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. 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.
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
