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

From: "Bob O'Hara (boohara)" <[email-masked]>
Date: Thu, 4 Aug 2005 02:07:39 -0700

<802.11 Technical advisor to CAPWAP hat>
Yes, it is my assertion that recertification is necessary.  Just because
you suggest it may not be true, does not make it less true.
</802.11 Technical advisor to CAPWAP hat> 

And actually, having to put another sticker on an AP has everything to
do with CAPWAP.  Using a protocol that requires such manual operations
at every CAPWAP AP (and not even manual operations across the network,
but manual operations at the top of a ladder with your head poked into
the hole made by moving the ceiling tile aside) hardly makes for ease of
management or configuration consistency.  It seems that a protocol that
requires such manual operations does not meet Objective 5.1.2,
configuration consistency, since the protocol cannot allow an AC to
determine if it is legal to operate a third party WTP after a software
download has taken place.  In the US, at least, it is not legal to
operate a Part 15.247 device (say, all 802.11b/g APs) without the
appropriate FCCID.  I am certain this is true in many other regulatory
domains, as well.

 -Bob
 
-----Original Message-----
From: Dan Harkins [mailto:[email-masked]] 
Sent: Wednesday, August 03, 2005 3:29 AM
To: Bob O'Hara (boohara)
Cc: [email-masked]
Subject: Re: [Capwap] Expanded discussion on regulatory certification 

  I was that presenter and I don't think that recertification is
necessary, but again, that's outside my job function.

  It may be your assertion that recertification is necessary but that's
just your assertion, it doesn't mean it's true. And furthermore whether
someone has to put a sticker on an AP has nothing to do with CAPWAP. 

  Dan.

On Wed, 03 Aug 2005 03:04:21 PDT you wrote
> 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
> 
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---

From: Dan Harkins <[email-masked]>
Date: Wed, 17 Aug 2005 16:23:43 -0700

Bob,

  After looking at an FCC test report for the certification of Airespace's
AS1250 it appears that you got certification not by running your operational
AP code but by running "ART_V48_build_13_alpha". So you received
certification for your APs by running code on them that is not your's and
is not what a customer runs on them. Your own operational image is loaded
onto these APs prior to shipping yet you do not recertify them with this
new code load.

  So this entire issue about recertification being necessary is just an
unfortunate bunch of FUD.

  Dan.

On Thu, 04 Aug 2005 02:07:39 PDT you wrote