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 to whether the EIRP, out of band emissions, and so on, meet the legal requirements. Of course it does not. > > 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, 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. > 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. 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. So, we certify the Star-OS WAR board with a Compex WLM54AG (super) and next month they drop that radio and start building a newer better version. THEY have to do all the work to make it compliant in the first place... why not let that work be all that's required for compliance? Computer manufactures do this, and that's the only reason we're not stuck with onerous delays for new technology. If they want innovation and advancement, then they need to build a regulatory framework that does NOT stand in the way, and at the same time encourages both compliance and advancement. > > 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. They did however say its a full green light for > manufacturers to apply for certification, already two manufacturers > have passed 5.4G certification testing. Boy, is there a lot of FUD about this. A lot of BS flying about, too. So, who's gotten certified for 5.4? > -------------------------------------------- Mark Koskenmaki <> Neofast, Inc Broadband for the Walla Walla Valley and Blue Mountains 541-969-8200 -- WISPA Wireless List: [email protected] Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
