[Cerowrt-devel] New FCC requirements and CeroWrt

Eric Schultz eschultz at prplfoundation.org
Tue Dec 9 15:34:14 EST 2014


Thanks for the response. We're getting advice from the EFF right now,
and hopefully other groups, on what the requirement is. It's
admittedly vague and hard to separate what the FCC means versus what
developers might think.

You bring up a lot of good points that I need to add to the page to
clarify. I'm not sure in this case you can separate the radio
frequency parameters from the kernel in the case of OpenWrt. I'm not a
kernel engineer but I've tried to general understanding of how the
frequency authorization works in OpenWrt and Linux.

As I understand it, the system for deciding which frequencies to use
is included as part of the kernel in OpenWrt. The kernel uses the
frequency database to decide on what commands to send to the wifi
driver (which include changing frequency, using DFS, etc). The driver
is clearly part of the device at this point. But how should the driver
verify that the commands coming in comply with requirements? It's not
entirely clear. And how does the manufacturer guarantee that only
authorized updates are made to the device?

I want to make clear, the wiki page does not include recommendations.
These were ideas that one of our members were throwing around
internally with their development and legal team. They've asked me to
try to come up with better solutions since they don't really like any
of the ones they've come up with internally.  I'm contacting folks to
try to come up with recommendations for companies so they don't go for
the more extreme routes that unnecessarily lock down devices and hurt
the community.


On Tue, Dec 9, 2014 at 2:14 PM, David Lang <david at lang.hm> wrote:
> 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 unreasonable.
> 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

Eric Schultz, Community Manager, prpl Foundation
eschultz at prplfoundation.org
cell: 920-539-0404
skype: ericschultzwi

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