Re: [Bloat] Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

Re: [Bloat] Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[Rich Brown]

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Folks,

Dave may have buried the lede in his previous note... The date for comments to the FCC is not a month away, but only three days away - 8 Sep 2015.

To see the talking points for preparing your comments, go to: https://libreplanet.org/wiki/Save_WiFi

To submit a comment, click the green "SUBMIT A FORMAL COMMENT" button on  https://www.federalregister.gov/articles/2015/08/06/2015-18402/equipment-authorization-and-electronic-labeling-for-wireless-devices

Please post a link to your comments when you're done.

Rich

On Sep 5, 2015, at 6:42 AM, Dave Taht <dave.taht@gmail.com> wrote:

> In other news:
> 
> I am glad to see the more political save-the-wifi coming online rapidly:
> 
> https://libreplanet.org/wiki/Save_WiFi
> 
> I HAD NO IDEA that the follow-on rules for 2016 would basically ban modifiable firmware entirely, nor that the DFS problem was due to only 41 old radars that need to be replaced anyway. 
> 
> Comment deadline for the fcc is sept 8th, not oct 8, which means we should strap ourselves into the writing console, like, today.


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Re: [Bloat] Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[Dave Taht]

while the current FCC course sucks, I personally have been unable to
summon the moxy to fight anymore. Decided to migrate to the eu
instead, only to find the same ruling going into play here. Is there
no place left on the planet safe to innovate in?

and: LTE-U is an even greater threat, and I'm low on ideas on how to counter it.

http://www.wsj.com/articles/cell-carriers-battle-for-wi-fi-airwaves-1440543853

On Sat, Sep 5, 2015 at 7:12 AM, Rich Brown <richb.hanover@gmail.com> wrote:
> Folks,
>
> Dave may have buried the lede in his previous note... The date for comments
> to the FCC is not a month away, but only three days away - 8 Sep 2015.
>
> To see the talking points for preparing your comments, go to:
> https://libreplanet.org/wiki/Save_WiFi
>
> To submit a comment, click the green "SUBMIT A FORMAL COMMENT" button on
> https://www.federalregister.gov/articles/2015/08/06/2015-18402/equipment-authorization-and-electronic-labeling-for-wireless-devices
>
> Please post a link to your comments when you're done.
>
> Rich
>
> On Sep 5, 2015, at 6:42 AM, Dave Taht <dave.taht@gmail.com> wrote:
>
> In other news:
>
> I am glad to see the more political save-the-wifi coming online rapidly:
>
> https://libreplanet.org/wiki/Save_WiFi
>
> I HAD NO IDEA that the follow-on rules for 2016 would basically ban
> modifiable firmware entirely, nor that the DFS problem was due to only 41
> old radars that need to be replaced anyway.
>
> Comment deadline for the fcc is sept 8th, not oct 8, which means we should
> strap ourselves into the writing console, like, today.
>
>



-- 
Dave Täht
endo is a terrible disease: http://www.gofundme.com/SummerVsEndo

[Bloat] RE : Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[luca.muscariello]

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is there any serious study that proves that LTE U is a threat?

-------- Message d'origine --------
De : Dave Taht
Date :2015/09/06 12:06 AM (GMT+01:00)
À : Rich Brown
Cc : make-wifi-fast@lists.bufferbloat.net, cerowrt-devel , bloat
Objet : Re: [Bloat] Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

while the current FCC course sucks, I personally have been unable to
summon the moxy to fight anymore. Decided to migrate to the eu
instead, only to find the same ruling going into play here. Is there
no place left on the planet safe to innovate in?

and: LTE-U is an even greater threat, and I'm low on ideas on how to counter it.

http://www.wsj.com/articles/cell-carriers-battle-for-wi-fi-airwaves-1440543853

On Sat, Sep 5, 2015 at 7:12 AM, Rich Brown <richb.hanover@gmail.com> wrote:
> Folks,
>
> Dave may have buried the lede in his previous note... The date for comments
> to the FCC is not a month away, but only three days away - 8 Sep 2015.
>
> To see the talking points for preparing your comments, go to:
> https://libreplanet.org/wiki/Save_WiFi
>
> To submit a comment, click the green "SUBMIT A FORMAL COMMENT" button on
> https://www.federalregister.gov/articles/2015/08/06/2015-18402/equipment-authorization-and-electronic-labeling-for-wireless-devices
>
> Please post a link to your comments when you're done.
>
> Rich
>
> On Sep 5, 2015, at 6:42 AM, Dave Taht <dave.taht@gmail.com> wrote:
>
> In other news:
>
> I am glad to see the more political save-the-wifi coming online rapidly:
>
> https://libreplanet.org/wiki/Save_WiFi
>
> I HAD NO IDEA that the follow-on rules for 2016 would basically ban
> modifiable firmware entirely, nor that the DFS problem was due to only 41
> old radars that need to be replaced anyway.
>
> Comment deadline for the fcc is sept 8th, not oct 8, which means we should
> strap ourselves into the writing console, like, today.
>
>



--
Dave Täht
endo is a terrible disease: http://www.gofundme.com/SummerVsEndo
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Re: [Bloat] RE : Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[Dave Taht]

Well, so far there has not been enough technical analysis. It is the
game theory fail that bothers me most - users of LTE spectrum can
encroach upon the wifi bands, and retreat to their own, but wifi users
cannot, and further, cannot even detect when or if lte-u is messing up
their lives, nor complain to a responsible party.

In only one of the two analyses published to date:

http://googlepublicpolicy.blogspot.de/2015/06/encouraging-innovation-wi-fi-and-lte-in.html

They buried the lede here -

"A distinctive aspect of LTE in unlicensed—as compared to other
unlicensed technologies developed to date—is that it is a license­
anchored system that operates simultaneously across licensed and
unlicensed bands. Furthermore, LTE in unlicensed allows traffic to be
moved dynamically, on a per­user and even on a per­traffic flow basis,
across the licensed and unlicensed bands. This makes LTE in unlicensed
substantially less sensitive to interference and collisions in the
unlicensed band, because it is able to move traffic so quickly from
the unlicensed band to the licensed band, in a very granular fashion,
whenever congestion occurs in the unlicensed band. Purely unlicensed
operations, by contrast, can fail entirely if there is interference in
that spectrum. Reduced sensitivity to the conditions in the unlicensed
bands significantly reduces the incentives that designers of LTE in
unlicensed have to develop well­functioning coexistence mechanisms."

secondly, having another user of this spectrum (in addition to the DFS
mess), will make it harder for wifi to continue to evolve. Certainly
we have here a lot of fixes stacked up that will make wifi a lot
better, and future versions of the wifi standards will do better.

I am no fan of the wifi mac, believe me, and if LTE-U was something I
could buy in a store, and hack on, and use for private use, and deploy
any way I wanted, I would probably favor it's deployment. But that is
*not* the case, which is why I am saying that 1) "unlicensed spectrum
= the public's spectrum" and 2) HANDS OFF OUR WIFI to the carriers.

Places like forbes are pitching this as a battle between isps that use
wifi, and the carriers... which bugs me. 5.x ghz is the people's
spectrum, that we should be free to use any way we want... and to make
it faster, easier to use, and more reliable, my goal - LTE-U is a huge
step backwards.

I would like vastly more spectrum opened up to free public use  - the
rules and regs around 24ghz and 60ghz are quite insane and
restrictive, and - for example - I'd like a uhf band opened up for
general use also....


On Sun, Sep 6, 2015 at 2:02 AM,  <luca.muscariello@orange.com> wrote:
> is there any serious study that proves that LTE U is a threat?
>
> -------- Message d'origine --------
> De : Dave Taht
> Date :2015/09/06 12:06 AM (GMT+01:00)
> À : Rich Brown
> Cc : make-wifi-fast@lists.bufferbloat.net, cerowrt-devel , bloat
> Objet : Re: [Bloat] Save WiFi from the FCC - DEADLINE is in 3 days
> *September* 8
>
> while the current FCC course sucks, I personally have been unable to
> summon the moxy to fight anymore. Decided to migrate to the eu
> instead, only to find the same ruling going into play here. Is there
> no place left on the planet safe to innovate in?
>
> and: LTE-U is an even greater threat, and I'm low on ideas on how to counter
> it.
>
> http://www.wsj.com/articles/cell-carriers-battle-for-wi-fi-airwaves-1440543853
>
> On Sat, Sep 5, 2015 at 7:12 AM, Rich Brown <richb.hanover@gmail.com> wrote:
>> Folks,
>>
>> Dave may have buried the lede in his previous note... The date for
>> comments
>> to the FCC is not a month away, but only three days away - 8 Sep 2015.
>>
>> To see the talking points for preparing your comments, go to:
>> https://libreplanet.org/wiki/Save_WiFi
>>
>> To submit a comment, click the green "SUBMIT A FORMAL COMMENT" button on
>>
>> https://www.federalregister.gov/articles/2015/08/06/2015-18402/equipment-authorization-and-electronic-labeling-for-wireless-devices
>>
>> Please post a link to your comments when you're done.
>>
>> Rich
>>
>> On Sep 5, 2015, at 6:42 AM, Dave Taht <dave.taht@gmail.com> wrote:
>>
>> In other news:
>>
>> I am glad to see the more political save-the-wifi coming online rapidly:
>>
>> https://libreplanet.org/wiki/Save_WiFi
>>
>> I HAD NO IDEA that the follow-on rules for 2016 would basically ban
>> modifiable firmware entirely, nor that the DFS problem was due to only 41
>> old radars that need to be replaced anyway.
>>
>> Comment deadline for the fcc is sept 8th, not oct 8, which means we should
>> strap ourselves into the writing console, like, today.
>>
>>
>
>
>
> --
> Dave Täht
> endo is a terrible disease: http://www.gofundme.com/SummerVsEndo
> _______________________________________________
> Bloat mailing list
> Bloat@lists.bufferbloat.net
> https://lists.bufferbloat.net/listinfo/bloat
>
> _________________________________________________________________________________________________________________________
>
> Ce message et ses pieces jointes peuvent contenir des informations
> confidentielles ou privilegiees et ne doivent donc
> pas etre diffuses, exploites ou copies sans autorisation. Si vous avez recu
> ce message par erreur, veuillez le signaler
> a l'expediteur et le detruire ainsi que les pieces jointes. Les messages
> electroniques etant susceptibles d'alteration,
> Orange decline toute responsabilite si ce message a ete altere, deforme ou
> falsifie. Merci.
>
> This message and its attachments may contain confidential or privileged
> information that may be protected by law;
> they should not be distributed, used or copied without authorisation.
> If you have received this email in error, please notify the sender and
> delete this message and its attachments.
> As emails may be altered, Orange is not liable for messages that have been
> modified, changed or falsified.
> Thank you.



-- 
Dave Täht
endo is a terrible disease: http://www.gofundme.com/SummerVsEndo

Re: [Bloat] RE : Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[Mikael Abrahamsson]

On Tue, 8 Sep 2015, Dave Taht wrote:

> wifi, and the carriers... which bugs me. 5.x ghz is the people's
> spectrum, that we should be free to use any way we want... and to make

Well, in the US at least, corporations are people, so...

But that aside, I don't know if there is anything that can be done really, 
unlicensed is unlicensed and if it's not free for everybody to use, what 
is it?

Also, isn't it pretty much the same players in wifi and LTE space, 
Qualcomm, Broadcom and the others, they're in both spaces and I don't see 
what they have to gain to make wifi worse?

And 802.11 isn't really open either, and the unlicensed spectrum still 
requires that devices are approved to be operated there, right, so if FCC 
and the likes do their job properly then these technologies should 
work together at least on the RF level?

-- 
Mikael Abrahamsson    email: swmike@swm.pp.se

Re: [Bloat] RE : Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[Dave Taht]

On Tue, Sep 8, 2015 at 1:22 AM, Mikael Abrahamsson <swmike@swm.pp.se> wrote:
> On Tue, 8 Sep 2015, Dave Taht wrote:
>
>> wifi, and the carriers... which bugs me. 5.x ghz is the people's
>> spectrum, that we should be free to use any way we want... and to make

Please note that the LTE-U debate is separate from the lockdown
debate, which only has a day to run. Can we get more letters into the
FCC for the lockdown problem?

>
>
> Well, in the US at least, corporations are people, so...

Corporations are people now, with an indefinite lifespan -  with the
rights of an adult, and the morals of a child. If it were up to me,
the lifetime of a corporation would be inversely proportional to the
number of employees.

Lest you think this is crazy, corporations were formed only for
limited times and purposes all the way up to the late 1800s.

I try really hard not to let my politics not interfere with
engineering truths - I'm always quoting feynman's last comments on the
shuttle commission on that.

> But that aside, I don't know if there is anything that can be done really,
> unlicensed is unlicensed and if it's not free for everybody to use, what is
> it?

Yes, a core difference in outlook is that - after two decades of "the
public"'s use -
what people insist on calling "unlicensed" spectrum is really "the
people's" spectrum - and if more people thought about it that way,
they would be reluctant to hand over even a tiny bit of it to the
carriers.

And jeeze, what makes sense - on the "licensed" spectrum - is the
government auctions it off for big bucks one year, and then the public
pays rents on it for all eternity. Far saner to have more openly
available spectrum

One failed concept in america, at least, is the idea of a commons - as
in a tragedy of the commons - elsewhere, for example, "public lands"
are actually "the queen's" lands and people tend to treat them with
more respect.

Still... a meme to propigate and redefine the debate with is that 2.4
and 5.x ghz is now - by common usage - the "public's" spectrum, and
not "unlicenced" spectrum.

There are other precedents - at least in europe - for defining things
this way - squatters rights, etc. - but jeeze, really, anyone with a
wifi AP of their own should have a visceral reaction to anyone else
encroaching on it....

> Also, isn't it pretty much the same players in wifi and LTE space, Qualcomm,
> Broadcom and the others, they're in both spaces and I don't see what they
> have to gain to make wifi worse?

I don't see them doing a whole lot to make wifi better, either.

> And 802.11 isn't really open either, and the unlicensed spectrum still
> requires that devices are approved to be operated there, right, so if FCC
> and the likes do their job properly then these technologies should work
> together at least on the RF level?

I appreciate the optimism, but honestly, given the low level of
analysis so far, my vote would be to boot the whole idea back to the
beginning for a couple years to bake some more. And to go back to
improving wifi dramatically, in ways everyone can use. For free.

> --
> Mikael Abrahamsson    email: swmike@swm.pp.se



-- 
Dave Täht
endo is a terrible disease: http://www.gofundme.com/SummerVsEndo

Re: [Bloat] RE : Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[Mikael Abrahamsson]

On Tue, 8 Sep 2015, Dave Taht wrote:

> On Tue, Sep 8, 2015 at 1:22 AM, Mikael Abrahamsson <swmike@swm.pp.se> wrote:
>> On Tue, 8 Sep 2015, Dave Taht wrote:
>>
>>> wifi, and the carriers... which bugs me. 5.x ghz is the people's
>>> spectrum, that we should be free to use any way we want... and to make
>
> Please note that the LTE-U debate is separate from the lockdown
> debate, which only has a day to run. Can we get more letters into the
> FCC for the lockdown problem?

I have already posted as well.

> And jeeze, what makes sense - on the "licensed" spectrum - is the 
> government auctions it off for big bucks one year, and then the public 
> pays rents on it for all eternity. Far saner to have more openly 
> available spectrum

Well, yes, we need both unlicensed and licensed spectrum.

> One failed concept in america, at least, is the idea of a commons - as 
> in a tragedy of the commons - elsewhere, for example, "public lands" are 
> actually "the queen's" lands and people tend to treat them with more 
> respect.

Yes, in sweden we have something called (translated) "Rights of public 
access" to land for instance, I'm allowed to go camping in someone elses 
forest as long as it's noncommercial and I leave it as I found it. It's a 
constant battle to keep this freedom and I agree we need this for radio as 
well. BUT it's not like unlicensed radio today means you can do whatever 
you want, there is still quite a lot of regulation around it. So I can 
understand if they want to achieve that regulated devices in unlicensed 
spectrum actually follows the regulation. The problem is that it's 
different across the world, I've heard that in Thailand for instance, 
you're only allowed to transmit with a total of 100mW from a device, so if 
you turn on both 2.4GHz and 5GHz radios, you need to limit them to 50mW 
each (or some combination). How would a completely open device solve this 
problem?

So I think a constructive approach would be to try to say how the FCC 
concern can be solved or at least mitigated in a FOSS world. Do we have 
any ideas?

Because I can understand that regulators whose job it is to make sure 
devices follow the rules have a problem with FOSS code that lets people do 
whatever they want.

Do we really want for regulators to bring back the vans who might roll 
around and impose a fine because you were running OpenWRT and happened to 
set the output power too high for whatever local regulation was in place?

-- 
Mikael Abrahamsson    email: swmike@swm.pp.se

Re: [Bloat] RE : Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[Dave Taht]

On Tue, Sep 8, 2015 at 1:55 AM, Mikael Abrahamsson <swmike@swm.pp.se> wrote:
> On Tue, 8 Sep 2015, Dave Taht wrote:
>
>> On Tue, Sep 8, 2015 at 1:22 AM, Mikael Abrahamsson <swmike@swm.pp.se>
>> wrote:
>>>
>>> On Tue, 8 Sep 2015, Dave Taht wrote:
>>>
>>>> wifi, and the carriers... which bugs me. 5.x ghz is the people's
>>>> spectrum, that we should be free to use any way we want... and to make
>>
>>
>> Please note that the LTE-U debate is separate from the lockdown
>> debate, which only has a day to run. Can we get more letters into the
>> FCC for the lockdown problem?
>
>
> I have already posted as well.
>
>> And jeeze, what makes sense - on the "licensed" spectrum - is the
>> government auctions it off for big bucks one year, and then the public pays
>> rents on it for all eternity. Far saner to have more openly available
>> spectrum
>
>
> Well, yes, we need both unlicensed and licensed spectrum.

Well, no... we need the concept of "the public's" spectrum, also.

>> One failed concept in america, at least, is the idea of a commons - as in
>> a tragedy of the commons - elsewhere, for example, "public lands" are
>> actually "the queen's" lands and people tend to treat them with more
>> respect.
>
>
> Yes, in sweden we have something called (translated) "Rights of public
> access" to land for instance, I'm allowed to go camping in someone elses
> forest as long as it's noncommercial and I leave it as I found it.

What is the word, actually?

> It's a
> constant battle to keep this freedom and I agree we need this for radio as
> well. BUT it's not like unlicensed radio today means you can do whatever you
> want, there is still quite a lot of regulation around it. So I can
> understand if they want to achieve that regulated devices in unlicensed
> spectrum actually follows the regulation. The problem is that it's different
> across the world, I've heard that in Thailand for instance, you're only
> allowed to transmit with a total of 100mW from a device, so if you turn on
> both 2.4GHz and 5GHz radios, you need to limit them to 50mW each (or some
> combination). How would a completely open device solve this problem?

The best approach that we can think of to ensuring regulatory
compliance throughout the globe, in linux, has long been:

https://wireless.wiki.kernel.org/en/developers/regulatory

and making it all available as open source code, as we do.

The only way it could be improved would be for devices to also try to
determine where they actually are on boot, and to mandate that all
device makers seeking FCC compliance publish their source code that
shows it making the appopropriate calls into that database - and the
FCC mandate regular updates, and so on.

I of course would go a step further and mandate all wifi drivers and
firmware be made available as open source code in publicly available
git repositories - wifi has FAR more problems than just potentially
emitting on the wrong bands or at the wrong power, and I would hope
the FCC wold recognize that making wifi better, for everyone, should
also be a goal, rather than just protecting their radards.

I keep seeing things on how LTE-U is "1.6 times better than wifi" -
which does not use a definition of "better" I agree with...

... and we've already outlined how we intend to improve wifi's
behavior by much more than that - by reducing power, improving spacial
reuse, and improving aggregation, and so on.

https://www.youtube.com/watch?v=-vWrFCZXOWk

> So I think a constructive approach would be to try to say how the FCC
> concern can be solved or at least mitigated in a FOSS world. Do we have any
> ideas?

I am trying - and failing - to write a letter today on that.

> Because I can understand that regulators whose job it is to make sure
> devices follow the rules have a problem with FOSS code that lets people do
> whatever they want.
>
> Do we really want for regulators to bring back the vans who might roll
> around and impose a fine because you were running OpenWRT and happened to
> set the output power too high for whatever local regulation was in place?

Well, pushing the responsibility back on the actual users of the
technology is fine by me. Enforcement seems only to be of a concern on
the DFS channels around a limited number of airports.

>
>
> --
> Mikael Abrahamsson    email: swmike@swm.pp.se



-- 
Dave Täht
endo is a terrible disease: http://www.gofundme.com/SummerVsEndo

Re: [Bloat] RE : Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[Mikael Abrahamsson]

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On Tue, 8 Sep 2015, Dave Taht wrote:

> Well, no... we need the concept of "the public's" spectrum, also.

What does that mean? Only devices that have FOSS firmware are allowed to 
send in this spectrum?

Because I actually fail to see the fundamental difference to spectrum I 
use to communicate from my purchased devices from VENDOR1 and VENDOR2 that 
I run myself, and my purchased device I use to communicate that are from 
VENDOR1 and VENDOR2 where the device from VENDOR2 is run by a mobile 
provider. I mean, do we rule out wifi networks run by providers?

Now, I will admit that I have no idea how LTE-U looks like on RF, but 
what's so different about it compared to the different other things 
sending in there like Bluetooth and wifi (and wifi has many different 
encodings).

>>> One failed concept in america, at least, is the idea of a commons - as in
>>> a tragedy of the commons - elsewhere, for example, "public lands" are
>>> actually "the queen's" lands and people tend to treat them with more
>>> respect.
>>
>>
>> Yes, in sweden we have something called (translated) "Rights of public
>> access" to land for instance, I'm allowed to go camping in someone elses
>> forest as long as it's noncommercial and I leave it as I found it.
>
> What is the word, actually?

"Allemansrätten". Literally "everymansright".

> Well, pushing the responsibility back on the actual users of the 
> technology is fine by me. Enforcement seems only to be of a concern on 
> the DFS channels around a limited number of airports.



-- 
Mikael Abrahamsson    email: swmike@swm.pp.se

Re: [Bloat] RE : Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[Michael Richardson]

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Mikael Abrahamsson <swmike@swm.pp.se> wrote:
    > So I think a constructive approach would be to try to say how the FCC
    > concern can be solved or at least mitigated in a FOSS world. Do we have
    > any ideas?

The FCC needs to think bigger: restricting who can make/design/update
(fundamentally: 'own') wifi devices leads to millions of compromised devices
attacking the Internet.

If you think of the wifi spectrum as a small component of a bigger "Internet"
spectrum, and that FCC really cares about all of it, then it makes no sense
to manage each part in isolation.

Or to put it differently: if company X's locked down wifi device is attacking
the Internet, then maybe their wifi license should be revoked.

    > Because I can understand that regulators whose job it is to make sure
    > devices follow the rules have a problem with FOSS code that lets people
    > do whatever they want.

Manufacturer devices that have security holes in them let black hats do
whatever they want with the device.

    > Do we really want for regulators to bring back the vans who might roll
    > around and impose a fine because you were running OpenWRT and happened
    > to set the output power too high for whatever local regulation was in
    > place?

Yes, actually, I do.
I'm starting to be convinced that the Bell FIBE "wireless TV" eats more than
it's fair share of wifi.   I have no way to prove it without that Van.

--
]               Never tell me the odds!                 | ipv6 mesh networks [
]   Michael Richardson, Sandelman Software Works        | network architect  [
]     mcr@sandelman.ca  http://www.sandelman.ca/        |   ruby on rails    [


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Re: [Bloat] RE : Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[MUSCARIELLO Luca IMT/OLN]

IMHO, the duty cycle based time sharing system used by LTE-U  doesn't seem
to be harmful. The fact that wifi is poor in using its air time is 
802.11's fault.

On 09/08/2015 09:55 AM, Dave Taht wrote:
> Well, so far there has not been enough technical analysis. It is the
> game theory fail that bothers me most - users of LTE spectrum can
> encroach upon the wifi bands, and retreat to their own, but wifi users
> cannot, and further, cannot even detect when or if lte-u is messing up
> their lives, nor complain to a responsible party.
>
> In only one of the two analyses published to date:
>
> http://googlepublicpolicy.blogspot.de/2015/06/encouraging-innovation-wi-fi-and-lte-in.html

This document does not prove unfairness. It shows wifi is inefficient
in recovering after a LTE-U busy period.

>
> They buried the lede here -
>
> "A distinctive aspect of LTE in unlicensed—as compared to other
> unlicensed technologies developed to date—is that it is a license­
> anchored system that operates simultaneously across licensed and
> unlicensed bands. Furthermore, LTE in unlicensed allows traffic to be
> moved dynamically, on a per­user and even on a per­traffic flow basis,
> across the licensed and unlicensed bands. This makes LTE in unlicensed
> substantially less sensitive to interference and collisions in the
> unlicensed band, because it is able to move traffic so quickly from
> the unlicensed band to the licensed band, in a very granular fashion,
> whenever congestion occurs in the unlicensed band. Purely unlicensed
> operations, by contrast, can fail entirely if there is interference in
> that spectrum. Reduced sensitivity to the conditions in the unlicensed
> bands significantly reduces the incentives that designers of LTE in
> unlicensed have to develop well­functioning coexistence mechanisms."

I agree in part. Mostly because LTE-U isn't really a technology designed
to compete with 802.11. It's mostly an offloading technique
that of course integrates better to LTE than wifi.

On the other hand LTE-U can be used as a full unlicensed technology
with DL/UL in the 5GHz band.  I do not see how full unlicensed mode
can be forbidden.
If I build an LTE-U AP with DL/UL in 5GHz band and I efficiently use
my fair share of air time, what's the problem? It's a different way
of using the public spectrum, which tends to waste a lot
of public air time.

I do not like public resources to be wasted that way. Do you?



>
> secondly, having another user of this spectrum (in addition to the DFS
> mess), will make it harder for wifi to continue to evolve. Certainly
> we have here a lot of fixes stacked up that will make wifi a lot
> better, and future versions of the wifi standards will do better.
>
> I am no fan of the wifi mac, believe me, and if LTE-U was something I
> could buy in a store, and hack on, and use for private use, and deploy
> any way I wanted, I would probably favor it's deployment. But that is
> *not* the case, which is why I am saying that 1) "unlicensed spectrum
> = the public's spectrum" and 2) HANDS OFF OUR WIFI to the carriers.
>
> Places like forbes are pitching this as a battle between isps that use
> wifi, and the carriers... which bugs me. 5.x ghz is the people's
> spectrum, that we should be free to use any way we want... and to make
> it faster, easier to use, and more reliable, my goal - LTE-U is a huge
> step backwards.

In a way you are saying that competition does not help innovation
while I've always heard people saying the opposite to be true.

I feel like carriers gave up trying to integrate LTE and wifi, because
the latter sucks. Wifi is selling Gbps with 70% overhead.
Wifi chip makers are selling 10Gbps wifi which is ridiculously far from 
reality.
Again, public air time is valuable  and shouldn't be wasted that way.


>
> I would like vastly more spectrum opened up to free public use  - the
> rules and regs around 24ghz and 60ghz are quite insane and
> restrictive, and - for example - I'd like a uhf band opened up for
> general use also....

Agree. But not wasted.

>
>
> On Sun, Sep 6, 2015 at 2:02 AM,  <luca.muscariello@orange.com> wrote:
>> is there any serious study that proves that LTE U is a threat?
>>
>> -------- Message d'origine --------
>> De : Dave Taht
>> Date :2015/09/06 12:06 AM (GMT+01:00)
>> À : Rich Brown
>> Cc : make-wifi-fast@lists.bufferbloat.net, cerowrt-devel , bloat
>> Objet : Re: [Bloat] Save WiFi from the FCC - DEADLINE is in 3 days
>> *September* 8
>>
>> while the current FCC course sucks, I personally have been unable to
>> summon the moxy to fight anymore. Decided to migrate to the eu
>> instead, only to find the same ruling going into play here. Is there
>> no place left on the planet safe to innovate in?
>>
>> and: LTE-U is an even greater threat, and I'm low on ideas on how to counter
>> it.
>>
>> http://www.wsj.com/articles/cell-carriers-battle-for-wi-fi-airwaves-1440543853
>>
>> On Sat, Sep 5, 2015 at 7:12 AM, Rich Brown <richb.hanover@gmail.com> wrote:
>>> Folks,
>>>
>>> Dave may have buried the lede in his previous note... The date for
>>> comments
>>> to the FCC is not a month away, but only three days away - 8 Sep 2015.
>>>
>>> To see the talking points for preparing your comments, go to:
>>> https://libreplanet.org/wiki/Save_WiFi
>>>
>>> To submit a comment, click the green "SUBMIT A FORMAL COMMENT" button on
>>>
>>> https://www.federalregister.gov/articles/2015/08/06/2015-18402/equipment-authorization-and-electronic-labeling-for-wireless-devices
>>>
>>> Please post a link to your comments when you're done.
>>>
>>> Rich
>>>
>>> On Sep 5, 2015, at 6:42 AM, Dave Taht <dave.taht@gmail.com> wrote:
>>>
>>> In other news:
>>>
>>> I am glad to see the more political save-the-wifi coming online rapidly:
>>>
>>> https://libreplanet.org/wiki/Save_WiFi
>>>
>>> I HAD NO IDEA that the follow-on rules for 2016 would basically ban
>>> modifiable firmware entirely, nor that the DFS problem was due to only 41
>>> old radars that need to be replaced anyway.
>>>
>>> Comment deadline for the fcc is sept 8th, not oct 8, which means we should
>>> strap ourselves into the writing console, like, today.
>>>
>>>
>>
>>
>> --
>> Dave Täht
>> endo is a terrible disease: http://www.gofundme.com/SummerVsEndo
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>

Re: [Bloat] [Cerowrt-devel] Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[Jonathan Morton]

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> On 5 Sep, 2015, at 17:12, Rich Brown <richb.hanover@gmail.com> wrote:
> 
> Please post a link to your comments when you're done.

I couldn’t figure out a way to link to my comment as submitted, so I’ve attached it to this e-mail instead.

 - Jonathan Morton


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Comment re: Proposed Rulemaking on Software Defined Radios
==========================================================

I am an EU resident and citizen, and a software engineer involved in cutting-edge networking research.  I wish to make certain that the FCC is aware that their regulations have global effects, not merely local to the United States.

I and others firmly believe that these newly proposed certification rules:

	- will likely have deeply harmful effects,

	- address a theoretical harm which has not been clearly demonstrated to exist in practice,

	- will also be ineffective at achieving their stated goal.

I would like to take this opportunity to briefly outline alternative rules which would more carefully address the problem, avoiding the disadvantages listed above.


Global Reach
============

It is a sad fact that most electronic device manufacture no longer takes place in the Western Hemisphere.  Reduced labour costs and less restrictive regulations in the Far East mean that most consumer devices are designed and made there, and only reach America and Europe by export.  If faced with tight regulations for imported devices, these manufacturers have few choices:

	- Abandon the restrictive market entirely.  North America is a large market, so this would be considered undesirable for the manufacturer, not just due to reduced choice for the consumer.

	- Produce a separate, specially adapted product for the restrictive market.  For large, durable goods such as road vehicles, it is possible to make such adaptations without much impact on final prices.  However, this would unacceptably increase design and manufacturing costs for small, relatively cheap consumer electronics devices, due to disruption of the economies of scale that these manufacturers rely on.

	- Produce a single product adapted for the most restrictive market the device is sold to.  This effectively imposes these restrictive regulations globally.

It seems clear that most consumer device manufacturers will choose the latter option.  That is why I am writing this comment.


Unintended Harms
================

The proposed regulations do not clearly define the limits of what must be protected, especially considering the inevitable fact that the relevant reader - based in the Far East - speaks English only as a second language.  This will lead to a misunderstanding of the true requirements, and the following likely consequences:

	- Firmware modification will be prevented on the entire device, not just the parts which intentionally radiate RF energy.

	- Software updates will be disallowed as well, even when they are clearly necessary to fix bugs and security holes in the original, certified firmware.

	- Malicious actors (including such state-level actors as the NSA, GCHQ, Russia and China) will find and exploit holes unknown at the time of certification.  This already occurs, due to the minimal effort manufacturers currently put into producing secure, high-quality firmware, but it will become difficult or impossible to close these holes subsequently, as is presently possible by installing third-party, actively-maintained firmware such as OpenWRT.

	- Legitimate end-user modifications, including those performed by licenced amateur-radio operators (whose permitted frequencies overlap with the capabilities of many SDR devices), will be actively discouraged.  Amateur radio has often proved invaluable during crises, including natural disasters and terrorist attacks; hampering its capabilities in this way could conceivably have fatal consequences.

	- Research which requires firmware modifications will be severely hampered.  One current focus of this research is improving the robustness and latency of wired and wireless networks through advanced queuing disciplines; this requires close integration with the relevant network hardware.  For example:  http://www.bufferbloat.net/projects/codel/wiki/CakeTechnical

	- FCC-compliant devices will be unable to use the wider frequency ranges and higher powers that may be available in other jurisdictions.

	- Devices sold abroad, but brought to the US by visitors, will radiate beyond the regulated limits (eg. on channels 12-14 in the 2.4GHz band), with no way for the user to prevent it, unless those capabilities are denied even in jurisdictions in which they are permitted.

	- An entire class of innovative products may be stifled due to the increased regulatory burden.

It is worth emphasising that most recent Wi-Fi devices use SDR techniques, and thus fall under these proposed rules.  One reasonable interpretation of the rules as presently proposed would encompass an entire laptop, including its operating system and applications, as the device for which software modifications are to be prevented.  If this seems absurd - as it should - then there is clearly scope to define the rules more narrowly.


Ineffectiveness
===============

As noted above, Far East manufacturers do not have an intrinsic incentive to adopt genuine best practices with respect to software quality and security.  While regulations can impose extrinsic incentives, these serve only to enforce the appearance of security, not its effect in practice.  This inevitably leads to measures which impose at least as much inconvenience and frustration on end-users as a genuinely secure system would, but without noticeably impeding the efforts of experienced, motivated attackers.

Previous experience in this area can be seen in the Digital Rights Management sphere, where technologies such as corrupted floppy-disk sectors, DVD’s CSS encryption, SecuROM, HDMI’s HDCP et al have all been bypassed, some with greater ease than others.  Of those mentioned, HDCP is both the least intrusive - most consumers are completely unaware of its operation - and stood the test of time best, but it too was eventually cracked.  Some DRM technologies actively harmed the equipment of legitimate users, in pursuit of the extrinsic goal of copy-protection imposed by the entertainment industry, but were immediately bypassed by experienced “software pirates” - the supposed targets of the technology - who already routinely removed copy-protection software before repackaging the product for distribution.

The response of corporations to security breaches is also instructive, with regulations being necessary even to make them admit that a major consumer-privacy breach has occurred, and even then cover-ups undoubtedly still occur.  This type of regulation is more difficult to extend to the Far East, where it would be required.

Typically, consumer devices of this type are based on a standard piece of hardware which, to simplify software development, has a variety of debugging interfaces included - generally including a serial console and a JTAG debugger interface.  While the connection headers are generally omitted from the final product for cost reasons, it is easy for an engineer or hacker to fit them manually, using a soldering iron.  Instructions for doing so are widely circulated for legitimate purposes, such as porting OpenWRT to the wide range of new devices which regularly appear on the market.  It seems highly unlikely that these interfaces can be modified or disabled in a way that would not also inhibit the manufacturer’s own development practices.  Hence, even if these debug interfaces become the only reliable way to modify firmware (thus removing this option from the general consumer), they will remain available to sufficiently motivated individuals and organisations.


Absence of Harm
===============

In proposing these rules, the FCC has not clearly articulated a specific harm that they could reasonably address.  Only the “potential” for the originally licenced and certified emissions limits to be bypassed, with no evidence that this is already occurring or likely to occur in practice, and some images of interference caused to a handful of obsolete radar installations (which are already due for replacement) by devices already in the field - devices which can reasonably be assumed to be certified and compliant in any case, but whose emissions can in aggregate be detected by sensitive equipment.

Meanwhile, it is straightforward and inexpensive to construct devices which do emit harmful interference in the relevant bands, whether using SDR techniques or not.  It is arguably easier to do so than to modify an existing device’s firmware to do so, even without any technological restrictions on the latter.

There has also, surprisingly, been little or no mention of any harm caused by certified and compliant devices which have been configured for a foreign jurisdiction with more permissive regulations.  For example, 2.4GHz channels 12 and 13 are available in the EU but not in the US; channel 14 is available only in Japan.  Power limits also vary between regulatory domains.  The volume of visitors to the US from these regions, and the general ignorance among consumers of these differences, implies that a significant amount of misconfigured radio equipment already exists in the US at any given time.


Alternatives
============

I make the charitable assumption, here, that reducing the potential for accidental emissions beyond the regulated limits is a desirable goal.  Here are some rules which address this goal while also retaining the ability to modify device firmware.  This should reduce harms on both sides of the equation, as well as being more realistically practical to implement.

	- Isolate the components of the radio responsible for the frequency and intensity of emissions from the rest of the system, and provide a narrow, clearly defined interface between the two.  This reduces the attack surface, making these isolated components easier to secure.  This isolation boundary may include, at maximum, the components of a distinct module such as a PCI Express card (which is currently the industry-standard method of attaching Wi-Fi radios to a device); preferably it would encompass only a minimal portion of that hardware.

	- Store the firmware of the isolated components securely within those components, eliminating the dependence on the integrity of the larger device’s software or firmware for compliance.  The isolated components can then be certified separately from any device they may be attached to.  It should, in this case, be possible to adjust certain parameters of the emission spectrum to cater for different regulatory domains; this could be done via a regulatory-domain configuration file uploaded through the defined interface, or via a simple numerical selector between such files stored within the firmware.

	- Alternatively, integrate a cryptographic verification system within the isolated components, which ensures firmware loaded into the components is verified as authentic before use.  This would allow updates to the firmware to be distributed after sale of the device, or different firmware to be loaded for different regulatory domains, while still ensuring that only certified firmware is loaded.

	- Alternatively, publish the firmware for the isolated components in a human-readable format, so that it can be audited for compliance and modified if necessary.  It must then be straightforward to verify (through conversion of the human-readable version into device format) that the published firmware corresponds to that actually loaded into devices on sale.  This option is the most beneficial for amateur-radio operators and researchers, since they would then be able to modify the firmware to meet their needs; they would of course assume liability for any regulatory compliance problems their modifications introduce.

The above rules specifically address the problem of potential harmful emissions at the RF level.  But I would go further to reduce other harms, though these aspirations may require a separate round of rulemaking:

	- Require device firmware to be demonstrably free of known security vulnerabilities at time of sale.  This should include reference to design best-practices (such as verification of digital certificates used for secure communication, absence of fixed default passwords) in consultation with acknowledged software security experts, and reference to a database of known software vulnerabilities, such as the CVE series.  There are well-established vulnerability scanners on the market which can be used to assist this process.

	- Require device firmware to be updated, automatically and without the need for end-user attention, to fix defects (in the above category or otherwise) discovered after time of sale, for the expected lifetime of the device.  This should, at minimum, extend to the ordinary manufacturer’s warranty period of the last device of the type sold at retail, and preferably to the period of an extended warranty which might be sold for that device.  This update process must also be demonstrably designed to be secure against man-in-the-middle hijack attempts.

	- Require claims of functionality made in marketing material for the device (including but not limited to the packaging and manual) to have a verifiable basis in fact.  In particular, it must be straightforward to quantifiably demonstrate the feature’s functionality and benefits in a typical installation configuration in the laboratory, using only configuration options available to the user and (if relevant) described in the user manual.

	- Require the ability to replace the manufacturer’s software or firmware with any alternative from a third-party, given explicit and verified consent from the end-user (such as holding down a button during power-on to initiate the firmware reload).  This would not necessarily include replacing the firmware of isolated radio components as described above.  Exercising this ability would necessarily relieve the manufacturer of any liability related to problems with the firmware, unless the process is repeated to replace the third-party firmware with the original.  This would enhance the ability of third-party firmware projects (such as DD-WRT and OpenWRT for consumer devices, or Linux on laptops) to take advantage of hardware advances.

The above requirements, if enforced, would go a long way to address the worrying state of consumer device security, especially with respect to the so-called “Internet of Things”.  In any case, without them any attempt to implement the rules on SDR as presently proposed are doomed to failure.

Thank you for your attention.

	- Jonathan Morton

Re: [Bloat] [Cerowrt-devel] Save WiFi from the FCC - DEADLINE is in 3 days *September* 8

[Rich Brown]

Thanks, Jonathan and Michael for letting us know about your submissions.

I will note that we got a bit of a reprieve on the deadline - it's now 9 
Sep (tomorrow). See

https://www.fcc.gov/document/fcc-databases-unavailable-filing-deadline-extensions-early-september

So if you meant to file something, you have one day to procrastinate, 
then submit something.