My comment to the FAA regarding a request for comments.

After reading about a request from the FAA regarding a redesign of the Embraer ERJ 190-300 aircraft on Schneier on Security, I took a moment to leave a comment with the FAA.

Note that my reading of the original call for public comments, it seemed to me what Embraer wants to do is create a single network off of which all equipment–from in-flight entertainment to some of the aircraft avionics–on a single network which includes off-the-shelf operating systems.

That is, I believe Embraer is not moving towards “security through obscurity” (though this may be an effect of what they are doing), but towards using more off-the-shelf components and towards using network security in place of physical security when designing in-flight electronics. (Current aircraft provide for network security by physically separating in-flight passenger entertainment systems from aircraft avionics.)

With that in mind, I left the following comment with the FAA.

Note that I did this without my usual first cup of coffee, so it’s not very polished.

(Oh, and as a footnote: if you choose to leave a comment with the FAA, be polite. And realize that, unlike most bureaucracies in the Federal Government, the FAA tends to attract people who love to fly or who love to be around airplanes. So if you leave a comment, realize you’re leaving a comment with a bunch of old pilots: very smart folks who are very concerned about aircraft safety, and who are trying to learn about new technologies to make sure the system remains the safest in the world.)

From the background information provided in FAA-2017-0239, it sounds to me like the new design feature of the Embraer Model ERJ 190-300 aircraft is the use of a single physical network architecture which would tie in equipment in the “passenger-entertainment” domain and the “aircraft safety” domain, and provide for separation of these domains through network security. That is, it would provide isolation in these domains through software, and would therefore require network security testing in order to verify the separation of these domains.

When considering computer security, it is useful to classify the potential problems using the “CIA triad”: confidentiality, integrity and availability.

In this context, confidentiality is the set of rules and the systems and mechanisms which limit information access to those who are authorized to view that information. Integrity are the measures used to assure the information provided is trustworthy and accurate. And availability is the guarantee that the information can be reliably accessed by those authorized to view the information in a timely fashion.

Taken individually we can then consider the types of attacks that may be performed from the passenger-entertainment domain against the aircraft security domain which may cause inadvertent operation of the aircraft.

Take attacks against availability, for example. Attacks against availability include denial of service attacks: one or more malfunctioning pieces of equipment flood the overall network with so much useless data that it chokes off the flow of information across the network. A similar attack, known as a SYN flood attack, attempts to abuse the underlying TCP/IP network protocol’s three-way handshake connection protocol to prevent a piece of equipment from responding to a network connection.

Embraer needs to demonstrate if they use a unified network architecture that the avionics and navigation equipment in their aircraft can survive such a denial of service attack against network availability. This means they need to demonstrate that map products and weather products are not adversely affected, that control services and auto-pilot functionality is not adversely affected, and that attitude, direction and airspeed information is not adversely affected during a denial of service attack. (If the test is to be passed by resorting to back-up indicators, the system must clearly visually indicate to the pilot that avionics are no longer reliable or available.)

Attacks against integrity include spoofing network packets–equipment plugged into the passenger-entertainment domain which spoof on-board data-packets sent from various sensors, and session hijacking: creating properly shaped TCP/IP packets which intercept a network connection between two pieces of equipment. (A sufficiently sophisticated attacker can, with a laptop connected to a network, create a seemingly valid IP packet that appears to come from anywhere in the network.)

Embraer needs to demonstrate that the network protocol they use to communicate between pieces of equipment are hardened against such spoofing. Hardening can be performed through using end-to-end encryption and through the use of checksums (above that provided by TCP/IP) which validate the integrity of the encrypted data. Embraer will also need to have processes in place which allow these security encryption protocols to be updated during maintenance in the event a disgruntled employee leaks those security protocols.

Embraer also needs to demonstrate their software is hardened against “fuzzing”. Fuzzing is an automated testing technique that involves providing invalid, unexpected or random data to a system and making sure it doesn’t fail (either stop working or provide inaccurate information to the pilots). Fuzzing can be performed both by providing completely random inputs, and by varying valid packets by small amounts to see if it creates problems with the system being tested.

In proving that systems are hardened against such protocol attacks, Embraer needs to demonstrate not only that invalid information does not flow into the aircraft-safety domain, but they must also demonstrate that such attacks do not shut down communications between the aircraft-safety domain and various sensors sending vital data.

Confidentiality attacks include passive attacks: users sniffing all the data on a network and eavesdropping on the data being sent and received, and active attacks: gaining internal access to systems which they are not authorized to access. Confidentiality attacks can lead to attacks against availability (by, for example, locking out someone using a password change) and integrity (by, for example, corrupting IFR map products).

Embraer needs to demonstrate their software is hardened against unauthorized access, both to the flight sensor data being sent across the network (through end-to-end encryption) and by verifying access to in-flight data products are restricted to authorized users (by using some form of access control, either though the use of a physical key, a password or biometric security: the “three factors” of authentication). For example, one way to satisfy this requirement is met for mapping products is to require that map data can only be changed from within the cockpit.

Of course, as always, Embraer needs to demonstrate that back-up attitude, directional and air-speed indicators continue to work in the event of a problem with the avionics, that the avionics provides a clear indication that the information they are providing may be invalid due to failure or due to a network attack. And Embraer needs to demonstrate the flight controls of the aircraft continue to operate in the event in-flight avionics are compromised. This includes making sure that all flight control systems are kept separate from the in-flight avionics, with the exception of the autopilot (which should not prevent the pilot from taking control with sufficient force).

I understand that this is an incomplete list of potential security attacks. But by classifying attacks in a networked environment along the “CIA triad”, it should be possible to create and maintain a comprehensive list of tests that Embraer can perform to assure the integrity of the aircraft security domain.

Thank you for your time.

– Bill Woody

One of my biggest complaints about the way we approach government is that we constantly complain about the lack of experts in government–but then, those of us who have some expertise never bother to publicly participate in what is supposed to be a democratic process.

So even if my comments are utterly worthless, they are far better than the expert in the field who never says anything.

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