There is also have a difference between accepted interpretations and  
trying to argue new interpretations. I would say you an attorney if  
you want to push through a new interpretation. While it may be  
supported in current law, unless there is a precedent then you are  
going to have to argue for it and win approval. Too often people like  
to argue in their own minds how something should be interpreted and  
then run with it.

-Matt

On Mar 9, 2009, at 4:48 PM, Jack Unger wrote:

> As I see it, there are two sources of information on FCC matters.
>
> 1. Those people (onlist) who have the most experience with an issue  
> (be it 3.65 or any other issue). Experience still adds up to  
> knowledge. Anything less is just guessing. Put your faith in those  
> that you trust who have experience with an issue, whatever the issue  
> is.
>
> 2. Your FCC attorney. FCC matters are, at base, a matter of law.
>
> jack
>
> [email protected] wrote:
>>
>> I dunno who to ask, I think even if you ask the FCC you might get a  
>> slightly
>> muddled answer.  I just used exactly what was certified including the
>> enclosure used, and followed the rest of the requirements as best I  
>> could.
>>
>>
>>
>>
>> ++++++++++++++++++++++++++++++++
>> <insert witty tagline here>
>>
>> ----- Original Message -----
>> From: "Scott Carullo" <[email protected]>
>> To: "WISPA General List" <[email protected]>
>> Sent: Saturday, March 07, 2009 5:47 PM
>> Subject: Re: [WISPA] 3.65 ptp
>>
>>
>>
>>> Who has the final word on this?  I've been told by testing  
>>> laboratories
>>> that do testing for the FCC that this is not the case...  They  
>>> said if the
>>> radio card (5Ghz when I asked but for this discussion it doesn't  
>>> matter)
>>> had been approved with an antenna then you could use the same or  
>>> less db
>>> like antenna and you were good to go - assuming the card  
>>> manufacturer
>>> (like
>>> ubiquity) had had appropriate testing completed and filed with FCC.
>>>
>>> It sure is difficult for any of us to make heads or tales out of  
>>> what can
>>> or can't be done because everyone has a different opinion - even the
>>> people
>>> at the top of the food chain I guess.
>>>
>>> Who's right?  And how am I supposed to know?
>>>
>>> Scott Carullo
>>> Brevard Wireless
>>> 321-205-1100 x102
>>>
>>> -------- Original Message --------
>>>
>>>> From: "Harold Bledsoe" <[email protected]>
>>>> Sent: Saturday, March 07, 2009 2:21 PM
>>>> To: "WISPA General List" <[email protected]>
>>>> Subject: Re: [WISPA] 3.65 ptp
>>>>
>>>> I think the confusion on this comes from the fact that for the P90
>>>> licensing process, only the transmitter information is collected.
>>>> Remember that even with Part 90 devices, they still must comply  
>>>> with
>>>> Part 15 requirements for unintentional radiators.  This is  
>>>> covered with
>>>> a Declaration of Conformity for the system typically.
>>>>
>>>> So the previous example of the XR3 + ARC + RB411 + PoE (sic) is
>>>> technically only legal if it meets all Part 90 requirements  
>>>> (which it
>>>> should according to the test report on file at the FCC) as well  
>>>> as Part
>>>> 15 requirements for unintentional radiators.  In this case, a
>>>> Declaration of Conformity should be on file at the assembler's  
>>>> location.
>>>>
>>>> This is why the label is important.  This kind of system built from
>>>> modular components should include a label with a manufacturer  
>>>> name/model
>>>> number, the contains FCC ID: xxxxxx, and the 2 required  
>>>> statements about
>>>> unintentional interference.  This information tells anyone  
>>>> including the
>>>> FCC who to contact for intentional emission issues (P-90 in this
>>>> example) as well as unintentional emission issues (P-15 in this  
>>>> case).
>>>> If there is no label on there, then it is illegal by default.   
>>>> Then if
>>>> there are problems with the intentional radiator, it is the module
>>>> maker's problem (assuming the integration instructions were  
>>>> followed
>>>> properly).  Finally if there are problems with the unintentional
>>>> emissions, it is the system assembler's problem.
>>>>
>>>> I know, I know....this is a licensed, Part 90 band.  So why does  
>>>> Part 15
>>>> even matter?  Simply put, P-90 covers the transmitter, P-15  
>>>> covers the
>>>> rest of the crap spewing from the device in the rest of the
>>>> spectrum.  :-)
>>>>
>>>> -Hal
>>>>
>>>> -----Original Message-----
>>>> From: David E. Smith <[email protected]>
>>>> Reply-To: WISPA General List <[email protected]>
>>>> To: WISPA General List <[email protected]>
>>>> Subject: Re: [WISPA] 3.65 ptp
>>>> Date: Sat, 07 Mar 2009 18:05:36 GMT
>>>>
>>>>
>>>>> My system is fully licensed.
>>>>>
>>>> How did you get your combination of "XR3
>>>> + Routerboard 400 series + Mikrotik RouterOS 3.x + whatever  
>>>> antenna"
>>>> certified? What's the process like, and how much did it cost?Or  
>>>> did you
>>>> just buy the kit from someone else who went through the  
>>>> certification
>>>> process? If so, from whom? I'd be willing to pay a small premium  
>>>> over
>>>> the price of "all those parts" just to avoid the legal heat.David
>>>> SmithMVN.net
>>>>
>>>>
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>>>>
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>
> -- 
> Jack Unger - President, Ask-Wi.Com, Inc.
> Serving the Broadband Wireless Industry Since 1993
> Cisco Press Author - "Deploying License-Free Wireless WANs"
> WISPs - Do you know where your customers are?
> For wireless coverage mapping see http://www.ask-wi.com/mapping
> FCC Lic. #PG-12-25133 LinkedIn Profile <http://www.linkedin.com/in/jackunger 
> >
> Phone 818-227-4220  Email <[email protected]>
>
>
>
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