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The FCC Might Ban Specific Operating Systems

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Re: The FCC Might Ban Specific Operating Systems

#111

Post by csirac2 »

fencepost wrote: post #52

My contribution to the commentary: I feel that the proposal to regulate device firmware and effectively ban non-vendor firmware is both overbroad and will result in significantly increased security risks faced by the general public (myself included). If the FCC chooses to go forward with this, it should also require and put in place penalties to enforce MANDATORY security updates from vendors within tightly constrain…

They are struggling with a very simple problem. If you configure your 5GHz U-NII device to the wrong country, and turn it on, it will stomp all over licensed/restricted spectrum.

That's because unlike 2.4GHz, 5GHz has been carved up very differently in different parts of the world (each place has had its own evolution of technology and spectrum pressures).

To such a degree that this isn't even about power and frequency. As an FCC registrant seeking to slap FCC stickers on your new/imported devices, you'll be required to submit proof of conformance documentation which demonstrates you've properly implemented radar avoidance in your frequency hopping/spread spectrum algorithms.

Finally, the FCC has made it obvious that this aimed at the transmitter module, not the overall device. And so, "banning" OpenWRT and other 3rd-party/alt firmwares would only be required if that's the only half-arsed way a manufacturer can hope to comply with the new regs.

In future, I'd hope hardware becoming better isolated from radio components, this ruling (and similar around the world) are essentially mandating region-locked devices, so we might see something similar to what's happening in mobile phones (Eg. baseband radio firmware separately versioned/updated from OS firmware).

Re: The FCC Might Ban Specific Operating Systems

#112

Post by csirac2 »

Vexs wrote: post #15

I thought to myself: "This looks like a good time to stock up on SDR equipment, in case this ever goes through." And then I realized this is exactly the same thing gun enthusiasts thought when they though Obama would limit their guns/bullets, and stocked up on them, and I thought it was silly. I guess we're a lot more similar than I would have thought, made me think a little bit more about it. I'm reminded a bit of t…

Do you have any FCC certified SDR kit currently?

This only impacts an OEM/importer's ability to gain FCC approval/certification for new devices.

If you're not slapping FCC stickers on things, or are using something that never had an FCC sticker on it in the first place, this doesn't impact such apparatus (you always needed a separate license to operate HackRF & friends).

Re: The FCC Might Ban Specific Operating Systems

#113

Post by csirac2 »

aylons wrote: post #21
Vexs wrote: post #15

I thought to myself: "This looks like a good time to stock up on SDR equipment, in case this ever goes through." And then I realized this is exactly the same thing gun enthusiasts thought when they though Obama would limit their guns/bullets, and stocked up on them, and I thought it was silly. I guess we're a lot more similar than I would have thought, made me think a little bit more about it. I'm reminded a bit of t…

Specifically, SDR kits are usually rated as professional and test equipment, which are not certified by the FCC. The OP is about consumer products and other FCC-certified products.

I think they're not rated as anything. They simply have no manufacturer-supplied licensing/approvals whatsoever. So it is up to the user to gain an appropriate license and operate them to the conditions stipulated by that license.

Re: The FCC Might Ban Specific Operating Systems

#114

Post by csirac2 »

fnordfnordfnord wrote: post #29
aylons wrote: post #21

Earlier quoted context omitted.

Specifically, SDR kits are usually rated as professional and test equipment, which are not certified by the FCC. The OP is about consumer products and other FCC-certified products.

>SDR kits are usually rated as professional and test equipment The cheap ones aren't even that. They're repurposed/upcycled television DTV receivers.

FWIW I haven't seen anything in the new rules (admittedly I have focused on SDR and U-NII regs) which pretends to cover anything but intentional radiators (i.e. transmitters).

Re: The FCC Might Ban Specific Operating Systems

#115

Post by Steko »

aianus wrote: post #106
Steko wrote: post #79

Earlier quoted context omitted.

You throw the number (1/10,000 chance) like it's low but I think that's fairly high. You cite crashing motorcycles but the total US deaths by traffic accidents was close to 1/10,000 in the most recent years [1]. You ask if we want to ban motorcycles but motorcyles aren't used to murder people, we ban or heavily regulate lots of things that are more generally harmful (explosives, lead, asbestos, radium, DDT, CFCs, etc…

Firearms are not generally used to murder people, they're generally used to poke holes in suspended pieces of paper or look pretty or make the owner feel safe or hunt animals. They're very rarely used to murder people relative to their other uses.

Not sure where you think I claimed that the only or chief use of firearms was to murder people. The main use of lead, asbestos and DDT were also not to cause health problems but they were still banned.

OTOH firearms are overwhelmingly the most common way people get murdered in the US today, so to say they're 'rarely used to murder people' is to only look at the question from one side.

Re: The FCC Might Ban Specific Operating Systems

#116

Post by csirac2 »

matheweis wrote: post #46

I was slightly surprised about a week ago when I came across the NPRM by accident and realized the comment period was already over. But, I'm more taken aback though by the reactions here to this guy's (admittedly alarmist) thoughts... From reading the comments here, it sounds like only a couple people scanned past the headlines. TL/DR, Eric (Who is actively involved in the OpenWrt project), makes a very good case tha…

The FCC responded to Ars saying that the line about DD-WRT was clumsily worded. I'm under the impression that if the OEM/importer demonstrates in their filing that their proof of conformance documentation will always be representative (valid) of the device no matter what the user can do through user-accessible features and menus, i.e. they can prove that the radio module is locked down in some way other than the main device firmware, this should be sufficient and does in fact meet the requirements.

After all, preventing APs from stomping on licensed spectrum due to wrong country selection seems to be half of what's driving all this anyway.

Re: The FCC Might Ban Specific Operating Systems

#117

Post by Tinyyy »

threeseed wrote: post #95
Buge wrote: post #72

Earlier quoted context omitted.

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

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?

Re: The FCC Might Ban Specific Operating Systems

#118

Post by lexicalscope »

fapjacks wrote: post #104
lexicalscope wrote: post #16

Earlier quoted context omitted.

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 gov…

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…

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).

Re: The FCC Might Ban Specific Operating Systems

#119

Post by paulmd »

fnordfnordfnord wrote: post #97
PhasmaFelis wrote: post #36

Earlier quoted context omitted.

> There are radios and amps that use a frequency analyzer to automatically cut out when operated out of their intended bands, they're just very expensive compared to most of the gear that's out there. Why is that expensive? It obviously can't require fancy hardware if it can also be done in software.

The sub-ten dollar wideband SDR is a recent phenomenon.

Wideband radios are not all that new. My radio is a Kenwood TS-820S from the 70s and covers multiple bands from 160M to 10M. My cheapo Radio Shack walkie talkie from 15 years ago covers most (all?) of 6M to 2M (i.e. all kinds of serious bands that I'm not allowed to transmit on). My Yaesu VX-5R from 10 years ago can do full-on wideband receive, from 6M up to microwave.

With the help of an auto-tuner to match the SWRs there's no physical reason I can't transmit/receive bands I'm not supposed to. It's not like tweaking a VFO is really a technical challenge, they're well-understood technologies. And the frequency display on my radio is literally just a frequency counter for my own edification, the base TS-820 non-S model doesn't even have one. To find your frequency you look at the dial, there's a printed scale for your band. You know what happens if you are pushing the limit too far? The FCC tracks you down and you get a pink slip telling you that they know what you're up to.

You both underestimate what older radios can do, and overstate what newer radios can do relative to them. The reasons that you didn't see people transmitting off-band before was primarily social, not technological. As for receive, the FCC was flipping out about people intercepting cellphone calls on omniband radios - 15 years ago. Omni SDR was around 10 years ago too, with the same capabilities (see: GNU Radio), it just cost more than $10 for a rig.

Re: The FCC Might Ban Specific Operating Systems

#120

Post by matheweis »

csirac2 wrote: post #116
matheweis wrote: post #46

I was slightly surprised about a week ago when I came across the NPRM by accident and realized the comment period was already over. But, I'm more taken aback though by the reactions here to this guy's (admittedly alarmist) thoughts... From reading the comments here, it sounds like only a couple people scanned past the headlines. TL/DR, Eric (Who is actively involved in the OpenWrt project), makes a very good case tha…

The FCC responded to Ars saying that the line about DD-WRT was clumsily worded. I'm under the impression that if the OEM/importer demonstrates in their filing that their proof of conformance documentation will always be representative (valid) of the device no matter what the user can do through user-accessible features and menus, i.e. they can prove that the radio module is locked down in some way other than the main…

Do you have a link for that? I'd like to see it...

The original wording from the FCC about DD-WRT was pretty awful, and I don't see how their intent can be interpreted otherwise (although they may be backpedalling now):

"2. What prevents third parties from loading non US versions of the software/firmware on the device? Describe in detail how the device is protected from "flashing" and the installation of third party firmware such as DD-WRT."

As seen on this thread and the document linked within: http://lists.prplfoundation.org/pipermail/openwrt/2015-July/...

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