Cleaning the Air on Wi-Fi Software Improvements

This week notable the closing of the reply remark period in the Commission’s radio device approval modernization rulemaking. The comments plus replies are largely supportive of the Commission’s proposals, but one particular component generated thousands of comments from individuals concerned that the proposal would motivate manufacturers to prevent modifications or improvements to the software used in devices like wireless local area networks (e. g., Wi-Fi routers). I’m pleased this issue attracted considerable attention plus thoughtful submissions into the record plus would like to make it clear that the proposal is not really intended to encourage manufacturers to prevent almost all modifications or updates to device software.

As I published last month, this proceeding has brought on a significance beyond the Commission’s original intent. One of our key goals is to protect against harmful disturbance by calling on manufacturers to secure their own devices against third party software adjustments that would take a device out of its RF compliance. Yet, as the report shows, there is concern that our proposed rules could have the unintended outcome of causing manufacturers to “lock down” their devices and prevent almost all software modifications, including those impacting security vulnerabilities and other changes on which users rely. Eliciting this kind of suggestions is the very reason that we sought comment in an NPRM and we are usually pleased to have received the feedback that will inform our decision-making on this issue.

In my last submit I recognized the need to work with stakeholders – particularly the user community – to address these concerns in a way that still enables the Commission to implement its mandate to protect users through harmful interference. I’m happy to declare the OET staff and I have got spoken directly with some of these stakeholders in the last few weeks.

1 immediate outcome of this ongoing dialogue is a step we’ve taken to explain our guidance on rules the Commission rate adopted last year in the U-NII continuing. Our original lab guidance record released pursuant to that Order inquired manufacturers to explain “how [its] device is protected through ‘flashing’ and the installation of third-party firmware such as DD-WRT”. This particular question motivated a fair bit of confusion – were we mandating wholesale blocking of Open Source firmware modifications?

We were not, but all of us agree that the guidance we provide in order to manufacturers must be crystal-clear to avoid confusion. So , today we released a revision to that guidance to explain that our instructions were narrowly-focused on modifications that would take a device away from compliance. The revised guidance today more accurately reflects our intention in both the U-NII rules as well as our current rulemaking, and we hope it serves as a guidepost for that rules as we move from suggestion to adoption.

There is more hard work ahead of us as we finalize rules, and we welcome ongoing input from manufacturers, users, technologists, and others.

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