Ok I just actually read it. Quote:

"An applicant must describe the overall security measures and systems that ensure that:

1. only properly authenticated software is loaded and operating the device; and
2. the device is not easily modified to operate with RF parameters outside of the authorization."

# 1 is insane for the FCC to have any purview over - not their turf.

Given the fact that these are Part 15 devices operating in the ISM bands #2 isn't to bad to certify.

I would ask the FCC for a rules change to reflect that. The FCC regulates the public spectrum not software.

--Martin