I've looked into this further, and found the cause of the problem.

The ipw3945 module is not loaded by the initrd as I originally
suspected, but by udevtrigger from "/etc/rcS.d/S10udev".  At this point
"/" is mounted read-only.  The daemon was failing to start, due to not
being able to write "/var/run/ipw3945d.pid".

I had installed Feisty with "/var" as a separate partition, so there was
no "/var/run" directory on the root filesystem, so "/var/run" did not
get mounted as a writeable tmpfs mount.

I corrected this by creating the "/var/run" directory on the root
filesystem, and now the regulatory daemon is started at boot.

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ipw3945d not started at boot
https://bugs.launchpad.net/bugs/111042
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