Conservancy Co-Signs Response to Proposed FCC Rule Changes Affecting Wireless Devices

[Bradley M. Kuhn]

URL: https://sfconservancy.org/news/2015/oct/14/FCC-comment/

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       Conservancy Co-Signs Response to Proposed FCC Rule Changes
                       Affecting Wireless Devices

Last week, Conservancy joined the prpl Foundation and several other
organizations in signing a comment filed in response to the Federal
Communications Commission's proposed rules to restrict third-party
modification of firmware in wireless devices.

The FCC's Notice of Proposed Rulemaking Proceeding No. 15-170, released
on July 21, 2015, includes new provisions which would require wireless
device manufacturers to prevent consumers and hobbyists from modifying
the firmwares on those devices. The comment, drafted by prpl's Eric
Schultz, notes that the FCC's rule would restrict wireless device owners
and users to use firmwares chosen by manufacturers, regardless of
whether superior, freely-licensed alternatives exist. The proposed rule
would also limit manufacturers' own ability to use copylefted code in
their devices firmware, thereby cutting them off from higher-quality
code that would improve their products. Conservancy and prpl were joined
by OpenWrt, DD-WRT/DD-WRT NXT, and the Open Source Initiative as
signatories of the comment.  Conservancy's Executive Director, Karen
M. Sandler, and President and Distinguished Technologist, Bradley
M. Kuhn, each also personally signed on to another comment filed by Dave
Täht, co-founder of bufferbloat.net and Dr. Vinton Cerf along with many
other security and free and open source software dignitaries. The
comment proposes an alternative to the FCC's new provisions, which would
require vendors of software-defined radio (SDR), wireless, or Wi-Fi
radio to make the complete source code for the device driver and radio
firmware public as part of FCC compliance.

"Software by its very nature has bugs and will be vulnerable to attack,"
said Sandler. "The only way we can be confident that such a critical
piece of our societal infrastructure is as safe as possible is if the
source code is made fully available for review and can be fixed by
anyone with authority when problems arise. The FCC's proposed rules are
untenable, as highlighted in the comment Conservancy joins in with the
prpl Foundation. The alternate proposal by Täht and Cerf, which is
grounded in a deep understanding of how security issues really play out
in this context, should be seriously considered by the FCC."
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