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FCC rules change will lock out your software on new equipment

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w6mrr
FCC rules change will lock out your software on new equipment
I haven't seen anything here so I thought you would be interested as you may feel the largest impact from this.
 
 

http://www.infoq.com/news/2015/07/FCC-Blocks-Open-Source

 
I have contacted Brennan Price, CTO at ARRL and haven't heard anything back.
 
73 Martin W6MRR
K5DLQ
K5DLQ's picture
Many of us have also

Many of us have also contacted the league.  They are aware of our legal use and are investigating.

w6mrr
As this is Part 15 it may be

As this is Part 15 it may be outside the purview of the ARRL. 

FCC comments are pretty thin so far: http://apps.fcc.gov/ecfs/proceeding/view?name=15-170

The FCC welcomes comments - please chime in.

 

kb9mwr
I wonder what prompted this? 

I wonder what prompted this?  I know back in 2011 the FCC tightened rules for manufactures on compliance for a specific country.  This was in response to a few WISPs that had been operating outside of Part 15 frequencies and running beyond the power limits imposed by Part 15 in addition to disabling radar detection in use near an airport on 5 GHz.  As a result the "Compliance Test" and other Country Code selection functions were longer available in Ubiquiti's AirOS unless you can get you hands on the older models or the worldwide/export models.  Then with release 5.5.8 of AirOS (January 23, 2014), the compliance test mode (commonly used by hams to access ham only channels) was removed from the airMAX product line regardless of whether or not you have the export/worldwide hardware versions.

I am not sure what the solution is, but I am not clear what the problem is either.  I know the FCC really doesn't get out much and do much field investigation/enforcement but people have been able to load modified firmware with extra channels etc for the past 15 years.  Moving forward more and more software defined radio peripherals will be in use (Hack RF etc).  So I am sure this is something on their minds.  Forcing a locking down in essence a software defined radio hardly seems the way to move forward.  It makes it hard on the manufactures to sell wide/wordwide market and makes life a pain for 3rd party development.

The FCC really gets with the picture and issues more than just a paper electronic license (think true digital certificate)  that one could use to signify to some sort of regulatory hardware abstraction layer that yes this user has permission to operate this device here at this power etc.

 

AE6XE
AE6XE's picture
"Whether that impact is

"Whether that impact is meaningful in the long term will likely come down to how the (mostly Chinese and Korean) OEMs choose to respond, and whether there is regulatory contagion from the US into its trading partners."

See:  http://www.infoq.com/news/2015/07/FCC-Blocks-Open-Source

Does this mean we might be doing the ebay 3 week delivery option from China or will there be an enterprising individual in Tijuana and we can walk across the boarder to the WISP outlet?    It's Friday... :) .

Joe AE6XE

kb9mwr
You'd think the FCC would

You'd think the FCC would worry about bigger things like:

http://www.amazon.com/EDUP-Wireless-Broadband-Booster-Amplifier/dp/B00JV...

AE6XE
AE6XE's picture
I had purchased a couple of

I had purchased a couple of these devices back in the linksys days.  I'd be happy to sell one for a hefty discount.  But, full disclosure, which won't help my case... The specs say "Input Power: 3dbM (min) ~ 20dBm (max)".    the Transmit gain is "17dBm nominal"   so 20dBm (max) + 17dBm nominal = 37dBm which is not the advertised 8W.   Also, upon further inspection the specs state "Optimal Input Power 9 ~ 13dBm".  Somewhere in the manufacture literature I had read that an input above 13dBm yields a distorted output--but can't find that now.    I had come to the conclusion these could only be run at 13dBm input + 17dBm gain = 30dBm.    I had also added a 2.4Ghz ch 1 band pass filter which introduced a -3dBm loss or 27dBm device when it was all said and done...  

+1 on why the FCC doesn't do something to drive this stuff off the market.  

 

KI6FJA
Why now

I don't get it. They should be more concerned with the unlicensed purchasing/modification of GMRS/FRS equipment.  Those devices carry a double certification, why shouldn't these?   You should only get to use FRS frequencies at low power until you prove you have a license..

KI6FJA
It is not Cryogenmod

The FCC doesn't know what they are talking about when they talk about stopping Cryogenmods. Cyrogen compiled modified open source software so that others can easily install the app on their computer. They would have to stop open source and app development.

kb9mwr
It reminds me of a talk I

It reminds me of a talk I watched some time back by Cory Doctorow: "The Coming Civil War over General-purpose Computing":
https://www.youtube.com/watch?v=HUEvRyemKSg

Unless we are missing something; it's more apparent than ever that the FCC no-longer has an technical folks, just lawyer types these days :-(

KI6FJA
Latest OPENWRT

Well it looks like OpenWRT was ready for this.  The latest version can be installed as to not change the existing firmware but update the menu system of the router and add a new menu options.  It also supports compressed builds and save files (like Puppy Linux) that can reside on any file system to take as little of space on the the flash RAM or utilize a USB port or SD card.  It also supports FreeBSD jails and hardened builds if the FCC wants to take it to another avenue.  Going this direction in the future it could move off of the router until the router is turned on. 

KG6JEI
I believe you may be

I believe you may be misunderstanding some of the release notes,  "Harded builds" refers to protecting programs from exploiting the hardware "Stack Smashing" and "Buffer Overflow Protection", more about making the operating system less likely to be remotely exploited, but nothing to do with preventing users from modifying the hardware.

Compressed builds have existed for years (we install compressed already), Off device storage is of no use when the device needs to be self contained,

Jails won't solve the issues discussed in this thread either (Jails only restrict a program to operate in an isolated environment inside of software, and requires duplicating all resources/files you need) 

Regarding installing and updating menus: I haven't seen that one, I suspect you mean it updates the LUCI menu's of OpenWRT.  Installing OpenWRT on another device would be somewhat possibly IF it was virtualized, but that means no access to the underlying hardware, which again means no ability to do most of what we do today.  This also ignores the hard drive space loss, CPU performance and memory access loss of running a virtual sub environment (MicroTik does this for letting 3rd parties run on the hardware and its very limited)

AE6XE
AE6XE's picture
KI6FJA,  These are all the

KI6FJA,  These are all the great features in the OpenWRT Chaos Calmer and some features in Barrier Breaker releases.     For example, "...update the menu system of the router and add a new menu option", is a feature of the LUCI User Interface that is technology uniquely created in the OpenWRT community.  LUCI is something we'd like to incorporate and pass through a lot of additional value in future releases of AREDN.    Unfortunately,  to get all the benefits of these OpenWRT features, the OpenWRT firmware would require a path to be installed on the hardware and subject to the FCC certification related rules.  

OK, going out on a limb here.  My crystal ball prediction of what will happen:    

1) Manufactures take lowest cost-effort approach to satisfy the FCC certification process.  They add a low cost roadblock to prevent 3rd party images being installed including openwrt, DDwrt, etc.  ....check the box, done.  No back and forth dialog with the fcc, no 2nd guessing the fcc, no redesign, no rework, etc. (I've not seen any fcc statements as to how high the roadblock is required to be and if there's no motivation for a manufacture to make it very high, it won't be.)

2) Upon product release, 15 minutes later (well, maybe a few weeks), the open source community discovers how to get around the roadblock. 

Maybe wishful thinking, but let's see how this unfolds.   

Joe AE6XE

 

 

KI6FJA
Never mind.

Darn, well then never mind.

A recent article on the internet about the latest OpenWRT update got me hoping on a work around.

If they are going to lock the remote update utility down for even the manufacturer then you are correct there is no hope. 

They just have it set now so that users can run OPENWRT without changing the factory firmware but as an update to the software.

Also they have many ways in their software to do it.

 

w6mrr
The period to file comments

The period to file comments has been extended to October 9 and reply to comments to November 9. 

Submit your comments here: https://federalregister.gov/a/2015-21634

 
You can review the received comments here: http://apps.fcc.gov/ecfs/comment_search/execute?proceeding=15-170
 
There is a good synopsis of the issues seen by the open source community here:  http://prpl.works/2015/09/21/yes-the-fcc-might-ban-your-operating-system/
 
The FCC does respond to feedback.  Your comments to the FCC are important.  Please take a couple of moments to help stop these rules in it's current form.
 
Thanks,
 
Martin Rothfield W6MRR
KA9Q
For a particularly good

For a particularly good response to this misguided FCC proposal, see

http://huchra.bufferbloat.net/~d/fcc_saner_software_practices.pdf

I did not really contribute to this letter though I eagerly signed it when asked. I especially liked the citation of the ongoing VW emissions cheating scandal as evidence that industry cannot be relied on to police itself. Opening up source code to public scrutiny is nothing more than applying the scientific method of peer review and publication to software. It should not be necessary to point out that the scientific method has been shown to work pretty well for lots of other things.

w6mrr
ARRL comments:
M1BKF
M1BKF's picture
Plan B

My guess, there will be a new series of FCC compliant devices, (like this: http://www.cnx-software.com/2016/02/21/tp-link-wifi-router-firmware-locked-down-due-to-new-fcc-rules/), but hackable ones will still be available via the slow boat from China.
If this does end up locking out third party firmware, though, there's always high-powered outdoor USB devices, eg the Alfa Tube-U http://www.alfa.com.tw/products_show.php?pc=2&ps=12
That, plus OpenWRT for the Raspberry Pi on an industrial SD card, eg http://panasonic.net/avc/sdcard/industrial_sd and you've got the functionality, if not the elegance.

kc2lsb
upgradability of current ubiquiti devices

I am thinking of using mesh solutions for a couple of tasks and would like to use the AREDN software if possible.  What I would like to know, though, is which, if any, of the AREDN supported Ubiquiti devices can still be firmware updated with the AREDN code.  I have see the TP-Link announcement and also read a thread somewhere on the Ubiquiti site that seem to suggest that they will remove the ability to upgrade firmware on their devices too.  Has that happened yet (or will it soon)?
Thanks

AE6XE
AE6XE's picture
Ubuiquiti hasn't formally

Ubuiquiti hasn't formally announced if or how any of their devices will be locked down.   There's a reasonable chance that Ubquiti will never lock any of the AirMaxM series supported by AREDN today--they can continue to ship these models as long as they are not 'marketing' them.    They may not be marketing these models because the AirMaxAC series, or whatever is next going through the FCC certification, will receive the Marketing $$ attention.    ...But let's wait and see what Ubiquiti formally announces to not speculate too much--jury is still out.

Let's also look to see if the TP-Link (or any vendor's) international products are available for purchase in the US under part 97.  This should be the same process we use today for the 3Ghz equipment.   The news releases from TP-Link that I've seen, suggest that these devices may still allow 3rrd party firmware, but don't explicitly say this--only say not locked to US rules.   

Joe AE6XE

G0OFY
G0OFY's picture
It seems that the router
It seems that the router manufacturers are missing a trick here. Surely they should jump on the bandwagon and produce an amateur band version of their product which could then be FCC (worldwide) approved. It could be packaged in a completely different way to differentiate it from the standard product.
There is a potential for thousands of units being sold all over the planet. If the Chinese can flood the amateur radio market with a £20 ($30) dualband handie then knocking out routers should be a breeze.
WL7COO
WL7COO's picture
This thread represents the the very best of;

*why* AREDN is so valuable to the Amateur Radio community.

Thank you one and all.

I *was* concerned about the issue, now I'm simply very interested.


Best
...dan wl7coo

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