----- Original Message ----- From: "Scott Reed" <[EMAIL PROTECTED]> To: "WISPA General List" <wireless@wispa.org> Sent: Thursday, April 26, 2007 9:22 AM Subject: Re: [WISPA] Modifications of Parts 2 and 15 of the,Commission’s Rules for unlicensed devices and,equipment approval
> Actually, the SBC is never an intentional radiator. The added card is. > As I read, and Tim says the same thing in a later post, we need the SBCs > certified the same as laptops. Certified as non-intentional radiators > that accept intential radiators that are certified. > > Isn't that what the presented ruling says can happen? I went back and read some stuff over again... You can certify a module with either a permanently attached antenna, or one with a "unique connector" to a transmitter module. For instance, it appears that if you built an AMP, for instance, that was AGC type with limiting so that it put out constant power and sideband limitations, OOB limitations, etc, regardless of input, you could certify it with any antenna that lives within the FCC rules for eirp, etc. Of course, the complexity and cost of that would make it into "why bother" product. Its just that's what it looks like can be done. Yes, it appears you can certify a mini-pci card... with either a permanently attached antenna, or with a "unique connector". Exactly how this "unique connector" is enforced, I don't know. Maybe someone has input on this. It says that the rf shielding that provides compliance must be part of the module, and that the enclosure it's put within (or no enclosure) now makes no difference. Is this "unique connector" required to be just the connection to the card? Obviously they expect there to be a pigtail, because this is meant to allow outside casing to be ... shall we say... irrelevant to certification. Do all connectors have to be uniqe, or just the one to the transmitter module? Now, as far as SBC's go, I know for a fact that Compex WP54's have passed FCC certification, because i have some assemblies from Compex that were certified with a detachable antenna. Thus, we know of at least one SBC that should be easily put in use. I guess maybe what we need is for Wistron, Ubiquiti, Compex... Maybe someone who does routinely certify assemblies to submit a mini-pci and cpe type antenna for approval under these rules. Or, maybe someone who knows the relevant decisionmakers to ask if we can. Rules do now permit "equivalent antenna" swaps already, and I saw nothing to prohibit this under these rules. As for the base station / client issue.... I recall some time back, that it was at least the intention of the FCC to allow the client to use PTP eirp rules while the AP was requierd to remain at the lower PTMP rules. Anyone remember the ultimate outcome of those inquiries? > > Dawn DiPietro wrote: > > Scott, > > > > The SBC would not be a transmitter without the mPCI wireless card now > > would it. The SBC would be the host device. > > > > Regards, > > Dawn DiPietro > > > > Scott Reed wrote: > >> Right, for the transmitter. That is the mPCI card that goes in the > >> laptop. I am talking about the laptop itself. Laptop = SBC = WRAP = > >> RB = ??? > >> > >> Dawn DiPietro wrote: > >>> Scott, > >>> > >>> In order for the system to be certified it must include the modular > >>> transmitter and the antenna. If you did not include these parts what > >>> would you be certifying exactly? > >>> > >>> As quoted from said document; > >>> > >>> The modular transmitter must comply with the antenna requirements of > >>> Section 15.203 > >>> and 15.204(c). The antenna must either be permanently attached or > >>> employ a “unique” > >>> antenna coupler (at all connections between the module and the > >>> antenna, including the > >>> cable). Any antenna used with the module must be approved with the > >>> module, either at > >>> the time of initial authorization or through a Class II permissive > >>> change. The > >>> “professional installation” provision of Section 15.203 may not be > >>> applied to modules. > >>> > >>> Regards, > >>> Dawn DiPietro > >>> > >>> > >>> Scott Reed wrote: > >>>> And look as I might, I have trouble find what antennae the card > >>>> vendor is certified with. > >>>> > >>>> From other discussions, I would ask a couple of additional > >>>> questions. If we assume we can find a mPCI card that has WISP > >>>> usable antennae in its certification then: > >>>> 1) Couldn't someone just get an RBxxx or WRAP or whatever SBC > >>>> certified as a base unit and we could put the card in it? > >>>> 2) If an SBC is certified without an enclosure, is it still > >>>> certified if it is in a box? > >>>> > >>>> Here is what I am thinking. If we would get an SBC certified bare > >>>> as a base unit then we could use it with various cards in whatever > >>>> enclosure we want to use. The FCC seems to be interested in RF > >>>> noise being emitted. I don't think there are very many enclosures > >>>> that increase the RF output, so if a bare SBC is certified, putting > >>>> it in a box shouldn't negate the certification. That would be like > >>>> saying I can't put my laptop in a suitcase if the laptop is powered > >>>> on. > >>>> > >>>> If this is the case, getting some of the equipment many of us use > >>>> in our operations certified may not be as hard as once thought. > >>>> And if we can show the mPCI makers the advantage of including some > >>>> of the antennae we use in their certifications, we may be able to > >>>> legally use a lot more equipment. > >>>> Jack Unger wrote: > >>>>> Scott, > >>>>> > >>>>> I believe that your comments are substantially correct. > >>>>> > >>>>> The main problem that I see with building our own equipment is > >>>>> that very few (if any) manufacturers of modular wireless cards > >>>>> have certified them with a range of usable external WISP-grade > >>>>> antennas. I don't think this 2nd Report and Order changes that. > >>>>> Also, remember that the software used must limit operation of the > >>>>> complete system only to those frequencies and power levels that > >>>>> are legal in the U.S. > >>>>> > >>>>> jack > >>>>> > >>>>> > >>>>> Scott Reed wrote: > >>>>>> I haven't read it really well and I have not yet looked up the > >>>>>> referenced sections of Part 15, but I read the part that is not > >>>>>> about "split modular" to be the part the refers to a PC. And I > >>>>>> read it that if the PC is certified to have radio cards AND the > >>>>>> radio card is certified with an antenna, then that PC, radio card > >>>>>> and antenna can be used. > >>>>>> > >>>>>> So, if that is true, then Tim may be on the right track. Jack is > >>>>>> right, not any "base," but I would read it that any "certified > >>>>>> base" is doable. > >>>>>> I have often wondered how it works for laptops, but hadn't > >>>>>> bothered to find it. This makes sense. Ubiquiti certifies the > >>>>>> CM9 card with a set of antennae. Dell certifies the laptop for a > >>>>>> radio card. Putting a CM9 in Dell's laptop is fine as long as it > >>>>>> connects to an antenna, using the proper cable, that was > >>>>>> certified with the CM9. > >>>>>> > >>>>>> Therefore, if MT can get an RBxxx board certified as a "base" > >>>>>> unit, we should be able to use a CM9 in that RBxxx with the > >>>>>> proper antenna and be good. The "gotcha" here is those sections > >>>>>> of Part 15 I have not yet followed up on. I am not sure what the > >>>>>> "professional installer" stuff is about. > >>>>>> > >>>>>> What am I missing or is this good news? > >>>>>> > >>>>>> Jack Unger wrote: > >>>>>>> Tim, > >>>>>>> > >>>>>>> I read the 2nd Report and Order and I don't see where it is > >>>>>>> saying that a certified mini PCI radio can be put into any > >>>>>>> "base" unit. > >>>>>>> > >>>>>>> I think what the FCC is doing is: > >>>>>>> > >>>>>>> 1. Providing eight criteria that clarify the definition of what > >>>>>>> a legal modular assembly is. > >>>>>>> > >>>>>>> 2. Allowing some flexibility regarding on-module shielding, data > >>>>>>> inputs, and power supply regulation. > >>>>>>> > >>>>>>> 3. Clarifying the definition of what a "split" modular assembly is. > >>>>>>> > >>>>>>> 4. Defining the (somewhat flexible) requirements that a "split" > >>>>>>> modular assembly must meet. > >>>>>>> > >>>>>>> Although a motherboard will certainly contain an operating > >>>>>>> system, I don't think that a mini PCI radio plugged into any > >>>>>>> motherboard meets the FCC's definition of a "split" modular > >>>>>>> assembly. I think the FCC considers a "split" modular assembly > >>>>>>> to be where circuitry that today would be contained on a single > >>>>>>> modular assembly is (now or in the future) "split" between two > >>>>>>> different physical assemblies. This splitting allows more > >>>>>>> equipment design flexibility because one "transmitter control > >>>>>>> element" (the new term that the FCC formerly called the module > >>>>>>> "firmware") could theoretically be interfaced with and control > >>>>>>> more than one "radio front end" (the amplifier and > >>>>>>> antenna-connecting) section. > >>>>>>> > >>>>>>> Of course, that's just my interpretation. I'll bet others could > >>>>>>> add more detail. The bottom line is - I don't think this 2nd > >>>>>>> Report and Order contains anything that will substantially > >>>>>>> change the way we do business. > >>>>>>> > >>>>>>> jack > >>>>>>> > >>>>>>> > >>>>>>> > >>>>>>> Tim Kerns wrote: > >>>>>>>> Am I reading this correctly???? Does this mean that if a mfg of > >>>>>>>> a mini pci radio gets it certified with different antenna, that > >>>>>>>> it then can be put into ANY base unit and be certified? > >>>>>>>> > >>>>>>>> Please correct me if I'm wrong, but isn't this what we have > >>>>>>>> been asking for? > >>>>>>>> > >>>>>>>> Tim > >>>>>>>> > >>>>>>>> ----- Original Message ----- From: "Dawn DiPietro" > >>>>>>>> <[EMAIL PROTECTED]> > >>>>>>>> To: "WISPA General List" <wireless@wispa.org> > >>>>>>>> Sent: Wednesday, April 25, 2007 8:36 AM > >>>>>>>> Subject: [WISPA] Modifications of Parts 2 and 15 of > >>>>>>>> the,Commission’s Rules for unlicensed devices and,equipment > >>>>>>>> approval > >>>>>>>> > >>>>>>>> > >>>>>>>>> All, > >>>>>>>>> > >>>>>>>>> I just received this document and thought it might be of some > >>>>>>>>> interest to the list. > >>>>>>>>> http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-56A1.pdf > >>>>>>>>> > >>>>>>>>> Regards, > >>>>>>>>> Dawn DiPietro > >>>>>>>>> -- > >>>>>>>>> WISPA Wireless List: wireless@wispa.org > >>>>>>>>> > >>>>>>>>> Subscribe/Unsubscribe: > >>>>>>>>> http://lists.wispa.org/mailman/listinfo/wireless > >>>>>>>>> > >>>>>>>>> Archives: http://lists.wispa.org/pipermail/wireless/ > >>>>>>>>> > >>>>>>>>> > >>>>>>>> > >>>>>>> > >>>>>> > >>>>> > >>>> > >>> > >> > > > > -- > Scott Reed > Owner > NewWays > Wireless Networking > Network Design, Installation and Administration > www.nwwnet.net > > -- > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
