The ability to install custom, free software on radio devices is crucial to both the free software movement and to amateur radio operators. This legislation will worsen vendor lock-in and further cement spectrum enclosure. There is already legislation in all member states punishing spectrum misuse, which means that this proposal does nothing but punish experimenters, high-speed multimedia radio (HSMM), emergency communication (EMCOMM) projects, AMPRnet users and on. These uses and many others rely on there existing ubiquitous, cheap radio hardware manufactured at commercial scale. Project like OpenWRT might become entirely unworkable should article 3(3)(i) pass.
Specifically in regard to the impact assessment:
>Increased security and safety for EU citizens in the digital society and economy.
The inability of the user to inspect and patch radio software will *worsen* their security, not improve it. The same applies to protecting personal data. If the software in my radio can't be inspected or fixed, then it cannot be trusted.
It should be noted that currently a user may choose to alter a device's *hardware*, making the device non-compliant. Since a user is free to do so, so long as they don't cause harmful interference, then they must also be free to alter the software as they see fit, provided they again do not cause interference. As more hardware moves into software, this need in fact becomes essential. Or put in other words: if I can take a soldering iron to a device, I should also be able to take a compiler to it.
Personally I'd like to see the Commission take the opposite stance: require all radio software to be 100% free and modifiable, to ensure user freedom and to encourage innovation in the electromagnetic field (pun intended).
Tomas Härdin, callsign SA2TMS, research engineer at Umeå University
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