From mboxrd@z Thu Jan 1 00:00:00 1970 Return-Path: Received: from nm23-vm4.access.bullet.mail.gq1.yahoo.com (nm23-vm4.access.bullet.mail.gq1.yahoo.com [216.39.63.111]) (using TLSv1 with cipher RC4-SHA (128/128 bits)) (Client did not present a certificate) by huchra.bufferbloat.net (Postfix) with ESMTPS id 51AE121FA71 for ; Thu, 8 Oct 2015 15:26:25 -0700 (PDT) DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; d=rogers.com; s=s2048; t=1444343185; bh=GQWAFnpk5CkysVnMOJ+uxxhXpKmQ2t6keDYvwfqaM4U=; h=Reply-To:Subject:References:To:From:Date:In-Reply-To:From:Subject; b=SP6eMXHJFbspy7zF1ykPRmgjLROmXvtURmeB+c+/oiAOZqRYn+7nirVsDT/jdgdeIAqngC87l3mqE9xf2efL72bwDdBH80fTK89Y+ADbmVVZxZH+K2W62/NZliBXWSAZ2w3uqREzEovdt9mO6hRz0UljYsEgbDj1POxtr3QM7OxVFAS2FlSHe7oVsNstubjHONz58exwmB/c/8z5Ho9niE6jzHX6P1UFurzj+7vTzyeq+I5D1JkOT3AS1+Su530ZxnlR/aNTJR89kdmn4u+OaxRgL/j0eJrLj0oI0rECCeBin96gcQajw9pH1ZEacW0wNGhVZePxLYTqq14EMxcfNQ== Received: from [216.39.60.172] by nm23.access.bullet.mail.gq1.yahoo.com with NNFMP; 08 Oct 2015 22:26:25 -0000 Received: from [98.138.226.241] by tm8.access.bullet.mail.gq1.yahoo.com with NNFMP; 08 Oct 2015 22:26:25 -0000 Received: from [127.0.0.1] by smtp112.sbc.mail.ne1.yahoo.com with NNFMP; 08 Oct 2015 22:26:25 -0000 X-Yahoo-Newman-Id: 21376.56544.bm@smtp112.sbc.mail.ne1.yahoo.com X-Yahoo-Newman-Property: ymail-3 X-YMail-OSG: AoA71DcVM1kh8JzKOSWMhvsxiq54IJR2gAAoAd3cTVz0OXK NIrqaRKQalCRxsKg8mD3pibJISYfCrW6nLYd.pQwBPTsbSGqQixt8WyZSiJo JMFZ1H2iAHmeDk2zlpEaw0tvW7y97LQ3tgIcQXumJAlG04hUPoBUmxSiddMX C8oKRC8VrQsumsKYLVr9HB21UxCWdRM0C_gXYH1asNQKW6sxLwCWDqYOu4d3 io0Yv6y5Y7hXsT_zc7SlohP8o.PwWplovi5tQ27k6wkVnkNRogzvzfsI8jH3 WHOapT6.WSZo_DHSRus9Y8lsPBKjmed7eb.4ZseLwxBFZVkq0XkYT4oKZ5mA M8zLdSo_gsH8XySYiYNjTVdz7hXgRI17IMGKRED7NC2QXY_5Sjr_E09Lunxa bHLHfEo.wNALqTEdSdUACyUwIO.CHpUCP62CPOAnT0VHv4ZCVToQonvDJ1ki YxyGQdRxHzQ2jT_VU7QHdK85TolWDtI2ULBCzkNLRFV1vuX4V4uk.Bonvnry o_4_.LZyQgqF7eeI0qdyIgEelS1K684dTf_798.zU8AbX6is- X-Yahoo-SMTP: sltvjZWswBCRD.ElTuB1l9j6s9wRYPpuyTNWOE5oEg-- References: <5616CE0D.1060309@rogers.com> <5616D005.9080404@rogers.com> To: bloat@lists.bufferbloat.net From: David Collier-Brown Message-ID: <5616ED8F.4090506@rogers.com> Date: Thu, 8 Oct 2015 18:26:23 -0400 User-Agent: Mozilla/5.0 (X11; Linux x86_64; rv:38.0) Gecko/20100101 Thunderbird/38.1.0 MIME-Version: 1.0 In-Reply-To: <5616D005.9080404@rogers.com> Content-Type: multipart/alternative; boundary="------------060904080409030401080601" Subject: Re: [Bloat] Another comment re FTC and weather radar from /. X-BeenThere: bloat@lists.bufferbloat.net X-Mailman-Version: 2.1.13 Precedence: list Reply-To: davecb@spamcop.net List-Id: General list for discussing Bufferbloat List-Unsubscribe: , List-Archive: List-Post: List-Help: List-Subscribe: , X-List-Received-Date: Thu, 08 Oct 2015 22:26:48 -0000 This is a multi-part message in MIME format. --------------060904080409030401080601 Content-Type: text/plain; charset=windows-1252; format=flowed Content-Transfer-Encoding: 8bit Here's a draft, below. Also at https://docs.google.com/document/d/1-HSewmPustGmV00E8u7KZ_8srNhKX_jMSSZxGcyuTaI/edit?usp=sharing On 08/10/15 04:20 PM, David Collier-Brown wrote: > 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) Summary 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. Introduction 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. Vendor Error 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. Compliance Requirements 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 --------------060904080409030401080601 Content-Type: text/html; charset=windows-1252 Content-Transfer-Encoding: 8bit
Here's a draft, below.

Also at https://docs.google.com/document/d/1-HSewmPustGmV00E8u7KZ_8srNhKX_jMSSZxGcyuTaI/edit?usp=sharing

On 08/10/15 04:20 PM, David Collier-Brown wrote:
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 )


Summary

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.


Introduction

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.

Vendor Error

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.

Compliance Requirements

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
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