A good read: http://www.arrl.org/tis/info/part15.html. Specifically, look at "Declaration of Conformity (DoC)" under "Equipment Authorization Procedures and Information."
The bottoms of 2 of my nearby laptops (HP and Dell) have a FCC logo and list a FCC registration number. That, with the fact that the Netgear PCI also complies with the FCC part 15 rules (no external antennas) the combination is allowed. Most of the internal cards that come with laptops are put together as a complete system, and DELL, HP, Gateway are all assuming the responsibility that their complete system will not exceed FCC limits. If you look at http://www.fcc.gov/oet/ea/Labelling_Guidelines_Parts_15_and_18.pdf on page 3 of 4, it states..."Devices authorized under the DoC procedure must also include a compliance information statement as required." Now here is the killer statement, "The main objective of this compliance statement is to allow the FCC to associate the equipment with the party responsible for compliance with the DoC requirements." There are two possibilities. First, what some have been saying is that IF someone (like ADI) says X, Y, and Z parts are used, and assembled this way; AND gets approved by the FCC as a system, then they can sell the rights as long as you follow their same procedures. You then are compliant, but only if you follow their tested procedures, but you need to follow the DoC procedure, and you also become liable. Second is if we (WISPA, independent ISPs, or hopefully Manufacturers) get a few SBCs tested as a Part 15 B device (un-intentional radiator) and get a couple mPCI cards tested with high-gain antennas (as a system). Then we (those that are testing) can certify the system. The bottom line, the DoC specifies who is liable. So those that are assembling those systems have to mimic the procedures of an approved system that someone will take responsibility for. No one has stepped to the plate and gotten a system approved and offered it to the general public. ADI is the first that I have seen that may be doing that. Eric Rogers Precision Data Solutions, LLC (317) 831-3000 x200 -----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Mike Hammett Sent: Tuesday, June 12, 2007 9:17 AM To: WISPA General List Subject: Re: [WISPA] MT Babble Then why can I purchase a Netgear PCI card for my Dell desktop? ----- Mike Hammett Intelligent Computing Solutions http://www.ics-il.com ----- Original Message ----- From: "Dawn DiPietro" <[EMAIL PROTECTED]> To: "WISPA General List" <[email protected]> Sent: Tuesday, June 12, 2007 7:39 AM Subject: Re: [WISPA] MT Babble > Mike, > > That post was looking for clarification on whether or not it was possible > it would make this legal without going through system certification as an > intentional radiator. Since the FCC wording can be mind boggling sometimes > there is confusion. In other words you cannot take certified parts and use > them together and expect to be legal no matter how anyone tries to justify > it. I am glad to see that you do understand. ;-) > > Regards, > Dawn DiPietro > > > > > > > Mike Hammett wrote: >> I understood that was the way it was until perhaps yesterday when someone >> brought up the issue of PC's with add in wireless cards being in no way >> different than what we do. >> >> >> ----- >> Mike Hammett >> Intelligent Computing Solutions >> http://www.ics-il.com >> >> >> ----- Original Message ----- From: "Dawn DiPietro" <[EMAIL PROTECTED]> >> To: "WISPA General List" <[email protected]> >> Sent: Tuesday, June 12, 2007 7:09 AM >> Subject: Re: [WISPA] MT Babble >> >> >>> Mike, >>> >>> What Marlon said IS NOT OPINION. The only way you can be legal is to >>> certify a system as a whole. You might want to take a look at the ADI >>> link I posted and maybe this will help you understand what is required >>> to become certified. You must have all the components certified >>> together. >>> >>> Is it that I keep misunderstanding what you are trying to say? But I >>> feel like this has been discussed before in no uncertain terms. >>> >>> Regards, >>> Dawn DiPietro >>> >>> Mike Hammett wrote: >>>> So you're saying (in your opinion, not necessarily any bearing on what >>>> the FCC actually requires) when we have certified SBCs, we'd be able to >>>> go that route? Those that are running a certified radio with no amp >>>> (who uses that garbage anymore) into an antenna with equal or lower >>>> gain on a PC based system run a good chance of being legal? >>>> >>>> >>>> ----- >>>> Mike Hammett >>>> Intelligent Computing Solutions >>>> http://www.ics-il.com >>>> >>>> >>>> ----- Original Message ----- From: "Marlon K. Schafer" >>>> <[EMAIL PROTECTED]> >>>> To: "WISPA General List" <[email protected]> >>>> Sent: Tuesday, June 12, 2007 12:39 AM >>>> Subject: Re: [WISPA] MT Babble >>>> >>>> >>>>> 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'" <[email protected]> >>>>> 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 >>>>>>>> >>>>>>> >>>>>> >>>>>> -- >>>>>> WISPA Wireless List: [email protected] >>>>>> >>>>>> Subscribe/Unsubscribe: >>>>>> http://lists.wispa.org/mailman/listinfo/wireless >>>>>> >>>>>> Archives: http://lists.wispa.org/pipermail/wireless/ >>>>>> >>>>>> >>>>>> >>>>>> -- >>>>>> No virus found in this incoming message. >>>>>> Checked by AVG Free Edition. >>>>>> Version: 7.5.472 / Virus Database: 269.8.11/836 - Release Date: >>>>>> 6/6/2007 >>>>>> 1:10 PM >>>>>> >>>>>> >>>>>> -- >>>>>> WISPA Wireless List: [email protected] >>>>>> >>>>>> Subscribe/Unsubscribe: >>>>>> http://lists.wispa.org/mailman/listinfo/wireless >>>>>> >>>>>> Archives: http://lists.wispa.org/pipermail/wireless/ >>>>> >>>>> -- >>>>> WISPA Wireless List: [email protected] >>>>> >>>>> Subscribe/Unsubscribe: >>>>> http://lists.wispa.org/mailman/listinfo/wireless >>>>> >>>>> Archives: http://lists.wispa.org/pipermail/wireless/ >>>>> >>>> >>> >>> -- >>> WISPA Wireless List: [email protected] >>> >>> Subscribe/Unsubscribe: >>> http://lists.wispa.org/mailman/listinfo/wireless >>> >>> Archives: http://lists.wispa.org/pipermail/wireless/ >>> >> > > -- > WISPA Wireless List: [email protected] > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ > -- WISPA Wireless List: [email protected] Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: [email protected] Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
