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: wireless@wispa.org
Subscribe/Unsubscribe:
http://lists.wispa.org/mailman/listinfo/wireless
Archives: http://lists.wispa.org/pipermail/wireless/
