[FCC] Comment template

Nate Cardozo nate at eff.org
Tue Sep 8 15:38:41 PDT 2015


This is great. We at EFF are likely going to do a public tool (such as
we did with dearfcc.org) to facilitate comments. Any objections to that?

Nate Cardozo | Staff Attorney
Electronic Frontier Foundation | https://eff.org
nate at eff.org | +1 415.436.9333 x146
783A 8CC4 166D 1768 4E8E DAFD 2D76 4786 4AE6 3181

On 9/4/15 12:19 PM, Joshua Gay wrote:
> I think we need to update our individual comment page with a template
> for people to use when submitting their comments.
>
> I have put together an (*extremely rough*) draft that is poorly
> formatted, poorly worded, and needs lots of improvements (I know, very
> helpful of me, right?)
>
> Does anybody want to take a shot at flushing it out a little bit more or
> adding notes on things we should add to it or make it better? Are there
> any really important components missing (like citing some FCC procedural
> rule)?
>
>
>
>
> Before the Federal Communications Washington, D.C. 20554
>
> In the Matter of:
>
>    Amendment of Parts 0, 1, 2, 15 and 18 of Commission's Rules
>    regarding Authorization of Radiofrequency Equipment
>
>    Request for the Allowance of Optional Electronic Labeling for
>    Wireless Devices
>
>    ET Docket No. 15-170
>    RM-11673
>
> COMMENTS BY [NAME OR AFFILIATION] RELATED TO THE NOTICE OF PROPOSED RULE
> MAKING, FCC 15-92
>
> To whom it may concern,
>
> I am writing in regard to the Notice of Proposed Rulemaking (rel. July
> 21, 2015) (NPRM) FCC 15-92 (80 FR 46900-46928).
>
> In a world with a rapidly increase use of wireless communications
> technologies, I recognize that the Commission has a critical role to
> play in ensuring that the plethora of devices operating across the many
> parts of the spectrum can operate in a way that minimizes interference.
>
> We understand that the FCC faces a great challenge in defining the rules
> and procedures for equipment authorization. ... However, we wish to
> present our concerns that where the Commission has sought to define a
> set of "security" measures in the rules for authorizing equipment have
> perhaps cast to wide of a net, and in so doing, may ultimately undermine
> the Commission's efforts at helping to secure radio equipment from
> unauthorized use, as well as limiting important freedoms that are
> otherwise have been assured by the vast majority of computer hardware,
> and that plays an essential role in allowing for both security and
> technological innovation.
>
> In particular where the Commission proposes the following: QUOTE and
> CITE RULE CHANGE.
>
> [We then explain to people how they can, in their own words, explain how
> these proposed rules are, with maybe some suggestions like this:]
>
> * Why the proposed rules are overreaching in nature
> * Why they may hinder freedom, prevent innovation, etc.
> * Why we shouldn't prevent people from installing firmware
> * Why exclusively allowing authorized vendors to control vital portions
> of our nations communications infrastructure is bad.
>
>
>
>


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