FCC's WiFi Rule-Making: Making It Fair For Both Open Source and Proprietary (fcc.gov) 173
Bruce Perens writes: The FCC wants to be sure that WiFi drivers don't cause interference with airport weather radars, but their proposal to lock down WiFi firmware, won't fly. Many commenters in the proceeding have made it clear that Open Source firmware for WiFi devices must remain legal. While an "alternative" proposal to the FCC that would require that all WiFi routers be Open Source is getting most of the publicity today, I have proposed another alternative that would be fair for both Open Source and proprietary software. It requires approval of the source code of a WiFi driver by a person with a technical license from FCC, the GROL+Radar, if that driver is to be mass-distributed in binary form for use by RF-naïve users by either the manufacturer or Open Source. The license assures that the responsible person actually understands how to protect radar systems in a WiFi driver. It's pretty easy for someone competent in radio engineering to pass the license test, and many thousands of people hold the license today. Vendors and Open Source are treated the same. It doesn't place restrictions on testing and development, or conversion of WiFi equipment to other radio services. And it includes an explanation of the problem, for those of you who don't know what the uproar is about.
Question for Bruce (Score:5, Insightful)
Bruce,
Is it your experience that people at the FCC even understand what Open Source is and that not all software is made by some huge entity like Microsoft and Adobe? It seems to be in my travels there are so many people making important decisions on the governmental level that either don't care about the greater Open Source community because of close ties to big corporations or don't have the background to understand why open software is important.
How can we encourage the FCC to consider this? (Score:2)
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Write a reply comment endorsing it. Collect signatures, not that this is a petition process, but it might carry some weight anyway. Submit it by the reply comment deadline of November 9.
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Do you have a link to where to submit the comments? I tried the almighty Google and have failed.
I will turn in my Geek card on the way out...
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This makes the most sense of all the proposals I've seen.
Having a GROL with a ship radar endorsement gives someone absolutely NO special training in how to deal with either WiFi or the software that runs it. If you look here [fcc.gov], you'll see what elements you need to pass to get a GROL and the ship radar endorsement (1,3, and 8), and here [fcc.gov] are links to the question pools from which the exams are created. Look for yourself and see how much relevant knowledge is required for the task Bruce is suggesting they do.
It is patently ridiculous to think a GROL holder will unde
Re:Question for Bruce (Score:5, Insightful)
I'm not Bruce, but several people within certain Bureaus of the FCC do indeed understand Open Source. Even as far back as the '90's one of the engineers in the former Mass Media Bureau (deals with broadcasters) actually published some Open Source code showing how to use Fortran as a CGI program for websites..... they also have released a large quantity of code over the years.
One thing to remember about government agencies is that they are made up of people; the question isn't whether the agency knows anything, it's whether the people employed by that agency know.
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In fact, the agency is strongly influence by the ham radio community, which is in many ways very similar to the open source community.
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How so?
Problem with the word(s) "mass-distributed" (Score:2)
Anything with a link on a website someplace will be considered "mass-distributed" for regulatory purposes. So in effect that would mean that only peer to peer sharing of open source code would be allowed which undermines the whole point of open source.
I think "commercially distributed" might cover it, so that people can't sell software or hardware without certification. But basically I think some simple disclaimer that comes along with the code that indicates that the code is intended for experimental use
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Why would you not want enterprises to utilize better software for their Wi-Fi infrastructure?
Open source simply must be permitted to still exist and be freely used in place of what comes with the equipment. I understand the FCC position, and would even accept a closed source blob that directly controls the radio interface, but there is a vast set of other tools that are used in enterprise environments outside of the core radio interface. These are more frequently patched for features and security enhancem
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Why would you not want enterprises to utilize better software for their Wi-Fi infrastructure?
Open source simply must be permitted to still exist and be freely used in place of what comes with the equipment. I understand the FCC position, and would even accept a closed source blob that directly controls the radio interface, but there is a vast set of other tools that are used in enterprise environments outside of the core radio interface. These are more frequently patched for features and security enhancements than what you can get from the manufacturer.
A no Open Source position hurts everyone - enterprise environments included.
I didn't say that enterprises shouldn't use open source. Actually, I think there is a good reason to require all source code for wifi and other radio devices be publicly available for inspection as open source. Some could have open source licenses while others could have proprietary licenses.
Just that instead of an outright FCC ban on the use of uncertified firmware, it should simply be made clear that the firmware isn't certified, so that anyone using the software is incurring some risk that the
Key words are "in binary form" (Score:2)
If source code is on a website, it's not "mass-distributed in binary form." I assume that by "binary form", Mr. Perens meant a form other than "the preferred form of the work for making modifications to it" (GPLv3). And if source code is specifically marked as experimental, it's not "mass-distributed [...] for use by RF-naïve users."
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If source code is on a website, it's not "mass-distributed in binary form." I assume that by "binary form", Mr. Perens meant a form other than "the preferred form of the work for making modifications to it" (GPLv3). And if source code is specifically marked as experimental, it's not "mass-distributed [...] for use by RF-naïve users."
If that is the case, then it is a fundamental disagreement. It shouldn't be made illegal to "mass-distribute" either uncertified binaries or uncertified source code of firmware for wifi routers. Claiming it is certified should be the regulatory issue. And on the use side, it should be the operator that incurs any liability for operating uncertified firmware or an uncertified device that is operating outside of defined parameters.
Vicarious or contributory interference (Score:2)
it should be the operator that incurs any liability
The legal theory here might be secondary liability [wikipedia.org] for interference with weather radar. If a company profits from an unlawful act (crime or tort) committed by another that it has power to prevent, it has vicarious liability for said other's act. If a company distributes tools that it knows will allow another to commit an unlawful act, it has contributory liability for said other's act.
Re: Vicarious or contributory interference (Score:2)
What if there is no profit?
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As I understand it, vicarious liability requires some form of financial gain, but contributory liability does not.
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The problem is that manufacturers would stop giving us chip documentation. They want to sell devices, so they cooperate with FCC, since FCC can block their imports.
We're not up to making WiFi chips on our own yet. But I'd encourage you to start at that, if you have the necessary background.
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We just be careful to mark test code as being test code, and point to the link for the released version. The goal is to keep the RF-naïve from deploying it. Warning them might be sufficient.
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FCC staffers come and go. We have, unfortunately, lost the two we knew were hams and up-to-speed on what's happening regarding individuals and innovation rather than companies as the sole source of it. Bill Cross, staffer who wrote some of the rulemakings, is retiring or might already have done so. Riley Hollingsworth was a ham attorney there who has retired.
FCC does have an advisory board, it would not be a bad thing to get some people we know on it.
My opinion is that whoever wrote this NPRM was not suffic
simple... don't piggyback wifi on assigned freqs (Score:2)
where else do we have random porn-surfing wackos interfering with a life-safety system?
so don't do it here, either. prohibit the overlap frequencies.
Very sensible (Score:2)
The only proposal so far to actually make sense. No corporate is going to open-source their Wifi code if they haven't already, especially those multi-channel directional systems. And binary- and official-only firmware has obvious problems as well.
This is the proposal to get behind, to reinforce to the FCC in the public consulations. It lets the corporates keep their trade secrets and allows open source firmware to exist at the same time.
Open source & locked down... (Score:2)
What exactly does Open Source have to do w/ something being locked down? Are we entering the 'TiVoization' argument again? Open Source simply means that the source code should be made available to the person who has the executables. Nowhere is there the requirement that the customer has to have the capability to actually modify the in-system code.
There are several good reasons to lock down firmware, regardless of where one stands on open source vs closed source. I am generally in favor of open source
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This is all just a DRM mandate, nothing more, and it should be scrapped entirely.
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Aside from the fact that Doppler radar operates in the 5 GHz band, sure.
Sorry, but there are real-world physics involved. You can't just blast 5-GHz noise in a radar's observation window. It basically creates a huge blind spot.
Granted, you have to be a hundred feet above ground level to be relevant, but there are tall buildings near some airports where Wi-fi equipment can be running. You can't have some schmuck turn on his tethering and knock a storm off the map.
All the software has to do is listen for a fr
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Granted, you have to be a hundred feet above ground level to be relevant,
I'm sorry, what? Do you understand how radio works?
You may have to be 100 feet above ground before you can create a false target or inject false data. You can absolutely interfere with a radar system if you simply transmit at significant power levels near one. If you cause the receiver to desense so it does not receive the echos it requires to work, then you've interfered with it.
Remember the microwave oven(s) at the National Radio Observatory in West Virginia that were creating fake signals? They weren'
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What exactly does Open Source have to do w/ something being locked down? Are we entering the 'TiVoization' argument again? Open Source simply means that the source code should be made available to the person who has the executables. Nowhere is there the requirement that the customer has to have the capability to actually modify the in-system code.
The ignorance, it burns!
In fact, the ignorance is so appalling I am inclined to think it's deliberate, but that doesn't matter.
Here's the actual, no kidding, defi [opensource.org]
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Thats *a* definition, not the only one. opensource.org doesnt have a monopoly on the term.
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The GPLv2 and GPLv3 define a work's source code similarly: "the preferred form of a work for making modifications to it".
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And again, they dont hold a monopoly on the term.
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Nor is this proposal by Bruce Perens the complete final bill. If "free software" as defined by Debian (or "open source" as defined by OSI) is meant, the DFSG/OSD will be written into the bill or at least included by reference.
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Umm.... What about the MIT and BSD licenses? They don't have a clause requiring the release of source when delivered in binary form. Do you not consider these licenses to be open source?
If the BSD-licensed binary software was shipped unmodified, then you still have access to the upstream release, and it's still open source.
If modifications were made, then a binary derivative work was shipped. If a proprietary license has been added to the derivative work or the source modifications are kept secret, then the derivative work is not open source. (But the original unmodified code that it was based on remains open source.)
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Umm.... What about the MIT and BSD licenses? They don't have a clause requiring the release of source when delivered in binary form. Do you not consider these licenses to be open source?
Those are open source, as per the OSI definition, but not CopyLeft, as per the FSF
How to support? (Score:2)
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Write a reply comment in support of my comment, collect signatures (not that this is a petition process, but it might be impressive anyway), submit your reply comment by the November 9 deadline.
How about the FCC just does its job? (Score:5, Interesting)
If someone is interfering with a licensed station, why doesn't the FCC investigate the source of the interference? In the old days, if you were being a nuisance to a licensed station, you were in for a world of hurt if being intentionally malicious. At the bare minimum, and idiot user would have had their equipment confiscated for being clueless.
Is it too hard for them to actually go out and do the one thing they unquestionably have the authority to do? Or is this just another power grab by the FCC and the administration to quash tech freedom wherever they see fit in the name of "safety".
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The FCC actually has investigated many complaints of transmissions from wireless devices interfering with terminal doppler weather radars. Here's a list of enforcement actions by the FCC: https://www.fcc.gov/encyclopedia/weather-radar-interference-enforcement [fcc.gov]. So, yes, there have been investigations of the source of interference and penalties for doing so.
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41% of those actions occurred in Puerto Rico, with the number two favorite being Colorado. Looks like two field offices care enough to investigate, most of the time.
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They do investigate, but investigations take expensive equipment out into the field and are extremely time consuming. The certifications are there to reduce the chance that an interfering piece of gear gets out on the market. The question is, where would the money for these investigations come from? The requirements today are mostly about paperwork and a few measurements on sample devices. For a commercial device, it's pretty effective- but the airwaves are a shared resource and we need a mechanism to preve
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That worked fine when pirate stations, CB, and ham radio were all they had to worry about. These days, there's nothing but a few bucks and a couple of minutes online keeping Joe Schmo from running a wireless router with firmware he doesn't understand that he downloaded from who-knows-where that may be at an early stage in the quality control process. And that situation is only getting more extreme with time as more people go online and more wireless routers make their ways into homes.
Mind you, I think that
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Is it too hard for them to actually go out and do the one thing they unquestionably have the authority to do? .
The FCC has been ramping down Enforcement because it has been spending it's cash on *other* things. They have closed the majority of field offices where monitoring personnel used to work, eliminated the jobs which used to be located there, and cut the enforcement division's staff in DC. It is so bad that it took over a decade to yank the license of a misbehaving amateur radio operator in Maine they had dead to rights on multiple and repeated violations. Heaven only knows if they will ever collect the fine
Noob question (Score:2)
Ok, I know nothing about radios, or how wi-fi works, or what the issue is. (Assume for the moment that I'm also unable to use google.)
Clearly though it's a Big Deal. Could someone in the know explain why the necessary restrictions to prevent abuse inherently can't be implemented the hardware, such that the software (open or closed) just can't do whatever it is that's causing the problem?
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Terminal Doppler weather radars (TDWRs) are installed at about 40 major airports. They operate in the 5 GHz range and are used to detect things like wind shear and microbursts, which are dangerous to aircraft. The higher resolution than the WSR-88D (Nexrad) radars probably makes it easier to detect these features. Also, if the nearest WSR-88D is a significant distance away from the, the beam will be significantly above the ground over the airport. Interference from wi-fi isn't an issue for the WSR-88D radar
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Thanks. So... presumably TDWR detection is too complex to be done (economically) in hardware?
Yeah, yeah (Score:2)
Usual thing; "pre-crime" and bored bureaucrats (Score:2)
It's the usual regulatory overenthusiasm. Basically trying to criminalize perfectly ordinary actions that might lead to actual criminal actions.
You can be penalized for emitting interference in a regulated frequency, or for using a regulated frequency for some other purpose. That is correct, and it is all that is necessary. Whether I my device is interfering because it is a cheap piece of crap, or because it is broken, or because I have flashed it - the reason doesn't matter, the result does. On the other s
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Two issues:
1. You are most likely correct for your individual scenario. The goings-on at your house will probably never matter. Your signal is going to be more noise on top of noise that is already ignored as ground clutter. You can have no impact unless you have a very, very tall house or are reflecting a strong signal off of something else. However, wifi is not limited to residential houses that are 12-40 feet tall and many miles from the airport.
2. Meteorological radars are extremely sensitive. They are
what problem is this trying to solve? (Score:2)
People can already interfere with "airport weather radars" in a variety of ways. What evidence is there that custom WiFi firmware is a problem, and that locking things down would fix this?
Trying mainly to get code *maintained* properly (Score:3)
In your slashdot posting today you mischaracterized our efforts as attempting to "open source" all routers. (as have multiple other reporters and people)
I lost sleep for years trying to create a third not "open source" or "closed source" *option* for making society's safety critical source code *public* vs what is currently buried in inauditable binary blobs - and in this letter, tried to shift the core fcc licensing requirements to mandating that the source code at the lowest layers of the network stack be "public, maintained, and regularly updated".
What license is slapped on this "public" code I totally do not care about - it could mandate you have to sell off your first born child, or slit your throat after reading, for all I care.
I care only that the sources be public, buildable, maintained and updated.
http://www.bufferbloat.net/pro... [bufferbloat.net]
Open source and closed source alike have been doing a terrible job of maintenance, and in the embedded market - aside from higher end devices like android and mainline OSes like redhat/ubuntu - are not being updated. That is the *real problem* here that we are trying to solve.
thx in advance for any efforts you might make to correct your messaging, particularly when talking about our efforts! I have been busting my b**ls to make these points with every reporter I've talked to.
Aside from that... I think extremely highly of your characterization of the problem's stakeholders, the quality of your letter is even better than ours overall, and your proposed solution quite possibly one that could succeed (although I would shoot for a new licensing regime that made the git committer more responsible, perhaps - it is very worthy of discussion!)
I am totally willing to discuss restrictions on "how public" things become - and how fast they become so! particularly as I am well aware dismal code quality in many mission and public safety critical pieces of software that is out there. Mandating that all that be made public all at once would induce a terrifying amount of risk to society as a whole, and a staged approach towards making the core blobby bits public would be best.
I would dearly like, also, to fix the dsl drivers and firmware worldwide, at least in part, because I strongly suspect quite a lot of it, in light of snowden's revelations, is compromised already, and they just need 50 lines of code or so, and a firmware update, to eliminate the bufferbloat in them - and verify, it really is doing what the authors say in the tin, to the FCC.
Sincerely,
Dave Taht
lead author, the cerowrt project's letter to the fcc
http://fqcodel.bufferbloat.net... [bufferbloat.net]
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OK, perhaps I misunderstood something. What you are talking about is "disclosed source code". It can be "all rights reserved" except for the rights necessary to produce incidental copies in reading an online document. It is a good idea to use it for any code that presents a risk to life or property, as it makes it possible for an external auditor to review it without going through any permission process. The counter-argument (one we've all dealt with before) is that it makes it somewhat easier to fi
No Bruce, a Wifi-Czar won't fly. (Score:2)
A single person has a surprisingly limited amount of bandwidth. They would quickly find themselves overwhelmed by the job.
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A single person
I think the idea was to have any one of such license holders review and approve such firmware mods.
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Anyone who gets the Gordon West / W5YI book on the GROL+Radar. Gordy himself will probably be at Pacificon (Pacificon.org) tomorrow. Ham Radio Outlet will be there, with the book. Or of course you can buy it on Amazon :-)
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I think the idea was to have any one of such license holders review and approve such firmware mods.
Anyone who gets the Gordon West / W5YI book on the GROL+Radar.
The comment you just made, in reply to the one before that, says that you intend that anyone who buys a book on the subject will be certified to approve WiFi software.
I'm sure you didn't really mean that, because if you did then you are crazy.
Re: No Bruce, a Wifi-Czar won't fly. (Score:2)
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You have to study and pass the test. But it is not very hard.
I know that. What I was pointing out was that you didn't say anything about getting the GROL in the comment I replied to, only buying the book.
Commas (Score:2)
but their proposal to lock down WiFi firmware, won't fly
Can we have some legislation against people misusing commas instead?
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Bastard. You beat, me to it.
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Missed the point (Score:2)
What the hell is the FAA doing running a safety critical (so they say) radar system in an ISM [wikipedia.org] band? And why is the FCC defending them?
No license is required to operate within these bands, making the proposal that a person holding a technical license approve router firmware an exception to current policy. Furthermore, equipment using these bands must be tolerant of interference caused by other in-band transmissions.
As far as I can tell, the FAA is violating FCC rules by operating their radar within these
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Pretty much all spectrum is shared. Sometimes, you get incompatible sharing partners.
Which is where the FCC issues licenses and reserves the right to call interfering users in and negotiate a compromise. Reduce power, change your broadcast pattern, change frequencies, etc. Because bthey know who and where they are. But once a block of frequencies is released for unlicensed use (ISM being the 'worst' possible example), how do you get hold of all the radio controlled drones, garage door openers, microwave ovens, and WiFi access points that are out there already?
FCC now wants to allocate yet more of those frequencies to WiFi.
And what will they do when the
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Those guys may have been there before WiFi. In general a service like WiFi is approved after they assure the regulators that they won't interfere with the incumbent users.
FAA won't put transmitters with a life-and-property duty anywhere without FCC licensing them. I doubt these radars are really operating as ISM devices, I think they have a license.
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No license is required to operate within these bands, making the proposal that a person holding a technical license approve router firmware an exception to current policy.
You are wrong. The fact that a specific use of a frequency does not require a license does not mean that the devices used there have no regulatory limitations or oversight.
For example, the FRS is license-free but you cannot legally use a radio that you put together yourself on those frequencies, nor can you modify a radio that has been certified for FRS and use it there.
As far as I can tell, the FAA is violating FCC rules by operating their radar within these bands.
The FAA, as a federal agency, is not subject to FCC rules. They operate under the auspices of the NTIA. But since there frequencies are
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No sharing according to this?
That's from the aviation communities point of view. And I understand it very well. The interference is a life safety issue.
The problem is: Who ever allowed it to happen? TDWR has been in use for at least a decade, but the asignment of that frequency band for what is essentialy "junk" use predates that by quite a bit. I have some wireless data link transceivers that operate in that band that date back to the 1990s.
using unlicensed to them bands
Unlicensed to anyone at one time. And once the FCC designated this band as aceptable for unlic
Won't work well (Score:2)
The problem will be that the bureaucracy will cause 'FCC licensed drivers' to be utterly outdated except for a few proprietary ones because someone could line someones pockets to get it pushed through.
The unlicensed firmware will still be shipped on most cheap routers however since they're coming from China where the FCC has no jurisdiction and the resellers don't care much about import requirements.
Be careful what you wish for if you let a government agency get involved with your plans. Your plans however
Re: How _real_ an issue is it? (Score:4, Insightful)
Have you heard about the airplanes dropping out of the sky because "Mom's WiFi" ruined the weather forecast?
Have you heard about government bureaucracies that constantly seek to expand using the flimsiest of justifications to increase their power?
Re: How _real_ an issue is it? (Score:5, Informative)
Actually, there are many examples of FCC enforcement against transmitters on certain 5 GHz bands interfering with terminal doppler weather radars: https://www.fcc.gov/encyclopedia/weather-radar-interference-enforcement [fcc.gov]. This is actually a real issue.
No, it isn't especially frequent, but it does take place. There are two reasons it isn't more frequent:
1) Most transmitters aren't located in buildings that are high enough to be in the line of sight of airport weather radars. Generally the enforcement actions are against operators of transmitters in or atop tall buildings. Your transmitter a couple of floors above ground is highly unlikely to ever interfere with a radar. And if the radar beam was refracted severely enough for this to occur, there would almost certainly be a lot more interference from ground clutter than your wi-fi transmitter. This is more of an issue in tall buildings. The actual buildings are normally pretty unlikely to cause problems because they are stationary point targets that get filtered as ground clutter. Wi-fi, however, would probably contaminate an entire radial, similar to a sun spike.
2) Transmitters operating on either of the 5.25-5.35 GHz and 5.47-5.725 GHz bands are required to use dynamic frequency selection. They are supposed to listen for the signals transmitted by weather radars and, upon detection, switch to a frequency that does not cause interference.
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Can the FCC point to any specific instances of aircraft radar interference, and especially, instances of interference caused by routers running Open Source software? Or is this another case of a Gov't agency using a bogy man (It's to prevent terrorism, It's for the children, etc) to assert control over a market segment that it didn't previously control.
Wondering which.
I suspect it's more the latter rather than the former, but not for the reasons given..
My money is on this being a method for the government to attempt to prevent widespread use of modified WiFi routers as mesh-network routers when they decide to shut down internet access due to 'terrorism' or domestic uprisings/protests.
Strat
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My money is on this being a method for the government to attempt to prevent widespread use of modified WiFi routers as mesh-network routers when they decide to shut down internet access due to 'terrorism' or domestic uprisings/protests.
Right. I've been working on just such a system, experimentally. Lots of commodity ($20) wifi routers, loaded with Open-WRT, connected to a small solar panel and rechargeable battery. They run forever and you can mount them anywhere, even on trees. Even if the access points are down, the hosts connected to the network can talk to each other. It's a neat system, and except for the wider Internet connections, relies on no ISP whatsoever.
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The GROL is not for just transmitting- that's a restricted license - the GROL is required to "... to adjust, maintain, or internally repair FCC licensed radiotelephone transmitters ..." [fcc.gov]
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Actually, I looke at the Fundamentals of Engineering (FE) test. [ncees.org] It's used for patent agents, among other things.
I really didn't want to require an entire engineering career of WiFi driver hackers, just enough that they would have a good chance of understanding the requirements.
We used to have a "First Radiotelephone" license for broadcast chief engineers. And a "Third Radiotelephone" for DJs. This seems to be what has replaced the "First Radiotelephone".
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And they'll be on the 2050 equivalent of eham complaining about these new kids with their 100 GHz links carrying gigabit/second not knowing the real ham radio back when we had 2 Mbps on one channel and thought it was cool. (by then, the guys who pounded brass in the military, or shipboard with their GROL, will have died, so the code vs no-code dispute will have died down)
Before the code vs. no-code dispute, there was a group of radio enthusiasts who would argue, "Spark Forever!"
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Getting a professional engineer requires a sponsor, engineering degree and/or equivalent work experience. It also has a large amount of non-electrical and non-RF learning required. It's completely overkill for something like this. Why not just require an extra class HAM license, or a new license based on those requirements? HAMs are already licensed to build their own radio equipment and broadcast up to 1500 watts on a number of bands. I realize those bands aren't right next to weather radars, but malfunctioning equipment could make them so. And unregulated bands are already open to be used by HAMs anyway.
For starters, you don't need an engineering degree to get GROL, I don't think you need one to get the Radar part. It's the same as the amateur service; you pass the exams, pay the fee, and you can get your license. The testing and licensing fees tend to be the killer and part of the reason the people who have these are engineers. A ham license, for example, will cost you about $15 depending where you test..that's paid at exam time and covers up to all three exams in one sitting. A friend of mine just got t
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Just a nit pick... But...
The current test fee for Armature Radio tests administered by a VEC is EXACTLY $15. Not a penny more or less is allowed. For this fee you are allowed to take as many of the 3 written tests elements in order starting with Element 2 (technician) as you wish to try and can successfully pass. So, if you want to study enough, you could conceivably take and pass all three in one setting. When I went for my General class test and passed, I took the Extra on the chance and happened to p
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The current test fee for Armature Radio tests administered by a VEC is EXACTLY $15. Not a penny more or less is allowed.
You are wrong. The fee is not set by the FCC. The FCC has deregulated the testing fee, as covered here [fcc.gov].
The ARRL VEC currently has a $15 testing fee. The Laurel VEC teams charge zero. Nada. Zip. Nothing. I've heard that other VEC teams charge just $5.
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A friend of mine just got the license that's a pre-requestite for GROL, it wasn't cheap...but he's working on his GROL.
Your friend is blowing smoke because there is no license that is a prerequisite for the GROL. You don't need to pass (or even take) a class, you don't need to have a high school diploma even. You need the following three things to get your GROL:
There is no telegra
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These radars are used to detect hazardous weather, not aircraft. There are about 45 terminal doppler weather radars installed in the US, which share the 5 GHz band with wi-fi. They are primarily used to detect wind shear and microbursts, which are dangerous to aircraft.
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The transmitters are locked into a frequency set. However, this is shared with the frequencies used by terminal doppler weather radars (TDWRs). Wi-fi equipment is supposed to detect when a radar is operating on a particular frequency and, upon detection, switch to a frequency that's not in use by a radar. Normally this isn't an issue if you're operating a transmitter near the ground. However, if it's located higher up in or atop a building that happens to be within the line of sight of a radar, it can cause
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The only way to ensure the frequencies is to lock the transmitters into a specific frequency set.
To what frequency set should a transmitter designed for different countries with different spectrum allocations be locked? For example, in the United States, the frequencies corresponding to Wi-Fi channels 1 through 11 are under an FCC unlicense for part 15 operation, while Wi-Fi channels 12 through 14 aren't.
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Are you actually arguing that the FCC, the regulatory body *created* to ensure that the radio spectrum within the United States doesn't become an unusable mess of noise created by overlapping bands, and horribly out of any reasonable spec transmitters blasting white noise everywhere, actually has "no business even being involved in" doing exactly that?
Hint: You don't need the FCC license to *write* the drivers. You don't need the FCC license to *deploy* the drivers. You just need someone with the FCC lic
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You just need someone with the FCC license to *certify* that the driver complies with existing laws before you can use/deploy devices utilizing those driver.
If all you want is someone "with the FCC license", then you might as well make it the Restricted Radiotelephone Operator's Permit, because that license requires just as much technical background relevant to software development and WiFi as the GROL (even with a ship radar endorsement) has. If you're going to claim that someone with a GROL can learn what he needs to do the job right, well, so can someone with the RROP.
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FCC, the regulatory body *created* to ensure that the radio spectrum within the United States doesn't become an unusable mess of noise created by overlapping bands, and horribly out of any reasonable spec transmitters blasting white noise everywhere...
It happened. Back in the days when ships were wood and men were steel (1926), the Attorney General ruled the Dept of Commerce (prior to FCC) had no legal authority to assign freq, power levels, etc. Hundreds of stations had a field day, millions of listeners across America turned off their receivers, and sale of receivers slowed to a trickle (ref GROL License Prep book by Maia and West).
Getting back to a general radio operator license (GROL), I'm not sure how applicable license questions are to wifi but
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They already have control; 47 CFR Part 15 covers this completely.
While you can write whatever code you would like, and you can compile it with no worries, if that code causes interference above and beyond Part 15 rules it is a violation of the regulations for that code to be run if the device running that code is within the jurisdiction of the FCC (USA and its possessions). If you have a license, you are covered by the particular section of 47 CFR that covers your particular license, and you must abide by
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The problem with radio is that one user's operations can block another user's. So, we need some regulation to enable us to share fairly. Think of it as a bus with a lot of bus devices belonging to different people with different goals. If you don't have a bus protocol, one device could grab all of the bandwidth, or lock others out arbitrarily.
Also, get a CB and use it. What you will meet there is what comes from FCC abdicating responsibility to regulate a radio service.
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The radar signal needs to reflect well off the things you are trying to observe. It also needs to have a very long range. The bands typically used for Doppler radar stations were chosen for a reason.
Due to the Rayleigh effect, weather radar needs to operate in roughly the 3-30 GHz band. The upper half of that frequency range (on a logarithmic scale) doesn't transmit through the atmosphere very well and is thus incapable of functioning at any reasonable distance. The lower half of that range is compatible wi
the set is small (Score:5, Insightful)
That is so. I hold two different USG RF licenses (old commercial first class with radar endorsement, amateur extra class.) And I blitzed all the tests (there were a series off them in both cases) so yes, not all that difficult for me.
However, the set of people competent to do what was described about must meet the above criteria, and be of the set of programmers that understands exactly how every layer of wifi is supposed to work and the set of programmers that is conversant with data- and code-hiding / obfuscation techniques. I'm a good programmer -- (about 45 continuous years of experience with many types and sizes of successful projects under my belt), and my debugging skills are right up there as well. I'm very good at seeing that vulnerabilities in my code are minimized. I'm also a good EE, and know RF backwards and forwards. Heck, I write some of the most advanced SDR software out there, so I pretty much eat RF for breakfast.
But I wouldn't be competent to do this job because first, I don't have the hiding / obfuscation chops (and the reason I know that is because I'm a good programmer and realize that's a skill in and of itself... :), nor am I intimately familiar with how wifi works at every level (and I also know that becoming so is non-trivial, because I've skimmed some of the specs.)
So this really doesn't sound like much of a "solution" to me. In practical terms, it doesn't seem achievable. I just don't think there is likely to be a pool of qualified persons being available to fill this kind of role. I suspect that for the workings of a router, you will almost always find a team underneath who (more or less) trust each other for some reason(s), and now we're talking about more risk if we, in turn must trust them and only them.
Closed source opens the door for closed attacks from uncheckable sources, like the NSA. And we know the NSA has been doing things outside the law and outside the acceptable constitutional bounds (and some laws are, in fact, also outside acceptable constitutional bounds.)
So open source for all routers seems to me to be a lot better path to follow. If you're going to mandate anything, I'd say it should be the ability to read the binary out of the depths of the various SOCs that are, or will be, at the core of many routers, as well as from the various types of external ROMs, flashable storage and so on for the types of systems that use them.
This means the router code can be compared bit-for-bit against the code we have been told it is running, and any number of people can then have looked at said code, and in such groups we are much more likely to bring together all the skills required: Joe says there's no obfustcated functionality, Larry says the relevant wifi specs are met, Linda says the networking protocols are okay, Fred tells us that the code itself isn't vulnerable to buffer overruns, Shannon tells us that it isn't going to transmit over the FAA's portion of the 5 MHz band, Mergatroid says what he built from the code that's supposed to be in the router matches every bit of what was actually lifted out of the router. (mind you, that's not perfect either, because a really sneaky team [cough, NSA, cough] could design the hardware to read out one set of code while the router runs something else entirely, but any such "prove it's okay" mechanism has those kinds of limits. Although perhaps Beverly who knows silicon foundry stuff and has access to the right kind of microscope and so forth might be so kind as to look at the die under the microscope and perhaps let us know that it doesn't look like there is a primary/spoof code storage mechanism in there. That, I think, would be one very difficult undertaking, but I'll allow for the possibility, anyway.)
Open source's key strength in re "trust" has almost always been, in a nutshell, "more than one person looks at this." Focusing all trust through one person doesn't leverage that.
IMHO
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There can be any number of software developers on a WiFi driver project. I am asking that just one of them has gone through the Gordon West / W5YI book on the GROL+Radar and has taken the test. Given my personal knowledge of Open Source developers, I don't think there would be any shortage of them.
What you really need is assurance that at least one person understands how to protect the radar and has the authority to get changes in the driver. The test is just to tell FCC that such a person has some minimum
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I hold both licenses as well, and although very competent in programming, and RF theory, I don't believe that the criteria set by having these two licenses should be tacit endorsement or permission to modify AP object code.
Why? Easy: I consider myself to be a responsible and competent operator and hacker. The delta of hardware underneath an AP is only discernible by actual specialists in AP design.
Putting in an altered conf file with a single mistake could render the AP a big problem. I instead suggest that
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I am asking that just one of them has gone through the Gordon West / W5YI book on the GROL+Radar and has taken the test. ...
What you really need is assurance that at least one person understands how to protect the radar and has the authority to get changes in the driver.
The GROL with ship radar license offers no such assurance. "Going through the book" is a good way of passing the test, but is no guarantee that the person who passes the test really understands anything on it, much less understands anything about something the test doesn't cover in any way.
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But Bruce, if that's all you're asking, then what you are really asking is that someone with no actual guarantee of competence certify the work (and take responsibility for it.) Not only does it do nothing useful in assuring the device is actually in compliance, it drops a great deal of responsibility and accountabili
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Manufacturers don't write bug-free firmware, and they don't keep it up to date. So, I did not feel that having them control "only the RF part" was a good idea. Also, splitting the RF part and the rest would introduce hardware complexity that we don't need.
I'm pretty sure my OpenWRT treats the WiFi better than what came with the router.
Easier to pinpoint an offender (Score:2)
I imagine that it's workable because it becomes easier to pinpoint an offender: a single user rather than all users of a particular make and model of transmitter.