There’s still a chance to save WiFi

You may not know it, but wifi is under assault in the USA due to proposed FCC regulations about modifications to devices with modular radios. In short, it would make it illegal for vendors to sell devices with firmware that users can replace. This is of concern to everyone, because Wifi routers are notoriously buggy and insecure. It is also of special concern to amateur radio hobbyists, due to the use of these devices in the Amateur Radio Service (FCC Part 97).

I submitted a comment to the FCC about this, which I am pasting in here. This provides a background and summary of the issues for those that are interested. Here it is:

My comment has two parts: one, the impact on the Amateur Radio service; and two, the impact on security. Both pertain primarily to the 802.11 (“Wifi”) services typically operating under Part 15.

The Amateur Radio Service (FCC part 97) has long been recognized by the FCC and Congress as important to the nation. Through it, amateurs contribute to scientific knowledge, learn skills that bolster the technological competitiveness of the United States, and save lives through their extensive involvement in disaster response.

Certain segments of the 2.4GHz and 5GHz Wifi bands authorized under FCC Part 15 also fall under the frequencies available to licensed amateurs under FCC Part 97 [1].

By scrupulously following the Part 97 regulations, many amateur radio operators are taking devices originally designed for Part 15 use and modifying them for legal use under the Part 97 Amateur Radio Service. Although the uses are varied, much effort is being devoted to fault-tolerant mesh networks that provide high-speed multimedia communications in response to a disaster, even without the presence of any traditional infrastructure or Internet backbone. One such effort [2] causes users to replace the firmware on off-the-shelf Part 15 Wifi devices, reconfiguring them for proper authorized use under Part 97. This project has many vital properties, particularly the self-discovery of routes between nodes and self-healing nature of the mesh network. These features are not typically available in the firmware of normal Part 15 devices.

It should also be noted that there is presently no vendor of Wifi devices that operate under Part 97 out of the box. The only route available to amateurs is to take Part 15 devices and modify them for Part 97 use.

Amateur radio users of these services have been working for years to make sure they do not cause interference to Part 15 users [3]. One such effort takes advantage of the modular radio features of consumer Wifi gear to enable communication on frequencies that are within the Part 97 allocation, but outside (though adjacent) to the Part 15 allocation. For instance, the chart at [1] identifies frequencies such as 2.397GHz or 5.660GHz that will never cause interference to Part 15 users because they lie entirely outside the Part 15 Wifi allocation.

If the FCC prevents the ability of consumers to modify the firmware of these devices, the following negative consequences will necessarily follow:

1) The use of high-speed multimedia or mesh networks in the Amateur Radio service will be sharply curtailed, relegated to only outdated hardware.

2) Interference between the Amateur Radio service — which may use higher power or antennas with higher gain — and Part 15 users will be expanded, because Amateur Radio service users will no longer be able to intentionally select frequencies that avoid Part 15.

3) The culture of inventiveness surrounding wireless communication will be curtailed in an important way.

Besides the impact on the Part 97 Amateur Radio Service, I also wish to comment on the impact to end-user security. There have been a terrible slew of high-profile situations where very popular consumer Wifi devices have had incredible security holes. Vendors have often been unwilling to address these issues [4].

Michael Horowitz maintains a website tracking security bugs in consumer wifi routers [5]. Sadly these bugs are both severe and commonplace. Within just the last month, various popular routers have been found vulnerable to remote hacking [6] and platforms for launching Distributed Denial-of-Service (DDoS) attacks [7]. These impacted multiple models from multiple vendors. To make matters worse, most of these issues should have never happened in the first place, and were largely the result of carelessness or cluelessness on the part of manufacturers.

Consumers should not be at the mercy of vendors to fix their own networks, nor should they be required to trust unauditable systems. There are many well-regarded efforts to provide better firmware for Wifi devices, which still keep them operating under Part 15 restrictions. One is OpenWRT [8], which supports a wide variety of devices with a system built upon a solid Linux base.

Please keep control of our devices in the hands of consumers and amateurs, for the benefit of all.










2 thoughts on “There’s still a chance to save WiFi

  1. Thanks for the insights into the american plans concerning this topic! But this not only applies to american law, but the europeans have put the same ideas in a EU-guideline which has to be transformed into law by the EU’s memberstates – by 13th June 2016.
    Apart from that, certain limitations already apply for the 5GHz band in the US from what i read in a german article.

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