FCC Hosts 5G Open Radio Access Networks Forum

Summary and Analysis

On September 14, 2020 the Federal Communications Commission (FCC or Commission) hosted a Forum on 5G Open Radio Access Networks. In introducing the Open Radio Access Networks (Open RAN or ORAN) Forum, the Commission stated that: “Open, interoperable, standards-based, and virtualized radio access networks offer an alternative to traditional cellular network architecture and could enable a diversity in suppliers, better network security, and lower costs.”   During the Forum, FCC Commissioners expressed support for Open RAN to increase the diversity of suppliers in the 5G marketplace, enabling greater innovation and a more secure network.  Panelists from various telecommunications industry stakeholders discussed the benefits of virtualized networks, particularly in relation to enabling 5G use cases.  Many speakers discussed the need for secure telecommunications infrastructure and pointed out ways that Open RAN can optimize network security.  Finally, participants discussed actions the federal government could take to promote the successful rollout and use of Open RAN. This event constitutes the latest in a string of actions this year by the Commission and other Federal agencies to address promoting 5G deployment and securing telecommunications infrastructure. 

Below is a summary of key takeaways from the forum.

Opening Remarks.

Chairman Pai highlighted the FCC’s 5G FAST Plan, which is centered around three key components: (1) pushing more spectrum into the marketplace; (2) updating infrastructure policy; and (3) modernizing outdated regulations, and the Commission’s work with respect to the 2019 Supply Chain Report & Order. Under the Supply Chain Order, the FCC has developed a process for identifying and categorizing restricted equipment and replacing it once Congress provides funding. He underscored that these are necessary steps in the face of security threats from China. Pai added that the long-term costs of using insecure equipment outweigh short term savings in cost. Further, more vendor diversity is helpful to create diverse supply chains. Innovation and competition create a healthier and more secure telecom ecosystem. Open RAN has the promise to deliver more vendor diversity and more agile, interoperable networks. The purpose of this forum is to encourage innovative solutions and convene top experts to discuss the benefits of Open RAN, challenges to implement it, and lessons learned from its deployment thus far.

Secretary Pompeo stated that “Clean Networks” and “Clean Telecos” can help prevent interference from China and state-affiliated Chinese companies aiming to erode freedom and democracy around the globe.  Pompeo said that the State Department is rolling out a Clean Network, and noted that a coalition of about 30 like-minded countries and companies have banned Huawei from their networks and chosen clean vendors. This can help to maximize connectivity without the risks by untrustworthy vendors. Pompeo said that companies can determine how they can join or support the clean network. He also stated his support for Chairman Pai and the FCC’s efforts to free up more spectrum for 5G, noting that freeing up spectrum, will drive economic and technological advancement.

Rob Blair noted that the Commerce Department is focused on implementing the National Strategy to Secure 5G, and highlighted several ongoing efforts. Blair mentioned that NIST is increasing focus and investment on advanced communications, identifying security gaps in the supply chain, and coordinating participation in standards development activities. The International Trade Administration is developing a strategic framework for promoting U.S. tech companies around the world and working with the State Department. NTIA is working to make more spectrum available for 5G and also launched a program to provide supply chain risk information to industry partners—this will be a key point for establishing clean paths and clean networks overseas.  NTIA is also working with industry partners to develop principles for promoting a vibrant and diverse 5G ecosystem.  Blair noted that the challenge facing the world is that presently there are only a few companies providing equipment for communications networks, some of which are controlled by authoritarian governments and there are high barriers for market entry for new companies.

Commerce has the goal of helping to harness 5G for a more prosperous and secure future.  This will be done through several steps. First, improving United States and our allies’ national security by building telecom systems without untrusted vendors and harnessing the power of innovation to improve those systems.  This is why NTIA is focused on increasing vendor diversity, which will reduce reliance on untrusted vendors and increase competition. The move towards more open architectures should be led by industry, but the government has to help, for example by working with like-minded countries to identify ways to collaborate.  Second, Commerce is working to help develop principles for open and interoperable networks, these principles could identify additional ways to foster vendor diversity and infrastructure resiliency, in more competitive markets.

Hon. Jane Harman noted that the United States has major advantages globally, with the best academic institutions and an innovative tech industry. With 5G specifically, industry standards matter and if the United States is not helping to set them, then someone else is. America and its companies need to be at the front of global standards setting. To do this, policymakers need to think outside the box, and promote a diversity of hardware and software players. Open networks will put more eyes and more brain power into this important area, and give more startups a chance to be innovative. Harman noted that Open RAN is not a geopolitical silver bullet, but just a part the overall strategy to promote a more secure telecommunications ecosystem.  The United States government needs to figure out how to help U.S. companies enter the market, and Open RAN is a part of this equation.  

Commissioner Starks noted that the Chinese government has artificially supported Huawei and ZTE to give them advantages, not through free market competition, but with a strategy to control networks globally. Beyond economic gamesmanship, China is also siphoning data, and creating backdoor access for state agencies, which is weaponizing telecommunications networks. Open RAN networks are part of the solution. Starks recommended requiring carriers that receive FCC funding for ripping and replacing restricted equipment (Huawei and ZTE) “to consider solutions offered by an O-RAN provider.” Although, no carrier should be forced to adopt Open RAN, he stated that this “would achieve many of our goals, including encouraging global competition with Huawei, capitalizing on U.S. software advantages, accelerating the development of O-RAN as a product-model and a business-case, and allowing for alternative vendors to enter the market and offer specific network solutions.” Open RAN holds promise and reduces reliance on insecure equipment.

Panel 1: Introduction to Open, Interoperable, and Virtualized Networks.

Chairman Pai asked the panelists to provide a general overview of RAN and Open RAN, and how Open RAN differs from traditional communications architecture, he also asked about security benefits and what the government’s role should be to encourage the growth of Open RAN.

Panelists Caroline Chan of Intel and Sachin Katti of VMWare noted that Open RAN is virtualizing and specifying open interfaces, developing on open door for innovation at both the hardware and software levels. It implements open interfaces between various components hardware- and software-defined functions.  This plays to American strengths in innovation.  Open interfaces allow for the mixing and matching of vendors, avoiding the traditional vertical integration of components from a single vendor (or with much more limited options). This disaggregation allows for flexibility in the marketplace and for new companies to advance new technology solutions. Open networks and interfaces allow for AI to optimize the networks, which can help tame the complexity of rolling out a 5G network. 

Tareq Amin of Rakuten used his company’s experience deploying and building an Open RAN network as an example of what other companies can expect, noting the many advantages in simplicity, security, and function that come with visualization and automation of networks. He underscored that Open RAN provides full visibility and transparency end-to-end for all components, which can be an unparalleled opportunity for industry. Katti added integrated architecture means the ability to inspect and the ability to replace components of the network, instead of reliance on one vendor. This allows for cleaner and more secure networks overall.

Thierry Maupile of Aliostar added that there are Open RAN opportunities for “brownfield” operators with existing networks, in that these operators can insert Open RAN in both 4 and 5G networks.  Inserting “greenfield” tech into existing systems allows for adoption and scaling in an agile way. He noted that Open RAN is aligned with 5G standards development to have programmable, intelligent networks. Maupile added that it is a necessity to have diverse and strong supply chains, but there has been a consolidation of vendors. In order to reverse this, government must help incentivize and change the economies of the industry. 

Panelists added that the government can assist in enabling newcomers and incentivizing Open RAN interfaces. Further, the government should encourage Open RAN in the deployment stage, because deployed hardware will lock in what is possible for the next decade.

Panel 2: Benefits of Deployment/Driving Innovation.

Commissioner Carr voiced his support for encouraging ORAN innovation.  He viewed the benefits of ORAN deployment as (i) improving service and network performance, (ii) benefitting U.S. companies and creating high paying U.S. jobs, and (iii) giving small and rural carrier more affordable choices for secure equipment.  Commissioner Carr also noted that the FCC’s recent efforts to reform the wireless infrastructure rules would make it even easier for carriers to upgrade their networks or swap out equipment. 

A panel of industry experts from Qualcomm, IBM, GlobalFoundries, CommScope, the Open RAN Policy Coalition, Dell, CableLabs, and NVIDIA joined Wireless Telecommunications Bureau Associate Bureau Chief Charles Mathias and Office of the Chairman Policy Advisor Evan Swarztrauber to discuss the “Benefits of Deployment/Driving Innovation.” 

The panelists emphasized that ORAN will usher in a more competitive marketplace, as the network’s modularity will enable a variety of competitors to compete on cost and innovation for each component of the network. John Roese of Dell noted that 5G will be the fabric underneath the digital transformation, supporting advances in smart manufacturing, connected cities, and healthcare, to name a few industries. Overall, the panelists expressed great excitement about the potential for ORAN to spearhead technological innovations and enable a more diverse infrastructure ecosystem. 

In addition to the benefits, the panel also discussed issues associated with ORAN development. IBM’s Craig Farrell emphasized the importance of interoperability among network components and the need for compliance with set ORAN standards and specifications. Some panelists including those from CommScope, Qualcomm, and NVIDIA encouraged government action to spur deployment, such as offering investment credits to de-risk ORAN development, establishing incentives to urge efficient use of spectrum, or adopting milestones that would drive operators to adopt ORAN.    

Panel 3: Lessons from the Field: Where Do We Go from Here?

Commissioner O’Rielly focused on the potential for Open RAN to reduce network security threats.  He explained that “[b]y breaking wireless networks into components and moving away from end-to-end product lines, overall security can actually be improved.”  Commissioner O’Rielly outlined three conditions for Open RAN to be successful:  (i) no government or intergovernmental body should impose technical mandates on Open RAN; (ii) government should maintain vendor neutrality and not “pick winners or losers, especially since doing so can stymie the advancement of ideas and innovation; and (iii) Open RAN must remain voluntary.  He reiterated that “[t]he market will sift the best ideas and ultimately determine which approaches work best.”

The third panel—moderated by Chairman Pai—featured lessons learned thus far from the field from AT&T, DISH, HPE, JIO, Mavenir, Nokia, and Parallel Wireless.  The panel explored some of the benefits that companies—both in the United States and abroad—have seen with ORAN deployment.  Unsurprisingly, panelists reiterated the security benefits of ORAN and highlighted the application of zero trust security.  Panelists also discussed network integration with respect to ORAN.  DISH’s Stephen Bye identified that the ORAN architecture is giving them better visibility into “where [] pain points are when it comes to integration,” which translates into a “tremendous opportunity to integrate more effectively.”  AT&T’s Laurie Bigler identified integration as the “biggest challenge ahead” and highlighted that the ORAN specs—which are still being developed—include testing and integration specs.     

Additionally, the themes of innovation and market-based approaches were highlighted, with panelists agreeing ORAN unlocks the potential for innovation.  Nokia’s Marcus Weldon said that “openness equals maximum innovation.”  Panelists discussed a growing number of vendors, as well as the impact of ORAN on the workforce, noting that ORAN opens the door for job creation and a talent pool.  Finally, Chairman Pai asked a series of other questions, including questions about the role of ORAN in rural areas and whether there is a “leapfrogging effect” for network architecture; questions about barriers to ORAN adoption; and questions about ORAN’s impact on the Internet of Things.  

Panel 4: Technical Deep Dive

Commissioner Rosenworcel expressed both optimism and a need for urgency on Open RAN.  She explained that Open RAN presented a way to diversify 5G equipment, in turn increasing security and pushing the equipment market toward areas where the United States is strong:  software and semiconductors.  The Commissioner urged several actions to accelerate the development of Open RAN, including (i) passing the USA Telecommunications Act, which would appropriate $750 million for the development of Open RAN, (ii) launching citywide Open RAN testbeds in New York and Salt Lake City, (iii) increasing participation in international standard-setting organizations, and (iv) incentivizing the replacement of existing equipment and the development of next-generation chips to support Open RAN.

The “Technical Deep Dive” panelists were also optimistic about Open RAN. In particular, the panelists explained that Open RAN’s technical characteristics—e.g., optimizing RF resources and lowering latency—could make complex applications more viable, such as machine learning and UAS. Panelists were also optimistic about the economics of Open RAN. They specifically applauded Open RAN’s ability to open up the 5G ecosystem to more vendors, which could deliver increasingly specialized and novel applications.

But the panelists also flagged challenges. The biggest worry was the potential for “unknown unknowns”. Specifically, panelists noted that Open RAN is complex and still developing, creating the potential for problems that may be difficult to anticipate. Another concern was security. Panelists noted that Open RAN would run applications across many interfaces, potentially increasing attack surface. Combined with Open RAN’s complexity, panelists agreed that security was an important factor to keep in mind throughout the development of Open RAN.

Related Governmental Activity on Securing Communications Networks

Although the 5G Open RAN Forum was originally scheduled for late March and delayed due to the pandemic, it comes amidst a flurry of Federal government activity aimed at securing 5G networks.  Notably:

• On March 23, 2020, the President signed into law the Secure 5G and Beyond Act of 2020 (S.893), which required the development of a strategy to ensure the security of next-generation wireless communications systems and infrastructure. On the same day, the Administration published the National Strategy to Secure 5G, establishing four lines of effort Including:

  • Facilitating domestic 5G rollout;

  • Assessing the cybersecurity risks to and identifying core security principles of 5G capabilities and infrastructure;

  • Addressing risks to United States economic and national security during development and deployment of 5G infrastructure worldwide; and

  • Promoting responsible global development and deployment of secure and reliable 5G infrastructure

• In May, the Commerce Department’s National Telecommunications and Information Administration (NTIA) put out a Request for Comments on the National Strategy to Secure 5G Implementation Plan. NTIA sought information on “how the U.S. Government can best facilitate the accelerated development and rollout of 5G infrastructure in the United States and with our international partners, and lay the groundwork for innovation beyond 5G.” NTIA received more than 80 industry and stakeholder comments in response to its Request for Comments.

• At the FCC, the Commission is aggressively enacting its 5G FAST Plan, and has taken steps in connection its 2019 Report and Order Protecting Against National Security Threats to the Communications Supply Chain Through FCC Programs, which has resulted in a series of actions by the Commission and stakeholders.

Wiley’s Telecom, Media & Technology, National Security, and Cybersecurity Practice Groups have been closely tracking these and other federal and congressional activities regarding the rollout of 5G and efforts to secure the nation’s communications infrastructure. 

For more information, contact Megan Brown (mbrown@wiley.law), Katy Milner (kmilner@wiley.law), Kat Scott (kscott@wiley.law), or Boyd Garriott (bgarriott@wiley.law)