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Software Defined Radio (SDR)

Software Defined Radio (SDR)

Application Review Guide

Application Review Guide

TCB Workshop October 6, 2009

Jim Szeliga

Laboratory Division

Office of Engineering and technology Federal Communications Commission

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Presentation Outline

Presentation Outline

What is an SDR application

Decision tree to determine if a radio can either

elect to be or must be a Software Defined Radio

(SDR)

SDR software security description required for

filling

Permissive changes for an SDR

Permit But Ask Procedure

– what should be included

Draft KDB 442812 available for review and

comment

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October 2009 TCB Workshop 3

Software Defined Radio

Software Defined Radio

2.944 requires that SDR applicants:

take steps to ensure only approved software

operates the radio

Any radio were third parties can operate

outside of the grant must be an SDR and take

steps (a) to ensure approved software

operates the radio.

A operational description must be provided

with the application for certification.

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Software Defined Radio

Software Defined Radio

When transmitter’s RF parameters can be modified, by third parties through software to operate in any other bands not permitted by the rules, and not in compliance with the

certification as granted it can be granted as an SDR.

However, radios that only operate as granted may also be granted as an SDR and have the ability to make Class III permissive changes - field upgrades by third parties are permissible.

The responsible party must maintain an acceptable software security process that ensures regulatory compliance for

SDR transmitters when sold and operated in the US. A detail description of this security process must be

submitted with an SDR filling along with description of the software related items.

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October 2009 TCB Workshop 5 1 RF Characteristics changed through Software 1 RF Characteristics changed through Software 2 Third parties, Load, modify, Configure software outside Grant 2 Third parties, Load, modify, Configure software outside Grant Yes Yes 5 Manufacture Elects SDR 5 Manufacture Elects SDR No SDR process SDR process No 4 Part 15.202 client device* 4 Part 15.202 client device* No Yes No

SDR Guide

SDR Guide

All Radios 6 Non SDR review Process 6 Non SDR review Process Yes Yes No 3 Capable of operating in any other way then what was granted
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Category

Description Software (2.944 [c])

General software operational description.

Describe all the radio frequency parameters that are modified by the software without any hardware

changes.

High level (simplified) block diagram of the software architecture

Labeling

How is the device to be labeled? Will the device have single label or will it use electronic label as per 2.925 (e)?

How can the FCC verify, in the field, that correct version of the software is running in the device? Submit a description of this capability and

instructions for the FCC to use in the field to verify that proper software is operating in the device.

The means by which software version numbers can be related to any future Class III permissive changes.

Security Description Guide

Security Description Guide

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October 2009 TCB Workshop 7 Category

Security

What ensures that third parties (Professional installers, qualified personnel, authorized certified technicians, end users, etc – not direct employees) can not operate US sold devices on any other regulatory domain frequencies or in any manner that is in violation of the grant or grant

conditions.

Explain if any third parties have the capability to operate a US sold device on any other regulatory domain frequencies or in any manner that is in violation with the grant.

Describe how the software updates are distributed for all regulatory domains and what ensures that product sold in the US can only operate as granted on US frequencies.

Security Description Guide

Security Description Guide

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Category

Security (continued)

Is the product as shipped in the US regulatory harden (factory hardware/firmware) and limited so that it can only operate as granted on US frequencies?

What stops third parties from loading non US version of software onto products intended for US sale?

Can third parties make factory level changes to reload non-us domain codes, etc.

Unauthorized changes (hack) to the software

(2.944).

Describe how open source is the operating code for granted RF properties. Describe the difficulty and proprietary nature of the code that controls the RF parameters as granted.

Security Description Guide

Security Description Guide

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October 2009 TCB Workshop 9

Permissive Changes

Permissive Changes

Class I No different than non-SDR grant.

Class II Any Class II change (even for

adding new antenna types) will prevent the

grantee from making future Class III

changes.

Class III As long as there is no host

hardware or previous Class II changes,

there is no limit to the number of Class III

changes permitted. In general there are

three categories for Class III changes:

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Class III Changes

Class III Changes

Modification to software that effect RF parameters that

degrade original reported RF parameters but still meet rules for the original equipment class. – Submit test

documentation similar to Class II requirements for non-SDR. Adding new technical rule part and/or equipment class. For example, an SDR first granted as a 15.247 DTS device

could later add part 15 UNII Subpart E. Submit a complete set of new test documentation for new equipment class similar to procedures for a non-SDR.

Major changes in software, distribution and security (SDS) that materially changed the descriptions provided on the

initial grant will require a Class III permissive change. Do not submit only the changes. A full description is required. The Class III documentations in effect replace the original

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October 2009 TCB Workshop 11

A Class III change should also

A Class III change should also

include

include

Identify all version of software that contain

the original grant and all other granted

Class III permissive changes including the

requested Class III change.

Provide a statement that confirms that this

change request does or does not modify

the Software, Distribution and Security

Documentation. If it does then a Class III

type 3 resubmission of SDS security

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Permit But Ask Procedure

Permit But Ask Procedure

The following should be submitted with the PBA request:

Define if PBA is an initial grant or permissive change to an SDR

– Permissive changes to a non SDR to SDR are not permitted

– If Class II permissive change is requested further Class III will not be permitted.

– If A Class III is requested provide a description as defined in slides (9,10,11) of this presentation.

Manuals and Operational Descriptions to allow the reviewer to understand the product and its function.

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October 2009 TCB Workshop 13

Permit But Ask Procedure

Permit But Ask Procedure

(cont

(cont

d)

d)

For initial grants a statement to affirm why the

grant is a SDR. This is generally a very simple

statement :

– Must be an SDR “World wide Radio with security for managing software as descried below”.

– Elects to be an SDR “To taking advantage of Class III permissive changes.

Software Defined Radio Security Description

– Provide a description as outlined in slides (6,7,8)

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