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Comments to FCC Regarding 5G Open Radio Access Networks

April 29, 2021

ITIF filed comments with the FCC on dynamics in the transition to radio access network (RAN) equipment that is more modular with openly defined interfaces. Open RAN is an important tool in mitigating the risks of an overly narrow market for RAN equipment, a market that could conceivably be dominated by Chinese firms that do not abide by the rules and expectations of international competition and trade. Restructuring the RAN architecture likely will not be sufficient to combat these unfair practices alone—the Commission and other government actors should avoid focusing too narrowly on RAN architectures as a solution to the Huawei challenge.

Many hurdles remain for a successful evolution to more modular and open RAN equipment. Security and reliability present challenges, given the extreme complexity of managing multiple hardware and software products form different vendors. The FCC and its advisory committees should work cooperatively with industry stakeholders and other participants in the standards setting environment to identify potential security challenges that need to be addressed, and continue with its risk-based approach to security.

A potential transition to wireless architectures based on open specifications is very encouraging. This technological evolution should drive continued innovation in wireless equipment, lower costs, and reduce long-term risk in the supply chain. But there is a possibility of an open RAN bandwagon driving well-intentioned policy that ultimately wastes resources or undermines innovation long-term. Support for testbeds and additional R&D in this area would no doubt be beneficial. But the FCC should avoid assuming how open radio architectures will evolve and avoid over-hyping the technology in unproductive ways.

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