FCC Proposing Bad Rule!

[K5GU]

I sent my comment to them today.

I also just now discovered a GPO document published on Sept. 1 http://www.gpo.gov/fdsys/search/searchr ... 0+FR+46900 (see number 2) that is extending the comment due date to October 9 and reply comments to November 9, 2015.

I sent Brian Butler, Policy and Rules Division, Office of Engineering and Technology Bureau, an email asking for a clarification.

[K5GU]

Got a reply from Mr. Butler at the FCC:

"If your email concerns ET Docket 15-170, Equipment Authorization and Electronic Labeling for Wireless Devices, please note that the comment period has been extended to October 9 and the reply comment period has been extended to November 9. See
https://www.federalregister.gov/article ... 015-21634/

Also note that planned system upgrades have made FCC IT systems, including the Electronic Comment Filing System, temporarily unavailable. You will be able to file electronic comments once the systems resume operation, which is scheduled for Tuesday, September 8th.

Brian Butler
Senior Engineer
Spectrum Policy Branch/Policy and Rules Division
Federal Communications Commission"

[Taypo]

Wow, the article says that this would also impact cell phones. Wonder what the heck their logic is for thinking there is a need for this rule?

The link on that page for comments doesn't seem to lead to an actual electronic comment page (http://fjallfoss.fcc.gov/ecfs2/) and instead goes to a FCC blog page.

Is the tin foil hat part of me completely off base by thinking this may be an effort to control communications? Im not a HAM guy, so I may be off base, but if they're making it harder to repurpose equipment, there must be some reason...

[Eric Lamberson]

"We further propose that an applicant for certification must specify which parties will be authorized to make software changes (e.g., the grantee, wireless service provider, other authorized parties) and the software controls that are provided to prevent unauthorized parties from enabling different modes of operation."

Bad idea but typical. Comment posted.

[TexasJohnBoy]

Comment posted. Thanks for alerting us Chas.

"This rule will stifle innovation and is an unneeded addition to an already large assortment of rules for manufacturers to follow. Requiring security measures to prevent consumers from modifying software on products that they own is an overreach of the government, and may not be something that the manufacturer even supports or wants to implement. The ability to modify a lawfully owned device should not be hindered in any way, as this is how innovation happens. A prime example of this is the ASUSWRT firmware that the manufacturer ASUS uses on their WiFi router devices (https://github.com/RMerl/asuswrt-merlin ... ut-Asuswrt) -- it was actually started as a firmware called Tomato and DD-WRT which was developed in response to Linksys routers being hacked with custom upgraded firmware in the early 2000's. Without that type of development being done by the community in the early 2000's, many of the features that people use on their home WiFi equipment today would not be available."

I have my trusty WRT54G running DD-WRT as well. It's at least 12 years old, and there's no way in hell it would still be usable today without the ability to flash custom firmware on it.

[SA_Steve]

I'm interested in the story behind the story, maybe the whole thing is related to this very popular alternative OS for Android cell phones:
http://www.cyanogenmod.org/

can't believe the FCC cares anything about hams (follow the industry money and their lobbyists desires)

[K5GU]

Brian at the FCC sent me this email Wednesday (I filed my comment last Saturday).

"I did not see your comment. Our systems are belatedly getting back to normal. Check for a few days and if you don’t see yours, but others filed with the same date, I’d suggest re-filing. No worries, there’s still time.
Brian"

If you filed before or during their IT upgrade (last weekend), you should check (see URL below) to see if your filing made it. If you don't see yours, refile it. If your comment is lengthy, put it in a .txt file on your computer using Notepad then upload it to them as an attachment (browse button on lower left of 'submit comment' screen). While on the search results page you can also view comments by clicking the "i" button. See the filings For docket 15-170: http://apps.fcc.gov/ecfs/comment_search ... sc&start=0

Update: It looks like they're missing comments submitted from Thursday 9-3 thru Tuesday 9-7.

[mcscanner]

snip...
can't believe the FCC cares anything about hams (follow the industry money and their lobbyists desires)

They (FCC) can be made to see the "RF". Takes a little motivation at times. Like grasping there right hand and scratching their left ear from behind the back. Unfortunately they seem to have a high pain threshold.

KE5MC, Mike

[K5GU]

Wow, the article says that this would also impact cell phones. Wonder what the heck their logic is for thinking there is a need for this rule?

The link on that page for comments doesn't seem to lead to an actual electronic comment page (http://fjallfoss.fcc.gov/ecfs2/) and instead goes to a FCC blog page.

Is the tin foil hat part of me completely off base by thinking this may be an effort to control communications? Im not a HAM guy, so I may be off base, but if they're making it harder to repurpose equipment, there must be some reason...

I read most of the proposed changes looking for what problem they're trying to solve and found words like, "technological advances", prevent alleged interference to weather radar", etc., none of which hold water with me.

[K5GU]

I'm interested in the story behind the story, maybe the whole thing is related to this very popular alternative OS for Android cell phones:
http://www.cyanogenmod.org/

can't believe the FCC cares anything about hams (follow the industry money and their lobbyists desires)

These large bureaucratic agencies consist of many good people, but unfortunately also many people with political agendas and pockets full of lobbyist money. The FCC branches involved here probably have no clue how the WRT is being used by hospitals, Red Cross, FEMA, public safety groups-first responders, etc., and they won't unless they hear a BIG LOUD noise from us.

Go here http://apps.fcc.gov/ecfs/comment_search ... &start=110 and read the comments by clicking on the filer's name, some of which are very educational to read.

[Charles L. Cotton]

Interesting, my comment isn't on the list.

Chas.

I realize this is hardly a hot topic with gun owners, but it is very important nonetheless.

The FCC is proposing a rule to require manufacturers of certain WiFi devices to ensure that their firmware cannot be changed. This is potentially a huge problem for altering equipment to legitimate use, especially older equipment that is no longer in service. For example, Linksys routers are being used by ham operators to create the HSMM-MESH network. It is essentially an Internet system that uses radio frequencies (RF) and is not dependent on the cable/fiber optic infrastructure. It is not merely an interesting or entertaining system; it is a critical piece of a disaster recovery communications system. Many hams are setting up these systems to link hospitals with other emergency responders to use as back-ups in case of mass communication and/or Internet failure. Let's face it, it would also be nice to have an alternative to the Internet if those in power decide to destroy it by regulation.

Comments close on Sept. 8, so please consider posting a comment against the proposed rule. Here is an article on the issue. CLICK HERE to post a comment.

Please take the time to comment. You may not be a ham, but you or your loved ones may one day need this valuable back-up communication system. (The rule could possibly stymie development of apps for cell phones and other devices, per the article, but I have no knowledge in this area.)

Thanks,
Chas.

[bmwrdr]

Remember the "broadband-over-power lines" controversies a few year back? It turned out that the FCC wizards promoting that had no clue what evaluation, studies and testing needed to be done. I think it eventually died.

Re this proposal on RF devices, changes, etc. - BOHICA (bend over here it comes again). Here's a direct link to the federal register document paragraph showing how and who to contact.

https://www.federalregister.gov/article ... evices#p-4

It's rather lengthy but has a pretty good TOC. If you scroll up to the Table of Contents, under Procedural Matters there's a link to the "A. Need for, and Objectives of, the Proposed Rules" section. I didn't see any citations related to complaints or problems which generated these proposed rule changes.

Broadband ove power lines is actually a standard and works well if applied correctly. In some countries it is used to bridge the last mile to the end customer using the electricity network already in place instead of pulling new cables.

[K5GU]

Remember the "broadband-over-power lines" controversies a few year back? It turned out that the FCC wizards promoting that had no clue what evaluation, studies and testing needed to be done. I think it eventually died.

Re this proposal on RF devices, changes, etc. - BOHICA (bend over here it comes again). Here's a direct link to the federal register document paragraph showing how and who to contact.

https://www.federalregister.gov/article ... evices#p-4

It's rather lengthy but has a pretty good TOC. If you scroll up to the Table of Contents, under Procedural Matters there's a link to the "A. Need for, and Objectives of, the Proposed Rules" section. I didn't see any citations related to complaints or problems which generated these proposed rule changes.

Broadband ove power lines is actually a standard and works well if applied correctly. In some countries it is used to bridge the last mile to the end customer using the electricity network already in place instead of pulling new cables.

Yes, BPL is beneficial to some areas, ie. rural/remote areas that may not have the population base needed to be economically feasible to run cable. The basic complaint from ham radio operators here in the early days of implementation were related to RF interference radiated at the junction where the signal was transferred to the power lines. Soon after those tests, which were done by hams working with certified engineers, the FCC was contacted by the companies providing the BPL service and they were notified that proper filtering (not in the specs) was needed, and requested more testing, extensions to implementation, etc. During that waiting period, some of the major providers in the DFW area made the decision to not implement at all, much to the relief of public safety agencies, first responders, police depts, hams etc. because they were the one's that would be effected.
For reference: http://www.dslreports.com/shownews/Broa ... bles-94078

[K5GU]

Interesting, my comment isn't on the list.

Chas.

I realize this is hardly a hot topic with gun owners, but it is very important nonetheless.

The FCC is proposing a rule to require manufacturers of certain WiFi devices to ensure that their firmware cannot be changed. This is potentially a huge problem for altering equipment to legitimate use, especially older equipment that is no longer in service. For example, Linksys routers are being used by ham operators to create the HSMM-MESH network. It is essentially an Internet system that uses radio frequencies (RF) and is not dependent on the cable/fiber optic infrastructure. It is not merely an interesting or entertaining system; it is a critical piece of a disaster recovery communications system. Many hams are setting up these systems to link hospitals with other emergency responders to use as back-ups in case of mass communication and/or Internet failure. Let's face it, it would also be nice to have an alternative to the Internet if those in power decide to destroy it by regulation.

Comments close on Sept. 8, so please consider posting a comment against the proposed rule. Here is an article on the issue. CLICK HERE to post a comment.

Please take the time to comment. You may not be a ham, but you or your loved ones may one day need this valuable back-up communication system. (The rule could possibly stymie development of apps for cell phones and other devices, per the article, but I have no knowledge in this area.)

Thanks,
Chas.

Charles, do you remember what day you submitted the comment?

[Charles L. Cotton]

9/4/15.

Chas.

Interesting, my comment isn't on the list.

Chas.

I realize this is hardly a hot topic with gun owners, but it is very important nonetheless.

The FCC is proposing a rule to require manufacturers of certain WiFi devices to ensure that their firmware cannot be changed. This is potentially a huge problem for altering equipment to legitimate use, especially older equipment that is no longer in service. For example, Linksys routers are being used by ham operators to create the HSMM-MESH network. It is essentially an Internet system that uses radio frequencies (RF) and is not dependent on the cable/fiber optic infrastructure. It is not merely an interesting or entertaining system; it is a critical piece of a disaster recovery communications system. Many hams are setting up these systems to link hospitals with other emergency responders to use as back-ups in case of mass communication and/or Internet failure. Let's face it, it would also be nice to have an alternative to the Internet if those in power decide to destroy it by regulation.

Comments close on Sept. 8, so please consider posting a comment against the proposed rule. Here is an article on the issue. CLICK HERE to post a comment.

Please take the time to comment. You may not be a ham, but you or your loved ones may one day need this valuable back-up communication system. (The rule could possibly stymie development of apps for cell phones and other devices, per the article, but I have no knowledge in this area.)

Thanks,
Chas.

Charles, do you remember what day you submitted the comment?