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Letter to the Hon. Ajit Pai, Federal Communications Commission - Federal Communications Commission


Date: Sept. 24, 2020
Location: Washington, DC

Dear Chairman Pai:
As the Federal Communications Commission (FCC) finalizes its rule to implement the Secure
and Trusted Communications Networks Act (the Act), we write to urge it to explicitly allow
impacted carriers to use reimbursement funds to purchase Open RAN technology. With the
Commission's recent finding that replacing certain Chinese-made and other untrusted equipment
will cost at least $1.84 billion, this moment presents a critical opportunity to secure and widen
our mobile network supply chain by providing as many options as possible for impacted carriers.
Congress passed the Act to support small, rural telecommunications providers to rip out and
replace certain Chinese-made and other untrusted equipment that presents significant national
security concerns and risks to Americans' privacy. While we fully expect that equipment from
trusted traditional RAN vendors will be reimbursable, as impacted carriers work to implement
the requirements of the Act, Open RAN solutions that are secure, interoperable, interchangeable,
and easily upgradeable to new applications and uses should also be made eligible for
reimbursement. The FCC plays an important role in providing impacted carriers with the
certainty they need to make investments for the future. Without clear guidance from the FCC,
smaller carriers will be unable to move forward with their rip and replace plans in a timely
Accordingly, we urge the FCC to adopt technology neutral rules that explicitly allow impacted
carriers to use funds to purchase Open RAN solutions for their networks. Thank you for your