Subject: RE: [Capwap] Expanded discussion on regulatory certification

From: "Tal Anker" <[email-masked]>
Date: Wed, 3 Aug 2005 13:39:35 +0300

Hi Bob,
Without taking sides on whether it should be LWAPP or SLAPP... I'd just like to know what's bad with the ability to perform image download via the CAPWAP protocol? If the vendor chooses to update the WTP with its own SW, then be it - its the vendor problem to get the WTP certified... However allowing to perform the image update from the AC in the framework of the CAPWAP control protocol seems like a good thing (whether the SW image is fromthe AC vendor or from the WTP vendor)....
 
- Tal

________________________________

From: [email-masked] on behalf of Bob O'Hara (boohara)
Sent: Wed 8/3/2005 12:04 PM
To: [email-masked]
Subject: [Capwap] Expanded discussion on regulatory certification

At the working group meeting, I asked the presenter for SLAPP about the
impact of downloading code into third party WTPs that have received
regulatory certification.  At that time, the presenter said that he was
not expert in that area, but suspected that recertification of the
device would be necessary with the newly downloaded code.  I would like
to discuss this further on the list. 

It is my assertion that all regulatory agencies that require
certification of WTPs for operation in their jurisdiction will require
that WTPs that receive code and use it for operation, when that code is
not from the entity that received the original certification for the
device, will require a new certification of that device with the new,
third party code.

In addition, nearly all regulatory agencies, certainly those in North
America, Europe, Asia, and the Middle East, require an external
indication of the certification, usually a sticker with an identifying
string.  I also assert that downloading new code to a third party WTP
will require that all WTPs that have received that code must now also be
physically accessed to have a new sticker affixed.

It is not sufficient for an AC vendor to simply develop code ports for
each silicon vendor and WTP reference design from those silicon vendors.
The AC vendors must now obtain regulatory certification for every WTP
manufactured.  Similarly, each WTP vendor must now obtain regulatory
certification with every AC vendor.

This will be a significant additional cost for all AC and WTP vendors.
Where current devices need to be certified once for each regulatory
domain, SLAPP will require that each device is certified several times
for each regulatory domain.  The cost of regulatory certification for an
AC vendor is now multiplied by the number of WTPs that is supports.
Similarly, the cost of certification for a WTP vendor is multiplied by
the number of ACs that are supported.  Even sharing the cost of
certification between AC and WTP vendor only cuts this cost in half.  It
is still dramatically larger than with any other proposal.

This is a very important issue.  With SLAPP, it is no longer sufficient
to state support for the ultimate CAPWAP protocol to be interoperable.
It is now necessary that there be a specific business relationships
between AC and WTP vendors or a list of "compatible" vendors and model
numbers.

I believe that this also significantly raises the barriers to entry for
AC and WTP vendors, since the cost of market entry is associated with
the costs of regulatory certification with a potentially large number of
ACs and WTPs.  As the number of ACs and WTPs increase, this cost also
increases.  The result is likely to be an entrenchment of the early
entrants into this market and the exclusion of new participants.

So, my final assertion is that adoption of the SLAPP model for CAPWAP
would have exactly the opposite effect that is desired from
standardization, which is lower costs, greater competition, and widely
interoperable products.

 -Bob

Bob O'Hara
Cisco Systems - WNBU

Phone:  +1 408 853 5513
Mobile: +1 408 218 4025

_______________________________________________
Capwap mailing list
[email-masked]
http://mail.frascone.com/mailman/listinfo/capwap

---

From: "Pat Calhoun (pacalhou)" <[email-masked]>
Date: Wed, 3 Aug 2005 04:43:12 -0700

> So, following the logic of the below, when does a new code 
> release by the WTP vendor require a recertification and new sticker?

In certain cases, the device needs to be re-certified, but the sticker
remains.

It is one thing to upgrade your code. It is something completely
different to have a 
foreign entity load their code on your Aps. How do you know whether that
AP will follow
geo-political regulatory restrictions?

I realize the group would prefer to deal with technical issues, but
creating a standard
that does not allow a vendor to implement it in a legal way is something
we must
consider within CAPWAP.

PatC

---

From: "Bob O'Hara (boohara)" <[email-masked]>
Date: Thu, 4 Aug 2005 02:16:35 -0700

Tal,
 
In general, firmware download of firmware developed by the manufacturer
of the WTP is a very good thing.  this allows for feature updates and
bug fixes, all keeping the WTP regulatory certification valid.  Firmware
download of firmware developed by someone other than the WTP vendor
invalidates the WTP regulatory certification.  
 
As anyone involved in the WLAN market can tell you ( and I am sure you
understand for yourself), few users of WLAN equipment understand the
radio aspect of it.  Even fewer of those that do understand the radio
aspect also understand the regulatory aspect of the equipment.  It
simply is not necessary for them to understand the regulatory aspect.
That is the responsibility of the manufacturer of the equipment.
 
the problem with allowing arbitrary firmware to be downloaded to a WTP
is that the vast majority of the users of the equipment will not then be
able to determine if their equipment is still certified and legal to
operate.

 -Bob

From: Tal Anker [mailto:[email-masked]] 
Sent: Wednesday, August 03, 2005 3:40 AM
To: Bob O'Hara (boohara); [email-masked]
Subject: RE: [Capwap] Expanded discussion on regulatory certification

Hi Bob,
Without taking sides on whether it should be LWAPP or SLAPP... I'd just
like to know what's bad with the ability to perform image download via
the CAPWAP protocol? If the vendor chooses to update the WTP with its
own SW, then be it - its the vendor problem to get the WTP certified...
However allowing to perform the image update from the AC in the
framework of the CAPWAP control protocol seems like a good thing
(whether the SW image is fromthe AC vendor or from the WTP vendor)....
 
- Tal

 -Bob

Bob O'Hara
Cisco Systems - WNBU

Phone:  +1 408 853 5513
Mobile: +1 408 218 4025

---

From: "Bob O'Hara (boohara)" <[email-masked]>
Date: Thu, 4 Aug 2005 02:21:29 -0700

David,

A recertification becomes necessary in just about all regulatory domains
when a vendor exceeds the terms of their original license.  In some
regulatory domains, this means that any firmware download will require a
new certification, as these regulatory domains allow no modification of
the product after it is certified.  

In some regulatory domains, there is much more leeway permitted to the
vendor, allowing them much greater flexibility to make changes in the
product.  Some of these domains require notification of the changes that
have been made.  Some do not.

I hope this is helpful.

 -Bob
 
-----Original Message-----
From: David T. Perkins [mailto:[email-masked]] 
Sent: Wednesday, August 03, 2005 3:52 AM
To: Bob O'Hara (boohara)
Cc: [email-masked]
Subject: Re: [Capwap] Expanded discussion on regulatory certification

HI,

So, following the logic of the below, when does a new code release
by the WTP vendor require a recertification and new sticker?

> standardization, which is lower costs, greater competition, and widely

Regards,
/david t. perkins