Comment to the FCC re: Consumer Router Firmware

Update: The deadline for filing has been extended to 9 October 2015, so you now don’t have any excuse for not sending in your opinion.

I filed the following comment on the FCC page regarding the new Proposed Rule that would (ultimately) prohibit individuals from installing third-party firmware (such as OpenWrt, DD-WRT, Tomato, and the myriad others) on their home router.

If you have an opinion on this, you should go to the FCC Comment Page and click the green SUBMIT A FORMAL COMMENT button.

You’re free to plagiarize my note, or take a cue from the Save WiFi page at LibrePlanet.org. I wrote:

I recommend that the FCC RESCIND its Proposed Rule, Document number 2015-18402 regarding wireless devices. The Proposed Rule is overbroad, would harm many communities of Americans, and is not warranted by the facts on the ground.

Although the FCC has the power to regulate equipment that generates radio frequencies, this is a heavy-handed rule that could be addressed other ways. Specifically, I am concerned about the ability of third parties to modify and create new firmware for “consumer routers.”

The proposed rule would require that router manufacturers lock down the RF portion of the router to obtain FCC approval. This “lock down” would prevent modification to the radio’s power, frequencies, etc to prevent it from radiating outside the specified limits. This is a laudable goal, but the application of this rule as written would result in undesirable consequences.

In practice, most radio functions are very tightly wedded to all the other factors of the hardware/software. The most likely way manufacturers would likely lock down the RF operation would be to make it impossible to modify any of the code in the routers.

There would be a number of adverse consequences both for me personally, to consumers in the US, and the networking industry. These consequences can be ameliorated by allowing the owners of routers to install their own code.

1) Security of the router. It is well known that vendor-supplied firmware for consumer routers often contain flaws. Just last week, the CERT released knowledge of a vulnerability to Belkin routers. See http://www.kb.cert.org/vuls/id/201168 The ability to install well-tested, secure firmware into a router benefits all consumers. The ability for a person to update their own router on a regular basis (as opposed to many manufacturer’s seemingly lackadaisical schedule) preserves security.

2) Research into the field of computer networking. Non-traditional research efforts (outside academia) lead to real improvements in the state of computer networking. An example is the CeroWrt project that developed the fq_codel algorithm. http://www.bufferbloat.net/projects/cerowrt The result of this multi-year effort was a major advance in performance for all routers. The fq_codel code has been accepted into the Linux kernel and now runs in hundreds of millions of devices. As a member of the team that worked on this, I assert that without the ease of modification of a consumer router to prove out the ideas, this improvement would likely not have occurred.

3) Personal learning environments. Individuals, as well as network professionals, often use these consumer routers as test beds for increased understanding of network operation. Losing the ability to reprogram the router would make it more expensive, if not prohibitive, for Americans to improve their knowledge and become more competitive.

4) I would incorporate all the other “talking points” listed on the Save WiFI page at: https://libreplanet.org/wiki/Save_WiFi

5) Finally, I want to address the FCC’s original concern – that these consumer routers are SDRs, and they must not be operated outside their original design parameters. While the goal of reducing radio frequency interference is important, the FCC has failed to demonstrate that the widespread practice of installing/updating firmware in consumer routers has caused actual problems. Furthermore, the FCC can use its current enforcement powers to monitor and shut down equipment that is interfering.

Creating a broad, wide-ranging rule to address a theoretical problem harms industry and individuals, and is an overreach of the rules necessary to preserve America’s airwaves.

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