Good job Tom, George and Brent. I personally have not done my due diligence in filing form 477, but will now put it on my priority list. It is good to hear about the 5.4GHz, hope the vendors will follow suit.
Victoria Proffer www.stlbroadband.com -----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Tom DeReggi Sent: Friday, February 16, 2007 10:47 PM To: WISPA General List Subject: [WISPA] Brief report from FCC visit We just got back from FCC and FTC visits yesterday. A couple notes... 1) Both meetings had full staff attending, which I consider an honor. Each meeting lasted about 2 hours. 2) Some of the WISPs had to cancel due to weather, but 3 made it, George Rigoto, Brent Anderson, and myself Tom DeReggi. 3) One thing was clear without a doubt. They are somewhat pissed that all WISPs are NOT filling From 477. I think the general concensus was that maybe only 10% were? The FCC primarilly stayed on the arguement that it wasn't a choice, it was law. But I could see it in their eyes that it was more than that, possibly even hurtful. After all that they have been doing for us, that the single only thing that they asked of us, we couldn't even bother to do. I tell you, we will alienate our friends at the FCC, if we do not cooperate. EVERYONE must file Form 477. They did Thank WISPA for helping in promoting the need to file. We talked a bit about why we thought some WISPs weren't filing. But anyway we looked at it, any reason not to was a false fear. The Form 477 is not intertwined with the taxation department, it is not intertwined with the Enforcement beaurow for illegal gear. They aren't giving the data to our competition. And the data they collect is to broad to even do us harm if it was disclosed. So if you are a WISP, please file. I personally am working on my Form today, and plan on sending it in Monday. I personally won't make the mistake of not filing, again. 4) We discussed the option for self/group effort to certifying gear combinations. It won't be an option that will be viable. It must be a "Manufacturer" that applied for equipment certification, as there must be an accountable/responsible/liable party. A group applying for certification, would have to take liabilty and prove their ability to be able to be accountable. I'm not the police and not going to tell you what to use, but any way you slice it, make your own StarOS / Mikrotik gear is illegal (non-certified) in the US. The only way to not be illegal, is to buy it from a manufacturer that has certified their combination, or you become a manufacturer yourself and apply for certification of your combination. The fact that XYZ certified the combination, does not make your combination certified. UNLESS you convince XYZ to be responsible and liable for the compliance of the gear that you bought elsewhere. A MPCI card and antenna is not enough to be a certified system. There are other components involved like Main boards and cases, and testing gear during the QC stage to verify compliance. But there is nothing wrong with a group of people taking up a collection to help a manufactuer pay for certifying their combination. The grey area is it is also in the new rules that all the components (such as antenna and cables) don't necessarilly have to be bought from the manufacturer, if they are the same products bought elsewhere. So if a manufacturer certified a complete combination, and discloses what components were in it, technically it could be argued that it is that same product as the manufacturers, if the same oem parts were used. But legally that won't completely fly either, because there is no FCC sticker that was issued to the manufactuer, and there is no one accountable for it. So technically, at least one major component of the solution would have to be certified where you'd get the sticker from the manufacturer. So legally we may be able to substitute antenna, but that is not the same thing as saying you are allowed to just build your own radio system from scratch. 5) Enforcement- The FCC was clear on the issue that the rules are the rules, period. But they also said, when reporting a complaint, it should be defined the details. Complaints are prioritized by severity, and more severe violation will be given higher priority to enforce. The mentons a very low number of complaints we filed. They stated enforcement is a reality, but it requires someone to complain, and disclose facts for the FCC to know something is needing investigation. 6) 5.4G violations. They were very concerned that some gear on the market may be able to illegally be configured to use 5.4Ghz without going through the certification process for compliance. They are much more concerned on the compliace of 5.4 gear because the importance NOT TO INTERFERE with DOD applications. So using uncertified 5.4 gear is on the Radar for enforcement, without sympathy. They did however say its a full green light for manufacturers to apply for certification, already two manufacturers have passed 5.4G certification testing. So I'm begging StarOS and/or MIkrotik, to go through the 5.4Ghz certification testing, so your software can be proven to work and comply, so third party manufactuers will certify your solutions for resale, and we can start using 5.4Ghz. The FCC did their job, now its time for the manufacturers to do theirs. The same request goes out to all the name brand vendors like Trango, Alvarion, and Whoever else. 5,4Ghz certified gear is the next big market for manufacturers. 7) Otard- Otard will never be extended to include standalone broadcast antennas. However, the existing rules do have some provisions for mesh with multiple radios. The primary point is that if a radio's primary roles is that of a subscriber antenna and meet the physical specifications of a subscriber antenna, it does not matter if it also has an AP built-in or a second antenna built in, it is still considered a subscriber antenna and protected by OTARD. That is good news. That about covers it for FCC visit. As for the FTC visit, its a little harder to put my finger on what we accomplished. The converstation went all over the place. The primary goal was to show them what a wisp was. It also was a very good meeting, its just hard to summarize. Maybe I'll try tommorrow. One of the guys gave us a report, that is also on the FTC website for download, that was very informative on Muni broadband. When I have the business cards in front of me tommorrow, I'll try and find and post names and links. But I think we made some new friends there. The task force (who we met with) seemed very eager to help us. George or Brett, feel free to jump in with comments, if I got anything wrong or you have something to add. Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband -- 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. 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