[Cerowrt-devel] New FCC requirements and CeroWrt

David Lang david at lang.hm
Tue Dec 9 15:14:05 EST 2014

We really need to find out what the new FCC requirements are.

People have been claiming that the FCC requires all sorts of lockdowns that they 
don't actually require for decades (when I first got into Ham Radio, we were 
hearing that any radio able to operate on the business bands had to be locked 
down to prevent the owner from changing it's frequency. It wasn't true)

If they are saying that the RF portion can't be modified in a Software Defined 
Radio, that would be somewhat reasonable, saying that the software implementing 
the 802.11(whatever) protocol on that RF portion must be locked down is less so, 
and saying that the main OS on the router must be locked down is completely 

I would be surprised if they required that the OS can't be changed.

As for the implementation of the 802.11(whatever) protocol, I would be surprised 
if they required this to be locked down, but not dumbfounded

now that I've finished the rant, reading the statement quoted on that wiki page:

> Applications for certification of U-NII devices in the 5.15-5.35 GHz and the 
> 5.47-5.85 GHz bands must include a high level operational description of the 
> security procedures that control the radio frequency operating parameters and 
> ensure that unauthorized modifications cannot be made.

All that it is talking about is the radio frequency parameters.

The followup/clarification is again talking about the RF parameters.

Remember, when the FCC is talking about a 'device', they are talking about the 
radio, not the entire computer that has a radio as part of it.

According to the background, they are worried about interference with radar, so 
this could mean that the firmware needs to have a mechansim to detect the radar 
and not transmit on that frequency, but this is only a few channels. You could 
still have an opensource, non locked down firmware that just didn't give you the 
option of using those channels, and a signed firmware that did.

This does not require secure boot or any of the other lockdown methods that are 
being talked about on that page. I hope these are not the "official" openwrt 
recommendations (and if they are, why are they not on an openwrt page?)

David Lang

On Tue, 9 Dec 2014, Eric Schultz wrote:

> Dave,
> Thanks for the quick response and I appreciate your passion.
> No one here wants Secure Boot or DRM at all. I personally find the
> idea abhorrent and no one at prpl wants it. The difficulty is figuring
> out how companies can comply with the regulation in a way that doesn't
> require hardware be locked down. I wish I could avoid ever thinking of
> this topic but unfortunately, if companies don't find a solution that
> fulfills the FCC's requirements, they're going to go with DRM. I want
> to see if we can give manufacturers a solution that avoids DRM
> entirely.
> I'd be happy to learn more about the make-wifi-fast effort and to see
> how we can facilitate it's success.
> Thanks a ton,
> Eric
> On Tue, Dec 9, 2014 at 11:49 AM, Dave Taht <dave.taht at gmail.com> wrote:
>> On Tue, Dec 9, 2014 at 9:11 AM, Eric Schultz
>> <eschultz at prplfoundation.org> wrote:
>>> All,
>>> I work for the prpl Foundation, an open source foundation organized by
>>> a number of companies, most related to MIPS. One project we work with
>>> externally is the OpenWrt project. Recently one of our members
>>> mentioned a new FCC requirement (described at
>>> http://wiki.prplfoundation.org/wiki/Complying_with_FCC_rules_on_5ghz_wifi)
>>> which requires wifi hardware devices to restrict modifications in ways
>>> that were not previously required. Some of the suggestions the company
>>> had internally for complying would be to use features like Secure Boot
>>> and other types of DRM-like mechanisms to prevent routers from being
>>> modified. This obviously would be quite bad for the OpenWrt ecosystem
>> It would be bad for everyone. Worse, since the research contingent
>> making progress on keeping wifi working in the first place in the face
>> of enormous growth, is centered around the ath9k chipset, additional
>> rules and regulations centered around DRM are likely to choke off
>> further development of then new ideas and techniques needed to keep it
>> working.
>>> so we agreed as a group
>>> to try to provide hardware companies with a way of complying without
>>> harming the community.
>> My view is mildly more extreme - the 2.4 and 5.8 ghz spectrum currently
>> allocated to wifi is the *public's* spectrum.
>> I am deeply concerned about  further intrusions on it by things like this:
>> https://www.qualcomm.com/products/lte/unlicensed
>> and we need more spectrum, not less, in order to keep wifi for
>> everyone, working.
>>> I'm looking to find individuals (and other companies!) interested in
>>> working with myself and the foundation, companies, the OpenWrt
>>> community
>>> and eventually regulators to provide guidance to hardware
>>> companies on how to best comply with these rules.
>> I intend to continue ignoring them to what extent I can. Regrettably
>> this situation is contributing to community members being unable to
>> apply new queue management techniques to new standards like 802.11ac,
>> and seems to be the source of all the proprietary ac firmware.
>> I think a first step would merely to be for a big maker to publicly
>> release their 802.11ac firmware and let the chips fall where they may.
>>> If you're interested
>>> in getting involved or just would like to know more, please get in
>>> touch with me. We want to make sure that routers are hackable
>>> and we could use all the help we can get.
>> +10. I would like to see prpl participating in the make-wifi-fast effort, also.
>> http://snapon.lab.bufferbloat.net/~d/ieee802.11-sept-17-2014/11-14-1265-00-0wng-More-on-Bufferbloat.pdf
>>> Thanks and I look forward to working with you,
>>> Eric
>>> --
>>> Eric Schultz, Community Manager, prpl Foundation
>>> http://www.prplfoundation.org
>>> eschultz at prplfoundation.org
>>> cell: 920-539-0404
>>> skype: ericschultzwi
>>> @EricPrpl
>>> _______________________________________________
>>> Cerowrt-devel mailing list
>>> Cerowrt-devel at lists.bufferbloat.net
>>> https://lists.bufferbloat.net/listinfo/cerowrt-devel
>> --
>> Dave Täht
>> thttp://www.bufferbloat.net/projects/bloat/wiki/Upcoming_Talks
> -- 
> Eric Schultz, Community Manager, prpl Foundation
> http://www.prplfoundation.org
> eschultz at prplfoundation.org
> cell: 920-539-0404
> skype: ericschultzwi
> @EricPrpl
> _______________________________________________
> Cerowrt-devel mailing list
> Cerowrt-devel at lists.bufferbloat.net
> https://lists.bufferbloat.net/listinfo/cerowrt-devel

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