IAB Comments to FCC on Rules regarding Authorization of Radiofrequency Equipment
statement-iab-comments-on-fcc-15-92-00
Document | Type | IAB Statement | |
---|---|---|---|
Title | IAB Comments to FCC on Rules regarding Authorization of Radiofrequency Equipment | ||
Published | 2015-10-07 | ||
Metadata last updated | 2023-08-09 | ||
State | Active | ||
Send notices to | (None) |
statement-iab-comments-on-fcc-15-92-00
On 7 October 2015, the IAB provided comments to the FCC on their proposed Amendment of Parts 0, 1, 2, 15 and 18 of the Commission’s Rules regarding Authorization of Radiofrequency Equipment (FCC 15-92):
The Internet Architecture Board (IAB) welcomes the efforts of the FCC to
simplify its procedures and to accelerate the verification processes
associated with Radio Frequency devices. We note, however, that there
may be additional clarification needed in one aspect of the proposed
rule making. As set out in Paragraph 20 of Notice of July 21st, the
document proposes that device manufacturers "incorporate software
security features that permit only those parties that have been
authorized by the manufacturer to make changes to the device's technical
parameters."
The IAB welcomes the focus on security, but notes that software security
features of this type must be broad enough to permit device firmware
updates by parties other than the manufacturer itself. This is necessary
first because a manufacturer ceasing operation would otherwise leave all
hardware orphaned from update, which itself poses significant potential
security risks. It is also necessary because many radio frequency
devices originally intended for one set of use cases have been adapted
by the experimental and open source communities for new uses. Closing
off this source of innovation and advancement is clearly counter to the
interests promoted by the FCC.
We encourage the FCC to amend this plan to require both software
security features and a clearly defined program by which authorization
for access to these update features can be granted; this program should
be as simple as possible, so that open source communities, academia, and
other experimental efforts may be sustained.
Respectfully submitted,
Andrew Sullivan (IAB Chair)
for the IAB