Assuring the security of the MetroCard system is a multi-layered effort encompassing technical solutions and procedures aimed at preventing unauthorized access and detecting unauthorized activities during the course of normal operations. The activity of the system is monitored for unusual behavior at many points in the operation. Procedures are in place to quickly respond to unusual occurrences in ways that not only limit risk, but can lead to immediate remedial action. NYC Transit is in the process of completing an extensive effort to become compliance [sic] with Payment Card Industry (PCI) rules relating to credit/debit transactions. While directly related to the business of accepting bank cards, these rules have also helped NYCT further harden its automated fare collection system against potential unauthorized access to sensitive transaction information by hackers and employees. In regards to your security related questions, which we will not address here in any detail, it is safe to say network environment is constructed in such a way that the serious security implications and vulnerabilities you reference do not exist.

Assuring the security of the MetroCard system is a multi-layered effort encompassing technical solutions and procedures aimed at preventing unauthorized access and detecting unauthorized activities during the course of normal operations. The activity of the system is monitored for unusual behavior at many points in the operation. Procedures are in place to quickly respond to unusual occurrences in ways that not only limit risk, but can lead to immediate remedial action. NYC Transit is in the process of completing an extensive effort to become compliance [sic] with Payment Card Industry (PCI) rules relating to credit/debit transactions. While directly related to the business of accepting bank cards, these rules have also helped NYCT further harden its automated fare collection system against potential unauthorized access to sensitive transaction information by hackers and employees. In regards to your security related questions, which we will not address here in any detail, it is safe to say network environment is constructed in such a way that the serious security implications and vulnerabilities you reference do not exist.

Their initial report last summer, which I blogged about at the time, was — almost entirely — rejected by the Government last autumn (blog article here).

The Committee decided that in the light of the Government’s antipathy they would hold a rapid follow-up inquiry to establish whether their conclusions were sound or whether the Government was right to turn them down, and indeed, given the speed of change on the Internet, whether their recommendations were still timely.

The written responses broadly endorsed the Committee’s recommendations, with the main areas of controversy being liability for software vendors, making the banks statutorily responsible for phishing/skimming fraud, and how such fraud should be reported.

There was one oral session where, to everyone’s surprise, two Government ministers turned up and were extremely conciliatory. Baroness Vadera (BERR) said that the report “was somewhat more interesting than our response” and Vernon Coaker (Home Office) apologised to the Committee “if they felt that our response was overdefensive” adding “the report that was produced by this Committee a few months ago now has actually helped drive the agenda forward and certainly the resubmission of evidence and the re-thinking that that has caused has also helped with respect to that. So may I apologise to all of you; it is no disrespect to the Committee or to any of the members.”

I got the impression that the ministers were more impressed with the Committee’s report than were the civil servants who had drafted the Government’s previous formal response. Just maybe, some of my comments made a difference?

Given this volte face, the Committee’s follow-up report is also conciliatory, whilst recognising that the new approach is very much in the “jam tomorrow” category — we will all have to wait to see if they deliver.

The report is still in favour of software vendor liability as a long term strategy to improving software security, and on a security breach notification law the report says “we hold to our view that data security breach notification legislation would have the twin impacts of increasing incentives on businesses to avoid data loss, and should a breach occur, giving individuals timely information so that they can reduce the risk to themselves“. The headlines have been about the data lost by the Government, but recent figures from the ICO show that private industry is doing pretty badly as well.

The report also revisits the recommendations relating to banking, reiterating the committee’s view that “the liability of banks for losses incurred by electronic fraud should be underpinned by legislation rather than by the Banking Code“. The reasoning is simple, the banks choose the security mechanisms and how much effort they put into detecting patterns of fraud, so they should stand the losses if these systems fail. Holding individuals liable for succumbing to ever more sophisticated attacks is neither fair, nor economically efficient. The Committee also remained concerned that where fraud does take place, reports are made to the banks, who then choose whether or not to forward them to the police. They describe this approach as “wholly unsatisfactory and that it risks undermining public trust in the police and the Internet“.

This is quite a short report, a mere 36 paragraphs, but comes bundled with the responses received, all of which from Ross Anderson and Nicholas Bohm, through to the Metropolitan Police and Symantec are well worth reading to understand more about a complex problem, yet one where we’re beginning to see the first glimmers of consensus as to how best to move forward.

But there's this lovely new segment of lightly licensed spectrum in the U.S., the 3.65 GHz band. It's a non-exclusive licensed band available only in parts of the country that don't have pre-existing ground-to-satellite or radar uses that overlap. This omits most of the eastern seaboard and most major cities; Seattle is one exception.

The licensing mechanism allows any number of operators to obtain inexpensive licenses, and register the base stations they use by location. If interference arises among base stations, operators are required to work out the problems themselves. I wrote extensively about this band and its rules on 9-May-2008 in profiling Azulstar, formerly a metro-scale Wi-Fi firm, but now a big proponent of WiMax in 3.65 GHz. I also went over the rules for the band on 11-June-2007 when the FCC announced the arrangement.

Several firms offer base station and customer premises equipment for this band now, so close to the 3.5 GHz band more commonly exclusively licensed in Europe and elsewhere. WiMax equipment is available because the 3.65 GHz band can be used with WiMax without any modifications to that protocol, although limited to just 25 MHz of the 50 MHz that the FCC set aside.

Equipment that conforms to a more stringent set of rules about contention and other factors can use the whole 50 MHz, and that's where 802.11y comes in. It's an extension of Wi-Fi to cope with the specific needs--and to open Wi-Fi technology up to 20 W EIRP, a vastly higher power output. This could allow connections over 5 km, the group says.

The Wikipedia entry on 802.11y, clearly written by someone involved with the specification, notes that three specific additions are needed: a tweak to support the way in which the FCC wants contention among competing devices to work; a method for an access point to tell a station (a connecting radio) that it's about to switch its channel or its channel's bandwidth, and the station should do likewise; and a mechanism to handle a base station allowing or revoking permission to use the spectrum without uniquely identifying the user's system or broadcasting its precise GPS-based location.

The standard is near completion and initial approval. I don't have any knowledge about whether any mainstream Wi-Fi equipment makers or metro-scale equipment makers are looking into building 802.11y into their gear.

The fact is that this could be a great technology for the mostly sub-metropolitan markets that 3.65 GHz is available in, although it has the same pain as WiMax: all new gear on the towers and all new adapters for customers.