Dawn;

I think you are reading the letter of the law and not understanding the reality. An RB153 is *NOT* an intentional radiator any more than the PC you mention is an intentional radiator. The cards which are placed in the RB153 are intentional radiators just like the cards you put in that PC you mention.

You are trying to make an Apples vs Oranges comparison out of an Apples to Apples situation.

In other words you are incorrect in your reading of the rules.

-m-

Dawn DiPietro wrote:
Doug,

You have to certify the system as a whole INCLUDING THE ENCLOSURE and the power supply and you cannot deviate from the configuration that was certified. This cannot be compared to a PC because that is a different certification. PC's are unintentional radiators the systems in question are intentional radiators.

Here is the link for more info on Modular Transmitters;
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-56A1.pdf

Here is a link to ADI and their certified system;
http://www.adiengineering.com/products/data/FCC-Whitepaper-R100.pdf

Regards,
Dawn DiPietro

Doug Ratcliffe wrote:
I found the FCC document regarding the modular certifications. If Mikrotik would submit (or someone submitted on their behalf, for them) their boards
and representative power supplies, for FCC testing, and passed (no
peripheral cards, they are SEPARATELY tested for FCC compliance by the
manufacturer, it's in this document), they would become PCs and fall under the 1996 FCC order listed below. If we used VIA, or any number of already modular certified FCC motherboards, it would all fall under this order. Cases are not FCC certified only motherboards, peripherals and power
supplies.  So take a motherboard, power supply and a peripheral wireless
card, put it into a NEMA enclosure, add an antenna that's certified for use
with that wireless card.  How is that not FCC legal?

It mentions an FCC DoC sticker some of us may be familiar with:

Trade Name          Model Number
FCC     Assembled from        Tested Components
(Complete System Not Tested)

I have a Compaq Presario 5100NX, Dell Dimension 8100 and Dimension 2400 in my repair department right now, NO FCC stickers on the cases. Part 15 as of May 4, 2007:
http://www.fcc.gov/oet/info/rules/part15/part15-5-4-07.pdf

Listed on these pages:
Page 12-15: Regarding labelling for Declaration of Conformity, home-build
and kit computers.
Page 28 - Section 15.101 Equipment authorization of unintentional radiators.

See type of device, class B personal computers and peripherals: Declaration
of Conformity.
Page 29 subsections C and D - Personal Computers shall be authorized in
accordance with one of the following methods

And of course, on page 86 the very vague "modular transmitter" section
regarding "unique" antenna connectors, shielded RF components (I believe
Ubiquity has cards like this).

I did a search in this document for the following words:
"operating system" 0 results.
"software" 2 results - neither of which have to do with operating systems.

Maybe this will be dismissed as a bad interpretation, but Mikrotik looks
suspiciously like a PC operating system, much like Windows or Linux. Not a modular transmitter device like an AP. I can put a CD in my home computer
and load Mikrotik on it.  So how is the device a Mikrotik OS runs on not
considered a PC?

Just some food for thought; with the information that backs it up right from
the FCC site.





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