Nobody, because A)the cellular radio is on a separate chip and has nothing to do with the OS, and B)people already install ROMs on their phones today, without having to be regulatory compliant. All I'm asking for is an Ubuntu ROM, because while CyanogenMod is cool, GNU>Android.
I agree completely about FOSS. But, based on my experience porting CyanogenMod to my old phone, things are not as compartmentalized as you would hope. For example, the user initiating a call to 911 and control of audio is not managed by the radio chip.
The radio is not completely isolated. I have broken ROMs such that dialing 911 does not work. The phone I spent time hacking on had the radio attached over USB, and there were all sorts of magic AT chats that were managed by some proprietary library. Also, firmware on the radio was loaded into the radio by the OS. Anyway, my point is these things are not obviously separable, particularly at the holistic level of what's required by laws and regulations.
Phones aren't required to make 911 calls. Consider the case of your MiFi access point. The Ubuntu phone could just be a smart access point.
We shouldn't let artificial restrictions get in the way of Free Software. The pre-alpha-Github version does not need to be perfect. It just needs to lay the foundation for perfection to be added later.
I assume it's nice to be flippant about laws and FCC regulations when you're not legally holding the bag. To be clear I don't know what sorts of things are required of "phones". I do know it was an issue when IP-based phones from cable companies were initially advertised as phones but lacked 911 services. My point is that from the standpoint of near complete ignorance of rules and regulations it's quite easy to bitch about heavily regulated items.