[Discuss] New WiFi firmware guidance from FCC

[Stephen Ronan]

Forwarded here from another list with S.M.'s permission
   -S

---------- Forwarded message ----------
Date: Thu, 12 Nov 2015 16:15:23 -0500
From: Sascha Meinrath <sascha at thexlab.org>

Hi everyone,

To be clear, the FCC clearly didn't listen to the feedback that 
technologists and engineers were providing and is doubling down 
on blocking open source software and preventing entirely legal 
tinkering of the hardware we purchase. The FCC is regulating that 
new wireless technologies *not be able to be used illegally* -- 
imagine trying to design a car that couldn't speed, or a pen that 
couldn't write death threats, or any other tool you can probably 
imagine to an equal specification. For example, if I buy a Wi-Fi 
router and move to a country with a different legal set of 
parameters, I should be able to change my device to be compliant. 
The FCC's rules would prevent that (or maybe they would allow it, 
in which case, I could just download the Czech patch for my Wi-Fi 
device and continue to use it illegally.

Put simply, the FCC is actively engaged in a war against 
innovation. As every engineer on this list knows, locking down 
firmware "to prevent modifications to the software that could, 
for example, disable dynamic frequency selection (technology 
necessary for preventing interference to radars), enable tuning 
to unauthorized frequencies, increase power above authorized 
levels, etc." while simultaneously "not intend[ing] to prevent or 
inhibit modification of any other software or firmware in the 
device, such as software modifications to improve performance, 
configure RF networks or improve cybersecurity" is not feasible.

Thus, this "clarified guidance" does nothing to address the 
fundamental technical reality that wireless firmware cannot be 
locked down against illegal use while also open to legal 
tinkering because in the Venn diagram of functionality, the two 
overlap so substantially. Anyone that knows anything about EIRP 
knows that the *antenna* matters, not just the firmware on your 
Wi-Fi device. So, in the end, this proceeding won't actually 
prevent harmful interference, cannot be operationalized 
successfully in a global market, and will most certainly prevent 
entirely legal modification of Wi-Fi devices.

Which is why we need to stop the FCC before their ludicrous new 
proposed regulations damage to the vibrant Wi-Fi market sector.

--Sascha Meinrath
Director, X-Lab
Palmer Chair in Telecommunications
Penn State University