Securing RF Devices Amid Changing Technologies

This summer, the particular Commission opened a rulemaking proceeding with the goal of modernizing our approval process for radio devices to help us keep pace with the accelerating introduction of an ever-expanding breadth of wireless devices and items into the marketplace.

The proposed rules will help the Percentage not only better address the facts of device manufacture and make use of today but plan for the range policy of the future. As Chairman Wheeler has announced, this month the particular Commission will consider a rulemaking for the use of higher-frequency bands for cellular and other uses that will “focus on developing a flexible regulatory framework that will enable maximum use of higher-frequency bands by a wide variety of providers, ” including “hybrid shared models” to promote more versatile use in higher bands.

But flexible use requires producers, users, and the FCC to be a lot more vigilant in monitoring and avoiding harmful interference – and that’s where this new rulemaking proceeding plays a critical role. The rulemaking will establish for all device home loan approvals a policy that the Commission has followed for individual device categories during the last few years of requiring manufacturers in order to certify that a device cannot be customized by the installation of third party software in a manner that causes those devices to create harmful interference.

For instance, in 2014 the Commission adopted a written report & Order in the U-NII proceeding establishing new rules for devices operating in the 5GHz band to deal with interference with FAA Doppler weather radar systems caused by modifications in order to RF devices. The Commission followed a rule requiring manufacturers in order to implement security measures to ensure that “third parties are not able to reprogram the device to work outside the [RF] guidelines for which the device was certified. ”

In that proceeding, the particular Commission declined to specify the particular technical solutions that a manufacturer might use to secure the device against modifications that could cause interference and particularly declined to require that producers “lock down” or otherwise render a tool inoperable if third party firmware can be installed. In fact , a number of manufacturers filed comments in that proceeding explaining exactly how some of their products already include protection measures that prevent RF modifications without banning third party firmware installation.

Shortly after adopting the rules, OET staff issued guidance in order to applicants for equipment certification. The document included a series of questions (many proposed by commenters in the proceeding) intended to identify, among other details, “how the device is protected from ‘flashing’ and the installation of third-party firmware such as DD-WRT” that would modify the particular RF parameters in a way that would take the device out of compliance and trigger harmful interference. This is consistent with the particular rule itself as well as the Commission’s preference not to prescribe specific security options or prevent a device from functioning in the event third party software is installed.

Nevertheless, our 2014 guidance on the 5 GHz rules has prompted some question as to whether the intent of the current proceeding would be to ban third party firmware installation on devices, particularly for Wi-Fi routers. To be clear, it is not: like the U-NII rules we adopted, the proposed rules do not require device makers to prevent installation of third party firmware or otherwise favor specific security solutions.

Quite the contrary, the particular proposed rules would require producers to select the security method they deem appropriate to prevent modifications that take the device out of compliance. They would further build a process by which third parties could seek approval for software modifications that alter the RF parameters in manners that do not conflict with a device’s certification. The goal of these proposed guidelines is to establish accountability in the certification process that reflects the facts of how these devices are used – plus modified – today.

The cornerstone of a flexible make use of spectrum regime is interference avoidance and, this requires that devices work within their authorized parameters. The proposed rules aim to create a certification procedure that recognizes this goal with out creating burdensome red tape for producers and headaches for users while also allowing innovative solutions simply by 3rd party vendors. It’s critical that individuals get the details right, and we anticipate fielding comments in the record this particular fall.


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