Three Inconvenient Truths and Some Conspiracy Theory About the FCC’s Mi-Fi Enforcements

The recent enforcement actions by the FCC against hotels that disrupted private Mi-Fi usage are interesting for a number of reasons. If you’re a Mi-Fi user that travels and you don’t really understand or care about the inner workings of business wireless networks, you likely did some variation of a fist-pump because evil companies must now seemingly mend their dastardly ways. (This blog may challenge the validity of that assumption, so click out of here now if you don’t want your bubble burst.) If you are a long-time wireless admin of business Wi-Fi networks, you are likely scratching your head a bit over several of the finer points of what the FCC is up to these days in going after companies like Marriott and MC Dean. I would guess that some Wi-Fi admins are feeling a bit uncomfortable but can’t quite put their fingers on why that is, but what the FCC’s doing all of the sudden just feels weird. And for those of you that are trying to keep an open mind about what it all really means as all sides of the debate try to be heard, I give you the following to ponder:

1. “Our Premises, Our Airspace to Keep Healthy” Since Late ’90s

The 802.11 Wi-Fi standard dates back to the late 90s. For over 15 years, wireless network administrators, security managers, and CTO/CEOs have been writing and enforcing policy about signals that compete with their WLAN systems and the use of “rogue” access points not put in by “Central IT”. Many of these policies pre-date Mi-Fi’s existance, but often address off-my-wire ad hoc (peer to peer, my laptop to yours) direct connect rogues that both interfere and bring their own security concerns. This is an entrenched technical cultural issue. Though Mi-Fi doesn’t meet the textbook definition of IBSS ad hoc networking, it does share the properties of being a competing Wi-Fi signal and it’s own security risk in that if you know what you are doing, you can bridge “isolated” networks to each other pretty easily. Rogue ad hoc is just as important to rogue on-wire by most WLAN policies I’ve reviewed- for both RF interference and security concerns.

All of these (and plenty more) are scraped from easily-found published private network policies on the Internet:

If there are cordless phones, ad hoc or peer-to-peer WAP’s in the prohibited frequency, [we} will attempt to notify the user in writing and ask them to remove the device.  If the device is not removed within 24 hours, [we] will take necessary actions to stop the interference of the device.

This policy covers any devices and users to adhere to the rules, regulations and policies concerning security and prevention of interference.

Due to possible interference from other sources within the 802.11 wireless 2.4GHz frequency range, [our] wireless spectrum should be kept clear of unauthorised transmissions.

Interference means the degradation of a wireless communication signal caused by electromagnetic radiation from another source. Interference can slow down or eliminate a wireless transmission depending on the strength of the interfering signal.

Interference or disruption of other authorized communications that result from the intentional or incidental misuse or misapplication of wireless network radio frequency spectrum is prohibited.

In the event that a wireless device interferes with other equipment, [we] shall resolve the interference as determined by use priority.

So, those of us administering wireless networks tend to recognize that solutions enforce policy, and the policies that guide WLAN security and interference management are nothing new. They are so ingrained in the Wi-Fi psyche from the system side that WLAN vendors and companies that train new WLAN staff are all on board with the philosophy that you can do what you need to to keep your own airspace clean and healthy for the greater good of your users, and to enforce YOUR OWN policies. And… this culture has been in place under the FCC’s own nose for all these years. Mi-FI devices are easy to lump into the spirit of long-established Wi-FI policies, with no malicious intent in doing so.

2. Non-Accommodation Equals Disruption, Too- To Users.

In convention centers where big events are going on, the Wi-Fi network will be made up of dozens (if not hundreds) of extremely low-powered WLAN cells. These cells only have limited channels to use, so staggering channels meticulously and controlling cell size is pivotal to network operation (and event success, in many cases). Along comes a Mi-Fi, with it’s often bad-neighbor config that blasts out a strength that may be an order of magnitude stronger than the conference Wi-Fi cells. As the Mi-Fi disrupts multiple cells (that other conference goers are trying to use), those same cells are also interfering with the Mi-Fi device. In these scenarios, there are typically no “free channels” so mutual interference is a fact of life.

So… I go to use my Mi-Fi at a convention center during an event, and lo and behold, it doesn’t work well. All I know from the headlines is that the FCC says it’s OK for me to do what I’m trying to do, so if it’s not working well, the stinking hotel must be trying to block me! I better report them to the FCC! It’s an outrage!  Except it’s not- it’s physics at work. So what comes next- convention centers needing to ask Mi-Fi users permission to use specific channels?

3.  The FCC Is Closing Many Field Offices, Which May Impact It’s Ability to Enforce. 

The agency is calling it an efficiency move, but what impact the cuts will have on the agency’s ability to enforce it’s own rules remains to be seen.

Let’s Play the “What If” Game A Bit

I, and others have voiced a fair amount of concern about not only what the FCC is doing with it’s new tactic of huge fines, but why it’s being done with very little substantive guidance. Even two of the five commissioners at the FCC don’t seem to agree, or to get what the agency is supposed to be accomplishing with their new fundraising campaign. With lack of leadership from the FCC, the WLAN community is left to speculate about what they could be thinking in DC. Here are a couple of theories to ponder:

  • What if the FCC really is clueless about how important Wi-FI has become to businesses of all types? What if, while we as IT organizations have been doing our best to write and enforce good WLAN policy, and have bought WLAN tools that help us to enforce those policies for the greatest number of people on our premises that rely on Wi-Fi, the FCC in it’s ivory tower was oblivious to it all for the last 15 years? What if an out-of-touch FCC is thinking one thing, while the rest of the WLAN community is basically thinking something else?  It might explain the rush to crank out big fines for what amounts to the same policy that private WLAN environments have been enforcing for the last 15 years. Because the hotels were charging big fees, they have cast the whole thing in a stinky light (and deserve to be called out on it), but the issues for the rest of us are made murky because of the FCC’s Mi-Fi related hits on the hotels and convention centers. It would seem that we all need help (that the FCC has no interest in providing) in:
    • Re-writing our business policies to accommodate Mi-Fi while still preserving our own business continuity
    • Understanding whether the hotels were only in trouble because they were trying to charge (what everyone seems to agree was too much) for their own Wi-Fi (it sure reads that way at times)
    • Or coming to grips with- if it’s what the FCC is saying- Mi-F- must be accommodated everywhere under all circumstances regardless of collateral damage from it’s interference
  • What if the FCC is just using these headline-grabbing fat fines to sew paranoia as a way to augment their enforcement capabilities as they reduce field offices and employee head-count? Uncertainty and paranoia can certainly be force-multipliers when you have the ability to name your price when handing out fines, and the bigger the fine the harder the impact of the tactic. The new-found interest in taking issue with practices that many companies have had written into their IT policies since Wireless Day 1 times out nicely with the cutting back of FCC field offices. It’s just a thought…

My personal sympathies are absolutely with those users who didn’t want to pay what the convention centers were asking for Wi-Fi. But there is so much more to the whole picture than that, and it needs to be talked about.

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