First off... why are you reading the law? Has someone pointed you to it, saying you are breaking the law?
Based on my observation, and my legal disclaimer... "I am not a lawyer, and I don't even play one on TV." This is low voltage line, there is no line voltage at 110AC or above. This is 24V DC with 300mA output. Also, you are not "Telecommunications" by the FCC definition. Do you have a lawyer you can consult? I would start there... Eric From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Clint Bridges at GCPowerNet Sent: Wednesday, January 16, 2013 2:49 PM To: wireless@wispa.org Cc: 1 - Clint Bridges Subject: [WISPA] Referencing the earlier L & I TelecommununicationsLicensing Discussions Reading the Washington State WACS Page 80 of 118 WAC 296-46B-925 Electrical/telecommunications contractor's license Things that puzzle me are items (10) and (12) below. If a WISP firm installs and maintains ownership and responsibility for the radio, cabling and POE adapter and power supply all the way to the customer's Internet router or personal computer, where would the demark point be? Would it not be at the point where the CAT 5 cabling from the POE LAN side connects into the customer-owned equipment and thereby qualify under item (12) and eliminate the need for an 09 license? If the WISP uses an all-in-one, UL approved and licensed POE unit where the power supply and the POE are built together as one unit, example: Ubiquity, then wouldn't that qualify under item (10) and eliminate the need for an 06 low-voltage administrator's license and an 06 low-voltage journeyman electrical license, required to install and connect a POE device to a Cat 5 cable? I wrote to the L&I people in September for a clarification on this but they simply came back citing Chapter 19.28 of the RCWs saying that to install Cat5 one had to have an 09 Administrator for the company and to install a POE adapter one had to have an 06 Administrator for the company and all POE installations had to be done by a licensed journeyman. This entire thing is frustrating to me and confusing, because it appears that the laws are at odds with each other and are very unclear on this subject, and that the people in Olympia can simply rule it however they wish to their own advantage. Can anyone here clarify the differences between the WACS and the RCWs and how they relate or interact? Does one trump the other? To be the WACS look like the standards on how to install, administer the laws contained within the RCWs. But if the WACS state that something does not fall under the requirements or are not legislated by the RCWs then does that mean we can go by what the WACs say to the exclusion of the RCWs, in this case the items (10) and (12)? Clint Bridges Moses Lake, WA Electrical/telecommunications contractor exemptions. (8) The following types of systems and circuits are considered exempt from the requirements for licensing and permitting described in chapter 19.28 <http://apps.leg.wa.gov/RCW/default.aspx?cite=19.28> RCW. The electrical failure of these systems does not inherently or functionally compromise safety to life or property. Low-voltage thermocouple derived circuits and low-voltage circuits for: (a) Built-in residential vacuum systems; (b) Underground landscape sprinkler systems; (c) Underground landscape lighting; and (d) Residential garage doors. For these types of systems and circuits to be considered exempt, the following conditions must be met: (e) The power supplying the installation must be derived from a listed Class 2 power supply; (f) The installation and termination of line voltage equipment and conductors supplying these systems is performed by appropriately licensed and certified electrical contractors and electricians; (g) The conductors of these systems do not pass through fire-rated walls, fire-rated ceilings or fire-rated floors in other than residential units; and (h) Conductors or luminaires are not installed in installations covered by the scope of Article 680 NEC (swimming pools, fountains, and similar installations). (9) Firms who clean and/or replace lamps in luminaires are not included in the requirements for licensing in chapter 19.28 <http://apps.leg.wa.gov/RCW/default.aspx?cite=19.28> RCW. This exemption does not apply to electric signs as defined in the NEC. (10) Firms who install listed plug and cord connected utilization equipment are not included in the requirements for licensing in chapter 19.28 <http://apps.leg.wa.gov/RCW/default.aspx?cite=19.28> RCW. The plug and cord must be a single listed unit consisting of a molded plug and cord and not exceeding 250 volt 60 ampere single phase. The plug and cord can be field installed per the manufacturer's instructions and the product listing requirements. The utilization equipment must be a single manufactured unit that does not require any electrical field assembly except for the installation of the plug and cord. (11) Firms regulated by the Federal Communications Commission or the utilities and transportation commission, supplying telecommunications service to an end-user's property, are not required to be licensed as a telecommunications contractor under chapter 19.28 <http://apps.leg.wa.gov/RCW/default.aspx?cite=19.28> RCW for telecommunications installations made ahead of the telecommunications network demarcation point. (12) Unregulated firms, supplying telecommunications service to an end-user's property, are not required to be licensed as a telecommunications contractor under chapter19.28 <http://apps.leg.wa.gov/RCW/default.aspx?cite=19.28> RCW for telecommunications installations made ahead of the telecommunications network demarcation point. (13) Leaseholders. For electrical installations, maintenance, or alterations to existing buildings only, any person, firm, partnership, corporation, or other entity holding a valid, signed lease from the property owner authorizing the leaseholder to perform electrical work, on the property the leaseholder occupies, will be allowed to purchase an electrical permit(s) and do electrical work on or within the property described in the lease. The lessee and/or his or her regularly employed employees must perform the electrical installation, maintenance and alteration. The lessee who performs the electrical maintenance or installation work must be the sole occupant of the property or space. Property owners or leaseholders cannot perform electrical work on new buildings for rent, sale, or lease, without the proper electrical licensing and certification. Refer to RCW 19.28.261 <http://apps.leg.wa.gov/RCW/default.aspx?cite=19.28.261> for exemptions from licensing and certification. (14) Assisting a householder. A friend, neighbor, relative, or other person (including a certified electrician) may assist a householder, at his/her residence in the performance of electrical work on the condition that the householder is present when the work is performed and the person assisting the householder does not accept money or other forms of compensation for the volunteer work. For the purposes of this subsection, a residence is a single-family residence. (15) Volunteering to do electrical work. There are no exceptions from the electrical contractor's license or electrician certification requirements to allow persons to perform volunteer electrical work for anyone other than a householder or a nonprofit organization as allowed by RCW 19.28.091 <http://apps.leg.wa.gov/RCW/default.aspx?cite=19.28.091> (7). For the purpose of this section, volunteer means that there is no remuneration or receiving of goods or services in return for electrical installations performed. (16) Farms or place of business. See RCW 19.28.261 <http://apps.leg.wa.gov/RCW/default.aspx?cite=19.28.261> for licensing/certification exemptions allowed for the owner(s) of a farm or other place of business and for the employees of the owner.
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