[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
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] 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
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
Marty et al - Same is true with folks involved with mesh networking across the Rocky Mountain Division and those separately involved with the fielding, expansion, and management of a huge Part 97 point-to-point microwave backbone/network that presently spans southern Wyoming, through Colorado, down into central New Mexico. Manufacturers potentially clamping down on their gear would significantly hamper or perhaps halt further expansion of these technologies across the amateur radio community. 73, Brian N5ZGT From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Marty Woll Sent: Wednesday, September 30, 2015 3:12 PM To: 'Sumner, Dave, K1ZZ'; 'arrl-odv' Subject: [arrl-odv:24711] Re: Draft agenda for October 3 EC Meeting 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] 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
It seems to me that the issue that the EC will address on Saturday is whether the new rules actually change the situation now with respect to modifying network equipment. It is not at all clear that they do. However, there is obviously confusion about the rules on this subject and we have dealt with it before in the SDR docket. The rule with respect to modifying amateur equipment is old and was created precisely to deal with linear amplifiers and doesn't address the widespread concern Marty and others raise. I think it likely that the EC will decide to address flexibility in commercial equipment modification by radio amateurs for their own use in the comments due a week from tomorrow. 73, Chris W3KD Sent from my iPhone
On Oct 1, 2015, at 12:01 AM, Brian Mileshosky <n5zgt@swcp.com> wrote:
Marty et al –
Same is true with folks involved with mesh networking across the Rocky Mountain Division and those separately involved with the fielding, expansion, and management of a huge Part 97 point-to-point microwave backbone/network that presently spans southern Wyoming, through Colorado, down into central New Mexico. Manufacturers potentially clamping down on their gear would significantly hamper or perhaps halt further expansion of these technologies across the amateur radio community.
73, Brian N5ZGT
From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Marty Woll Sent: Wednesday, September 30, 2015 3:12 PM To: 'Sumner, Dave, K1ZZ'; 'arrl-odv' Subject: [arrl-odv:24711] Re: Draft agenda for October 3 EC Meeting
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] 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
_______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv
Thanks, Chris. The comments file on this proposal include the record of an interesting exchange between the FCC and the Free Software Foundation In it, the FCC states, “In 2014, 47CFR15.407 was updated to include rules that would require manufacturers to put in place mechanisms that would restrict a user’s ability to control or modify the software that controls the radio.” Do we know – or can we find out – whether that 2014 rule change went through the public exposure and comment process? It would seem that, as far as U-NII devices, that’s when the alleged damage was actually done. If it did not go through the NPRM process at that time, that may explain why interested users (and, perhaps, some manufacturers) are only now learning about the limitations that Mesh ops find concerning. If it did not go through the NPRM process at that time, should it have? 73, Marty N6VI From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Chris Imlay Sent: Thursday, October 1, 2015 3:20 AM To: Brian Mileshosky Cc: arrl-odv Subject: [arrl-odv:24714] Re: Draft agenda for October 3 EC Meeting It seems to me that the issue that the EC will address on Saturday is whether the new rules actually change the situation now with respect to modifying network equipment. It is not at all clear that they do. However, there is obviously confusion about the rules on this subject and we have dealt with it before in the SDR docket. The rule with respect to modifying amateur equipment is old and was created precisely to deal with linear amplifiers and doesn't address the widespread concern Marty and others raise. I think it likely that the EC will decide to address flexibility in commercial equipment modification by radio amateurs for their own use in the comments due a week from tomorrow. 73, Chris W3KD
Marty, that proceeding was Docket 13-49. The ARRL publicized the proceeding and filed comments at the time. Our principal focus was on 5850-5925 MHz. Dave From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Woll, Marty, N6VI Sent: Thursday, October 01, 2015 8:26 AM To: Imlay, Chris, W3KD; Mileshosky, Brian, N5ZGT Cc: arrl-odv Subject: [arrl-odv:24715] Re: Draft agenda for October 3 EC Meeting Thanks, Chris. The comments file on this proposal include the record of an interesting exchange between the FCC and the Free Software Foundation In it, the FCC states, “In 2014, 47CFR15.407 was updated to include rules that would require manufacturers to put in place mechanisms that would restrict a user’s ability to control or modify the software that controls the radio.” Do we know – or can we find out – whether that 2014 rule change went through the public exposure and comment process? It would seem that, as far as U-NII devices, that’s when the alleged damage was actually done. If it did not go through the NPRM process at that time, that may explain why interested users (and, perhaps, some manufacturers) are only now learning about the limitations that Mesh ops find concerning. If it did not go through the NPRM process at that time, should it have? 73, Marty N6VI From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Chris Imlay Sent: Thursday, October 1, 2015 3:20 AM To: Brian Mileshosky Cc: arrl-odv Subject: [arrl-odv:24714] Re: Draft agenda for October 3 EC Meeting It seems to me that the issue that the EC will address on Saturday is whether the new rules actually change the situation now with respect to modifying network equipment. It is not at all clear that they do. However, there is obviously confusion about the rules on this subject and we have dealt with it before in the SDR docket. The rule with respect to modifying amateur equipment is old and was created precisely to deal with linear amplifiers and doesn't address the widespread concern Marty and others raise. I think it likely that the EC will decide to address flexibility in commercial equipment modification by radio amateurs for their own use in the comments due a week from tomorrow. 73, Chris W3KD
Thanks, Dave. That was well before the AREDN project was launched in San Diego and perhaps before the BBHN group in Texas turned its attention from old Linksys routers to the newer Ubiquiti hardware platforms. Apparently no one knew at the time to bring the software-mod issue to our attention. In any case, the inclusion of flexibility comments as Chris suggested is appropriate. Sorry for the bandwidth (no pun intended) on this issue, but it has become a hot topic among some members. When the League releases a story concerning our filing of comments, it may be helpful to include a few words of explanation as to what rules changed when. 73, Marty N6VI From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Sumner, Dave, K1ZZ Sent: Thursday, October 1, 2015 5:49 AM To: Woll, Marty, N6VI; Imlay, Chris, W3KD; Mileshosky, Brian, N5ZGT Cc: arrl-odv Subject: [arrl-odv:24716] Re: Draft agenda for October 3 EC Meeting Marty, that proceeding was Docket 13-49. The ARRL publicized the proceeding and filed comments at the time. Our principal focus was on 5850-5925 MHz. Dave
Thanks, Marty. I’m all in favor of accepting the FCC’s invitation to offer clarifying language for 2.1043(h) to make it clear that the amateur exemption applies generally. Dave From: Woll, Marty, N6VI Sent: Thursday, October 01, 2015 9:11 AM To: Sumner, Dave, K1ZZ; Imlay, Chris, W3KD; Mileshosky, Brian, N5ZGT Cc: arrl-odv Subject: RE: [arrl-odv:24716] Re: Draft agenda for October 3 EC Meeting Thanks, Dave. That was well before the AREDN project was launched in San Diego and perhaps before the BBHN group in Texas turned its attention from old Linksys routers to the newer Ubiquiti hardware platforms. Apparently no one knew at the time to bring the software-mod issue to our attention. In any case, the inclusion of flexibility comments as Chris suggested is appropriate. Sorry for the bandwidth (no pun intended) on this issue, but it has become a hot topic among some members. When the League releases a story concerning our filing of comments, it may be helpful to include a few words of explanation as to what rules changed when. 73, Marty N6VI From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Sumner, Dave, K1ZZ Sent: Thursday, October 1, 2015 5:49 AM To: Woll, Marty, N6VI; Imlay, Chris, W3KD; Mileshosky, Brian, N5ZGT Cc: arrl-odv Subject: [arrl-odv:24716] Re: Draft agenda for October 3 EC Meeting Marty, that proceeding was Docket 13-49. The ARRL publicized the proceeding and filed comments at the time. Our principal focus was on 5850-5925 MHz. Dave
participants (5)
-
Brian Mileshosky -
Chris Imlay -
G Widin -
Marty Woll -
Sumner, Dave, K1ZZ