Save WiFi/Joint Letter

This the joint letter that will be submitted by the groups to the FCC in reply to the NPRM for Save WiFi

Issues?

Although the signers believe that Commission has the best of intentions, the signers believe that the NPRM is a dangerous intrusion upon the rights of computing users, harms the ability of companies to collaborate with communities and customers and {does something bad} interferes with companies reselling technology.

Incorporate contents from: Save_WiFi_letter_language

Innovation

Innovation in network and wireless technology depends on the ability of users and resellers to experiment with software and hardware at the deepest levels. CeroWrt, an open source router firmware, developed a fix for an important form of network congestion called Bufferbloat. This fix is was added to the Linux kernel to be used by the billions of users of Linux. Mesh networking technologies for developing stable distributed internet access are regularly implemented using various versions of Linux installed by an end-user and much research and implementation on mesh networking has occurred outside of manufacturers. Nearly 7,200 scholarly articles on wireless networking technologies reference a particular brand of open and modifiable hardware which would be banned under these rules. Without the ability to change the software on the device, these innovations would not have occurred. Additionally, innovations done by the community are later often picked up by vendors and being integrated into their first-party software versions for their next generations of devices.

Recommendations

The signers respectfully recommend the following changes:

The regulations on software defined radios should not restrict the ability to replace software on computing devices

As written, the regulations require that manufacturers prevent modification of all software computing devices which use software defined radios. The Commission should amend the regulations in a manner which protects the traditional right of law abiding users to understand and improve the software on their devices.

The regulations on e-labels should not restrict the ability to replace software on computing devices

The signers appreciate the need for proper labeling of wireless devices and the requirements set by Congress in the E-Label Act. The Commission should amend the regulations to guarantee electronic labels do not interfere with the ability of downstream parties to install any software they so choose.

Conclusion

The signers share the commission's interest in protecting the wireless spectrum. As the Commission deliberates on the NPRM, we invite the Commission to meet with signers, the computing industry, users, free and open source software advocates and all interested parties. Through a collaboration between all interested parties, we believe the wireless spectrum can be protected while enabling the innovation and freedom key to American competitiveness in the 21st century.