Tanaza S.p.A.
TANAZA
Disaggregate Wi-Fi sw/hw to minimize CAPEX/OPEX of Wi-Fi deployments, with the ultimate goal to make internet accessible to everyone and fight the Digital Divide.
ID: 047303434157-61
Lobbying Activity
Response to Application of Article 3 (3) (i) and 4 of Directive 2014/53/EU relating to Reconfigurable Radio Systems
4 Mar 2019
We strongly advise against blocking the possibility to load new and third-party software (including firmware) on hardware devices manufactured by any vendor.
That would have serious implications from multiple stand-points:
1) innovation: large companies building hw/sw do not have all incentives that small companies and startups have. Blocking startups would block innovation.
2) security: many devices installed and operated in the field are not supported anymore by vendors from the SW standpoint. If a new security breach is discovered, only third party software can fix the issue.
3) environment: third-party software extend the life of hardware, for example fixing security issues (see item 2) and also improving performance. If this is blocked, more hardware would become a waste.
4) allocative efficiency: third party software can be the key to bring performance, features, and services where not possible according to the pricing of the sw/hw vendor, minimizing capex and opex. If this is blocked, large incumbents would be able to leverage their market power to extract more margins thanks to overpriced sw/hw combinations and no one could fight for a more democratic approach that has the interest of consumers at the hearth.
Forcing hw/sw certification per each software combination may not be the right answer, as it would also be non-sustainable for hw/sw vendors. For example, established incumbents may find it too expensive to improve the products every month, and would end up having one software upgrade per year instead, dramatically damaging all users.
In order to ensure that emissions are under control, a good trade-off may be reached with a-posteriori controls, with continuous monitoring of the environment, in a way that only effective breaches would generate a response and enforcement.
Having all the responsibility on the products only may not be the answer too, but if that's the path to follow, then hw/chipset vendors may be forced to store the max power and radio behavior settings at the hardware level, or anyway where cannot be modified by software.
We hope that the EC will adopt an approach that can take in considerations all aspects.
Attached, please find a study about the advantages of open networking and sw/hw disaggregation.
Best regards
Sebastiano Bertani
CEO at Tanaza S.p.A.
Disclosure: Tanaza S.p.A. developed TanazaOS, an Operational System to fully disaggregate Wi-Fi software and hardware, minimizing CAPEX and OPEX in Wi-Fi deployments to make it more affordable, ultimately connecting everyone and fighting the digital divide. Tanaza is a member of the Open Compute Project initiative (https://www.opencompute.org) and Telecom Infra Project initiative (https://telecominfraproject.com), which leverage sw/hw disaggregation, open networking and open source principles in order to make connectivity and internet more democratic and affordable for everyone.
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