[Bloat] Another comment re FTC and weather radar from /.

[David Collier-Brown]

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 at spamcop.net           |                      -- Mark Twain

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