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> they aren't prohibiting operating systems, they _might_ be prohibiting installation of operating systems that are not approved on certain types of devices that ...

"prohibit installation" means to ban.

"operating systems that are not approved on certain types of devices that ..." means specific operating systems.

So, the FCC "might ban specific operating systems"; you've paraphrased what the title says.

I disagree - saying they might ban operating systems, with no context, leaves out the fact they're only talking about modular radio systems or software defined radio systems.

Edit: also to be clear, as another comment pointed out, this doesn't have any impact on test/kit equipment that is not compliant with FCC regulations anyway and requires a separate license to use - this is targeting consumer equipment. So I still think it's pretty misleading.

The rest is the fact that I think the article is wrong anyway :)

The context is more or less obvious from "FCC". We know from those three letters that it's not about, say, banning Ubuntu from your PC.

But the FCC regulates a great deal of equipment, and this is only targeting a very specific subset of that equipment - not all of it. I was initially pretty concerned as I'm a Ham radio operator, but this really does not concern me overly much now that it's clear it's:

A) SDR/Modular only B) Consumer only

Quite a bit of "consumer" equipment is halfway to an SDR already, and a ruling like this would mean you could never write or release FOSS firmware for a wireless card. (Note that wireless cards with FOSS firmware exist today.)

Yeah - it sucks and this FCC rules is concerning, but not as concerning as I initially thought it was.

Don't get me wrong - I think this is a stupid rule, but I just don't think it's as big a deal as the article, and title in particular, make it out to be.

and you can be certain that companies that make wireless routers and cellphones will take the easy route out and fully lock things down.

It's a title. Of course it's lacking context. If you want context, you read the rest of the essay, which explains everything you're doing much better than you are, and makes a solid case for why the FCC is, indeed, banning certain operating systems.

I still think it's kind of alarmist, but I can see your point of view as well. My goal was not to be better than their explanations, but only to summarize why I think they're being alarmist - I agree it's a topic worthy of discussion though :).

> they're only talking about modular radio systems or software defined radio systems

Which, in practice, means any computer/electronic device that has a radio in it.

> this is targeting consumer equipment

Including "consumer" equipment that is being used for research, software coding, etc.

    Which, in practice, means any computer/electronic device that has a radio in it.

No. FCC approvals apply to the modular transmitter. Another approval may apply to the overall device.

> FCC approvals apply to the modular transmitter.

Including the software that controls it. Which, in practice, includes the OS of a laptop or the firmware of a router, as discussed in the article. Technically that might not be the "entire device", but it's the part that matters.

> Which, in practice, includes the OS of a laptop or the firmware of a router, as discussed in the article.

The article is continuing to imply that the FCC is explicitly banning alt firmware for 5GHz WiFi devices. That is only the case if the module manufacturer fails to come up with any other way of getting their device approved. I don't see anywhere in the regs where banning alt. firmware is a goal of the regs.

Given that this also means a brave new world of region-locked/region-specific 5GHz WiFi devices, and the added compliance burden for integrators ("host device manufacturers") trying to use modular transmitters that rely on host device manufacturer controls to achieve FCC approval, I am hopeful that this will change the way that WiFi manufacturers lock down their radio firmware - and that is exactly what the FCC wants.

The situation where a modular transmitter places additional avoidable test/conformance/approval burden on the host device will also be a PITA for manufacturers, not just end-users.

Check my other comment here https://news.ycombinator.com/item?id=10256905

> I don't see anywhere in the regs where banning alt. firmware is a goal of the regs.

It's not an explicit goal. But the article argues (and I tend to agree) that the practical result will be manufacturers locking down their devices to prevent alt firmware from being loaded, since that will be the easiest and cheapest way for them to demonstrate compliance.

> I am hopeful that this will change the way that WiFi manufacturers lock down their radio firmware - and that is exactly what the FCC wants.

Are you saying the manufacturers will come up with some way of locking down their radio firmware that still permits something like OpenWRT to be installed on a router (or Linux on a laptop, for that matter)? Why would they bother when they could just lock the device down completely?

> Are you saying the manufacturers will come up with some way of locking down their radio firmware that still permits something like OpenWRT to be installed on a router (or Linux on a laptop, for that matter)? Why would they bother when they could just lock the device down completely?

Yes. In the actual regs (which nobody seems to read), they suggest a list ("including but not limited to") a number of mechanisms by which manufacturers may choose to control the portion of their radio software that would impact the validity on their RF testing/validation/compliance results. One of them is signed firmware blobs: to me, that's the easiest, cheapest non-invasive method for WiFi module makers that won't create a huge compliance burden on the host device manufacturer. You go from having to load an unsigned firmware blob anyway, to a signed one. Which is a huge step in the right direction for firmware security anyway. As for modules which don't have blobs but do have the means to create non-compliant emissions just through the driver: it doesn't seem like much of a stretch that they could run new region-locked revs of their modules, or at least move those previously adjustable RF parameters/behaviours over to a signed image in a $0.10 SPI EEPROM chip.

All of this isn't just a PITA for users, it's a PITA for the device manufactures as well.

Particularly for laptop manufacturers. They could save $5 locking down the entire laptop, something they've never been able to do even when they try, or they could spend the extra $5 and get the module that's got a stand-alone certification and only requires them to submit a reference to the module's own FCC approval and some demonstration that the gain of the antennas in their product are in-spec.

> One of them is signed firmware blobs

I'm not sure I understand what you're describing here. Suppose I have a router and I want to run OpenWRT on it. Are you saying that the router will have basically two "firmwares" in it? One that controls the radio chip only, and is signed, and has some kind of defined driver interface; and another that controls the rest of the device, and has a driver that talks to the signed blob, so as long as OpenWRT has that driver, I'm good?

Or suppose I have a laptop and I want to load Linux on it. Are you saying the wifi chip inside the laptop will have a signed firmware blob that controls the radio, and has a Linux driver interface, so I can load Linux on the laptop and talk to the chip?

Assuming the above is correct, how different is it from the way these devices are designed now?

FCC is talking about the radio firmware blobs which drive the radio MCU/DSP chip. That is where you have the capability to drive the device out-of-spec. Not (necessarily) the Linux environment it is being driven from. This is a discrete, separate part to the main ARM or x86 CPU running Linux (though some SoCs are blurring those lines).

We already use firmware blobs on WiFi chips. It's why OpenWRT and friends are locked into old kernel versions for some routers: they don't have the source to the WiFi radio blob and can't recompile or reverse-engineer to make it work on newer kernels with different ABI. It's why we have a /lib/firmware directory for certain drivers in Linux: the device doesn't bother with flash memory, you have to load its firmware onto the device every power cycle into the DSP chip's memory.

So for many devices currently in existence, separate radio firmware is already how things are architected.

Some devices are flashed though, and don't require the host computer to load its own firmware, which is why I discussed a smaller EEPROM that would store signed config locking down the RF parameters and other aspects affecting certification.

Basically separate radio and OS firmware are how mobile phones currently work. That's why you see separate baseband versions from your OS version info in "about this phone": these new rules for SDR devices (separate to U-NII discussion here) will actually require a whole new FCC approval for each radio firmware change.

EDIT: And we haven't properly distinguished FCC approval process differences between modular WiFi transmitters (Eg. miniPCI-e cards) used in laptops and more expensive routers, which can self-contain and solve these issues by themselves without requiring the host device to care about U-NII security measures at all, versus cheaper/integrated products that may be crappy enough to require security measures in the main host device firmware in order to guarantee the radio firmware integrity to the FCC's satisfaction.

Thanks, this is very helpful information.

> for many devices currently in existence, separate radio firmware is already how things are architected

This makes me feel better about things like laptops and routers (at least the more expensive ones), but this...

> cheaper/integrated products that may be crappy enough to require security measures in the main host device firmware in order to guarantee the radio firmware integrity to the FCC's satisfaction.

...makes me wonder about the future, since the trend for pretty much every category of device is towards "cheaper/integrated products". You mention that some SoCs blur the lines already.

> these new rules for SDR devices (separate to U-NII discussion here) will actually require a whole new FCC approval for each radio firmware change.

To make sure I understand, this would be an incentive for mobile phone manufacturers (for example) to continue to have separate radio firmware, even if they move to cheaper SoC designs, correct? Since otherwise (if there were only one firmware blob that contained both the OS and the radio controls), they would have to get FCC approval every time they wanted to push an OS update.

> ...makes me wonder about the future, since the trend for pretty much every category of device is towards "cheaper/integrated products". You mention that some SoCs blur the lines already.

Yes, that's a legitimate concern, but there's a small consolation that this is a problem only for existing SoC architectures doing 5GHz. The new regs don't rule out new SoC architectures which would implement the enforced separation in silicon somehow. Although you're still stuck not having access to modular transmitter rules but that was the case already.

> To make sure I understand, this would be an incentive for mobile phone manufacturers (for example) to continue to have separate radio firmware, even if they move to cheaper SoC designs, correct?

Indeed, although I have oversimplified somewhat - some basebands do run on the same CPU as the OS, but something resembling a secure hypervisor (with secured boot, among other things) is used to enforce isolation between the baseband and OS (see OKL4).

FWIW there's a recap in Ars with a response from the FCC.

http://arstechnica.com/information-technology/2015/09/fcc-op...

Everything is an "operating system" these days.

Are you being obtuse on purpose? The headline is intentionally worded in such a way to make people believe the FCC is going to ban OSX, Linux, or Windows.

If the author believes it's an important issue, he should be intellectually honest about it, because otherwise he risks having people write him off as a quack. It makes it look appear as if there aren't many valid arguments in his favor, so he has to resort to FUD.

The FCC will ban linux from being installed on devices with a radio that can be controlled via software. That's pretty bad.

> This is already present insofar as hardware requirements in radios - radios cannot be permitted to listen on frequencies reserved for cell phones, and must not be restricted in such way as they can be easily modified to enable it (e.g., a header/jumper). This really just extends this requirement that it is non-trivial to enable illegal broadcasting or reception on software defined radios.

Cough, cough, HackRF(https://greatscottgadgets.com/hackrf/) + GNURadio(http://gnuradio.org/) don't seem to have these limitations.

As I recall, they got around this by not being FCC licensed - in other words, HackRF is classified as a kit/developer component, and is not legal to operate unless you hold an independent license from FCC (e.g.: if you're a Ham you can use it on Ham frequencies you are licensed for). Read the disclaimer at bottom

> HackRF One is test equipment for RF systems. It has not been tested for compliance with regulations governing transmission of radio signals. You are responsible for using your HackRF One legally.

Realistically you're not going to probably get in trouble, but I _will_ caution you - if you use this kind of equipment illegally, the FCC does have radio direction finding equipment and will send someone out to find you if you piss them off - they've done this for people that were on Ham frequencies without authorization, people doing nasty things on government frequencies, and anything disturbing people who paid for a license.

Re: GNURadio The software itself has no requirement - there is no "if you run radio software, it has to do X" and there still is no requirement under proposed rules for that as far as I can tell - it's just if you build hardware, your hardware must enforce that only certain software can be installed :).

I doubt the possibility of detection is very high if you're only receiving.

Agreed - they're more concerned about transmission, which is part of why they have more strict requirements around scanners to try a lot harder to avoid this.

What harm does listening on a frequency cause? If radio waves travel through my house I'm not allowed to listen to them?

That rule was put in place in the early, analog, days of cell phone usage to help build confidence that J Random Somebody wasn't listening to your calls. Cordless phones at the time were well known for being easy to listen to, and the wireless industry didn't want that stigma on cell phones.

What harm does spying on my neighbour through her window cause ?

If light travels through my telescope into my house I'm not allowed to watch it ?

Seriously just because something is "in your house" does not mean you some inherent right to it.

I'm not in the US and I don't know much about US laws, so can you enlighten me on the relevant laws regarding this? Would it be illegal to stick a 4k camera on your window sill? What about for surveillance purposes?

There seems to be some incredibly bizarre idea floating around here that it is illegal to MONITOR using the equipment (id est "listen") and that is simply not true, except for listening to cell frequencies. That is in American law, but here's the thing: They will not be able to determine that you're listening on those frequencies without looking at your equipment. You can possess and operate your equipment in monitor mode without a license. One must simply get a license (in most countries) to transmit using the equipment. Now, the other thing I want to mention is that the parent comment is right that the FCC has dogs of war that will chase you down and put you in jail (or levy heavy fines) for operating without a license. And they do chase people down with location equipment. I'm not advocating operating a station without a license, but if you keep the power very low and use it sparsely for testing, you have a very, very small chance of being caught by the FCCs enforcement arm. And in most of these cases of nerds transmitting without a license, they are satisfied with merely confiscating your equipment.

I've seen some of the enforcement actions - on a first offense they often just give you a stern warning unless it's clear you were doing it willfully and maliciously (interfering with a company's communications because you have a bone to pick, for instance).

Amusingly, there's been a few cases local law enforcement has asked the ham community to RDF people using their frequencies - at least here most law enforcement uses APCO-25 without encryption, so is easy to monitor and mess with by and large - because it's easier than having FCC get involved.

My favorite mistaken transmission was when a friend noted spurs coming off the strategic command in Omaha that were ending up on ham frequencies. We reported it, an hour later all their spurs were gone.

In any event - yes - monitor mode stuff they won't be able to detect unless they see your equipment, but most equipment is required to restrict the cell frequencies in such a way it's not easy to modify to detect. Most other equipment you have a jumper to enable "everything but cell" TX/RX (Looking at you Yaesu VX-9).

RDF = Radio Direction Finder

> This would prevent open/free components insofar as the actual driver, but would not permit the operating system itself from being installed.

If the SDR has a microcontroller, you potentially only need the firmware of the microcontroller to be signed (with the microcontroller checking the signature), and can have a fully free driver around it. You can even release the source of the firmware (and allow reproducible builds!) because it's guaranteed by the signature, not by the availability of the source.

Good call - similar to how you load firmware for Wifi using a blob a lot of the time. But for a lot of advocates of this they still might not be okay with this as they don't want any blobs. Which I can get, but even more reason it's kind of alarmist in my view.

radios cannot be permitted to listen on frequencies reserved for cell phones

Is this true ? I've never heard of the FCC restricting receivers before. You don't need a license to buy or operate a HAM receiver.

Depends on the licensing/certification of the device - for consumer equipment (particularly scanners) it's required, for certain experimental and test equipment it is not.

EDIT: I think this happened in 1994 - google "cell blocked" scanner and you'll find stuff on it.

Edit Again: Here's a QRZ thread on it: http://forums.qrz.com/index.php?threads/why-are-ham-radios-s...

I don't know if it is true, but I think that many commercial receivers that you can buy nowadays don't allow you to listen to those frequencies

This is ancient, dating back to when cell phones didn't use encryption. As opposed to today, when many of them still use fundamentally broken encryption like A5/1 and A5/2, other than the ones doing something vaguely sensible like VoLTE. (Though I haven't heard anything about the ban on such devices being lifted.)

But in general, "you can't listen to this frequency" is completely crazy; "listen all you like but you won't get anything useful" makes more sense (along with "don't broadcast on this frequency above this power without a license").

Listening to the the cell frequencies, selling a device capabable of listening to them, or modifying a device to enable listening to them, has been illegal in the US for years: http://www.gpo.gov/fdsys/pkg/CFR-2010-title47-vol1/xml/CFR-2...

The law dates back to the days when cell phone tranmissions were analog and could be picked up with a consumer-grade police scanner. As I recall, it was passed soon after an incident where a congressman's conversation with his mistress was picked up and publicized, but I don't have a authoritative source for that.

Even with modern phones being digital and encrypted, the law remains in effect.

The regulation you linked to appears to date to 2010, long after analog phones had been replaced.

18 U.S.C. 2512 may be older but I wonder why such a regulation would have been issued so recently.

Also if this regulation is intended to implement 18 U.S.C. 2512 it appears to be broader in scope than that law. The law only prohibits devices that are "primarily useful for the purpose of the surreptitious interception of wire, oral, or electronic communications". The regulation on the other hand restricts scanners that are capable of receiving such communications. I don't see how a broadband scanner that includes cell phone frequencies along with other bands could be considered to be "primarily useful" for intercepting cell phone communications.

If the net result is that I can't install OpenWRT on my router in Australia, then yes, that's really bad.