Unfortunately, the concern raised by Marty rings true. We all remember how for so many years, ham amplifiers could no longer have 10m positions so that CBers couldn't mis-use them. It doesn't seem at all unlikely that once again, legal and appropriate use could be limited by changes designed to thwart inappropriate use. 73, Greg, K0GW On Wednesday, September 30, 2015, Marty Woll <n6vi@socal.rr.com> wrote:
Hi, Dave.
Concerning agenda item 4.1.3, I have polled several members of the Amateur Broadband user and development communities in our Division, and they are universally concerned that access to Amateur-modifiable commercial equipment will be shut down as a result of this rulemaking. Notwithstanding your observations about the wording in the existing rules (ODV-24666), one developer told me that Ubiquiti (the supplier of choice these days) expects to modify its product to eliminate the use of Open-WRT as a result of the new rule. Even if an exemption is granted for Hams, it is very unlikely that any manufacturer will continue to produce a modifiable version of their consumer products for the relatively tiny Amateur market.
Below are some other observations from the manager of the AREDN project team.
73,
Marty N6VI
Here is a synopsis of AREDN Project concerns:
· While modifications to type approved radios are allowed under the grant of our licenses and further allowed under existing and proposed rules, following the FCC’s guidance shuts off all such modification in the 5 GHz ham band.
· Typically, at the core of Wireless ISP devices is a single chip intended for multiple markets. Locking this chip down is the only viable way of ensuring conformance to the FCC guidance. In doing so, vendors are likely to do so across all of their product lines… effectively preventing the use of all 802.11 technologies within the ham bands. This includes recent advances into 3 GHz where Emcomm use of the technology has the best chance of success. Due to the relatively small market hams represent to these manufacturers, it is not likely they will offer a version specifically for us.
· Implementations of proposed rules, as described in the FCC guidance, will make it difficult, if not impossible to enhance spectrum usage (develop, test, and implement new RF protocols) due to the limited open source development that will be allowed to take place.
· Violations cited as the rationale for locking the software have all been by professional installers using stock manufacture’s firmware. It seems these incidents could be far better handled through the existing Notice of Potential Liability fine system with increased fines for endangering lives.
· It seems inconsistent with FCC enforcement history to impose such broad restrictions on users… the result of which stifles creative advancement of the art.
· Locked down device firmware increases the likelihood of cyber security risk and prevents the user community from being able to have control their network assets.
*From:* arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org <javascript:_e(%7B%7D,'cvml','arrl-odv-bounces@reflector.arrl.org');>] *On Behalf Of *Sumner, Dave, K1ZZ *Sent:* Monday, September 28, 2015 12:17 PM *To:* arrl-odv *Subject:* [arrl-odv:24708] Draft agenda for October 3 EC Meeting
Attached is the agenda for this coming Saturday’s meeting of the Executive Committee.
73,
Dave K1ZZ