The "conspiracy" portion of my brain makes me wonder if it's possible that Apple phones have lower power levels if the location services determines that the phone is in a location with a known anechoic chamber. There can't be that many of them.

Such behavior has already been shown by automobile manufacturers during the "diesel-gate" incidents.

You don’t have to do that, usually you’ll run special test firmware on the device and say that this behaves appropriately (I’ve done this for other companies)

Remember that this is fundamentally a legal/social thing that involves engineering/science and not the other way around.

Right, you're supposed to test to the worst case and you get to define "worst case." Cheating would be as simple as defining a favorable "worst case."

Before the tin-foil crowd calls regulators stupid, I'd like to point out that in the absence of cheating this allows hardware engineers to do a better job & design a system that is robust to software shenanigans. That's a nice thing. Maybe we cannot have nice things, but if so, let's prove it rather than presuppose it.

I'd estimate the likelihood of cheating by looking to see if people are choosing phones on the basis of EIRP the way they choose cars based on MPG. I don't see that happening, so I estimate that the likelihood of cheating is low, and would vote to keep the cooperative model around.

The main problem with all this kind of testing is how little precision there is.

“Double the energy limit” sounds a lot, but for a lot of these labs that’s inside of the error range of their equipment.

I’m sure Apple has their own test chambers.