Anyone who's an American citizen want to write a short to-the-point response suggesting that this was vendor error, caused by not using the database that linux uses for wi-fi cards?
I want them to have a public "out" from the current scheme of telling the vendors to protect their code.
I prefer to give the FCC the option of telling the vendors to stop messing up their code, like a regulatory agency would like to be seen doing (;-))
About one page!
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
In the Matter of )
)
Amendment of Part 0, 1, 2, 15 and 18 of the ) ET Docket No. 15-170
Commission’s Rules regarding Authorization )
Of Radio frequency Equipment )
)
Request for the Allowance of Optional ) RM-11673
Electronic Labelling for Wireless Devices )
There is a significant likelihood that the problem addressed by this rulemaking may have been caused by a wi-fi vendor failing to realize that they needed to set the location to the United States when adapting laptop and personal-computer software to work on a smaller, less capable single-board computer for use as a home router.
If so, and in any case, the FCC should require the vendor to certify that they have set their system to the correct table of standards-conformance parameters for operation in the United States, require a basic test of that operation, and penalize vendors who have not taken those basic measures.
The academic, open source and IETF communities have been concerned about the above rulemaking, especially
in light of the absence of an example of a failure to comply, and
with the mention of a specific open source Linux router, DD-WRT
In a wide-ranging discussion, one plausible cause of error was raised, that of complaints from airports and other entities whose radar is being interfered with by 5GHz WiFi.
Numerous possible cases have been raised, and one of the technical features of Linux- and BSD-based routers has a high probability of causing just such a problem. While it may or may not be the current problem, it is likely enough that the FCC would be well-advised to nip it in the bud.
The technical problem is that the software used for small home routers was developed for use on personal computers and laptops, to operate wi-fi cards plugged into a fairly powerful machine. The software assumes that the machine has been told what country or legal regime and time zone it is in, and uses that to select a set of compliant parameters the correct ones for wi-fi operation in a given country.
The home routers, on the other hand, are very low-cost devices, and there is no reason for the owner to set a country or timezone, and in most cases, there is no means by which these can be set. Whatever the default is in the country of manufacture, that is the value that is most likely to be set.
If the country is not the United States, the compliance rules are sure to be wrong.
The same applies to any replacement software loaded onto the machine. If the DD-WRT software were from Canada, for example, the compliance parameters will be those of Canada, and therefor will probably break the compliance rules of the United States.
We therefore urge the FCC to make it a requirement that the vendor of any routers sold in the United States certify in writing that they have selected the correct compliance rules, if the system supports more than a single American rule-set.
We further recommend that the FCC ensure the vendor has done so, by carrying out a test that the router software cannot detect, and thereby ensure that the certification has not been obtained improperly, as has recently occurred with diesel Volkswagons.
This same test can be used in the field to detect and identify routes which are causing problems, and allow the FCC to take action against their owners.
This is, of course, in addition to the existing measure the FCC takes to ensure compliance by the vendors and the purchasers and operators of such equipment.
-- David Collier-Brown, | Always do right. This will gratify System Programmer and Author | some people and astonish the rest davecb@spamcop.net | -- Mark Twain