Hi Tom, I remember our nice little seafood feast afterward too (is George on
the WISPA list also?). As I recall, the conversation revolved around
certified gear. The rules change they made did not include or cover
uncertified systems, because I would assume, by definition, they do not
exist as part of the legal process. In other words, the FCC was not trying
to make life of law breakers even easier. They were trying to improve the
flexibility so manufacturers could be more responsive to customer needs by
getting more antenna choices included within the manufacturers master system
certification. Basically, all they did was relax a little the existing
"permissive change" rules.

I believe the FCC was reluctant to give operators carte blanche, because it
would be a strain on resources to track accountability and enforcement.
Reigning in a few manufacturers who have major incentive to follow the rules
is a lot different than trying to keep track of thousands of WISPs, many
already flying under the radar (not filing form 477, etc.) AND many of whom
who have already shown a massive propensity to ignore -- willfully or
ignorantly -- the rules as they are. Use whatever clich├ęs you want --
"asking the fox to guard the hen house," "giving the inmates the keys to the
asylum,"...they all apply. I think you have to acknowledge that the abuse is
rampant and one of the only reasons it is less rampant now is that so many
systems come integrated with antennas, PoE, and high power (internal
integrated amps).

>From the vendors standpoint, I understand the FCC position and I also
understand the quality (and legal) WISPs position. I would like to see an
independent body that could provide WISP technician certification that the
FCC could accept (and hold accountable), much like a PE needs to sign off on
certain design documents in many mechanical fields. I envisioned such a
thing a few years ago, using the BICSII RCDD as the model.

Anyway, also a vendor I am relieved too that operators cannot make their own
choices in the sense of the nightmare this would create for both system
performance (e.g. MAJOR tech support costs and head aches) and warranty
issues. You cannot fathom the massive costs we'd incur as every WISP making
its own antenna choice came to us about performance, capacity, and coverage
issues for which the antenna plays such a key role. How could we answer
questions? How could we assert performance specs? How could we predict
coverage and capacity? How could we advise about co-location issues? Etc. ad
nauseum.

Let me ask you this: would you willingly warranty and support your end
user's end-to-end experience across your network from the desktops to the
Internet while also permitting the user to implement whatever router,
switch, etc. he/she wanted?

Patrick Leary
AVP Marketing
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
Vonage: 650.641.1243

-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Tom DeReggi
Sent: Friday, August 18, 2006 3:51 PM
To: WISPA General List
Subject: Re: [WISPA] roll your own radios..

> I was in the room where Marlon pressed them on this point hard and they 
> would not bend.

http://www.rapiddsl.net/latest_news/FccVisitOct2004.htm

Thats right, you were there Patrick. (PS. Your wherever Wireless goes, DSL 
follows speach rocked!)  And you are right, Marlon was pressing hard, and 
they were not bending on giving operator's control (the pandora's box) in 
most of the meeting.  And the original intent was to make it easier and more

cost effective for manufacturers to add complete product lines under their 
existing certifications.

But towards the end, I felt a little bend. The relevant part is why they 
didn't want to bend. What would make it a Pandora's box? It was 
accountabilty and the ease of breaking the rules. Its the reason they also 
refused to bend on the unique connector rule.  (Technically, which would 
make every N connector based radio an uncertifiable system, if they lived to

the letter of their rules.).   Where it was getting grey, is questions were 
asked like, what if What makes it a grey area are things like, What is the 
definition of "Manufacturer" ?

Sure its clear that Alvarion is the Manufacturer of a BH40 and holds the 
certification of that radio platform, and the responsible party, and 
Alvarion is appropriate to decide what is and isn't and equivellent product 
to meet certification under its certification.  I don't deny that.

But who is the manufacturer of an uncertified system? Atheros? WRAP? The 
Operator? Who is responsible to certify the system? Its not spare parts 
manufacturers. The line of who is a manufacturer, who is a provider, and who

is a reseller is getting blurred.  And what qualifies as a method of a 
Manufacturer giving approval of what's certifyable? If an operator calls a 
Manufacturer and asks is this PacWireless dish of the same power or less as 
the originally certified version AND the beam pattern is fundamentally 
similar, and they say yes, is the operator free to proceed? Who is the 
authoritary person from the manufacturer able to do so?  And what proof 
needs to be given that such permission was granted?  And if you violate, 
what are the penalties if you comply after the fact?  Details were left out.

It all boils down to someone is going to be held responsible, when output of

a system violates allowable specfications.  And the way the rule is written,

they have the abilty to hold people accountable.  But the intent was not to 
prevent innovation by responsible WISPs.

The general census was, which will never be found in print, was if its in 
legal limits, the FCC police aint comming to knock on your door.  But the 
second someone complains, and you weren't within specification, they were 
comming after you.

What I will say, is I appreciate Alvarions effort to certify a variety of 
antennas and make available list of certified antenna lines for their 
products, which I beleive they have, so WISPs that use the Product don't 
have to worry about certification and compliance issues.

Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband


----- Original Message ----- 
From: "Patrick Leary" <[EMAIL PROTECTED]>
To: "'WISPA General List'" <wireless@wispa.org>
Sent: Friday, August 18, 2006 4:25 PM
Subject: RE: [WISPA] roll your own radios..


> For sure. It has nothing to do with how the antenna is sold or sourced. 
> What
> is clear however is that as operators, you do not have the choice. Such
> flexibility is ONLY given to the manufacturers. I was in the room where
> Marlon pressed them on this point hard and they would not bend. For the 
> FCC,
> they still refused to open what they see as a Pandora's Box in terms of
> letting operators make their own choices in terms of antennas. We all were

> a
> bit surprised by this, though I understand their issue.
>
> Patrick Leary
> AVP Marketing
> Alvarion, Inc.
> o: 650.314.2628
> c: 760.580.0080
> Vonage: 650.641.1243
>
> -----Original Message-----
> From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
> Behalf Of Tom DeReggi
> Sent: Friday, August 18, 2006 1:24 PM
> To: WISPA General List
> Subject: Re: [WISPA] roll your own radios..
>
> Patrick,
>
> Not exactly. What you said is mostly true, and to the letter of the 
> original
>
> text, but there are added flexibilties.
>
> It doesn't need to be the antenna that the manufacturer actually sells. 
> For
> example, if the manufacturer OEMed a MTI antenna for certification,
> operators can now use the functional MTI antenna bought direct.  Also in
> face to face meetings, even though not the written text, we asked if
> operators could take responsibilty for determining the functional
> equivellent.  They responded that the reason the Manufacturers were 
> required
>
> to be the one, is that there had to be someone to take responsibilty, 
> where
> it was inforcable to comply.  It was a grey area, but FCC staff stated 
> that
> if the operator took responsibility, it could be feasible that it was
> allowed for the Operator to make the substitution.  The arguement is as
> integrators we have the abilty to get certifications just like
> Manufacturers.   So really the letter of the law was that who ever got the
> gear certified originally, would ahve the abilty to make the modifications
> of whats considered functional equivellent.  What this meant was that if 
> an
> Operator isntalled an uncertifed network, but used gear that could be
> certified, meaning making qualified decisions, it was within the Operators
> power to correct the violation, by getting the components certified.
> Although the politically correct method would be to certify the gear
> combination a head of time.  But my point is its not just the manufacturer
> that has the master decission.
>
> With that said, its rare that a operator would want to go through the cost
> of certification, when the manufacturer already did, if the manufacturer 
> now
>
> also had cost effective ways to make decissions on what gear is acceptable
> to use under the certification, and manufacturers had fair pricing on
> antenna gear, to take away the motive for someone to self certify.
>
> Tom DeReggi
> RapidDSL & Wireless, Inc
> IntAirNet- Fixed Wireless Broadband
>
>
> ----- Original Message ----- 
> From: "Patrick Leary" <[EMAIL PROTECTED]>
> To: "'WISPA General List'" <wireless@wispa.org>
> Sent: Friday, August 18, 2006 3:29 PM
> Subject: RE: [WISPA] roll your own radios..
>
>
>> John is 100% accurate. Also, with respect to using your own antenna, even
>> with that new relaxation of the rules, it ONLY applies to manufacturers,
>> NOT
>> operators. What is does is to enable manufacturers to self-certify
>> additional antennas so long as the power is the same or less as the
>> originally certified version AND the beam pattern is fundamentally
>> similar.
>>
>> This rule does NOT permit operators to use whatever antennas they like.
>>
>> As always, I know from 1st hand direct questioning of those FCC staffers
>> who
>> wrote the rule revision. This is not hearsay, my assumption or my
>> interpretation.
>>
>> Patrick Leary
>> AVP Marketing
>> Alvarion, Inc.
>> o: 650.314.2628
>> c: 760.580.0080
>> Vonage: 650.641.1243
>>
>> -----Original Message-----
>> From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
>> Behalf Of John Scrivner
>> Sent: Friday, August 18, 2006 11:31 AM
>> To: [EMAIL PROTECTED]; WISPA General List
>> Subject: Re: [WISPA] roll your own radios..
>>
>> The rules state that any radio / antenna combination has to either be a
>> certified system or that a substitute antenna used would have to meet
>> the same specs as one used for certification in a system. Many think
>> that this means "anything goes". The truth is that there are almost
>> certainly a good bit of installed systems which would not pass FCC
>> enforcement inspection. Many believe that following maximum EIRP rules
>> is the only requirement. This is not so. It is a good practice if you
>> are not following the rules but that does not mean it is legal. Another
>> common belief is that "anything goes" is the rule of thumb due to the
>> general lack of enforcement in unlicensed bands. This is unfortunate and
>> further illustrates the need for our industry to mature.
>>
>> Part of this maturity process should start by operators demanding to see
>> FCC certifications for the systems they buy. It is tough for operators
>> to remain compliant when so few systems are certified. Another step
>> should be that manufacturers certify their systems with commonly used
>> antenna / radio configurations every time they release a product.
>> Finally, distributors need to demand that all systems they sell meet
>> certification requirements. The fact is that certification is not
>> terribly costly or complicated and should be a step taken by all
>> manufacturers and eventually all of us. If anyone here represents
>> manufacturers who certify all their systems then now would be a good
>> time to toot your horn.
>>
>> I believe the day will likely come that the FCC will inspect WISP
>> systems. It took them about 20 years to start cracking down on the cable
>> television industry for signal leakage and other infractions. Something
>> tells me this industry will not have to wait that long. Of course the
>> decision to follow the rules is inevitably up to each person. I would
>> like to think we all will be compliant in the future but this is an
>> unrealistic goal I am sure if manufacturers do not take a leadership
>> role in this effort. WISPA stops short of demanding that members do
>> anything but I will say, as President of WISPA, we should all try to
>> follow the law regarding this industry. No industry association could
>> expect to have impact in policy and legislative efforts if they took the
>> stand that shirking the law is a correct course of action.
>> Scriv
>>
>>
>> chris cooper wrote:
>>
>>> It sounds like several of you here build your own radios and use off
>>> the shelf antennas.  So if I buy a board, cards and an antenna what
>>> are my obligations to FCC as far as having a certified system in
>>> production?  Thanks for the education
>>>
>>>
>>>
>>> Chris
>>>
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