200625 comments nationalstrategytosecure5g commercedept1


August 19, 2020


On behalf of the U.S. Chamber of Commerce, I am pleased to provide these comments to inform the development of the implementation plan for the National Strategy to Secure 5G. We believe that fifth generation wireless technology (5G) offers the potential for significant benefits to consumers, businesses, research institutions, and governments worldwide, many of which will only become apparent as 5G networks are deployed and utilized. These benefits undoubtedly will help to drive economic growth for the next decade. That said, the promise of 5G only will be fully realized in the United States if the U.S. government continues to support the private sector’s deployment of 5G through a coordinated and comprehensive strategy that leverages the government’s strengths in overcoming unfair competitive practices, ensuring robust deployment, adopting secure networks, and managing the risks to our economic and national security.

Accordingly, the Chamber urges the U.S. government to take the following actions:

  1. Support investments in research.
  2. Uphold fair processes in standards-setting bodies.
  3. Accelerate deployment of all technologies that will support the 5G ecosystem.
  4. Provide strong intellectual property rights for innovators.
  5. Help allies see a larger market for trusted vendors.
  6. Facilitate the transition to interoperable technology-neutral solutions.

The Chamber, together with our members, is heavily invested in a successful rollout of 5G wireless communications systems and networks in the United States. This generation of communication systems is the most advanced and secure system deployed to date. The faster speeds, higher bandwidth, and lower latency of 5G (fiber-enabled) networks, have the potential to enable and support a wide range of applications (e.g., autonomous vehicles, remote surgery, virtual reality and the Internet of Things (IoT), and others), far beyond what current networks can support. The private sector currently is deploying these networks in a manner that includes procedures to identify, manage, and mitigate attendant risks that arise from next-generation technologies applied in novel ways.

Governments—including the U.S. government—are appropriately orienting themselves to address these risks, which include the availability and integrity of networks; the security and resilience of the supply chains that support them; and confidentiality and privacy of data that flows over and through them and is stored on them. Our members share the U.S. government’s concern that there is no place for untrusted vendors in any part of 5G networks, i.e., in the core, radio access network (RAN), or edge. Further, we believe that the U.S. government and its traditional international allies can – and must – foster trust and improve security through continued engagement with the private sector on technical and nontechnical risk identification and mitigation efforts, as well as the promotion of continued development of trusted 5G technologies, services, and products.

The Chamber acknowledges and appreciates the robust efforts underway within the U.S. government, including: (a) the White House National Strategy to Secure 5G; (b) the work of the National Economic Council to develop 5G software and other trusted 5G infrastructure; (c) the Department of Homeland Security Cybersecurity and Infrastructure Security Agency (CISA) Overview of Risks Introduced by 5G Adoption in the United States; (d) the National Institute of Standards and Technology’s (NIST) program Preparing a Secure Evolution to 5G; and (e) the leadership in advancing 5G spectrum issues by the National Telecommunications and Information Administration (NTIA) and the Federal Communications Commission (FCC).

In addition, the leadership of the National Security Council, U.S. Department of State, and CISA in working with allied foreign governments was critical in the negotiation and adoption of The Prague Proposals, in which the participating governments agreed on a set of recommendations to focus collective action to drive policies that ensure the deployment of secure and trusted 5G networks. Similarly, the common international approach to security is evidenced in the European Union’s Cybersecurity of 5G networks EU Toolbox of risk mitigation measures, which included technical consultations with the U.S. government. We recognize the U.S. government for its international engagement and leadership and look forward to future engagements. The implementation plan for the National Strategy to Secure 5G must continue to utilize a whole-of-government approach to the deployment and implementation of 5G networks, draw on the deep resources and working groups across the U.S. government, and tap the expertise resident in the private sector to inform this effort. We urge the U.S. government to organize an interagency policy development process that aligns and focuses its various 5G initiatives and strategies across agencies, with input and feedback from the private sector.

A main thrust of policymaking over the past few years is on the mitigation of threats of certain high-risk vendors (HRV) in the marketplace. The Chamber cautions the administration against policies that create artificial impediments to a vibrant marketplace merely for the sake of increasing domestic manufacturing capability. As we have said previously, it is imperative thatAmerica win the global race to 5G and close the digital divide here at home. Passage of the Secure and Trusted Communications Act (P.L. 116-124) earlier this year made meaningful progress toward
establishing a fund with the FCC to replace certain HRV equipment in previous generations of rural wireless networks. And we look forward to working with Congress, the FCC, and the National Telecommunications and Information Administration (NTIA) on implementing a flexible, fully funded replacement plan that emphasizes investment in next-generation infrastructure.

As the U.S. government further develops its implementation plan and considers new initiatives, the Chamber urges the U.S. government to continue leveraging the multi-stakeholder process that has underpinned the development of global internet policy. The Chamber also urges governments at home and abroad to bring a full spectrum of industry stakeholders together for rich discussions on threat and risk assessments and mitigation measures (strategic and technical). Our experience is that consensus-oriented, technology-neutral, and industry-supported policies and a clear and coordinated interagency policy development process offer the best approach and are scalable to meet the global challenge.

As we have stated, it is imperative that America win the global race to 5G and close the digital divide at home. Detailed responses to the four lines of effort follow in the attachment. Thank you for your consideration of these recommendations. We look forward to working with you and your colleagues across federal agencies and with our international partners.


Christopher D. Robert

200625 comments nationalstrategytosecure5g commercedept1