EFF's cognitive radio comments to the FCC

I've just turned in EFF's comments to the FCC's "Cognitive Radio" docket, which asked (among other things) whether the Commission should regulate Americans' access to digital-to-analog converters and whether Trusted Computing should be mandated for software defined radios (we didn't much like these ideas).

EFF asks the Commission to consider the question of enforcement separately from the question of functionality. The Commission should allow this proceeding, and others like it, to consider the question of the characteristics of the best possible design and operation of flexible radios without regard to enforcement questions. It should allow American technologists to build the devices that make most efficient use of spectrum and allow the greatest amount of speech over the public's airwaves.

As each new type of device and operational norm is approved, the Commission shoul dask, separately, how best to police the airwaves in light of the fact that the newly approved devices will soon proliferate. It must assume that Americans should and will acquire the best and most-capable radios possible and determine how to address the problems that may arise from this reality.

Further, the Commission should seek to backstop enforcement by hardening existing radio applications against harmful interference, spoofing and other attacks: for example,if air-traffic control signals carried cryptographically secured signatures, the risk of spoofed signals would be greatly reduced. Our government has already required that airlines install reinforced cockpit doors: reinforcing the cockpit radios is a logical next step.

104K PDF Link