I agree entirely. This matter has been settled it seems. Patrick
-----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Jack Unger Sent: Monday, October 01, 2007 6:37 PM To: WISPA General List Cc: [EMAIL PROTECTED] Subject: Re: [WISPA] Flexible antenna certification Tom, You asked quite a few questions and I can't address all of them so I'll address the original question so WISPs can go about their business without fear of being "busted" by the FCC. 1. Mike Hammett said that he thought he read that WISPs could use a substitute antenna with the same or less gain as and the same in-band and out-of-band radiation characteristics as an antenna that the manufacturer originally certified a radio with. 2. Patrick Leary said that he thought so BUT ONLY IF the manufacturer included that antenna make and model on a list of acceptable antennas as part of the certification process. 3. I said that I thought that WISPs could use any substitute antenna of the same or less gain and the same antenna type even if the manufacturer didn't list it on the certification application. I agreed to check with the lab that I work with to get THEIR INTERPRETATION. 4. I checked and the lab reported back that my understanding was correct. 5. Marlon agreed to run this by the FCC and he did. 6. The FCC responded that my labs interpretation was correct. 7. Marlon asked the FCC AGAIN to verify that the above interpretation was correct. 8. The FCC responded AGAIN that the interpretation was correct. This statement has now been TRIPLE-CHECKED - once by the lab and twice by the FCC. I think that WISPs can now go about their business knowing that they are safe to use a substitute antenna of the same or less gain and of the same antenna "type" (panels are panels, yagis are yagis, dishes are dishes, etc.) than an antenna that the radio was originally certified with. If anyone has any questions about this, please ask and I'll try to clarify it further but it seems pretty clear to me. IMHO, The FCC's not going to "come after" anyone for doing the above. No one has any standing "in court" to argue with the above. Nobody is going to "measure" the antenna to see if the vendor was truthful with their spec. No WISP is going to have to "prove" that their antenna is in compliance as long as they take responsibility for observing and complying with the above conditions. The FCC is simplifying the in and out of band requirements down to the "same antenna type" A third-party antenna manufacturers spec sheet IS enough to relieve a WISP of responsibility for the antenna characteristics. The RESPONSIBILITY is ON THE WISP to use an antenna that has the same or less gain and is of the same antenna type as the originally certified antenna, period. The WISPs responsibility is clear. I think it's my responsibility to express this clearly and I hope that I have. I can't speculate about the answers to your other questions about why specific manufacturers chose certain antennas to certify their equipment with. I'd suggest that those questions be addressed directly to the equipment manufacturers. jack Tom DeReggi wrote: > Marlon, > > Sounds like good news, and that it pays to read the actual code, > apposed to just on the fly FCC personel feedback. > . >> 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 think the grey area is how to define "similar in-band and > out-of-band radiation patterns". > As John mentioned it could be interpreted and simplified as "Yagi, > Parabolic, Panel, etc". > But is "interpreted" and "simplified to style antenna" good enough? > I think its good enough, for a WISP to use as an arguement to defend > themselves, if the FCC comes knocking on their door. > I think its good enough, for a WISP to openly use third party antennas > without fear the FCC will come after them. > But not sure its good enough, if someone forced the issue in court, > and/or the antenna does not perform within spec. > Will a WISP be held accountable if they use an antenna that they > THOUGHT was equvellent and "similar radiation patterns" and then turn > out not to be? > I beleive that if a WISP selected their own antenna brand to meet > "similar radiation patterns", it would become the burden of the WISP > to prove that compliance. > There could be a situation where the WISP must pay to get a third > party to certify the results of the specific antennas after the fact, > to verify the WISP's claim, that it is "similar". I don't think a > third party's manufacturer's spec sheet will be enough to relieve the > WISP of responsibilty. > > By the Manufacturer providing a LIST of certified antennas, it puts > the responsibilty on the manufacturer's shoulders, and relieves the > WISP's liabilty. > > What interests me is.... Many of the OEM system's certifications were > done with Lower gain antennas. (For example ADI's under 22dbin 5.8G) > I'm wondering why they aren't getting the certifications for larger > 32db Parabolics, so everything under it would also be certified? Is it > the FCC that is only allowing them to certify the lower gain antennas, > or is it the OEM manufacturer not realizing higher gain antennas need > certification? > > For example... With a MESH system, certifying tri-band cards with Dual > purpose AP, CPE or PTP, what antenna would be certifyable would depend > on the use of the system. What is the FCC saying about this? > > Tom DeReggi > RapidDSL & Wireless, Inc > IntAirNet- Fixed Wireless Broadband > > > ----- Original Message ----- From: "Marlon K. Schafer (509) 982-2181" > <[EMAIL PROTECTED]> > To: <wireless@wispa.org> > Sent: Monday, October 01, 2007 6:47 PM > Subject: Fw: [WISPA] Flexible antenna certification > > >> 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/> >>>> >> >> >> >> >> >> >> ------------------------------------------------------------------------ -------- >> >> >> ** Join us at the WISPA Reception at 6:30 PM on October the 16th 2007 >> at ISPCON ** >> ** ISPCON Fall 2007 - October 16-18 - San Jose, CA www.ispcon.com ** >> ** THE INTERNET INDUSTRY EVENT ** >> ** FREE Exhibits and Events Pass available until August 31 ** >> ** Use Customer Code WSEMF7 when you register online at >> http://www.ispcon.com/register.php ** >> >> ------------------------------------------------------------------------ -------- >> >> WISPA Wants You! Join today! >> http://signup.wispa.org/ >> ------------------------------------------------------------------------ -------- >> >> >> WISPA Wireless List: wireless@wispa.org >> >> Subscribe/Unsubscribe: >> http://lists.wispa.org/mailman/listinfo/wireless >> >> Archives: http://lists.wispa.org/pipermail/wireless/ >> >> >> -- >> Internal Virus Database is out-of-date. >> Checked by AVG Free Edition. Version: 7.5.487 / Virus Database: >> 269.13.27/1020 - Release Date: 9/20/2007 12:07 PM >> >> > > ------------------------------------------------------------------------ -------- > > > ** Join us at the WISPA Reception at 6:30 PM on October the 16th 2007 > at ISPCON ** > ** ISPCON Fall 2007 - October 16-18 - San Jose, CA www.ispcon.com ** > ** THE INTERNET INDUSTRY EVENT ** > ** FREE Exhibits and Events Pass available until August 31 ** > ** Use Customer Code WSEMF7 when you register online at > http://www.ispcon.com/register.php ** > > ------------------------------------------------------------------------ -------- > > WISPA Wants You! 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