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[72.71.228.130]) by smtp.gmail.com with ESMTPSA id q140sm4707414qha.5.2015.10.02.07.22.38 (version=TLSv1 cipher=ECDHE-RSA-RC4-SHA bits=128/128); Fri, 02 Oct 2015 07:22:39 -0700 (PDT) Content-Type: text/plain; charset=us-ascii Mime-Version: 1.0 (Mac OS X Mail 8.2 \(2104\)) From: Rich Brown In-Reply-To: Date: Fri, 2 Oct 2015 10:22:37 -0400 Content-Transfer-Encoding: quoted-printable Message-Id: References: <49d53a3e-b7a0-4069-a87b-d9778bb8a229@reed.com> <16684.1443643019@turing-police.cc.vt.edu> <21167.1443646296@turing-police.cc.vt.edu> To: Dave Taht X-Mailer: Apple Mail (2.2104) Cc: esr@icei.org, "cerowrt-devel@lists.bufferbloat.net" , david.collier.brown@worldgaming.com, make-wifi-fast@lists.bufferbloat.net, mellon@fugue.com, fcc@lists.prplfoundation.org, Christopher Waid Subject: [Cerowrt-devel] Editorial questions for response to the FCC X-BeenThere: cerowrt-devel@lists.bufferbloat.net X-Mailman-Version: 2.1.13 Precedence: list List-Id: Development issues regarding the cerowrt test router project List-Unsubscribe: , List-Archive: List-Post: List-Help: List-Subscribe: , X-List-Received-Date: Fri, 02 Oct 2015 14:23:05 -0000 Folks, I have screwed up my nerve to take an editorial pass over the document. = It has a lot of good information and many useful citations, but it needs = focus to be effective. As I read through (yesterday's) draft of the document and the comments, = I came up with observations to confirm and questions that I want to = understand before charging ahead. Observations: 1) Unfortunately, we are coming to this very late: if I understand the = timeline, the FCC proposed these rules a year ago, the comment period = for the NPRM closed 2 months ago, and we only got an extra month's = extension of the deadline because their computer was going to be down on = the original filing date. (Note - that doesn't challenge any of our = points' validity, only that we need to be very specific in what we = say/ask for.) 2) The FCC will view all this through the lens of "Licensed use has = priority for spectrum over unlicensed." That's just the rules. Any = effort to say they should change their fundamental process will cause = our comments to be disregarded. 3) The *operator* (e.g., homeowner) is responsible for the proper = operation of a radio. If the FCC discovers your home router is operating = outside its allowed parameters *you* must (immediately?) remediate it or = take it off the air. 4) We must clearly and vigorously address the FCC admonishment to = "prevent installing DD-WRT" 5) [Opinion] I share dpreed's concern that the current draft overplays = our hand, requesting more control/change than the FCC would be willing = to allow. See Question 7 below for a possible alternative. Questions: 1) What is our request? What actions would we like the FCC to take? 2) How much of a deviation from their current rules (the ones we're = commenting on) are we asking them to embrace? 3) How much dust could/should we kick up? For example, is it useful to = point out that these FCC rules do not address other practices that are = possible today:=20 - Use of high gain antennas (which would certainly introduce a = stronger signal than the design parameters);=20 - Use of other (non-commercially produced) SDR transmitters; - Malicious attack that takes control of insecure vendor = software to alter the RF parameters=20 - Router manufacturers in most cases are already *contractually = obliged* to release full source code for their routers (GPL). In the = past, many have been resistant to doing so, especially for the RF = drivers. Do any concerns of the FCC change if there were to be a full = source code release? 4) Footnotes 15, 16, and 17 cite published reports of router vendors = using activation codes or new firmware lockdowns where previously not = present. Do any readers have personal/verified knowledge of these = activities? 5) Vendors certify release X of their firmware in tests with the FCC. It = includes the entire binary, including radio control parameters, OS = version, web GUI, etc. Do we know anything about whether vendor's X+1 = release goes through the same FCC certification process? Or do they just = fix a couple bugs and re-release knowing that they haven't touched the = RF driver... 6) Vendors are generally do not release source code for the wireless = drivers. How likely is it that this reluctance is due to a concern that = the vendor could get in trouble with the FCC if people modified that = code? 7) Would it be feasible to ask the FCC to require that vendors *publish* = the critical parameters/source code for operating in spec, so that = responsible software developers can carefully observe those parameters? = (We already have code that handles the RF specs for various countries. = Could we envision doing the same for each router/model/version radio = parameters?) I'm going to collect your comments for ~24 hours, then start editing. My = goal is to have a draft by Monday morning, 5 Oct to refine for the 9 Oct = deadline. Thanks! Rich=