2/11 FCC Comments on Behalf of Public Interest Organizations Supporting Modernization of Consumer Device Authorization Rules

New America's Open Technology Institute wrote and filed comments with the Federal Communications Commission (Commission) urging the agency to reform its consumer device authorization rules to be more consumer-friendly. OTI filed alongside Public Knowledge, Consumer Reports and Access Humboldt, together “Public Interest Organizations” or "PIOs." The PIOs urged the Commission to modernize its rules regarding equipment authorization to permit conditional sales, but not delivery, of radiofrequency devices to consumers before they are authorized and supported the Commission's proposal “to allow a limited number of radiofrequency devices subject to Certification to be imported into the United States prior to equipment authorization for pre-sale activities, including imaging, packaging, and delivery to retail locations.” Available below is an introduction for the comments:

New America’s Open Technology Institute, Public Knowledge, Consumer Reports and Access Humboldt (“Public Interest Organizations”) respectfully submit the following comments in response to the Commission’s Notice of Proposed Rulemaking on Allowing Earlier Equipment Marketing and Importation Opportunities (“NPRM”). Commenters support the Commission’s proposals to update the equipment authorization program to ensure that consumers and industry are not hindered by outdated and cumbersome rules on device marketing and importation. As Commissioner Starks stated in voting to adopt the NPRM, updating these rules is “a good commonsense proposal” given that “[c]onsumer expectations and the market for radiofrequency devices have evolved since the Commission first established its equipment marketing rules, and this NPRM proposes rule changes that update our policies to reflect those changes.”