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FCC vs. Hotels vs. Consumers

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March 01, 2015
Jeffrey Stephen Parker

I am as bad as anyone. I will sit in a pub or a hotel lobby and look for free networks before selecting a pay for network provided by the establishment, even though I know I am potentially opening my equipment and my identity up to the legions of hackers, activists and the FBI. I kid myself that I am an expert and my computer is protected, but that expertise also lets me know better.

We all realize that Wi-Fi has become more important than hot water or ESPN for hotels. Operators are constantly fighting a battle for quality, bandwidth and coverage. However, more and more attacks are being launched either from our networks, or against our networks, and there is a more nefarious trend toward creating network spoofs, called honey pots, that target our guests. We are left with fighting a multifront battle, and the U.S. FCC is sitting on one of those fronts, in many ways preventing hotels from battling the evil-doers to protect consumers from the big hotel business.

Many hotels live in incredibly dense urban centers, where there are dozens if not hundreds of competing networks. Operators live with balancing the guest requirement of stable, fast, reliable networks with the restrictions of the Wi-Fi systems themselves. While Wi-Fi networks can broadcast on 11 channels, only three are true channels (1, 6, 11) and saturation on any of these can degrade the broadcast signal. (See Mark Munger’s article on page 44 for more technical information on these signals.) It is impossible to put a Faraday cage around our hotels, blocking all external wireless networks, so we have looked to technology to build stronger networks and provide isolation from the competing signals. With recent rulings from the FCC, we are left questioning what we really can do.

Marriott made front page headlines when it was found to be blocking guests from standing up their own hotspots in their meeting rooms or guestrooms. The FCC has even taken credit for the number of hotels jumping on the free Wi-Fi trend. A great deal of this is misinformation at best, and political double talk at the worst.

According to Marriott, the blocking in question was at one of its Gaylord properties. The Gaylord hotels are cities unto themselves, sitting on acers of land with a large number of rooms and restaurants/bars/pools/meeting space throughout. The instance in question was one where a third-party business was standing up a cellular-based hotspot to sell competing Internet to meeting room guests. The hotel interfered with the signal to thwart this attempt. One side of the coin is the Gaylord was acting to protect its revenue stream (we are still in the revenue business, right?), and the other is that the hotel was only acting to prevent a third party from launching an attack on the property's guests and interfering with the service for which the client hosting the meeting paid.

FCC Title 47 part 15 sets limits on devices that radiate in an unlicensed spectrum. All of the access points and wireless systems commonly deployed in hotel and restaurant operations are licensed under this title. Check the unit. It will have the FCC’s seal of approval. The need for clarification on what happens when a licensed device is used to protect networks is more critical now that the recent rulings seem to take this tool out of a network manager’s tool box.

Honey pots, or rogue networks, are networks set up to collect information from users who unsuspectingly connect to these access points. Often with SSIDs identical or very similar to the ones of the target environment. Do hotels have a right to prevent these networks, and protect our guests from the villains?
In addition to honey pots, there are botnets, software unbenounced to the user that lives on their computer. Botnets live to bind processing power from many computers together to hack into larger systems, or launch distributed denial of service (DDOS) attacks to make the target networks so busy they cannot respond as intended to. Botnets are often targeting data associated with identity theft, but also governmental organizations and military ones. The botnet grows by infecting other computers open to their attacks, and they spread even further.
Then there is the non-nefarious signal competitors, mobile hotspots and ultra-portable access points. I am again guilty on both charges, and have no problem justifying it to myself. Mobile hotspots are great for the traveler, virtually guaranteeing omnipresent Internet, even if the hotel or coffee shop has bad service. However, they also use the same channels, and are often defaulted to channel 1 or 6. Looking at a network analysis for one of our hotels, I have seen dozens of Sprint, Verizon and AT&T hotspots sitting on channel 6 flooding that frequency. Our networks are set to react and balance to the other channels, but in the end the other guests are being impacted, and complaints go up. (“I get five bars of signal, but cannot connect.” Sound familiar?)

With all this going on, we also have the requests of our guests, often from government contractors, to set up protected networks to prevent external attacks. I have even seen hotels put up the Faraday cage in the walls of certain meeting rooms to isolate them. One clarification I would like to see is, if the network is private, requested by the client (guest) to be so, what can be done within the rules? When does it cease to be a public network?
The American Hotel and Lodging Association (AH&LA) recently formed a taskforce to address these issues, and provide an open communication channel between the FCC, the U.S. Senate and many of the major players in the Internet Service Provider (ISP) space. The overall goal is to clarify the FCC’s position on Part 15 devices in public and private networks, and educate as to when some level of blocking is designed to improve guest experience, and even protect guests.

In the end, this is yet another example, in a very long list, of government regulation not being agile to keep up with technology, threats and services. I believe that once the FCC understands that it is not Big Business (hotels in this case) versus the consumer, rather it is villains versus hotels and consumers, then it will help us clarify the specifics of the rules. There has to be a way for hotels and other operations like coffee shops and pubs, to have the ability to protect themselves and their patrons.

Jeffrey Stephen Parker, vice president of technology for Stout Street Hospitality is also the Chair of AH&LA's Technology Subcommittee on Data Protection and part of the AH&LA task force on cyber security.

More details on Title 47 can be found at http://www.fcc.gov/encyclopedia/rules-regulations-title-47

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