The FCC is asking for comments on a proposal to require manufacturers to lock down computing devices

[RMerlin]

Here is my own entry.

The third party firmware market is a driving force for innovation and product functionality. A lot of (perfectly legal and harmless) product features first started in a third party firmware product, and was eventually integrated into manufacturer's official firmware.

While some of these projects can indeed provide functionalities that allow for circumventing channel and power output limitations, that does not mean that the entire third party firmware market is doing so.

It is my belief, both as a long-time user and a third party firmware developer myself that forcing manufacturers to flat out prevent the flashing of a third party firmware will be harmful to the market, and deny end users of choice (for cases where an original manufacturer's firmware would be devoid of advanced features and/or contain unfixed security holes and/or has software defects and/or are no longer being supported by the original manufacturer.

Therefore, I recommend that the scope of these rules be reduced to only ensuring that the radio components are operating within the legal parameters, possibly by shifting the solution to a hardware limitation, rather than a software limitation.

 

[Ronv42]

I posted my comments today. But the last time I got involved with commenting on FCC regulations they ignored the people and we got the internet now regulated like the old analog phone service.

 

[jegesq]

Re: Posting Comments to the FCC on Proposed Rules 15-170, use this link:
http://apps.fcc.gov/ecfs/upload/begin?procName=15-170&filedFrom=E

You can attach a separate file containing your comments, and it can be of almost any length.

Reading through the comments that have been received to date (only 16 of them), you have roughly two camps: 1) the HAM radio folks, who request tha there should be exceptions for their licensed uses (and several have suggested that if the real issue is with WiFi devices, perhaps the FCC should ban their use entirely....an extreme position no doubt). On the other end of the spectrum are several comments where people in support of allowing firmware modifications on wifi routers spout various platitudes about "open source" innovation, and fear of the NSA. One commenter simply said "Worst Idea Ever." Seriously, that was his only comment.

Plainly, if the FCC is going to have any serious input from folks who matter, we need that voice to be from people who frequent these forums, who know the issues, and who can express their views in a coherent, meaningful way that federal regulators will take seriously. We don't need silly comments like "Worst Idea Ever" (even if it is the truth), but something that has at least a modicum of gravitas, that legislators and rulemakers will take seriously.

People like R. Merlin, T. Higgins, SFX2000, et.al, need to make their voices heard on this to the FCC. We all need to comment. Don't let the only serious voices be from Hams or from the Consumer Electronics Association or other trade groups.

Edited to add: I had not seen R. Merlin's posted comments at the time I was posting this message. Thank you Eric. Excellent comments and they can provide a template for many others here to use as a basis for their own comments (i.e., no reason to reinvent the wheel), and indeed, I agree with you completely, the focus should be on restricting the hardware radio portion of devices so that they can only operate within prescribed limits, and leave the ability to install other firmwares unimpaired. If everyone one of us made that simple point, perhaps that message would get through to the FCC loud and clear and not be muddled in a mess of almost meaningless platitudes (such as the wonders of "open source" or "consumer choice"). Again, thank you R. Merlin. Your voice does matter.

 

[red_pope]

jegesq

Your FCC Electronic Filing site link is obsolete!


This is what I get to your link
Not Found

The requested object does not exist on this server. The link you followed is either outdated, inaccurate, or the server has been instructed not to let you have it. Please inform the site administrator of the referring page.

Here is an active link:
Please, the same comments you are posting, copy and paste them in their web site make your opinion to be heard, it it is your right.
https://www.federalregister.gov/art...-and-electronic-labeling-for-wireless-devices

 

[red_pope]

jegesq said:

There are legitimate aviation, weather and military concerns and those are going to gain priority over hobbyists, makers, and consumers who want to improve the performance of their wifi devices.

What makes you think that WIFI devices will interfere with airports, military, and weather?
The FCC frequency for those specific services are in a very different spectrum from a WIFI device. Each is individually allocated differently. Unless you are on the same frequency and channel is different subject. Home WIFI devices are not interfering at all. Unless someone is intentionally hacking and modifying that device. Then you need the same identical equipment to be successful.

 

[red_pope]

Merlin
Please, send the same comments you are posting, copy and paste them in their web site make your opinion to be heard, it it is your right.
https://www.federalregister.gov/art...-and-electronic-labeling-for-wireless-devicesP

 

[sfx2000]

Well put and very well written...

 

[System Error Message]

Lets keep posting comments to them. You should if you're an american (anywhere on the continent including canada and brazil) or british. Although i think the possibility of them not doing firmware lock is bleak despite the comments.

 

[RMerlin]

Merlin
Please, send the same comments you are posting, copy and paste them in their web site make your opinion to be heard, it it is your right.
https://www.federalregister.gov/art...-and-electronic-labeling-for-wireless-devicesP

As I said, I have already filed a formal comment with them, I merely reposted it here afterward.

 

[RMerlin]

I contacted Brainslayer today, who had just found out as well about this. He intends to pursue his own venues to fight this proposal, and raise public awareness.

The OpenWRT devs are already working actively on this proposal (they've been for a few weeks now).

 

[RMerlin]

I posted my comments today. But the last time I got involved with commenting on FCC regulations they ignored the people and we got the internet now regulated like the old analog phone service.

A few years ago, the CRTC put forward some rules that would have effectively killed the wholesaler market for ISPs, due to a totally brain-damaged pricing plan. The people complained a lot to the government, and the Ministry of Industry called the heads of the CRTC in front of a panel of politicians to explain their decision to them. They failed to convince the government, who told the CRTC to go back to the drawing board, and come back with a different plan. And the Minister himself warned them that if they came back with the same plan, he would personally scrap it.

The CRTC scrapped the plan, and came back with a more reasonable plan.

Granted, it's a Canadian case and not a US one, but it's one pretty good case where the people made the government review a decision, and force the organization responsible for it to revise it.

 

[RMerlin]

Lets keep posting comments to them. You should if you're an american (anywhere on the continent including canada and brazil) or british. Although i think the possibility of them not doing firmware lock is bleak despite the comments.

One hope we might have is if the heavy weights get involved. That means the actual manufacturers themselves: Netgear, Linksys, DLink, Asus, etc... Those stand to lose quite a lot if this comes to pass.

 

[jegesq]

jegesq

Your FCC Electronic Filing site link is obsolete!


This is what I get to your link
Not Found

The requested object does not exist on this server. The link you followed is either outdated, inaccurate, or the server has been instructed not to let you have it. Please inform the site administrator of the referring page.

Here is an active link:
Please, the same comments you are posting, copy and paste them in their web site make your opinion to be heard, it it is your right.
https://www.federalregister.gov/art...-and-electronic-labeling-for-wireless-devices

***************
Edit 8/30/2015 @ 11:20 a.m. PDT: This link works for me: http://apps.fcc.gov/ecfs/upload/display

**************
The FCC website is currently being transitioned to a new site: See this explanation at http://transition.fcc.gov/

The comments sections for this Proposed Rule Making are being moved, as is the rest of the FCC's web resources. It's going to sometime between 9/2 and 9/8 before everything settles down. Coincidentally, that was the exact time period that public comments were supposed to be closed on ET Docket No. 15-170 (the particular set of rules in question). I think in part, this is why the FCC granted the Petitions filed by the Consumer Electronic Association, and others. Here's a copy of the PDF Order extending the time for filing public comments until November 9: http://transition.fcc.gov/Daily_Releases/Daily_Business/2015/db0825/DA-15-956A1.pdf.

I'll try to find a better link for filing Electronic Comments once the FCC websites settle back down. The link I posted though was working this afternoon, and must have been taken off-line shortly after I posted it here.

As for your other question about weather, aviation and military radar, while I don't have time tonight to get into that subject, there are ample reports and studies that demonstrate adjacent interference with the lower UNI-II band channels, and this is precisely why DFS and TPC are required to be implemented on some of the mid-range and higher level 5ghz band channels. Studies done primarily in Europe by ETSI (which I've linked to several times in other threads) make clear that even very low powered signals from wifi radios can interfere with weather and aviation radar. Maybe I'll have some time to go back into those links and pull some of that info for you later, but in the meantime, you might want to search for some of the threads where the topics of DFS and TPC and locking and unlocking various channels, both in the US and Europe (mostly in England) were fairly hot topics here within the last year. I'm not dodging the issue, but I honestly don't have time to pull out the proof at the moment to support the statement that indeed there are legitimate governmental and public safety issues at work with regard to parts of the same 5ghz frequencies that can be overlapped with unlicensed routers operating at higher than authorized transmit levels, or on channels where they shouldn't be operating, and that is what I think the FCC is most concerned about. But like most ham-fisted governmental agencies, how to go about regulating otherwise unlicensed spectrums to insure that end-users continue to operate such devices only within the properly authorized frequencies and at properly authorized transmit levels, is a lot harder to do than it is to simply verbalize the issue.

 

[System Error Message]

I think if this rule came into affect it would mean you cannot use pfsense with a WLAN card lol.

 

[red_pope]

jegesq

Your link redirects EVERYONE ELSE TO something else from the FCC, and not the Federal register were people could comment and send their proper comments ON THIS MATTER.

In my opinion, your links are disruptive.
If you feel you are that righteous, then make your own forum Mr!
Stop suggesting your links! Yes, WE COULD ARGUE A MILLION WEB PAGES ALL DAY! BUT NOT IN THIS FORUM!
I don't need to flood this forum with NON topics not related to the FCC PROPOSAL

Stay on the main subject nothing else!

Did you post it your comments with the FCC? A lot of people has done it, either American, foreigners or aliens.

Here is, an active link:
Please, the same comments you are posting, copy and paste them in their web site make your opinion to be heard, it it is your right.
https://www.federalregister.gov/art...-and-electronic-labeling-for-wireless-devices

 

[red_pope]

I think if this rule came into affect it would mean you cannot use pfsense with a WLAN card lol.

No Sir, the problem the whip antennas of those European (Ruskin) military radios are not set for frequency hopping and their encryption is weak!! They rather spam the lower frequencies.

 

[red_pope]

As I said, I have already filed a formal comment with them, I merely reposted it here afterward.

Thank You

 

[RMerlin]

I contacted Asus about this whole situation, and already got an answer from them. The short version: they have no plan to lock third party firmwares out of their router. They are only protecting the wireless part of the code, by closing its source.

That makes me a bit confused. That would mean that the checklist is NOT a binding requirement, but just some questions asking manufacturers how their devices are secured overall? In that case, someone who speaks legalese might need to analyze the actual rules rather than just the manufacturer form to figure out what's the REAL risk there.

I assume Asus's assessment to be correct, since they've had to get new devices validated under the new rules already, such as this one.

EDIT: updated link

 

[red_pope]

I contacted Asus about this whole situation, and already got an answer from them. The short version: they have no plan to lock third party firmwares out of their router. They are only protecting the wireless part of the code, by closing its source.

That makes me a bit confused. That would mean that the checklist is NOT a binding requirement, but just some questions asking manufacturers how their devices are secured overall? In that case, someone who speaks legalese might need to analyze the actual rules rather than just the manufacturer form to figure out what's the REAL risk there.

I assume Asus's assessment to be correct, since they've had to get new devices validated under the new rules already, such as this one.

Merlin
I do get this error msg from the FCC website

Date and time of error: Sun Aug 30 13:01:10 EDT 2015
Requester's browser type: Mozilla/5.0 (Windows NT 6.1; WOW64; rv:40.0) Gecko/20100101 Firefox/40.0
Called from: http://www.snbforums.com/threads/th...s-to-lock-down-computing-devices.26712/page-2
Parameters specified: RequestTimeout=500
Diagnostic information: Variable CALLEDFROMFRAME is undefined.
The error occurred on line 16.​

 

[sfx2000]

I contacted Asus about this whole situation, and already got an answer from them. The short version: they have no plan to lock third party firmwares out of their router. They are only protecting the wireless part of the code, by closing its source.

That makes me a bit confused. That would mean that the checklist is NOT a binding requirement, but just some questions asking manufacturers how their devices are secured overall? In that case, someone who speaks legalese might need to analyze the actual rules rather than just the manufacturer form to figure out what's the REAL risk there.

That's basically how I read it on second review - and it seems to be focused mostly on the UNII-2 blocks, which a vendor could just lock out those in the chip/radio sections.

FCC's intent is to open up that UNII-2 band, but they want to have some confidence that devices will behave well there...