The topic at hand is how hotels are allowed to manage Wi-Fi communications on their own properties. It started with the Gaylord Opryland, managed by Marriott, interfering with guests’ Wi-Fi by blocking their Wi-Fi connections to their personal hotspots. After the FCC received a complaint from a guest, the FCC conducted an investigation. On October 3, 2014, a public consent agreement with a $600,000 fine was announced between the FCC and Marriott. In August, 2014, while the FCC investigation was being conducted, a petition for rulemaking was submitted to the FCC by the AHLA, Marriott and Ryman properties, asking for permission to interfere and for clarification of the FCC rules.

The topic was debated through public opinion and legal briefs were submitted for and against, but with guests’ comments overwhelmingly against until January 14, 2015, when Marriott announced it would not pursue getting permission to block guests from using their personal Wi-Fi devices. Marriott listened to its customers, but this does not mean the issue has gone away, only that hospitality providers need to address it within the current boundaries of the FCC guidelines.

What’s the Big Deal?
The issue remains: Should a hotel be able to interfere with Wi-Fi communications on its own property if such Wi-Fi communications either present security risks such as spoofing the hotel Internet or producing Wi-Fi congestion that inhibits the hotel’s guests from using the Wi-Fi service provided by the hotel? Additionally, since equipment exists that is FCC-approved to allow a hotelier to interfere and block Wi-Fi communications, does the fact that the FCC has approved the equipment allow a hotelier to use it to manage the Wi-Fi environment?

There are also responsibility and liability topics to address. Is a hotel responsible for its guests’ data security if they use Wi-Fi in a guestroom, lobby or convention area that is not provided by the hotel? If their data is stolen off their laptop via a nefarious Wi-Fi network while the laptop is in the hotel room, where does liability fall?

The consent decree agreed to by both sides makes clear that the FCC currently does not think a hotelier or any other entity, has any right to interfere with or block Wi-Fi signals, but it leaves in question what rights and responsibilities a hotelier or any facility that provides public Wi-Fi has.

There are many technical and policy issues surrounding providing secure and reliable Wi-Fi to hospitality guests. Wi-Fi is a valuable service hotels provide. The weak link is that Wi-Fi is delivered via public frequencies which are open equally to everyone. (See Jeff Parker’s article on page 118.) Ultimately, this is not a problem to be entirely solved today, but one that will evolve as policies and technologies are developed over the next few years.

Wi-Fi History
Today’s Wi-Fi is based on two unlicensed radio spectrums. As unlicensed spectrums, they are available for anyone to use and not owned by any entity. This is unlike the radio spectrum your mobile phone uses, which the carrier owns and has exclusive rights to use and manage. Any individual or company can use the Wi-Fi radio spectrums and has equal rights to use them. No individual or company can infringe on these rights nor can they interfere with others’ rights to use them.

Wi-Fi is generally understood to be defined by the IEEE under a set of specifications in the 802.11 standards.  Each specification introduces features such as speed and security improvements defined by letters following the number such as 802.11b or 802.11n. The 802.11 standards started with “a” and “b,” with the latest version available being “ac.” Wi-Fi is an international standard which has helped it reach ubiquity worldwide.

Wi-Fi communications occur over one of two radio frequencies or spectrums. These are 2.4GHz and 5GHz. Early popular Wi-Fi started with 802.11b and 802.11g, which use the 2.4GHz spectrum. 2.4GHz has a traffic limitation equivalent to a three-lane highway. It has only three usable, non-overlapping channels that can be active without congestion or co-channel interference. Each access point must select a channel to serve. Two access points within range of each other can use the same channel, though they cannot use it at the same time, as it would create congestion, reduce throughput, and in an extreme case, could make the channel entirely unusable.

Standards such as 802.11n and the new 802.11ac use the 5GHz radio spectrum. They have more lanes, though the total number depends on which country you are in and the abilities of the device you are using. 802.11ac provides at least eight or more than 100 usable channels depending on the location and implementation of the standard.

Many factors can affect Wi-Fi communications including interference from non-Wi-Fi devices, competition of Wi-Fi devices for unique channels, and advances in communication technologies that offer innovative enhancements to providing Wi-Fi service.

Wi-Fi is Everywhere
Wi-Fi is found everywhere. It is expanding to a wide array of personal, wearable devices with the Internet of Things, a host of sensors to monitor our environment.

Internet access via Wi-Fi is an expected amenity that hotels and other hospitality companies must provide. It is consistently ranked as the No. 1 guest amenity above free breakfasts, room service or even having a restaurant or spa onsite. Organizations spend money on infrastructure and ongoing service to meet this expectation. As with all technology, it will continue to evolve and be upgraded. As an example, the newest Wi-Fi version, 802.11ac, increases to gigabit speeds, improves reliability and adds capability for more devices per access point. Most hotels are not installed with this latest standard.

Congestion and security are the two primary concerns in a Wi-Fi environment. Congestion is a bigger issue when additional Wi-Fi access points are brought into the environment, as they compete for the same airspace as the existing access points. Most mobile phones, tablets and stand-alone MiFi devices are capable of being Wi-Fi access points. Should every visitor to a convention center have one of these devices, it becomes evident that the airspace will become congested very fast.

Besides congestion, there is a security concern. Should someone turn on an access point that spoofs the name of the establishment and tricks guests into connecting to the Internet through it, guests’ passwords and other information could be captured and stolen. Ron Peterson from hospitality Wi-Fi Internet provider Blueprint RF said, “The issue is between the access point and laptop. If you don’t connect to the right Wi-Fi network, you have issues.”

Options for Hoteliers
The newer Wi-Fi standards provide more than additional bandwidth. They provide more ways to deal with these issues. With newer devices supporting 802.11ac along with better equipment and antenna options, hoteliers can address congestion issues. United Kingdom-based service provider Air Angel indicated that with newer equipment and controllers, its company has not seen congestion having a huge impact on providing reliable service. Updating equipment to increase reliability can be costly and take time but the return is a better guest experience and the likelihood of guests using the hotel’s wireless rather than turning on their own.

The standards have evolved, providing more performance and management abilities. One significant advancement is having multiple transmitters/receivers in a single access point. This Multiple In Multiple Out (MIMO) technology has both improved performance and reduced congestion by bonding channels. The new 802.11ac standard defines a beamforming technology using MIMO that instead of broadcasting a signal every direction, is able to focus the signal in the direction of the device with which it is communicating. This improves communications and reduces overall wireless congestion.

There are ways to enhance wireless and Internet service with both equipment and software. And the number of vendors offering wireless technology has grown significantly in the past several years. Traditional players offer complete lines of standard equipment and software. Newer innovative vendors, such as Ruckus Wireless, have leveraged technologies such as adaptive antenna arrays which, like beamforming in 802.11ac, allows direct targeting of older standards wireless devices. This does not increase their speed or other capabilities but can reduce congestion of the Wi-Fi space.

New equipment and technology will help improve service to guests. But guidance is needed from the FCC as to what actions are acceptable in securing against spoofing and other issues that affect guests of the hotel. The technology exists, with equipment currently approved by the FCC, to mitigate access points that may be operating nefariously. When it is reasonable and lawful to act and use this equipment is unclear. It is also unclear to what extent a hotel is responsible for this type of security risk to guests on its property.

At a minimum, hotels should implement a Wi-Fi information policy to educate guests as to what the hotel-provided Wi-Fi services are named. Additional information advising that any other Wi-Fi service is not provided by the property and should not be used. Simply telling guests that Wi-Fi is offered without specific details and names is not enough to protect guests and provide service. It is the hotelier’s responsibility to educate and assist guests in protecting their data while on property.

Mark Munger is an independent consultant specializing in hospitality and gaming systems. He can be reached at mark@markmunger.com.