Rick;

I think that your opinion is like mine, both informed and experienced. I am perfectly comfortable with my opinion. And I did not get into an argument, or even suggest one was somehow a good idea.

That said, let me also say this. If I don't have to have my router boards certified without radios because they are not intentional radiators, then when I add an FCC certified card to them I still don't have to have them certified because they are still what they were.

If you tell me that every PC running a pci wireless card has to be certified then I'll go with suggesting that a single board computer, which is designed to be a router, should also be certified like all those PC's otherwise, Rick, I think that both you and Dawn are incorrect.

Like I said, I think your opinion is like mine, both informed and experienced. I don't think you, or I, or Dawn, have the last word in this matter and I'd be happy to take the issue up with the FCC to get a reading from them.

-m-

Smith, Rick wrote:
Hey Michael, Dawn's right.  Don't get into an argument on all this here,
again.

In order to be a LABELLED CERTIFIED system, you take antennas, jumpers,
pigtails,
minipci cards (already separately cert'd most likely), RB's, ENCLOSURE,
POE device, and
anything else that's necessary to that system running, and they throw it
in a quiet room
and put it through its paces.  If all falls within the proper bands for
operation as
you intended, you get the right to copy that device and slap pretty fcc
labels on it
and sell it as certified.   If not, fix it, resubmit it and try again.
Repeat until
certified.

-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Michael Erskine
Sent: Sunday, June 10, 2007 9:41 PM
To: WISPA General List
Subject: Re: [WISPA] MT Babble

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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