I've been in contact with UBNT for some time.    The modular approval 
specifies the antenna to be used, and it is, according to both the FCC ( 
email from the FCC in response to an inquiry ) and UBNT entirely legal to 
use with any OS that properly operates the card.

So, yes you can grow your own, and if nothing else, you simply use the FCC 
ID on the card itself as your FCC ID...    If you wish to have your own 
number on the box, you must apply to the FCC for your own number, and simply 
cite the "this is unchanged from XXXXXX " in your applicaiton.

All stated clearly and unambiguously by the FCC personell.

I hope this puts this argument to bed.    Modular approval is just that. 
The module, ON ITS OWN, is approved and can be put in anything appropriate. 
Again, stated clearly by the FCC.

BTW, on your license, you're required to put the ID of the equipment you're 
putting in place.   In this case, it's the FCC ID for UBNT.

BTW, current XR3's out now are not ACTUALLY the right card.   I've been 
promised a pair from the first stickered and channelized batch.   I would 
not deploy anything being sold by retailers right now, as they are pretty 
much engineering mules...   Not optimized and not properly channel filtered 
and limited.




++++++++++++++++++++++++++++++++
<insert witty tagline here>

----- Original Message ----- 
From: "Randy Cosby" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Wednesday, June 04, 2008 9:12 AM
Subject: Re: [WISPA] 3650 XR3 locations (was: Rapid Link Launches WiMax)


>I had a feeling this would unleash a can of worms.
>
> I'm the one who registered the locations.  My first location (my office
> rooftop) was done purely as an academic exercise to see what exactly was
> required.  I had hoped the FCC would come back and say, "you need to do
> X Y and Z before this is acceptable." I would have been fine with that
> and taken that into consideration in my feasibility study.  They did not.
>
> Since then, there has been some further digging to clarify some
> questions that were brought up by this approval.  From what I
> understand, using the XR3, MT and an 18dbi antenna (or smaller) is
> approved as far as Part 90 goes.  See
> http://forum.ubnt.com/forum/viewtopic.php?t=1451&start=14 for 
> clarification.
>
> Now, if you were to go out and SELL that bundle as a product, I would
> think there would need to be further licensing
> (http://www.fcc.gov/oet/ea/ ) to be approved. Hana Wireless (
> http://www.streakwave.com/mmSWAVE1/Video/HW3.pdf ) is selling pretty
> much the same kit I made myself, but I do NOT see any OET approvals for
> them.   I hear other WISPS are using the Hana units, but I see nothing
> of the sort registered in ULS, so I would think they are not legal.
>
> If I use any of these, they will be for PTP links.  Because the XR3 was
> only approved for 18dBi antennas, and has a max output of 25dbm (see
> *http://tinyurl.com/4jpndg *,
> http://ubnt.com/downloads/ubi_mtik_power.pdf ) and assuming .5 dB loss
> for the jumper cable, at slow speeds we're only going to get a 42.5 dBm
> or 17.8 watts, not the full 20 watts allowed under the rules in a 20 mhz
> channel.   If you want  to run  at full 54 mbps, you will only get 18
> dBm on the radio,  plus 18 on the antenna, or 35.5 dbm, or 3.5 watts.
> Not the ideal PTP solution.
>
> So is it moral or legal to run it?  I'm glad this has stirred some
> debate and further clarifications.  I'd like to see 802.11Y moved along
> and put into MT and the cards, that would help open up lots of other
> non-wimax possibilities.  For now, it is what it is.  I've seen nothing
> to indicate it is illegal.  Is it unwise?
>
> I honestly am interested in hearing verifiable refutations to anything
> I've found so far.  I want to do what is legal, as well as wise.
>
> Randy
>
>
>
>
> Leon D. Zetekoff, NCE wrote:
>> George...you can not plug-n-play components as I said earlier. It has to
>> be certified as a system that makes use of a contention based protocol.
>>
>> Leon
>>
>> * George Rogato wrote, On 6/4/2008 11:22 AM:
>>
>>> Thanks for explaining that Travis.
>>> I asked Jack Unger to look into this recently.
>>> There was a post somewhere else recently about 3650 use and I forwarded
>>> it to Jack to find out from the FCC if in fact it is the way the post 
>>> read.
>>>
>>> I'd like to hear Jack's opinion based on what he has found out from the 
>>> FCC.
>>>
>>> As far as using those cards, if they work in mt and star, then for most
>>> of us it's just add another card to the multi port board and go. It
>>> sounds a lot cheaper than I had expected.
>>>
>>> George
>>>
>>> Travis Johnson wrote:
>>>
>>>
>>>> John,
>>>>
>>>> Here is what I have heard or read so far:
>>>>
>>>> (1) I "heard" that 3650 users that are conflicting will have to "work 
>>>> it
>>>> out" and that "more than likely" the FCC would not get involved in a
>>>> frequency conflict.
>>>>
>>>> (2) Getting a license for 3650 takes about 2 hours, start to finish
>>>> (from what I have heard from people that have done it). Meaning any
>>>> person with Internet access can have a valid, FCC license in 2 hours.
>>>>
>>>> (3) The FCC has already approved someone using just the Ubiquiti XR3
>>>> card as the registered "base station". Putting that card in a MT system
>>>> does not broadcast any call signs or info in the packet frame, yet you
>>>> are "licensed" and "FCC legal" as per the registration.
>>>>
>>>> (4) If it truly is a "first registered, everyone else work around me"
>>>> then I will be registering every single tower within a 1,000 mile 
>>>> radius
>>>> from my NOC. :)
>>>>
>>>> I'm not trying bash you or anything you said... I'm just thinking the
>>>> 3650 band is going to get just as messy as the 5ghz band within a few
>>>> years... and I think the FCC has given "false hope" that it is somewhat
>>>> protected... yet I don't see how.
>>>>
>>>> Travis
>>>> Microserv
>>>>
>>>> John Scrivner wrote:
>>>>
>>>>
>>>>> Here is how it is different than 5 GHz. In 5 GHz the rules are that 
>>>>> you have
>>>>> to accept interference. Also any equipment on earth can use the band 
>>>>> from
>>>>> mobile phones to cameras and of course broadband devices of many 
>>>>> types.
>>>>> There is little involved in dropping your link. Also there is little 
>>>>> chance
>>>>> of you knowing what the interfering source is without some leg work. 
>>>>> In 3650
>>>>> only people who get a license can launch. Base stations must be 
>>>>> certified
>>>>> systems with the FCC and must be registered with the FCC. The rules 
>>>>> state
>>>>> that it is a requirement that anyone using the band must work to 
>>>>> eliminate
>>>>> interference with other users. That means if you are there first and 
>>>>> someone
>>>>> interferes with you then they broke the law and it is their duty to 
>>>>> fix it.
>>>>> Also, since everyone must register base stations, you will know who is
>>>>> interfering. In the case of WiMAX base stations, the call letters of 
>>>>> the
>>>>> license holder are actually transmitted in the data frames which show 
>>>>> up as
>>>>> the intefering carrier within the monitoring tools in the base 
>>>>> stations
>>>>> themselves. I think there is a great opportunity in this band and I am 
>>>>> proud
>>>>> to say I just got my license in 3650 last week. I am looking to build 
>>>>> my
>>>>> first WiMAX base station very soon.
>>>>> Scriv
>>>>>
>>>>>
>>>>> On Tue, Jun 3, 2008 at 5:52 PM, Travis Johnson <[EMAIL PROTECTED]> wrote:
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>> So, how exactly does 3.65ghz licensing work? If Rapid Link has 
>>>>>> licensed
>>>>>> a base station at tower X, and I want to license 3.65ghz at tower X 
>>>>>> as
>>>>>> well, what happens? Also, what if I want to license at Tower Y that 
>>>>>> is
>>>>>> 100 feet away? Is this band really any different than 5ghz, except 
>>>>>> you
>>>>>> have to tell the FCC where your base stations are located?
>>>>>>
>>>>>> Travis
>>>>>> Microserv
>>>>>>
>>>>>> Mike Prachar wrote:
>>>>>>
>>>>>>
>>>>>>
>>>>>>> -  Atlanta business can now enjoy the only wide-area alternative to 
>>>>>>> AT&T
>>>>>>> -
>>>>>>>
>>>>>>>
>>>>>>> OMAHA, NE - June 3, 2008 - Rapid Link, Incorporated (OTCBB: RPID), a
>>>>>>> leading provider of WiMax and Communication Services, announced 
>>>>>>> today
>>>>>>> the official launch of its much anticipated WiMax service offering 
>>>>>>> in
>>>>>>> the Atlanta Metropolitan area.
>>>>>>>
>>>>>>> Following the soft launch of this service in February 2008, Rapid 
>>>>>>> Link
>>>>>>> has several active customers enjoying the benefits of this cutting 
>>>>>>> edge
>>>>>>> technology.  Due to the overwhelming success of the early release
>>>>>>> through our Channel Partners, Rapid Link is now offering voice and
>>>>>>> internet service via WiMax to the commercial public.
>>>>>>>
>>>>>>> Operating in the licensed-only 3650 MHz spectrum, customers can now
>>>>>>> enjoy guaranteed high speed connectivity, voice and internet bundled
>>>>>>> service, at the best cost/efficiency ratio in the industry.
>>>>>>>
>>>>>>> Matt Liotta, Chief Technology Officer of Rapid Link states, "We are
>>>>>>> clearly ahead of the competition and the technology power curve with
>>>>>>> this offering.  Customers are increasingly discovering the 
>>>>>>> limitations
>>>>>>> of antiquated technologies.  Following the recent release of WiMax
>>>>>>> technologies and equipment in the United States, Rapid link is proud 
>>>>>>> to
>>>>>>> be a licensed WiMax carrier offering this breakthrough service to 
>>>>>>> our
>>>>>>> foundation of customers in the greater Atlanta area."
>>>>>>>
>>>>>>>
>>>>>>> About Rapid Link
>>>>>>>
>>>>>>> Rapid Link, Incorporated is a Diversified Communication Services
>>>>>>> company, supplying bundled internet and voice services to Business 
>>>>>>> and
>>>>>>> Residential customers. Rapid Link offers broadband access via its 
>>>>>>> own
>>>>>>> facilities to ensure fast and reliable delivery of its content. As a
>>>>>>> leading licensed WiMAX carrier, Rapid Link is on the cutting edge of
>>>>>>> this exciting new technology. We are one of the only carriers that 
>>>>>>> can
>>>>>>> offer an end-to-end solution for our customers without a dependency 
>>>>>>> on
>>>>>>> any other company's resources.
>>>>>>>
>>>>>>> For more information, visit www.rapidlink.com.
>>>>>>>
>>>>>>> "Safe Harbor" Statement under the Private Securities Litigation 
>>>>>>> Reform
>>>>>>> Act of 1995: With the exception of historical information, the
>>>>>>> statements set forth above include forward-looking statements that
>>>>>>> involve risk and uncertainties. The Company wishes to caution 
>>>>>>> readers
>>>>>>> that a number of important factors could cause actual results to 
>>>>>>> differ
>>>>>>> materially from those in the forward-looking statements. Those 
>>>>>>> factors
>>>>>>> include, but are not limited to, risks and uncertainties such as the
>>>>>>> failure to satisfy contractually agreed upon closing conditions that 
>>>>>>> may
>>>>>>> delay or prevent the closings of subsequent debt financings 
>>>>>>> contemplated
>>>>>>> by the applicable agreements; the risk factors noted in the 
>>>>>>> Company's
>>>>>>> filings with the United States Securities and Exchange Commission, 
>>>>>>> such
>>>>>>> as the trading price of the Company's common stock reaching levels 
>>>>>>> that
>>>>>>> would cause funding to occur; the rapidly changing nature of 
>>>>>>> technology,
>>>>>>> evolving industry standards and frequent introductions of new 
>>>>>>> products,
>>>>>>> services and enhancements by competitors; the competitive nature of 
>>>>>>> the
>>>>>>> markets for the Company's products and services; the Company's 
>>>>>>> ability
>>>>>>> to gain market acceptance for its products and services; the 
>>>>>>> Company's
>>>>>>> ability to fund its operational growth; the Company's ability to 
>>>>>>> attract
>>>>>>> and retain skilled personnel; the Company's ability to diversify its
>>>>>>> revenue streams and customer concentrations; and the Company's 
>>>>>>> reliance
>>>>>>> on third-party suppliers.
>>>>>>>
>>>>>>> Contact:
>>>>>>> Investor Relations
>>>>>>> Rapid Link, Inc.
>>>>>>> Tel.:  402-392-7561
>>>>>>>
>>>>>>>
>>>>>>>
>>>>>>>
>>>>>>>
>>>>>>>
>>>>>>>
>>>>>> --------------------------------------------------------------------------------
>>>>>>
>>>>>>
>>>>>>
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>
> -- 
> Randy Cosby
> Vice President
> InfoWest, Inc
>
> office: 435-773-6071
>
>
>
>
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