BWAUG List member: I will back Patrick up on this. Demarc has been working on FCC approval for some time now to make sure we have certifications that are going to work in all the setups are and will offer. This has proven to be more difficulty then original though BUT we are closer then every to getting this complete. My point is going thought this process we have learned directly from the FCC what is and is not permitted. At this time, in there interpretation, a wireless radio AND antenna is certified as a system and can only be swapped out for other antennas listed on the grants. Its this simple no questions asked. They have also made this process more difficult with radios that use PCMCIA ports, they consider this mobile are only allow up to 15dBi gain antennas unless the unit is a complete integrated fixed wireless system which is NOT a antenna/cable/PCMCIA radio. This has changed from older certifications that are on the books like a PCMCIA card, amp and 24dBi gain antenna, this will no longer be an option.
Sincerely Tony Morella Demarc Technology Group Office: 908-996-7995 Cell: 908-246-9170 Fax: 908-847-0202 email: [EMAIL PROTECTED] http://www.demarctech.com Open Chat Server http://www.demarctech.com:8000 Yahoo IM: tonymorella Wireless Solution Provider > -----Original Message----- > From: [EMAIL PROTECTED] > [mailto:[EMAIL PROTECTED]] On Behalf Of Patrick Leary > Sent: Monday, December 02, 2002 7:24 PM > To: [EMAIL PROTECTED] > Subject: RE: [BAWUG] 15.23... > > > This is one of this community's urban legends that has been > emphatically disproven many times personally by multiple FCC > OET staffers (including the principal writer of the rule) in > my presence and in the presence of several hundred others. > > If you are looking for a documented case, you have only to > contact Sting Communications in PA. They were required to > change the sector antennas on over 30 towers because they > used one not certified for use with the radios they used. > They were not violating power rules. They were not using amps. > > Refusal to accept reality here is nothing more than wishful > thinking or simply abject denial. I encourage folks to call > your local FCC enforcement office -- that is all it will take > for individuals to clear it up for themselves instead of > accepting the guessing of some here. > > HOWEVER, if you are making modification (experimenting) for > private use, not for re-sale, and for the small quanities > named, this rule may not apply. I do not have a factual > answer to this. It has never been asked by me or anyone I > know directly to an OET staffer. > > Patrick J. Leary > Chief Evangelist, Alvarion, Inc. > Executive Committee Member, WCA/LEA > [EMAIL PROTECTED] > Ph: 760.494.4717 > Cell: 770.331.5849 > Fax: 509.479.2374 > > > -----Original Message----- > From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] > Sent: Monday, December 02, 2002 4:02 PM > To: Jeff King > Cc: Tim Pozar; [EMAIL PROTECTED] > Subject: Re: [BAWUG] 15.23... > > > I guess I can bring this up on this list as well. 15.203 > (not .23, but .203), talks about External Power Amplifiers > AND Antennas and subsection (c) is what some people think > stops people from mixing and matching antennas on certified radios. > > Keyword is "AND". If you read 15.203 sections a-c with the > word OR in the title, instead of AND, then it would more > closely follow some of the "other" interpretations out there. > > I respect everything that Tim Pozar discusses and I think I > agree with him on just about every issue, except for this one > particular issue (swapping of antennas). I think its in how > you read the rules and the fact of the matter is, especially > after so much disagreement on what it actually means, that > the rules really need to be more explicit so we can put this > issue to rest, once and for all. > > My interpretation is that antennas may be swapped, so long as > you are NOT using an amp, up/down converter or any other > similiar device, just the antenna and radio itself, so long > as that radio has already been certified for use by the > manufacturer, even if its only been certified with a single > antenna. It basically means that the radio itself (digital > device) conforms to the equipment authorization requirements > set forth by the FCC. Changing the length of coax, or even a > bad connector can cause a device to emit noise. But those > issues are not intentional. > > Using an antenna that is "better" or of higher quality, than > the stock antenna supplied with the radio, should not be > illegal, so long as you are in good faith technical > compliance with the rules (ie, not exceeding EIRP limits, > doing your best to utilize antennas that will give you > directional gain with low sidelobes and F/B ratios in order > to keep the transmissions your emitting to the lowest > possible levels). > > If it is illegal in the eyes of the FCC, in multiple years, > I've seen not one well documented case of someone failing to > comply with the rules if they were not using an amp. Any > case that I have seen, has been a case for some other reason > (ie, amps were used, the person was intentionally > interfering, or both, or some other circumstance). > > If the FCC didn't want someone to swap antennas, they'd save > everyone a whole lot of time, if they documented one public > message on the subject. Some kind of official FCC stance on > the issue, other than just the rules themselves. If that > means a documented case, great, lets see it. If that means > an official letter from the appropriate officials, then why > not make it happen? This would clear up the confusion and > push people in the direction to conform. But this has not > happened. The FCC is almost always hands-off, because, what I > sense, is that they want to allow for the technology to > advance, grow and for users of the technology to be able to > expand and utilitize the spectrum that they've allocated for > "unlicensed use". The FCC wants to enable, not stifle. > > The FCC gave us something, said, here you go, make something > with it. We'll be here, watching, listening, but we want to > avoid driving you in any particular direction, except where > you may interfere with other users of the same spectrum, > because we are here to oversee that everyone is able to make > "fair use" of the "limited" spectrum available. If tomorrow > brings new technologies with more efficent ways to utilize > that spectrum, they are more than happy to revise or rewrite > the rules (UWB is a great example). > > The FCC knows whats happening, they aren't turning a blind > eye, nor are they going after WISP's or home operators who > are sharing service with their neighborhood and the rest of > urban or rural america. Unless there is some kind of bad > faith abuse of the spectrum, then they comment and/or act. > > Its rare that they have to comment or act, because the huge > majority of operators out there, are working in good faith, > to build networks and/or businesses (which benefit the > economy in so many ways). > > Also, the FCC being the large organization that it is, the > interpretation of one person within the FCC may be much > different than the interpretation of another. This is why, > "if there is an issue" (I don't see an issue, personally), > then there needs to be an official stance, by the FCC, on the > subject of swapping antennas in 2.4Ghz and 5.8Ghz or > unlicensed spectrum in general. "If this was an issue", I'd > can see a large number of very creative and intelligent > people, put out of work and on the streets, because their > businesses would not be meeting compliance rules. This > doesn't just mean WISP's or small operator networks, but also > manufacturers and many employees of those manufacturers as > well as many international corporations who staff employees > who build the radios and antennas that so many people use, every day. > > Anyway, I'll leave it at that. No more FCC discussions from me. > > Jeff King wrote: > > > Would you also need to mine the silicon for the transistor's and > > carbon > for the > > resistor's to be compliant with 15.23? > > > > Until and unless you have a written ruling, it is up in the air. The > unnamed > > friend of a friend, or my buddy at the FCC is not a ruling. If your > > not marketing the device, 15.23 says your free to > experiment with it > > as long > as you > > are in good faith technical compliance with the rules. > > > > Quoting Tim Pozar <[EMAIL PROTECTED]>: > > > > > 15.23 Home-built devices. > > > > > > (a) Equipment authorization is not required for devices > > > that are not marketed, are not constructed from a kit, and > > > are built in quantities of five or less for personal use. > > > > > > (b) It is recognized that the individual builder of > > > home-built equipment may not possess the means to perform > > > the measurements for determining compliance with the > > > regulations. In this case,the builder is expected to employ > > > good engineering practices to meet the specified technical > > > standards to the greatest extent practicable. The > provisions > > > of 15.5 apply to this equipment. > > > > > > Of course 15.5 refers to "Thou shall not interfere and thou shall > > > accept all interference". > > > > > > It seems to me that this section refers to equipment that is not > > > already certified since any equipment that is "marketed" > needs to be > > > certified. Even "kits" need to be certified (15.25). > When I have > > > talked to others "knowledgeable" in equipment certification, they > > > seem to have the same interpretation. It sounds as if > using an AP > > > that is certified would not be allowed to be mixed and matched > > > outside of its certification. > > > > > > If applied to what we are doing, it would seem that we > would have to > > > develop our own SS radios and antennas to take advantage of 15.23. > > > > > > Tim > > > -- > > > general wireless list, a bawug thing <http://www.bawug.org/> > > > [un]subscribe: http://lists.bawug.org/mailman/listinfo/wireless > > > > > -- > > general wireless list, a bawug thing <http://www.bawug.org/> > > [un]subscribe: http://lists.bawug.org/mailman/listinfo/wireless > > > > > -- > general wireless list, a bawug thing <http://www.bawug.org/> > [un]subscribe: http://lists.bawug.org/mailman/listinfo/wireless > -------------------------------------------------------------- > -------------- > ---------------------------------------- > This email and any files transmitted with it are confidential > and intended solely for the use of the individual or entity > to whom they are addressed. 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