FCC Software Configurable Radio Whitepaper

By Eric Schultz, Community Manager, prpl Foundation

I’m excited to be wrapping up this year’s work in the Software Configurable Radio (SCR) sub-group. After a lot of work, I’m happy to report that on December 7, the Technical Advisory Council (TAC) of the FCC approved for release the sub-group’s report.

As background, I’ve been researching and speaking on the topic of regulations related to wireless radios and open source over the last year and half. Given the controversy over these regulations, the TAC, an independent advisory board for the FCC, decided that reviewing the topic would be helpful for regulators. Notably, the SCR sub-group wasn’t charged with addressing any of the particular regulations proposed by the FCC. Instead, the sub-group was asked to consider a more general topic:

“How to strike the appropriate balance between embedding frequency security mechanisms into Software Defined Radios while allowing innovation and the flexible addition of features”

While the sub-group began work in May and ended at the end of November; I was invited to join the group in late October. It was an honor to be asked to participate and a joy to work with experts committed to understanding a difficult topic. I was particularly encouraged by how dedicated every member of the sub-group was to understanding the needs of those from groups they didn’t represent. Every member understood why they were there but they were open to other viewpoints. The sub-group member’s open-mindedness is reflected in the document not only as it applies to technical mechanisms for embedding frequency security mechanisms but also in the social and economic effects of those mechanisms.

As the sub-group analyzed the problem and potential technical solutions we soon realized that finding a balance was not possible for the group in the limited time allotted. The questions we were being asked, although seemingly straightforward technically, actually reach into areas like humanitarian and rescue efforts, amateur radio, international travel, public safety, consumer rights, maker communities, manufacturing economics and others. Even within the free and open source software community, which I represented through prpl, there are many different facets and viewpoints to be analyzed and considered. Given our limitations and the breadth of the topic, the group made a unanimous recommendation that:

“the FCC encourage the formation of a multi-stakeholder forum to find a way in which manufacturers can strike the appropriate balance between embedding security mechanisms into software configurable radios and their ecosystem to ensure compliance with FCC service rules, while allowing innovation and the flexible addition of features, and fostering cybersecurity overall.”

I think this is a fantastic conclusion. We all benefit when individuals from diverse communities collaborate to work on difficult problems. Through this collaborative effort, I’m convinced we will be able to find solutions that meet the needs of the broadest range of people and, in particular, protect the core interests of the open source community. I also look forward to learning more about the specific problems regulators are seeing so we can work collaboratively to address them. In many ways, this effort mirrors how prpl Foundation approaches problems: bringing all relevant parties together to find solutions that meet the needs of everyone involved.

While the decision about how to handle the sub-group’s recommendation lies with the FCC, I’m heartened that Julius Knapp, Chief of the FCC’s Office of Engineering and Technology, spoke supportively during the TAC meeting about having a multi-stakeholder forum look into this topic further. It’s also reassuring that a number of members of the subgroup, including myself, offered to continue their participation in a multi-stakeholder forum. I look forward to participating in the multi-stakeholder forum, should it be created, and in providing advice to all parties as they look to better understand how to balance the interests of the open source community with the interests of regulators.

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