Comment on ET Docket No. 15-170

Although the signers believe that Commission has the best of intentions, the signers believe that the NPRM harms computing users and substantially interferes with innovation in the wireless space.

The signers are concerned about three changes in the NPRM:

2.1033 Application for grant of certification. Paragraph 4(i),
2.935 Electronic labeling of radiofrequency devices. Clause (d) and
2.1042 Certified modular transmitters. Section 8(e)

The NPRM removes the ability of computing users to control and modify their devices. In Paragraph 4(i), the manufacturer is required to describe how the software of the device is secured against modification. Additionally, Clause (d) implies that the device must be secured against modification due to the requirement to prevent label information from being modified. Finally, Section 8(e) requires manufacturers to only allow “approved” software to be installed on a device. These requirements combined prevent most modifications to the device even when the user wants to improve on the security of the device or to correct problems with the wireless radio software itself.

The signers second many of the comments the commission has already received. Restricting the ability of law-abiding computing users to modify their devices would negatively impact them. Without the ability to modify the operating systems, drivers, and wireless radio firmware, users would be restricted to the software created by the manufacturer, regardless of its appropriateness or quality. Not only would this have a negative effect on users, it would hinder companies and organizations creating third-party operating systems and software for legal purposes, such as free and open-source operating system developers and wireless network providers. Additionally, academic and industry researchers would no longer be able to use low-cost devices for experimenting with improved radio performance and reliability. Finally, these restrictions prevent manufacturers from benefiting from and redistributing the improvements created by users.

The signers respectfully request that the commission carefully balance the important work of protecting the radio spectrum with the immeasurable value in experimentation, innovation, and freedom for law-abiding users. Additionally, the signers invite the commission and other regulatory agencies to collaborate with industry; free, open source, and proprietary software developers; and device users on developing wireless device policies and recommendations that meet the needs of regulatory agencies and protect the ability of users to inspect, modify and improve their devices.