<html><head></head><body>Sounds great to me<br clear="none"><br clear="none"><div class="gmail_quote">On Sep 25, 2015, Dave Taht <<a shape="rect" href="http://dave.taht">dave.taht</a>@gmail.com> wrote:<blockquote class="gmail_quote" style="margin: 0pt 0pt 0pt 0.8ex; border-left: 1px solid rgb(204, 204, 204); padding-left: 1ex;">
<pre class="k10mail">The core of the FCC letter is currently this. comments?<br clear="none"><br clear="none">snip snip<br clear="none"><br clear="none">In place of last year’s and the new proposed regulations, we propose a<br clear="none">system of rules that would foster innovation, improve security, make<br clear="none">Wi-Fi better, and overall improve usage of the Wi-Fi spectrum for<br clear="none">everybody.<br clear="none"><br clear="none">1) Mandate that: for a SDR, wireless, or Wi-Fi radio of any sort - in<br clear="none">order to achieve FCC compliance - full and maintained source code for<br clear="none">at least the device driver and radio firmware be made publicly<br clear="none">available in a source code repository on the internet, available for<br clear="none">review and improvement by all.<br clear="none"><br clear="none">2) Mandate that: the vendor supply a continuous update stream, one<br clear="none">that must respond to regulatory transgressions and CVEs within 45 days<br clear="none">of disclosure, for the warranted lifetime of the product + 5 years<br clear="none">after last customer ship.<br clear="none"><br clear="none">3) Mandate that: secure update of firmware be working at shipment, and<br clear="none">that update streams be under ultimate control of the owner of the<br clear="none">equipment. Problems with compliance can then be fixed going forward.<br clear="none"><br clear="none">4) Failure to comply with these regulations will result in FCC<br clear="none">decertification of the existing product and in severe cases, bar new<br clear="none">products from that vendor from being considered for certification.<br clear="none"><br clear="none">5) In addition, we ask that the FCC review and rescind the rules for<br clear="none">anything that conflicts with open source best practices, and/or which<br clear="none">causes the vendors to believe they should hide the mechanisms they use<br clear="none">by shipping undocumented “binary blobs” of compiled code. This had<br clear="none">been an ongoing problem to all in the internet community trying to do<br clear="none">change control and error correction on safety-critical systems.<br clear="none"><br clear="none"><br clear="none">On Fri, Sep 25, 2015 at 9:16 PM, David P. Reed <dpreed@reed.com> wrote:<br clear="none"></pre><blockquote class="gmail_quote" style="margin: 0pt 0pt 1ex 0.8ex; border-left: 1px solid #729fcf; padding-left: 1ex;">Those of us who innovate at the waveform and MAC layer would argue<br clear="none">differently. The cellular operators are actually the responsible control<br clear="none">operators and hold licenses for that. They may want to lock down phones'<br clear="none">cellular transmitters. But U-NII and ism bands are not licensed to these<br clear="none">operators. There is no license requirement for those bands to use particular<br clear="none">waveforms or MAC layers.<br clear="none"><br clear="none">So this is massive overreach. The control operator of the "licensed by rule"<br clear="none">Part 15 radios in your phone or home are licensed to the device user and not<br clear="none">to the mfr at all. For example, the user is responsible that the device not<br clear="none">interfere with licensed services, and that the device stop transmitting if<br clear="none">such harmful interference is called to their attention, *even* if the device<br clear="none">passed certification.<br clear="none"><br clear="none">Lock down has not been demonstrated to be necessary. This is all due to<br clear="none">fearful what - if speculation by people who have no data to justify the<br clear="none">need, plus attempt to stop innovation by licensees who want to exclude<br clear="none">competitors from being created, like LTE operators proposing LTE-U which<br clear="none">will be locked down and is the stalking horse for taking back open part 15<br clear="none">operation into a licensed regime based on property rights to spectrum.<br clear="none"><br clear="none"><br clear="none">On Sep 24, 2015, Dave Taht <<a shape="rect" href="http://dave.taht">dave.taht</a>@gmail.com> wrote:<br clear="none"><br clear="none"><blockquote class="gmail_quote" style="margin: 0pt 0pt 1ex 0.8ex; border-left: 1px solid #ad7fa8; padding-left: 1ex;">a commenter that I will keep anonymous wrote:<br clear="none"><br clear="none"><br clear="none">Regarding the FCC firmware lockdown issue, I’m sure you’re aware that<br clear="none">baseband firmware in cellphones has been subject to similar<br clear="none">restrictions for some time. In fact, the FCC effectively mandates that<br clear="none">baseband functionality is implemented on a whole separate subsystem<br clear="none">with its own CPU to make it easier to isolate and protect. Also, the<br clear="none">cellphone system is designed so that a misbehaving node can be easily<br clear="none">identified and blocked from the network, making it useless and<br clear="none">removing most of the incentive to find ways around regulatory<br clear="none">restrictions. Wi-Fi devices have none of these protections.<br clear="none"><br clear="none">I believe this new attention to Wi-Fi devices is a consequence of many<br clear="none">factors:<br clear="none"><br clear="none">The precedent from cellphone baseband firmware control; regulators are<br clear="none">easily inspired by success stories in related areas<br clear="none">The substantial increase in flexibility offered by SDR implementations<br clear="none">Technical ignorance, for example of the difference between OS,<br clear="none">protocol, and UI firmware and baseband firmware<br clear="none">The expansion of allowed capabilities in Wi-Fi hardware (from 5.8 GHz<br clear="none">ISM to the U-NII bands, increases in transmit power allowances, etc.)<br clear="none">The improved spectrum utilization of newer Wi-Fi modulation schemes<br clear="none">Inconsistencies among international regulations for spectrum allocation<br clear="none">Spectrum sharing between Wi-Fi and life safety applications<br clear="none">The relative lack of attention to (and sometimes, the deliberate<br clear="none">flouting of) regulatory constraints in open-source firmware<br clear="none">The increased availability of open-source firmware for higher-power<br clear="none">and narrow-beam Wi-Fi devices (not just the WRT-54G :-)<br clear="none"><br clear="none"><br clear="none">And probably more I can’t think of off the top of my head, but which<br clear="none">regulators are obsessing over every day.<br clear="none"><br clear="none">Although I agree with the spirit of your FCC email draft letter, it<br clear="none">does not address most of these factors, so it’s likely to be seen as<br clear="none">missing the point by regulators. If you want to reach these people,<br clear="none">you have to talk about the things they’re thinking about.<br clear="none"><br clear="none">What you ought to be pushing for instead is that Wi-Fi devices be<br clear="none">partitioned the same way cellphones are, defining a baseband section<br clear="none">that can be locked down so that the device can’t operate in ways that<br clear="none">are prohibited by the relevant local regulations, so that the OS,<br clear="none">protocol, and UI code on the device can be relatively more open for<br clear="none">the kinds of optimizations and improvements we all want to see.<br clear="none"><br clear="none">It’s possible that the partition could be in software alone, or in<br clear="none">some combination of hardware and software, that doesn’t require a<br clear="none">cellphone-style independent baseband processor, which would add a lot<br clear="none">of cost to Wi-Fi devices. For example, the device vendor could put<br clear="none">baseband-related firmware into a trusted and _truly minimal_ binary<br clear="none">module that the OS has to go through to select the desired frequency,<br clear="none">power, and modulation scheme, even for open-source solutions. That<br clear="none">doesn’t mean the source code for the binary module can’t be published,<br clear="none">or even that there can’t be a mandate to publish it.<br clear="none"><br clear="none">I’m sure that doesn’t sound like a great solution to you, but making<br clear="none">it easy for end users to configure commercial devices to transmit at<br clear="none">maximum power on unauthorized frequencies using very dense modulation<br clear="none">schemes doesn’t sound like a great solution to regulators, and the<br clear="none">difference between you and the regulators is that they are more<br clear="none">determined and, frankly, better armed. It will do you no good to<br clear="none">constrain the range of the solutions you’ll accept so that it doesn’t<br clear="none">overlap with the solutions they will accept.<br clear="none"><br clear="none">. png<br clear="none"><br clear="none"><br clear="none">On Sep 21, 2015, at 5:10 AM, Dave Taht <dmt@millcomputing.com> wrote:<br clear="none"><br clear="none"><br clear="none">Dave,<br clear="none"><br clear="none"><br clear="none">Huh. I have been interested in mesh networking for a couple of years<br clear="none">now, and curious about Battlemesh, but I had no idea I knew someone<br clear="none">who was active in it.<br clear="none"><br clear="none"><br clear="none">Are there any other reports online from this year or last year? The<br clear="none">website doesn't seem to serve any purpose beyond announcing the event.<br clear="none"><br clear="none"><br clear="none"><br clear="none">As you can tell I am way, way behind on my email. I've mostly been<br clear="none">chasihg funding for my main project, make-wifi-fast for over a year<br clear="none">now - I added in the mill and the "cake switch chip" to that overall<br clear="none">list as I tried to climb the financial ladders. My funding at google<br clear="none">dried up suddenly (due to the re-org), and I was forced to chase other<br clear="none">avenues. I think i got a grant from comcast coming in, but it is for<br clear="none">1/10th the total I needed for make-wifi-fast... and it is hung up in<br clear="none">legal, and in the fact the work has to mostly happen in europe.<br clear="none"><br clear="none">So I've moved to europe, trying to find bases in bristol, england,<br clear="none">berlin, and sweden. That's taken a while (I dropped out of the mill<br clear="none">process in may or so due to the sudden google silences, and the lack<br clear="none">of compiler - and I view mill's biggest problem is funding, so it<br clear="none">seems like just combining my own quest with yours the right thing)<br clear="none"><br clear="none">I was very involved in the early days of wireless networking but<br clear="none">dropped out by 2002 or so, much to my now, later regret. The only devs<br clear="none">left that understand it at more than one level all go to battlemesh,<br clear="none">so I've been there twice. I still find it quite discouraging how few<br clear="none">grok the minstrel algorithm, or what is wrong with packet aggregation.<br clear="none">A billion+ users that all think wifi "just works", and "always<br clear="none">sucked"... :( I gave a talk on the latter as well at at this<br clear="none">battlemesh.<br clear="none"><br clear="none">anyway the videos and results from this battlemesh are all now online.<br clear="none">I am pushing on all fronts, but being a manager was a bit wearying so<br clear="none">I took time out to do some recording at a place called <a shape="rect" href="http://theconvent.net">theconvent.net</a><br clear="none">for the past 2 weeks. Haven't played the piano so much in 5 years!<br clear="none"><br clear="none">Youtube videos:<br clear="none"><br clear="none"><a shape="rect" href="https://www.youtube.com/channel/UCxfh-2aOR5hZUjxJLQ2CIHw">https://www.youtube.com/channel/UCxfh-2aOR5hZUjxJLQ2CIHw</a><br clear="none"><br clear="none">blog post:<br clear="none"><a shape="rect" href="https://wlan-si.net/en/blog/2015/09/08/battlemesh-v8-and-its-many-stories">https://wlan-si.net/en/blog/2015/09/08/battlemesh-v8-and-its-many-stories</a>/<br clear="none"><br clear="none">The test results were dismal, as expected. Finally knocking a few<br clear="none">heads to use abusive network tests like what toke and I developed were<br clear="none">hopefully an eye-opener, and a lot more people grok what<br clear="none">make-wifi-fast is really about, and how to do it.<br clear="none"><br clear="none"><a shape="rect" href="http://docs.battlemesh.org">http://docs.battlemesh.org</a>/<br clear="none"><br clear="none">one very positive outcome of the fcc talk was a level of net outrage<br clear="none">and organisation over some new fcc rules I have not seen before. My<br clear="none">letter to the fcc, in progress, with vint cerf and other<br clear="none">co-signers is up for review at:<br clear="none"><br clear="none"><br clear="none"><a shape="rect" href="https://docs.google.com/document/d/1VTOHEpRXSvhWvQ0leM-sROJ_XC7Fk1WjFXq57ysFtAA/edit?usp=sharing">https://docs.google.com/document/d/1VTOHEpRXSvhWvQ0leM-sROJ_XC7Fk1WjFXq57ysFtAA/edit?usp=sharing</a><br clear="none"><br clear="none">A similar letter has to go to the eu, as they just passed similar rules.<br clear="none"><br clear="none">as much as I would like to be working on the mill, it seems politics,<br clear="none">finance, and organisation are in more need of my attentions right now.<br clear="none">but I will keep plugging y'all at every opportunity.<br clear="none"><br clear="none">But, but... as I said, I just took a few weeks off and am picking up<br clear="none">the pieces and trying to figure out what to focus on, at the moment.<br clear="none"><br clear="none">If you wish a faster response to my email, please use <a shape="rect" href="http://dave.taht">dave.taht</a>@gmail.com</blockquote><br clear="none"><br clear="none"><br clear="none"><br clear="none">-- Sent with K-@ Mail - the evolution of emailing.</blockquote><br clear="none"><br clear="none"></blockquote></div><br clear="none">-- Sent with <b><a shape="rect" href="https://play.google.com/store/apps/details?id=com.onegravity.k10.pro2">K-@ Mail</a></b> - the evolution of emailing.</body></html>