they would not budge that only a manufacturer can pick and chose additional antennas and then only antennas of equal or less power AND with similar specs (relative to emissions on sidelobs, etc.). Really all that was done in that ruling was to make the permissive change rules more simple. None of this was done for the protection of the manufacturers, but rather to make sure the FCC had one throat to choke. Patrick Leary AVP WISP Markets Alvarion, Inc. o: 650.314.2628 c: 760.580.0080 Vonage: 650.641.1243 [EMAIL PROTECTED] -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of George Rogato Sent: Monday, February 19, 2007 8:24 AM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit Sam Tetherow wrote: So are you saying that a PCMCIA card with software and internal antenna is not certified? No one has yet to answer this question for me. Is it legal for Best Buy to sell DLink/Linksys/Netgear/Belkin/... pcmcia cards for laptops? What about USB dongles? If they are legal how is they can certify a card and drivers, but we can't certify a minipci with software? If your talking boxed units like netgear, dlink, and linksys sell, Of course they are certified. Is the certification void if it was torn apart and had a bigger antenna and amplifier added, probably not, unless it is to their certified specs. -- 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/ This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals computer viruses(190
Re: [WISPA] Brief report from FCC visit
On Sun, 18 Feb 2007 09:27:18 -0600 (CST), Butch Evans wrote On Sun, 18 Feb 2007, Tom DeReggi wrote: The idea behind component certification and filing DoC type of certifications, is that there IS a sticker, and that sticker refers to a filing that describes EXACTLY what's in the box, whether it's software, hardware, whateverware. Verifying software in checking and enforcing systems would be hard for the FCC, they'd actually have to login to confirm apposed to a visual check. Well, this is true, but in the end, the thing they want is X amount of EIRP, no more than Y sideband noise. That is the interferance/reuse portion of the law. They don't have to log onto anything to measure that OR to see the components used. In the end, they want compliance with the rules, rules which are designed to protect primary users of a band of spectrum, or licensed users of a band of spectrum. I do not know if the FCC considers the process as sacrosanct, or if their focus is more about how to achieve compliance. I know that the rules for part15 compliance were in NO way designed to have a lot of small businesses innovating with commodity components. Mark Koskenmaki Neofast, Inc Broadband for the Walla Walla Valley and Blue Mountains 541-969-8200 -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
RE: [WISPA] Brief report from FCC visit
Good job Tom, George and Brent. I personally have not done my due diligence in filing form 477, but will now put it on my priority list. It is good to hear about the 5.4GHz, hope the vendors will follow suit. Victoria Proffer www.stlbroadband.com -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Tom DeReggi Sent: Friday, February 16, 2007 10:47 PM To: WISPA General List Subject: [WISPA] Brief report from FCC visit We just got back from FCC and FTC visits yesterday. A couple notes... 1) Both meetings had full staff attending, which I consider an honor. Each meeting lasted about 2 hours. 2) Some of the WISPs had to cancel due to weather, but 3 made it, George Rigoto, Brent Anderson, and myself Tom DeReggi. 3) One thing was clear without a doubt. They are somewhat pissed that all WISPs are NOT filling From 477. I think the general concensus was that maybe only 10% were? The FCC primarilly stayed on the arguement that it wasn't a choice, it was law. But I could see it in their eyes that it was more than that, possibly even hurtful. After all that they have been doing for us, that the single only thing that they asked of us, we couldn't even bother to do. I tell you, we will alienate our friends at the FCC, if we do not cooperate. EVERYONE must file Form 477. They did Thank WISPA for helping in promoting the need to file. We talked a bit about why we thought some WISPs weren't filing. But anyway we looked at it, any reason not to was a false fear. The Form 477 is not intertwined with the taxation department, it is not intertwined with the Enforcement beaurow for illegal gear. They aren't giving the data to our competition. And the data they collect is to broad to even do us harm if it was disclosed. So if you are a WISP, please file. I personally am working on my Form today, and plan on sending it in Monday. I personally won't make the mistake of not filing, again. 4) We discussed the option for self/group effort to certifying gear combinations. It won't be an option that will be viable. It must be a Manufacturer that applied for equipment certification, as there must be an accountable/responsible/liable party. A group applying for certification, would have to take liabilty and prove their ability to be able to be accountable. I'm not the police and not going to tell you what to use, but any way you slice it, make your own StarOS / Mikrotik gear is illegal (non-certified) in the US. The only way to not be illegal, is to buy it from a manufacturer that has certified their combination, or you become a manufacturer yourself and apply for certification of your combination. The fact that XYZ certified the combination, does not make your combination certified. UNLESS you convince XYZ to be responsible and liable for the compliance of the gear that you bought elsewhere. A MPCI card and antenna is not enough to be a certified system. There are other components involved like Main boards and cases, and testing gear during the QC stage to verify compliance. But there is nothing wrong with a group of people taking up a collection to help a manufactuer pay for certifying their combination. The grey area is it is also in the new rules that all the components (such as antenna and cables) don't necessarilly have to be bought from the manufacturer, if they are the same products bought elsewhere. So if a manufacturer certified a complete combination, and discloses what components were in it, technically it could be argued that it is that same product as the manufacturers, if the same oem parts were used. But legally that won't completely fly either, because there is no FCC sticker that was issued to the manufactuer, and there is no one accountable for it. So technically, at least one major component of the solution would have to be certified where you'd get the sticker from the manufacturer. So legally we may be able to substitute antenna, but that is not the same thing as saying you are allowed to just build your own radio system from scratch. 5) Enforcement- The FCC was clear on the issue that the rules are the rules, period. But they also said, when reporting a complaint, it should be defined the details. Complaints are prioritized by severity, and more severe violation will be given higher priority to enforce. The mentons a very low number of complaints we filed. They stated enforcement is a reality, but it requires someone to complain, and disclose facts for the FCC to know something is needing investigation. 6) 5.4G violations. They were very concerned that some gear on the market may be able to illegally be configured to use 5.4Ghz without going through the certification process for compliance. They are much more concerned on the compliace of 5.4 gear because the importance NOT TO INTERFERE with DOD applications. So using uncertified 5.4 gear is on the Radar for enforcement, without sympathy.
Re: [WISPA] Brief report from FCC visit
Mark, wireless ISP, exactly why would you know about it? Wireless guys are more likely to have some knowlege of the FCC.. non-wireless... The FCC is foreign and irrelevant to them. This argument is moot considering they were talking about WISP's, specifically, not non wireless guys. 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] Brief report from FCC visit
Mark: You're overlooking one critical difference between PCs and Wireless systems. PCs are UNintentional radiators, with radiated power levels that are very, very low. Wireless systems are intentional radiators, at significant power levels, and through unintended mixing, have the potential to disrupt other communications systems, including critical systems like public safety. This is a very real fear of the FCC, borne out over nearly 100 years of experience now with the evolution of wireless technology. These things DO happen, and having a proliferation of unlicensed systems out there with significant power levels (EIRP) can cause havoc. When a WISP slaps together a system, do they hook it up to a spectrum analyzer to insure that substantially all the radiated energy is contained within the desired band? No, they don't. Um, the FCC is getting innovation and advancement - look at Clearwire. When there weren't Clearwire, NextWave, Sprint Nextel and ATT actively deploying Broadband Wireless Internet Access, the FCC needed WISPs. Now they've got those big players starting to deploy and they can point to them as a success story for Broadband Wireless Internet Access. Thanks, Steve On Feb 16, 2007, at Feb 16 11:38 PM, wispa wrote: I'd say that that's probable. Further, I'd say that at least 75% of those who did or do not don't even know about it. Especially, if you're a non- wireless ISP, exactly why would you know about it? Wireless guys are more likely to have some knowlege of the FCC.. non-wireless... The FCC is foreign and irrelevant to them. If the government officials take it personal, we're doomed. We're all doomed. If they see things as must get them under our control then there's no longer any good going to happen. It becomes adversary vs adversary. Let me predict that form 445 will get perhaps HALF that response. Again, who's even going to know? I think that's the wrong approach, and along with you, I sincerely doubt it can be gotten past a regulatory body. I suggested component, rather than assembly certification. This way there IS a responsible party. The maker of the equipment is responsible if it is not within spec, and the user is responsible if the user fails to follow the rules concerning EIRP and out of band emissions. Look, there's GOOD precedent for this. Do any of you remember when PC's had to be FCC certified? In the FCC's own terminology - in their own words, even - assemblies using normally compliant parts can be considered compliant and require only a DoC, or Declaration of Conformity. No testing needed. For instance, the SAME mini-pci card the FCC wants certified as an assembly with a WRAP board is perfectly legal to stuff into a laptop with nothing other than a DoC by the maker of the laptop! The only thing this would require... is some specific guidelines from the FCC for component certification by the manufacturer, and the ability for us to file DoC with the FCC for obviously legal assemblies that obviously comply with the intentional radiator standards, because we file for combinations of parts with CERTIFIED behavior and it would be almost simplistic to both do and oversee. So, WOULD I file DoC's on the parts combinations I'd like to use, and then sticker them so * I * am responsible for those? Of course. If Wistron Neweb wants to sell 500K CM-9's let them certify their behavior. Let PacWireless certify the patterns and gain of thier antennas. Let Ubiquiti certify the behavior of SR-9's and SR-2's. It makes little sense to test, retest, re-retest over and over and over, the same basic parts to the same standards. If Wistron's mini-pci fails to perform as spec'd, is it the fault of ... Builder X, who certified the assembly? Or the fault of Wistron? If PacWireless antennas are sold as 21 db gain and are really 27, is that the fault of Builder X or PacWireless? If accountability is what they want, THIS IS IT. Again, the grey area you talk about concerning the use of identical parts of a different brand is actually resolved, from a regulatory viewpoint, rather than being gray. THIS I would argue, not that individual unknown parts be assembled and then magically declared conforming. Like it's going to matter if the case is made of aluminum, steel, or stainless, and whether it's 6X8 or 16X12 as to whether the EIRP, out of band emissions, and so on, meet the legal requirements. Of course it does not. Again, this process of using compliant parts with a DoC on file would be a great way to solve ALL of this. The FCC could ALWAYS restrict it to WISP applications, even, if they wanted. I would argue that the market lifespan and the almost frantic pace of innovation and technological improvement has obsoleted the assembly certification process, as parts suppliers update what's being sold as often as every few months.
Re: [WISPA] Brief report from FCC visit
On Sat, 17 Feb 2007, Steve Stroh wrote: When a WISP slaps together a system, do they hook it up to a spectrum analyzer to insure that substantially all the radiated energy is contained within the desired band? No, they don't. As odd as it may sound, I am in agreement with Mark on this one. Mark went into detail about how it can (and should) be accomplished. For example: 1. A radio (CM-9 for example) has known output power when combined with a specific driver. It's up to the software folks to insure they don't attempt to drive this card outside the manufacturer's given parameters. SO, a card (combined with a specific driver/OS) could be certified to behave in a specific manner. Once we have #1 done, we can use this card and OS in combination with ANY mother board and we won't be changing the operating parameters of the card. What is wrong with a certification that includes these 2 parameters? 2. Once we know that a radio/OS combo produces a CERTIFIED, known, behaviour in terms of power levels, we can combine THAT CERTIFIED COMBO with a specific antenna. This antenna would have to be type certified as well. So long as that antenna exhibits a known (certified) behaviour, we can easily, and RELIABLY predict the EIRP, radiation pattern and even sideband noise. I don't need a spectrum analyzer to know these things. So long as the above is true, then what is the problem? I'll tell you what the problem is...It is currently illegal to operate. I agree with Mark's contention that it SHOULD be the way he described (in terms of what is legal), but it is not. I'm at a loss for how this fact benefits Americans. Perhaps I am just slow... Um, the FCC is getting innovation and advancement - look at Clearwire. When there weren't Clearwire, NextWave, Sprint Nextel and ATT actively deploying Broadband Wireless Internet Access, the FCC needed WISPs. Now they've got those big players starting to deploy and they can point to them as a success story for Broadband Wireless Internet Access. This is somewhat telling, huh? As a WISP consultant, I can tell you that I am fully aware of SEVERAL WISPs that are operating illegally. MOST of them are operating within the parameters of the legal EIRP, but with non-certified combinations of radio systems. I do tell those that don't know that they are operating illegally. The fact is, the FCC wants innovation? They have it with WISPs. They really need to work on a means to allow us (as WISPs) to operate legally, but not dramatically limit our choices. Allow us to provide reliable service, within the limits of the EIRP, radiation patterns and such. Allow us to make decisions on the combination of gear we use based on the coverage we need, so long as we don't go outside these limitations. I just don't see what's so wrong with this kind of request (beyond the current legal status). -- Butch Evans Network Engineering and Security Consulting 573-276-2879 http://www.butchevans.com/ My calendar: http://tinyurl.com/y24ad6 Training Partners: http://tinyurl.com/smfkf Mikrotik Certified Consultant http://www.mikrotik.com/consultants.html -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
RE: [WISPA] Brief report from FCC visit
Thanks for your summary Tom. I not even going to pretend to be surprised by anything they mentioned -- as your meeting only validates my recent posts on the subject, no matter how much so many reject what I say as opinion and no matter how many think these are matters of choice. They are not. When the pain comes, such WISPs cannot say they were not adequately informed. As for, The same request goes out to all the name brand vendors like Trango, Alvarion, and Whoever else... regarding 5.4 certification. No worries there --ever-- about Alvarion not following the FCC requirements to the letter. I can and will tell folks that it will be the WISP relativism of so many and the rampant use of uncertified 5.4 GHz that will bring this all to a head. The FCC has been patient and EXCEPTIONALLY laissez-faire, but in 5.4 GHz that ends. Why, because many WISPs may not be aware how difficult 5.4 GHz has been for the FCC. They don't know the lengths that they, the NTIA, and others went through to come up with something expectable for the military. And this time, when the violations come, it will be the DoD that applies the pressure on the FCC to enforce the rules. Patrick Leary AVP WISP Markets Alvarion, Inc. o: 650.314.2628 c: 760.580.0080 Vonage: 650.641.1243 [EMAIL PROTECTED] -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Tom DeReggi Sent: Friday, February 16, 2007 8:47 PM To: WISPA General List Subject: [WISPA] Brief report from FCC visit We just got back from FCC and FTC visits yesterday. A couple notes... 1) Both meetings had full staff attending, which I consider an honor. Each meeting lasted about 2 hours. 2) Some of the WISPs had to cancel due to weather, but 3 made it, George Rigoto, Brent Anderson, and myself Tom DeReggi. 3) One thing was clear without a doubt. They are somewhat pissed that all WISPs are NOT filling From 477. I think the general concensus was that maybe only 10% were? The FCC primarilly stayed on the arguement that it wasn't a choice, it was law. But I could see it in their eyes that it was more than that, possibly even hurtful. After all that they have been doing for us, that the single only thing that they asked of us, we couldn't even bother to do. I tell you, we will alienate our friends at the FCC, if we do not cooperate. EVERYONE must file Form 477. They did Thank WISPA for helping in promoting the need to file. We talked a bit about why we thought some WISPs weren't filing. But anyway we looked at it, any reason not to was a false fear. The Form 477 is not intertwined with the taxation department, it is not intertwined with the Enforcement beaurow for illegal gear. They aren't giving the data to our competition. And the data they collect is to broad to even do us harm if it was disclosed. So if you are a WISP, please file. I personally am working on my Form today, and plan on sending it in Monday. I personally won't make the mistake of not filing, again. 4) We discussed the option for self/group effort to certifying gear combinations. It won't be an option that will be viable. It must be a Manufacturer that applied for equipment certification, as there must be an accountable/responsible/liable party. A group applying for certification, would have to take liabilty and prove their ability to be able to be accountable. I'm not the police and not going to tell you what to use, but any way you slice it, make your own StarOS / Mikrotik gear is illegal (non-certified) in the US. The only way to not be illegal, is to buy it from a manufacturer that has certified their combination, or you become a manufacturer yourself and apply for certification of your combination. The fact that XYZ certified the combination, does not make your combination certified. UNLESS you convince XYZ to be responsible and liable for the compliance of the gear that you bought elsewhere. A MPCI card and antenna is not enough to be a certified system. There are other components involved like Main boards and cases, and testing gear during the QC stage to verify compliance. But there is nothing wrong with a group of people taking up a collection to help a manufactuer pay for certifying their combination. The grey area is it is also in the new rules that all the components (such as antenna and cables) don't necessarilly have to be bought from the manufacturer, if they are the same products bought elsewhere. So if a manufacturer certified a complete combination, and discloses what components were in it, technically it could be argued that it is that same product as the manufacturers, if the same oem parts were used. But legally that won't completely fly either, because there is no FCC sticker that was issued to the manufactuer, and there is no one accountable for it. So technically, at least one major component of the solution would have to be certified where you'd get the sticker from the manufacturer. So
Re: [WISPA] Brief report from FCC visit
I, for one, agree with Butch. Parts certification is the way it needs to go. Hold the part manufactures responsible for their published numbers. Allow operators to mix-n-match parts as they see fit, within the power limits. Hold operators responsible for their EIRP numbers. This would allow ongoing innovation in the field without driving the small guys out. I don't want to be locked into a single manufacturer. Quite honestly, I don't trust that what I need will still be available 6 months from now if I'm locked into one provider. Using commodity hardware I can build what I need. If, as an example only, the SR2 cards becomes unavailable, I can use a CM9 and a small amp to replace it. I'm sure others can come up with more examples... What happens to me when the single source supplier I was using drops support and production of the equipment I was using? Blair Davis West Michigan Wireless ISP 269-686-8648 Butch Evans wrote: On Sat, 17 Feb 2007, Steve Stroh wrote: When a WISP slaps together a system, do they hook it up to a spectrum analyzer to insure that substantially all the radiated energy is contained within the desired band? No, they don't. As odd as it may sound, I am in agreement with Mark on this one. Mark went into detail about how it can (and should) be accomplished. For example: 1. A radio (CM-9 for example) has known output power when combined with a specific driver. It's up to the software folks to insure they don't attempt to drive this card outside the manufacturer's given parameters. SO, a card (combined with a specific driver/OS) could be certified to behave in a specific manner. Once we have #1 done, we can use this card and OS in combination with ANY mother board and we won't be changing the operating parameters of the card. What is wrong with a certification that includes these 2 parameters? 2. Once we know that a radio/OS combo produces a CERTIFIED, known, behaviour in terms of power levels, we can combine THAT CERTIFIED COMBO with a specific antenna. This antenna would have to be type certified as well. So long as that antenna exhibits a known (certified) behaviour, we can easily, and RELIABLY predict the EIRP, radiation pattern and even sideband noise. I don't need a spectrum analyzer to know these things. So long as the above is true, then what is the problem? I'll tell you what the problem is...It is currently illegal to operate. I agree with Mark's contention that it SHOULD be the way he described (in terms of what is legal), but it is not. I'm at a loss for how this fact benefits Americans. Perhaps I am just slow... Um, the FCC is getting innovation and advancement - look at Clearwire. When there weren't Clearwire, NextWave, Sprint Nextel and ATT actively deploying Broadband Wireless Internet Access, the FCC needed WISPs. Now they've got those big players starting to deploy and they can point to them as a success story for Broadband Wireless Internet Access. This is somewhat telling, huh? As a WISP consultant, I can tell you that I am fully aware of SEVERAL WISPs that are operating illegally. MOST of them are operating within the parameters of the legal EIRP, but with non-certified combinations of radio systems. I do tell those that don't know that they are operating illegally. The fact is, the FCC wants innovation? They have it with WISPs. They really need to work on a means to allow us (as WISPs) to operate legally, but not dramatically limit our choices. Allow us to provide reliable service, within the limits of the EIRP, radiation patterns and such. Allow us to make decisions on the combination of gear we use based on the coverage we need, so long as we don't go outside these limitations. I just don't see what's so wrong with this kind of request (beyond the current legal status). -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Brief report from FCC visit
On Sat, 17 Feb 2007 10:17:09 -0800, Steve Stroh wrote Mark: You're overlooking one critical difference between PCs and Wireless systems. I merely used PC's because anyone who's been around the PC business for a few years will be aware of the change that occurred a while back that allowed much easier changes to pc design and MUCH lower prices by simply using known devices in mix-n-match. PCs are UNintentional radiators, with radiated power levels that are very, very low. Wireless systems are intentional radiators, at significant power levels, and through unintended mixing, have the potential to disrupt other communications systems, including critical systems like public safety. But this is NOT limited to UNintentional radiators. It is also used for many intentional radiators, too. I found references to cell phones, wireless telephone handsets, digital voice devices, all of which were using known compliant devices and thus were compliant merely with DoC procedures. This is a very real fear of the FCC, borne out over nearly 100 years of experience now with the evolution of wireless technology. Actually, part 15 devices were never imagined to be built from componentized parts. There's at least 50 different 802.11 type mini-pci boards, more likely 200, all of which are common form factor, chipsets, and function. Since part 15 was designed for consumer items like baby monitors and mini tv cameras and doorbells and security monitors and car starters and other such standalone devices, it was never concieved of millions of the same exact function device being built from commodity parts. This is why Part 15 has no current provisions for DoC compliance like many other sections of the FCC code. There are licensed and some unlicensed stuff which does have DoC procedures. This was done because manyh things like Cell phones ARE built from commodity components. These things DO happen, and having a proliferation of unlicensed systems out there with significant power levels (EIRP) can cause havoc. When a WISP slaps together a system, do they hook it up to a spectrum analyzer to insure that substantially all the radiated energy is contained within the desired band? No, they don't. Um, the FCC is getting innovation and advancement - look at Clearwire. When there weren't Clearwire, NextWave, Sprint Nextel and ATT actively deploying Broadband Wireless Internet Access, the FCC needed WISPs. Now they've got those big players starting to deploy and they can point to them as a success story for Broadband Wireless Internet Access. Well, there you have it folks. the only valid innovation is always big business overspending on overpriced stuff selling overpriced services at a loss, screwing the investors. Which is being defended in practice by people who claim to be my friends. sigh Mark Koskenmaki Neofast, Inc Broadband for the Walla Walla Valley and Blue Mountains 541-969-8200 -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Brief report from FCC visit
On Sat, 17 Feb 2007 14:02:09 -0600 (CST), Butch Evans wrote On Sat, 17 Feb 2007, Steve Stroh wrote: As odd as it may sound, I am in agreement with Mark on this one. Mark went into detail about how it can (and should) be accomplished. For example: As much as we've had our differences and sniped at each other, thanks. Oh, and I regret now my acid comments your way at times. I misjudged you. If you can look past our disagreements, so can I. My apologies. Um, the FCC is getting innovation and advancement - look at Clearwire. When there weren't Clearwire, NextWave, Sprint Nextel and ATT actively deploying Broadband Wireless Internet Access, the FCC needed WISPs. Now they've got those big players starting to deploy and they can point to them as a success story for Broadband Wireless Internet Access. This is somewhat telling, huh? As a WISP consultant, I can tell you that I am fully aware of SEVERAL WISPs that are operating illegally. MOST of them are operating within the parameters of the legal EIRP, but with non-certified combinations of radio systems. I do tell those that don't know that they are operating illegally. The fact is, the FCC wants innovation? They have it with WISPs. They really need to work on a means to allow us (as WISPs) to operate legally, but not dramatically limit our choices. Allow us to provide reliable service, within the limits of the EIRP, radiation patterns and such. Allow us to make decisions on the combination of gear we use based on the coverage we need, so long as we don't go outside these limitations. I just don't see what's so wrong with this kind of request (beyond the current legal status). I detest Mikrotik in use... and I have no intention of having another MT vs Star-OS Jihad, but in this regard, if it were not for MT and Star-OS and a few others out there who were ALL Small guys there would ahve been almost NO innovation from the big guys. Like it or not, the try stuff and think outside the box types have solely been responsible for the advancement of this industry, in my view. EVERY ONE OF THEM has been illegal in some fashion, because there simply is no provision to innovate using commodity equipment within Part 15. Unlike Steve's characterization of slapping equipment together, the suggestion and procedure I detailed is all about doing things RIGHT, and following time honored and entirely legitemate means of BEING COMPLIANT with standards and rules, and all we're asking here is to change the law to allow standards compliant devices to be legal in the letter of the law. If this industry is going to move forward, and if the FCC REALLY intends compliance... There is ONLY one means of accomplishing this,and it's something like what Butch and I detailed. If we have to wait for Trango or Alvarion, or Motorola to crawl along, this industry dies, because the new stuff every 6 months or less will stop happening, and our innovation will be as slow and ponderous and timid as Cellular and POTS services. Not because the companies are necessarily slow, but they don't 'throw stuff up and try it, and cannot. They spend a LOT to get certified and in production, and it takes us WISP's about 24 hours to start telling them what we think of it. missing this, that doesn't work, why can't you...blah blah. Funny, HAM radio operators CAN build whatever they want out of whatever, and try it, for instance, in the 2.4 gig band. Oddly enough, they're lagging behind individual WISP's in knowledge, understanding, and practical applications. May I make a modest proposal, that the new 3.65-3.7ghz band have this type of equipment certification..and when it's available, the number of products that can be affordably deployed with rival that of unlicensed within 18 months. Man, anything but the status quo. -- Butch Evans Network Engineering and Security Consulting 573-276-2879 http://www.butchevans.com/ My calendar: http://tinyurl.com/y24ad6 Training Partners: http://tinyurl.com/smfkf Mikrotik Certified Consultant http://www.mikrotik.com/consultants.html -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ Mark Koskenmaki Neofast, Inc Broadband for the Walla Walla Valley and Blue Mountains 541-969-8200 -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
RE: [WISPA] Brief report from FCC visit
Blair, that is certainly a possible thing for WISPs to advocate for as a rules change, and if you feel strongly about that you should do the work with other like-minded WISPs to effect change. That's a positive thing to do and caring enough to actively effect change using the process is always something to be admired and respected, regardless of what any of us might think of the ideas themselves. But, at the same time you should also acknowledge that in the interim the existing rules must be followed. We all don't get the luxury to pick and chose those rules we are willing to tolerate, at least not without being willing to accept whatever eventual consequence may result from flaunting the rules. As to your question, What happens to me when the single source supplier I was using drops support and production of the equipment I was using? I'd say that's not difficult to address, but it requires a necessary step that should be taken at the time you are planning your business. Make your technology decisions inclusive of generally accepted business due diligence. In this case it means NOT making the business decision to chose a flaky or unstable supplier. If you do not take into account such basic business questions in your question, then the hard truth is that you would might be SOL -- a simple result from a risky decision. Patrick Leary AVP WISP Markets Alvarion, Inc. o: 650.314.2628 c: 760.580.0080 Vonage: 650.641.1243 [EMAIL PROTECTED] -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Blair Davis Sent: Saturday, February 17, 2007 12:33 PM To: WISPA General List Subject: Re: [WISPA] Brief report from FCC visit I, for one, agree with Butch. Parts certification is the way it needs to go. Hold the part manufactures responsible for their published numbers. Allow operators to mix-n-match parts as they see fit, within the power limits. Hold operators responsible for their EIRP numbers. This would allow ongoing innovation in the field without driving the small guys out. I don't want to be locked into a single manufacturer. Quite honestly, I don't trust that what I need will still be available 6 months from now if I'm locked into one provider. Using commodity hardware I can build what I need. If, as an example only, the SR2 cards becomes unavailable, I can use a CM9 and a small amp to replace it. I'm sure others can come up with more examples... What happens to me when the single source supplier I was using drops support and production of the equipment I was using? Blair Davis West Michigan Wireless ISP 269-686-8648 Butch Evans wrote: On Sat, 17 Feb 2007, Steve Stroh wrote: When a WISP slaps together a system, do they hook it up to a spectrum analyzer to insure that substantially all the radiated energy is contained within the desired band? No, they don't. As odd as it may sound, I am in agreement with Mark on this one. Mark went into detail about how it can (and should) be accomplished. For example: 1. A radio (CM-9 for example) has known output power when combined with a specific driver. It's up to the software folks to insure they don't attempt to drive this card outside the manufacturer's given parameters. SO, a card (combined with a specific driver/OS) could be certified to behave in a specific manner. Once we have #1 done, we can use this card and OS in combination with ANY mother board and we won't be changing the operating parameters of the card. What is wrong with a certification that includes these 2 parameters? 2. Once we know that a radio/OS combo produces a CERTIFIED, known, behaviour in terms of power levels, we can combine THAT CERTIFIED COMBO with a specific antenna. This antenna would have to be type certified as well. So long as that antenna exhibits a known (certified) behaviour, we can easily, and RELIABLY predict the EIRP, radiation pattern and even sideband noise. I don't need a spectrum analyzer to know these things. So long as the above is true, then what is the problem? I'll tell you what the problem is...It is currently illegal to operate. I agree with Mark's contention that it SHOULD be the way he described (in terms of what is legal), but it is not. I'm at a loss for how this fact benefits Americans. Perhaps I am just slow... Um, the FCC is getting innovation and advancement - look at Clearwire. When there weren't Clearwire, NextWave, Sprint Nextel and ATT actively deploying Broadband Wireless Internet Access, the FCC needed WISPs. Now they've got those big players starting to deploy and they can point to them as a success story for Broadband Wireless Internet Access. This is somewhat telling, huh? As a WISP consultant, I can tell you that I am fully aware of SEVERAL WISPs that are operating illegally. MOST of them are operating within the parameters of the legal EIRP, but with non-certified combinations of radio systems. I do tell
Re: [WISPA] Brief report from FCC visit
Many good arguements that you stated for component certification method. I played the restricting innovation card, at the meaning. The FCC did say that they would put some more thought into this. But remember, components in a PC aren't supposed to go airbourne, so its a little more risky and open to abuse for wireless gear. In otherwords, more harm can be done by a wireless abuser. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: wispa [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Saturday, February 17, 2007 2:38 AM Subject: Re: [WISPA] Brief report from FCC visit On Fri, 16 Feb 2007 23:47:27 -0500, Tom DeReggi wrote We just got back from FCC and FTC visits yesterday. A couple notes... 1) Both meetings had full staff attending, which I consider an honor. Each meeting lasted about 2 hours. 2) Some of the WISPs had to cancel due to weather, but 3 made it, George Rigoto, Brent Anderson, and myself Tom DeReggi. 3) One thing was clear without a doubt. They are somewhat pissed that all WISPs are NOT filling From 477. I think the general concensus was that maybe only 10% were? The FCC primarilly stayed on I'd say that that's probable. Further, I'd say that at least 75% of those who did or do not don't even know about it. Especially, if you're a non- wireless ISP, exactly why would you know about it? Wireless guys are more likely to have some knowlege of the FCC.. non-wireless... The FCC is foreign and irrelevant to them. the arguement that it wasn't a choice, it was law. But I could see it in their eyes that it was more than that, possibly even hurtful. If the government officials take it personal, we're doomed. We're all doomed. If they see things as must get them under our control then there's no longer any good going to happen. It becomes adversary vs adversary. Let me predict that form 445 will get perhaps HALF that response. Again, who's even going to know? 4) We discussed the option for self/group effort to certifying gear combinations. It won't be an option that will be viable. It must be a Manufacturer that applied for equipment certification, as there must be an accountable/responsible/liable party. A group applying for certification, would have to take liabilty and prove their ability to be able to be accountable. I think that's the wrong approach, and along with you, I sincerely doubt it can be gotten past a regulatory body. I suggested component, rather than assembly certification. This way there IS a responsible party. The maker of the equipment is responsible if it is not within spec, and the user is responsible if the user fails to follow the rules concerning EIRP and out of band emissions. Look, there's GOOD precedent for this. Do any of you remember when PC's had to be FCC certified? In the FCC's own terminology - in their own words, even - assemblies using normally compliant parts can be considered compliant and require only a DoC, or Declaration of Conformity. No testing needed. For instance, the SAME mini-pci card the FCC wants certified as an assembly with a WRAP board is perfectly legal to stuff into a laptop with nothing other than a DoC by the maker of the laptop! The only thing this would require... is some specific guidelines from the FCC for component certification by the manufacturer, and the ability for us to file DoC with the FCC for obviously legal assemblies that obviously comply with the intentional radiator standards, because we file for combinations of parts with CERTIFIED behavior and it would be almost simplistic to both do and oversee. So, WOULD I file DoC's on the parts combinations I'd like to use, and then sticker them so * I * am responsible for those? Of course. If Wistron Neweb wants to sell 500K CM-9's let them certify their behavior. Let PacWireless certify the patterns and gain of thier antennas. Let Ubiquiti certify the behavior of SR-9's and SR-2's. It makes little sense to test, retest, re-retest over and over and over, the same basic parts to the same standards. If Wistron's mini-pci fails to perform as spec'd, is it the fault of ... Builder X, who certified the assembly? Or the fault of Wistron? If PacWireless antennas are sold as 21 db gain and are really 27, is that the fault of Builder X or PacWireless? If accountability is what they want, THIS IS IT. Again, the grey area you talk about concerning the use of identical parts of a different brand is actually resolved, from a regulatory viewpoint, rather than being gray. THIS I would argue, not that individual unknown parts be assembled and then magically declared conforming. I'm not the police and not going to tell you what to use, but any way you slice it, make your own StarOS / Mikrotik gear is illegal (non-certified) in the US. The only way to not be illegal, is to buy it from a manufacturer that has certified their combination
RE: [WISPA] Brief report from FCC visit
Tom, George Brent, I just want to thank you men for taking the time, money and effort to be there for all of us. I appreciate the great update on the meetings as well. I look forward to my turn even though I don't have the time - -I feel its each of our duties to make the time. Thanks, Mac -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Tom DeReggi Sent: Friday, February 16, 2007 10:47 PM To: WISPA General List Subject: [WISPA] Brief report from FCC visit We just got back from FCC and FTC visits yesterday. A couple notes... 1) Both meetings had full staff attending, which I consider an honor. Each meeting lasted about 2 hours. 2) Some of the WISPs had to cancel due to weather, but 3 made it, George Rigoto, Brent Anderson, and myself Tom DeReggi. 3) One thing was clear without a doubt. They are somewhat pissed that all WISPs are NOT filling From 477. I think the general concensus was that maybe only 10% were? The FCC primarilly stayed on the arguement that it wasn't a choice, it was law. But I could see it in their eyes that it was more than that, possibly even hurtful. After all that they have been doing for us, that the single only thing that they asked of us, we couldn't even bother to do. I tell you, we will alienate our friends at the FCC, if we do not cooperate. EVERYONE must file Form 477. They did Thank WISPA for helping in promoting the need to file. We talked a bit about why we thought some WISPs weren't filing. But anyway we looked at it, any reason not to was a false fear. The Form 477 is not intertwined with the taxation department, it is not intertwined with the Enforcement beaurow for illegal gear. They aren't giving the data to our competition. And the data they collect is to broad to even do us harm if it was disclosed. So if you are a WISP, please file. I personally am working on my Form today, and plan on sending it in Monday. I personally won't make the mistake of not filing, again. 4) We discussed the option for self/group effort to certifying gear combinations. It won't be an option that will be viable. It must be a Manufacturer that applied for equipment certification, as there must be an accountable/responsible/liable party. A group applying for certification, would have to take liabilty and prove their ability to be able to be accountable. I'm not the police and not going to tell you what to use, but any way you slice it, make your own StarOS / Mikrotik gear is illegal (non-certified) in the US. The only way to not be illegal, is to buy it from a manufacturer that has certified their combination, or you become a manufacturer yourself and apply for certification of your combination. The fact that XYZ certified the combination, does not make your combination certified. UNLESS you convince XYZ to be responsible and liable for the compliance of the gear that you bought elsewhere. A MPCI card and antenna is not enough to be a certified system. There are other components involved like Main boards and cases, and testing gear during the QC stage to verify compliance. But there is nothing wrong with a group of people taking up a collection to help a manufactuer pay for certifying their combination. The grey area is it is also in the new rules that all the components (such as antenna and cables) don't necessarilly have to be bought from the manufacturer, if they are the same products bought elsewhere. So if a manufacturer certified a complete combination, and discloses what components were in it, technically it could be argued that it is that same product as the manufacturers, if the same oem parts were used. But legally that won't completely fly either, because there is no FCC sticker that was issued to the manufactuer, and there is no one accountable for it. So technically, at least one major component of the solution would have to be certified where you'd get the sticker from the manufacturer. So legally we may be able to substitute antenna, but that is not the same thing as saying you are allowed to just build your own radio system from scratch. 5) Enforcement- The FCC was clear on the issue that the rules are the rules, period. But they also said, when reporting a complaint, it should be defined the details. Complaints are prioritized by severity, and more severe violation will be given higher priority to enforce. The mentons a very low number of complaints we filed. They stated enforcement is a reality, but it requires someone to complain, and disclose facts for the FCC to know something is needing investigation. 6) 5.4G violations. They were very concerned that some gear on the market may be able to illegally be configured to use 5.4Ghz without going through the certification process for compliance. They are much more concerned on the compliace of 5.4 gear because the importance NOT TO INTERFERE with DOD applications. So using uncertified 5.4 gear
Re: [WISPA] Brief report from FCC visit
On Fri, 16 Feb 2007 23:47:27 -0500, Tom DeReggi wrote We just got back from FCC and FTC visits yesterday. A couple notes... 1) Both meetings had full staff attending, which I consider an honor. Each meeting lasted about 2 hours. 2) Some of the WISPs had to cancel due to weather, but 3 made it, George Rigoto, Brent Anderson, and myself Tom DeReggi. 3) One thing was clear without a doubt. They are somewhat pissed that all WISPs are NOT filling From 477. I think the general concensus was that maybe only 10% were? The FCC primarilly stayed on I'd say that that's probable. Further, I'd say that at least 75% of those who did or do not don't even know about it. Especially, if you're a non- wireless ISP, exactly why would you know about it? Wireless guys are more likely to have some knowlege of the FCC.. non-wireless... The FCC is foreign and irrelevant to them. the arguement that it wasn't a choice, it was law. But I could see it in their eyes that it was more than that, possibly even hurtful. If the government officials take it personal, we're doomed. We're all doomed. If they see things as must get them under our control then there's no longer any good going to happen. It becomes adversary vs adversary. Let me predict that form 445 will get perhaps HALF that response. Again, who's even going to know? 4) We discussed the option for self/group effort to certifying gear combinations. It won't be an option that will be viable. It must be a Manufacturer that applied for equipment certification, as there must be an accountable/responsible/liable party. A group applying for certification, would have to take liabilty and prove their ability to be able to be accountable. I think that's the wrong approach, and along with you, I sincerely doubt it can be gotten past a regulatory body. I suggested component, rather than assembly certification. This way there IS a responsible party. The maker of the equipment is responsible if it is not within spec, and the user is responsible if the user fails to follow the rules concerning EIRP and out of band emissions. Look, there's GOOD precedent for this. Do any of you remember when PC's had to be FCC certified? In the FCC's own terminology - in their own words, even - assemblies using normally compliant parts can be considered compliant and require only a DoC, or Declaration of Conformity. No testing needed. For instance, the SAME mini-pci card the FCC wants certified as an assembly with a WRAP board is perfectly legal to stuff into a laptop with nothing other than a DoC by the maker of the laptop! The only thing this would require... is some specific guidelines from the FCC for component certification by the manufacturer, and the ability for us to file DoC with the FCC for obviously legal assemblies that obviously comply with the intentional radiator standards, because we file for combinations of parts with CERTIFIED behavior and it would be almost simplistic to both do and oversee. So, WOULD I file DoC's on the parts combinations I'd like to use, and then sticker them so * I * am responsible for those? Of course. If Wistron Neweb wants to sell 500K CM-9's let them certify their behavior. Let PacWireless certify the patterns and gain of thier antennas. Let Ubiquiti certify the behavior of SR-9's and SR-2's. It makes little sense to test, retest, re-retest over and over and over, the same basic parts to the same standards. If Wistron's mini-pci fails to perform as spec'd, is it the fault of ... Builder X, who certified the assembly? Or the fault of Wistron? If PacWireless antennas are sold as 21 db gain and are really 27, is that the fault of Builder X or PacWireless? If accountability is what they want, THIS IS IT. Again, the grey area you talk about concerning the use of identical parts of a different brand is actually resolved, from a regulatory viewpoint, rather than being gray. THIS I would argue, not that individual unknown parts be assembled and then magically declared conforming. I'm not the police and not going to tell you what to use, but any way you slice it, make your own StarOS / Mikrotik gear is illegal (non-certified) in the US. The only way to not be illegal, is to buy it from a manufacturer that has certified their combination, or you become a manufacturer yourself and apply for certification of your combination. The fact that XYZ certified the combination, does not make your combination certified. UNLESS you convince XYZ to be responsible and liable for the compliance of the gear that you bought elsewhere. A MPCI card and antenna is not enough to be a certified system. There are other components involved like Main boards and cases, and testing gear during the QC stage to verify compliance. Like it's going to matter if the case is made of aluminum, steel, or stainless, and whether it's 6X8 or 16X12 as
