The top of the page says:

his page will compile all relevant information available on the FCC's new regulations on 5Ghz Wifi and the OpenWrt's community recommendations for hardware manufacturers.

Then down below it lists suggested workarounds. Even though that section says they aren't recommendations, it still reads like it.


In Linux/OpenWRT there are several layers to deal with.

The radio itself has it's own processor, which runs some hard-coded software and (potentially) some additional firmware that is loaded from the OS (with validation and cooperation of the hard-coded software)

The Device Driver talks to the radio processor and can ask it to change channels or change country codes (if the radio processor knows about those codes)

The software in the OS asks the device driver to ask the radio to change channels.


Manufacturers can put the checking into whatever layer they want. From a openwrt point of view, the more that can be changed by openwrt the better.


There is a key word to recognize, the devices need to be "resistant" to inappropriate changes. This doesn't mean that they need to be proof against them. Based on what happens in other equipment, requiring that the person changing this take a clear, unambigous, deliberate action to unlock the radio and therefor be clear that they are responsible for anything it does wrong is probably good enough. It probably does need to be something other than just a software setting though.


What I think would be a good approach is the jumper/0-ohm resister approach (google does this with the chrome laptops, open them up, remove a washer that acts as a jumper, and it's now unlocked). With the jumper in place, the firmware and country code cannot be altered, with it removed, it can be (and a nice big warning in the documentation that doing so may be illegal for people to ignore)

It's just not possible to prevent the OS from trying to set the channel inappropriately unless you are going to lock down the device to the point that you don't allow any software updates at all

David Lang

On Tue, 9 Dec 2014, Eric Schultz wrote:

Date: Tue, 9 Dec 2014 14:34:14 -0600
From: Eric Schultz <[email protected]>
To: David Lang <[email protected]>
Cc: Dave Taht <[email protected]>,
    "[email protected]"
    <[email protected]>
Subject: Re: [Cerowrt-devel] New FCC requirements and CeroWrt

David,

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.

Eric



On Tue, Dec 9, 2014 at 2:14 PM, David Lang <[email protected]> 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 <[email protected]> wrote:

On Tue, Dec 9, 2014 at 9:11 AM, Eric Schultz
<[email protected]> 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
[email protected]
cell: 920-539-0404
skype: ericschultzwi
@EricPrpl
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--
Dave Täht

thttp://www.bufferbloat.net/projects/bloat/wiki/Upcoming_Talks




--
Eric Schultz, Community Manager, prpl Foundation
http://www.prplfoundation.org
[email protected]
cell: 920-539-0404
skype: ericschultzwi
@EricPrpl
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