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My contribution to the commentary: I feel that the proposal to regulate device firmware and effectively ban non-vendor firmware is both overbroad and will resu

My contribution to the commentary: I feel that the proposal to regulate device firmware and effectively ban non-vendor firmware is both overbroad and will result in significantly increased security risks faced by the general public (myself included). If the FCC chooses to go forward with this, it should also require and put in place penalties to enforce MANDATORY security updates from vendors within tightly constrained timelines, including to products which the vendors no longer sell or wish to support. I have used various third-party firmware replacements (generally OpenWRT, occasionally DD-WRT) to replace firmware on routers with known security holes, undoubtedly including some for which patches were years late if ever delivered. I have done this for myself, friends, family and customers. If the FCC mandates that I may not legally replace the firmware with secure versions unless they come from the equipment vendors without also taking steps to ensure the availability of those security fixes, then the FCC is acting to ensure that the state of network security in the United States is AND WILL REMAIN unacceptably poor.

csirac2 11y ago
They are struggling with a very simple problem. If you configure your 5GHz U-NII device to the wrong country, and turn it on, it will stomp all over licensed/restricted spectrum. That's because unlike 2.4GHz, 5GHz has been carved up very differently in different parts of the world (each place has had its own evolution of technology and spectrum pressures). To such a degree that this isn't even about power and frequency. As an FCC registrant seeking to slap FCC stickers on your new/imported devices, you'll be required to submit proof of conformance documentation which demonstrates you've properly implemented radar avoidance in your frequency hopping/spread spectrum algorithms. Finally, the FCC has made it obvious that this aimed at the transmitter module, not the overall device. And so, "banning" OpenWRT and other 3rd-party/alt firmwares would only be required if that's the only half-arsed way a manufacturer can hope to comply with the new regs. In future, I'd hope hardware becoming better isolated from radio components, this ruling (and similar around the world) are essentially mandating region-locked devices, so we might see something similar to what's happening in mobile phones (Eg. baseband radio firmware separately versioned/updated from OS firmware).

csirac2 11y ago

They are struggling with a very simple problem. If you configure your 5GHz U-NII device to the wrong country, and turn it on, it will stomp all over licensed/restricted spectrum. That's because unlike 2.4GHz, 5GHz has been carved up very differently in different parts of the world (each place has had its own evolution of technology and spectrum pressures). To such a degree that this isn't even about power and frequency. As an FCC registrant seeking to slap FCC stickers on your new/imported devices, you'll be required to submit proof of conformance documentation which demonstrates you've properly implemented radar avoidance in your frequency hopping/spread spectrum algorithms. Finally, the FCC has made it obvious that this aimed at the transmitter module, not the overall device. And so, "banning" OpenWRT and other 3rd-party/alt firmwares would only be required if that's the only half-arsed way a manufacturer can hope to comply with the new regs. In future, I'd hope hardware becoming better isolated from radio components, this ruling (and similar around the world) are essentially mandating region-locked devices, so we might see something similar to what's happening in mobile phones (Eg. baseband radio firmware separately versioned/updated from OS firmware).