Here's an interesting new twist on the issue.
What do you think of this conversation Patrick? Check out the names
CC'd to it. If this isn't the group to make such a call I sure don't
know how to get to a better one.
laters,
Marlon
(509) 982-2181
(408) 907-6910 (Vonage) Consulting services
42846865 (icq) WISP Operator since
1999!
[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam
----- Original Message ----- From: "John Reed" <Sent: Monday, October
01, 2007 2:20 PM
Subject: RE: [WISPA] Flexible antenna certification
I concur provided the gain of the replacement antenna is equal to or
less than the highest gain of that type of antenna that was certified
with the transmitter. The antenna does not have to be one listed by
the grantee nor do you need to notify the grantee or obtain their
approval.
________________________________
From: Marlon K. Schafer (509) 982-2181 [mailto:[EMAIL PROTECTED]
Sent: Mon 10/1/2007 11:56 AM
To: John Reed
Cc: Ronald Repasi; Bruce Romano; Ira Keltz; Geraldine Matise; Karen
Ansari; Joe Dichoso; Jim Szeliga; Rashmi Doshi; Kwok Chan
Subject: Re: [WISPA] Flexible antenna certification
Thanks John,
Just to make SURE that I'm reading this correctly. As long as we, the
operator, uses an antenna of the same basic type (equal or lesser gain,
similar in and out of band emissions specs) and stay at or below the
gain of
the certified antenna, we can use anything we want. We don't have to
make
sure that it's listed by the grantee of the original system. As an
example,
I can take a Tranzeo connectorized radio (JUST an example) and if
they've
certified it with a 4' grid antenna, I can use ANY 4' or smaller grid
antenna. As long as said grid antenna has similar in and out of band
emissions specs.
The grantee has to certify with that first antenna, this gets them the
certification. After that, we can mix and match without their
knowledge or
approval. (As long as we stay within the proper emissions limits.)
If this is correct, it's quite different from what we understood when
we met
with the FCC team to discuss this issue a couple of years ago.
Thanks,
Marlon
(509) 982-2181
(408) 907-6910 (Vonage) Consulting services
42846865 (icq) WISP Operator since
1999!
[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam
----- Original Message -----
From: "John Reed" <
Sent: Monday, October 01, 2007 4:46 AM
Subject: RE: [WISPA] Flexible antenna certification
Based on Section 2.1043(b)(1)-(b)(4), changes made to a Part 15
certified
transmission system (the system includes the transmitter, the antenna
and
amplifier if one was certified with the system - see 15.204(b)) by
anyone
other than the grantee voids the certification on the product. However,
Section 15.204(c)(1)-(3) permits the grantee to obtain certification for
multiple antennas of the same type and up to whatever maximum
directional
gain level is tested. Further, Section 15.204(c)(4) permits changes
to the
antenna to be made by anyone (the grantee, the user, the system
provider,
etc.) provided the antenna is of the same type and is of equal or less
directional gain than the antenna with which the transmitter was
certified.
Section 15.204(c)(1) states that the antenna type refers to antennas
that
have similar in-band and out-of-band radiation patterns. In other
words,
the antenna should match the same design that was used in certification,
i.e., monopole, Yagi, dish, etc. I recognize that this is a simplified
approach, especially when considering some internal antenna designs,
but it
usually works. Note that the use of a different type of antenna or
one with
higher gain puts you back to Section 2.1043 where only the grantee is
allowed to make changes to the equipment. This also means that you
can not
just take a 100 mW output transmitter and add a 16 dBi gain antenna
to bring
the output up to 36 dBm. It's quite possible that the transmitter was
certified with a much lower gain (or different type of) antenna.
I don't know what started the problems cited below but no one seems
to have
picked up on the changes permitted under Section 15.204(c)(4) - only
on the
grantee requirements under Section 15.204(c)(1) - (c)(3).
Hope this helps.
John A. Reed
________________________________
From: Marlon K. Schafer (509) 982-2181 [mailto:[EMAIL PROTECTED]
Sent: Wed 9/19/2007 12:28 PM
To: John Reed
Subject: Re: [WISPA] Flexible antenna certification
Hi John,
Can you please put an official spin on this discussion?
In a nutshell....
On one hand we think that we can mix and match any antennas we want
as long
as they are of a similar type, have equal or lesser gain and similar oob
specs.
On the other hand, we think that we can still only use the antennas
that the
manufacturer says we can use.
What's reality?
Thanks,
Marlon
(509) 982-2181
(408) 907-6910 (Vonage) Consulting services
42846865 (icq) WISP Operator since
1999!
[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam
----- Original Message -----
From: "Patrick Leary" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Wednesday, September 19, 2007 8:32 AM
Subject: RE: [WISPA] Flexible antenna certification
Wow, that's a big surprise since it is a 180 degree contradiction to
what Julie and his staff told us at the FCC after the rule was released.
But I am good with it. It is a flexibility that makes sense. As a
manufacturer, the only head ache is that providing tech support is more
a challenge since we don't know the characteristics of substitute
antennas from the stand point of best practices for co-location,
separation and general performance. WISPs just need to be aware of that.
I remember the day some years back when Sting Communications in Maryland
was forced to change out dozens of antennas at tower sites because they
chose an antenna that was not part of the certified combination, even
though the antenna did not violate power rules. At least this means that
WISPs no longer have that risk.
Patrick Leary
AVP, Market Development
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
[EMAIL PROTECTED]
Visit Alvarion at WiMAX World
Chicago, September 25-27
Booth #409
-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Jack Unger
Sent: Wednesday, September 19, 2007 12:12 AM
To: WISPA General List
Subject: Re: [WISPA] Flexible antenna certification
Patrick,
I asked the certification lab/TCB that I work with to answer this
question.
They replied that it is their interpretation that a WISP can use any
antenna /"of the same type and of equal or lesser gain as an antenna
that is authorized with the intentional radiator". /Here's the text from
47 CRF 15.204(c)(4):
"Any antenna that is of the same type and of equal of less gain
directional gain as an antenna that is authorized with the intentional
radiator may be marketed with, and used with, that intentional radiator.
No retesting of this system configuration is required. The marketing or
use of a system configuration that employs an antenna of a different
type, or that operates at a higher gain, than the antenna authorized
with the intentional radiator is not permitted unless the procedures
specified in S2.1043 of this chapter are followed".
47 CFR 15.204(c)(3) says:
"Manufacturers shall supply a list of acceptable antenna types with the
application for equipment authorization of the intentional radiator".
47 CFR 15.204(c)(1) says:
"The antenna type, as used in this paragraph, refers to antennas that
have similar in-band and out-of-band radiation patterns".
I can see how the lab and TCB could conclude that WISPs can substitute
antennas per these regulations. If the manufacturer specifies a range of
acceptable antenna types (not specific makes or model numbers) then per
15.204, the WISP can select the specific make and model of antenna to
use.
I know FCC regulations are often somewhat vague and however it's
possible that the FCC regulations may have been revised and loosened
slightly since your FCC visit. Perhaps there is now a basis for the
"myth".
jack
Patrick Leary wrote:
Thanks Jack. I know what they are going to say (that I am correct),
but
it is something that has to be repeated often since the myth is so
persistent.
Patrick Leary
AVP, Market Development
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
[EMAIL PROTECTED]
Visit Alvarion at WiMAX World
Chicago, September 25-27
Booth #409
-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]
On
Behalf Of Jack Unger
Sent: Sunday, September 16, 2007 1:43 PM
To: WISPA General List
Subject: Re: [WISPA] Flexible antenna certification
Patrick,
In an attempt to get an up-to-date interpretation on this point, I
just
emailed the Certification Lab that I work with to get their
interpretation of this rule.
I'll post their answer as soon as I receive it in the next few days.
jack
Patrick Leary wrote:
Mike,
You are right, but you, as an operator, cannot make the choice or
decide
on your own what antenna toi uses, even if it has similar propagation
patterns and a lower dBi. The FCC still requires the burden to be on
the
manufacturers to add antennas, it just does not make us go through
the
wringer now for every change. I do not know how many times I have to
explain this on the various lists, but that is the fact. The order
clearly says this AND I was there at the FCC right after the order
and
they explained that clearly, much to the chagrin of Marlon and others
present. Here is the part in the order that clearly discusses the
fact
that it is still the manufacturer that holds the burden: "The
manufacturer must supply a list of other acceptable antennas in the
literature delivered to the customer."
Patrick Leary
AVP, Market Development
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
[EMAIL PROTECTED]
Visit Alvarion at WiMAX World
Chicago, September 25-27
Booth #409
-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]
On
Behalf Of Mike Hammett
Sent: Sunday, September 16, 2007 6:47 AM
To: WISPA List
Subject: [WISPA] Flexible antenna certification
Many times I've been asked to prove a regulation I swore happened.
It
was the one stating that once a radio manufacturer certifies a radio
with an antenna of x gain, antennas with lower gain, but a similiar
pattern and gain characteristics can be used without certification.
On various lists I have been basically laughed at. Well, I found a
reference to it today, so I tracked it down.
Here is the text of the R&O in question:
8. In order to support more flexible antenna requirements for
unlicensed devices, the Commission proposed to allow that devices be
authorized for use with multiple antennas. Although the Commission
proposed to modify Sec. 15.203 to implement the modifications, it
believes that the changes are better suited for Sec. 15.204.
Accordingly, the Commission modifies Sec. 15.204 to permit
intentional
radiators to be authorized with multiple antennas of similar in and
out-of-band gain and radiation pattern. Compliance testing for the
intentional radiator must be performed using the highest gain antenna
that will be used with the device. The manufacturer must supply a
list
of other acceptable antennas in the literature delivered to the
customer.
http://frwebgate.access.gpo.gov/cgi-bin/multidb.cgi?WAISdbName=2004_regi
ster+Federal+Register%2C+Volume+69+%282004%29&WAISqueryRule=%28%22page+5
4027%22%29&WAIStemplate=multidb_results.html&WrapperTemplate=aces140_wra
pper.html&WAISqueryString=%22page+54027%22&WAISmaxHits=40
http://frwebgate2.access.gpo.gov/cgi-bin/waisgate.cgi?WAISdocID=94961739
4663+1+0+0&WAISaction=retrieve
http://frwebgate2.access.gpo.gov/cgi-bin/waisgate.cgi?WAISdocID=94961739
4663+1+1+0&WAISaction=retrieve
http://frwebgate2.access.gpo.gov/cgi-bin/waisgate.cgi?WAISdocID=94961739
4663+1+2+0&WAISaction=retrieve
-----
Mike Hammett
Intelligent Computing Solutions
http://www.ics-il.com <http://www.ics-il.com/>
<http://www.ics-il.com/>
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