It works like this Doug.

A radio card is an intentional radiator. Under part 15 rules it can only be sold as a part of a certified system. That means if you put the radio card in a computer and it's designed to be used in a computer either with it's own built in antenna or the antenna build into the computer that's ok. As long as it's CERTIFIED that way.

If you take that same card, hook a pigtail to it and put an amp on it. You are out of compliance. If you put an antenna larger than the one certified, you are out of compliance. If you put a different type of antenna than it was certified with (yagi to grid or panel to omni etc.) you are out of compliance.

The thing that's screwing us all up with MT, StarOS and others like that is that they don't have ANY certified systems available to us.

And, if you look on LEGAL computer boards, even though they are UN-intentional radiators, they will have an FCC certification on them. Many of the war board type devices don't have that FCC logo on them.

Yes the rule is silly. Yes it's widely ignored, even by the FCC. No, uncertified systems don't seem to be a problem in the real world.

However, do YOU want to take a chance on having YOUR customers go dark because you want to ignore the rules? Do you really want to give your competition that much ammunition against you?

I have the contacts, forms to fill out etc. just waiting for me to get the time to take this issue on as part of the FCC committee's job. We have basically no FCC committee though. The principal membership doesn't seem to be all that interested in anything other than whining about the work that other people do. No one wants to step up and take on the hard issues.

When I get done with the CALEA work (that's costing me 2 to 4 hours per DAY and others are working harder than I am!!!!) I'll write up a petition to get this certified system rule changed. Ideally I'd like to get a real pro installer mechanism in place so that joe q public still has to buy certified systems, but we could just buy certified components.

Or, if anyone would like to take this issue on, I've got a bit of a road map and some basic language worked out already :-).

In the mean time, run an honest legal business as much as you possibly can.

laters,
marlon

----- Original Message ----- From: "Doug Ratcliffe" <[EMAIL PROTECTED]>
To: "'WISPA General List'" <wireless@wispa.org>
Sent: Monday, June 11, 2007 4:27 PM
Subject: RE: [WISPA] MT Babble


But the base product, the "computer" does not start life as an intentional
radiator.  So at what point does a FCC certified computer become an
intentional radiator as a whole?

When you add a wireless card? That would land Dell, HP and Compaq in a load
of trouble.  But alas, is a FCC certified Netgear card, any different than
an FCC certified Ubiquiti card when used with the certified antennas?

I'm NOT talking about marketing these as products as a vendor, I'm talking
about USING these computers, with wireless cards installed in them after the
sale.

I don't see how page 78 and on reference a computer becoming an intentional
radiator?  At the beginning of the day, you have a motherboard and power
supply, which become a "Personal Computer". At the end of the day, you add
a wireless card and antenna which makes it what then?

Calling a Cisco Aironet a PC or vice versa doesn't make sense.  Cisco
Aironet=Intentional Radiator, PC=Unintentional Radiator.


-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Dawn DiPietro
Sent: Monday, June 11, 2007 7:10 PM
To: WISPA General List
Subject: Re: [WISPA] MT Babble

Sam,

Since some here feel I have no credibility because I no longer run a
WISP I will let you decide from this information provided.

Starting on page 78 of the following link should explain why the
wireless devices in question cannot be certified as computers.
http://www.fcc.gov/oet/info/rules/part15/part15-2-16-06.pdf

Regards,
Dawn DiPietro


Sam Tetherow wrote:
I think the question that really hasn't been answered is if a RB can
be certified class B and then use a certified radio/antenna combo as
is allowed with a PC/laptop.
And you are right that then FCC makes the rules.  What is not clear is
that Dawn's (and others) position that the component rules can not
apply to an RB or other SBC.  The only people that can clarify this is
the FCC.

As for FCC certification in general, I think there are two major
factors that come into play with uncertified gear.  There are several
that deployed  the equipment under the false impression that it was
legal because they complied with the EIRP rules (and many still
persist in this belief).
The other is the simple fact that no one has been fined, to my
knowledge, for using uncertified gear.  There have been instances of
people that have been fined for using over EIRP and unauthorized use
of licensed bands.

If the FCC has not fined for the behavior yet and has made unofficial
statements to the effect that they are more worried about EIRP and
477, it comes as no surprise that people will not follow the law.  As
you pointed out most people regularly break the speed limit, which is
a law with an associated fine but they continue to do so because the
fine is not large enough or incurred often enough to make it an
effective deterrent.

   Sam Tetherow
   Sandhills Wireless

Matt Liotta wrote:
This has become a ridiculous thread. Dawn's customer experience is
irrelevant in this case. Plenty of operators who have lots of
customers (including me) understand and agree with the position
presented. Don't kill the messenger! The FCC makes the rules; not
Dawn or me or any of the other folks who have made accurate
statements regarding certification. Use of certified equipment is
required by law. Many people break laws for a variety of reasons, but
that doesn't change the law. For example, everyday I drive over the
speed limit and occasionally I am fined for doing so.

-Matt



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