There is no possible regulation of iOT software upgrades/downgrades/sideloads or installs from the US Government, the FCC, or any other regulatory agency of any other country on the planet we call "Earth".

No hardware or software product can be regulated "to function properly" or "for any period of time" beyond the moment of its sale, and receipt of orderly condition by its consumer regardless of the expectation of perpetuity by a consumer of its potential for hardiness over a period of time due to its "solid state circruitry" or backing by "standards bodies", or large well capitalized companies which to this day deliver expensive products to consumers in the guise of "new-ness", which will not function by-design in a few short years.

This FCC proposed regulation is not just folly, ignores the state of the software/hardware market going back several decades, ignores standard tech industry business practices, consumer reality going back decades and tries to create a "phony", invented hardware/software "category", called "IOT" which is just a marketing term invented by the tech industry to sell into established embedded, industrial, commercial, and domestic markets things which are more or less obvious and some which are less obvious. But iOT is a full stop marketing term that means literally nothing except there's some semblance of a computer running some semblance of software in SOMETHING.

As such, being a product of marketing and enticing people to embed, extend or purchase as part of a larger system "half baked" electronics running "half baked" software that may or may not work tomorrow is simply not novel, special or imperative to any possible regulatory regime unless that regime has the completely innoble, unnenforceable, and mundane title of "Buyer Beware".

It is in this sense in which I must call out the abject and unforgivable immaturity of the FCC for having the immaturity to neither understand the markets as they have existed for decades, the market forces that drive the current behavior and the lack of specialness of the recipient of ANY product, that is a civilian or government consumer who purchases on a lark some product of any category and has a foregone expectation which can never be satisfied to the fullest due to naivte, and the lack of proper inspection prior to purchase.

But rather than try to convince this esteemed committee, I will reject this proposal from the FCC based on the following OBVIOUS prior art in the age of planned obsolescence.

1) There is no discrete, nor regulatable device category that exists under the name iOT - iOT is a marketing term.
2) If there WERE such a category of devices there would be no way to exclude mobile devices such as cell phones or desktop computers from it.
3) Computers running software whether embedded or not cannot be regulated for content, durability or express suitability for a purpose outside of an EXPLICIT contract between seller and purchaser. Regulatory bodies are not capable of establishing such a contract between the tech industry and any consumer.
4) The biggest collection of iOT devices ever produced by the US government, is no longer reproducible, the circuitry and software in the orbiters and landers in the moon missions. The US government cannot possibly hold industry to a higher standard than it itself can produce.
5) Noone on the committee seems to have even the slightest knowledge that every modern cellphone is designed to NOT run software after a decaying series of updates intentionally renders it obsolete.
This includes garage door openers, battery chargers for transportation devices, heart monitors, mp3 players, note takers calendars, email apps, messaging apps, home automations clients and any other app that has been made or can be made to run on a cell phone. Not a single piece of software on a modern iphone, runs on the first iPhone.
6) The products and services of a company that may or may or may not exist tomorrow has never been nor will ever be made reproducible due to a government mandate. I will support this proposal when I can buy a new 1967 Corvette.
7) In essence the treating of a phony marketing category of computer is just more govt overreach of trying to regulate the software and hardware components of products which are no different than any other products on the market that break, cease to be sold and often failt o live up to marketable expectations. No govt can put the burdens of regualtion sought in this proposal on any company regardless of product. Its illegal, and Unconstitutional, unworkable, and flies in the face of common sense.