tentative summary of argument

They conclude that it is permitted for individuals to use uncertified FOSS in software radios (“consistent with the FCC’s position on experimental or specialized equipment. Such equipment is exempt from the certification requirements if it is not marketed to the public and is only used under controlled conditions”, citing “47 C.F.R. Part 2.803”). In §3.3, they go so far as to argue that it is permitted for equipment manufacturers to ship uncertified software intended for individuals to use in this way, so long as they do not ship that software as part of a device; though this stronger proposition (that radio equipment manufacturers can develop and distribute such non-certified software) is conspicuously absent from the Conclusion section.

I suppose this means it’s fine for Ubuntu etc. to ship such software, but if Dell etc. wants to ship Ubuntu preloaded then they need to modify it to use certified software (which will probably involve proprietary software due to the “higher burden” to prove FOSS as sufficiently secure), probably instead of, rather than in addition to, the uncertified software.

Obviously you’d be foolish to rely on my casual summary; I provide it only for the sake of the curiosity of casual readers like myself.

Comments of confirmation or denial by people who've read more carefully than I are welcome.