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