2020年美國國家5G戰略和未來的無線創新 -美國信息技術和創新基金會（英文版）（56頁）.pdf

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1、 June 18, 2020 National Telecommunications and Information Administration U.S. Department of Commerce 1401 Constitution Avenue NW Washington, DC 20230 RE: Comments on the National Strategy to Secure 5G RE: Comments on the National Strategy to Secure 5G Implementation PlanImplementation Plan Docket N

2、o. 200521Docket No. 200521- -01440144 The Information Technology and Innovation Foundation appreciates this opportunity to comment on the development of a national strategy to facilitate a secure 5G deployment in the United States and around the world.1 ITIF strongly believes that continued wireless

3、 innovation plays a critical role in integrating a wide range of emerging technologies into productive capacities throughout the economy. A successful deployment of 5G, as well as sustained wireless innovation beyond 5G, are opportunities of national importance. This fact is not lost on our geopolit

4、ical rivals: For years China has enacted policiessome fair and legitimate, many notto boost its domestic development, manufacture, and use of wireless technology. It is past time for a coordinated U.S. response. The administration is tasked with developing a comprehensive national strategy for 5G.2

5、NTIAs request for comments outlines four potential areas of effort: (1) facilitating domestic 5G rollout; (2) assessing the cybersecurity risks to and identifying core security principles of 5G capabilities and infrastructure; (3) addressing risks to United States economic and national security duri

6、ng development and deployment of 5G infrastructure worldwide; and (4) promoting responsible global development and deployment of secure and reliable 5G infrastructure.3 ITIFs recent report, “A U.S. National Strategy for 5G and Future Wireless Innovation,” enclosed herein, addresses these points.4 Fo

7、r further information on how Chinas policies have 1 ITIF is an independent 501(c)(3) nonprofit, nonpartisan research and educational institutea think tank. Its mission is to formulate, evaluate, and promote policy solutions that accelerate innovation and boost productivity to spur growth, opportunit

8、y, and progress. ITIFs goal is to provide policymakers around the world with high-quality information, analysis, and recommendations they can trust. See About ITIF: A Champion for Innovation, ITIF (accessed June 2020), https:/itif.org/about; National Telecommunications and Information Administration

9、, “The National Strategy to Secure 5G Implementation Plan,” RFC Docket No. 2005210144, 85 Fed. Reg. 32016 (May 28, 2020), available at https:/www.ntia.doc.gov/files/ntia/publications/fr-secure-5g-implementation-plan-05282020.pdf. 2 Secure 5G and Beyond Act of 2020, Public Law No. 116129, 134 Stat. 2

10、23227 (2020). 3 The National Strategy to Secure 5G Implementation Plan, supra. 4 Doug Brake, “A U.S. National Strategy for 5G and Future Wireless Innovation,” ITIF (April 2020), https:/itif.org/publications/2020/04/27/us-national-strategy-5g-and-future-wireless-innovation. 2 undermined the global te

11、lecommunications equipment industry, please also see the forthcoming ITIF report “How Chinas Mercantilist Policies Have Undermined Global Innovation in the Telecom Equipment Industry.”5 Accelerating a secure 5G deployment will be a force multiplier for growth, justifying government assistance the pr

12、ivate sector-led rollout and subsidies for uneconomic areas. Government agencies should leverage 5G for their own processes and encourage its use in their related industries, and state and local governments should eliminate barriers to deployment. Congress should appropriate funds for pilot programs

13、 to identify and overcome challenges with the ongoing transition to virtualize network functions, introducing more software running on generic hardware infrastructure in wireless networks. Policymakers should increase funding for early stage wireless R support fair processes in standards-setting org

14、anizations; assist allies to see a larger market for trusted vendors; and protect IP rights for innovators. It is critical networks are built with secure components. A ban on Chinese 5G equipment entering the U.S. makes sense, but a direct ban on exports to Huawei only hurts U.S. technology firms. A

15、 better strategy should drive wireless innovation beyond 5G, with equipment from a diversity of suppliers. Efforts to define standard, open interfaces between critical components of wireless networks are a promising opportunity to shift the radio access equipment market toward one that is more innov

16、ative, less costly, and more difficult for any single company to corner. The government should look to develop appropriate mechanisms to help openly define radio access equipment interfaces and assist in identifying and overcoming challenges with the deployment of such equipment at scale. For exampl

17、e, the Manufacturing USA program should begin a wireless institute focused on scaling up the manufacture of secure, open radio equipment in the United States. For more details, please see the report below. Thank you for your consideration. Sincerely, Doug Brake Director, Broadband and Spectrum Polic

18、y The Information Technology and Innovation Foundation 5 Robert D. Atkinson, “How Chinas Mercantilist Policies Have Undermined Global Innovation in the Telecom Equipment Industry,” ITIF (forthcoming, June 2020). INFORMATION TECHNOLOGY support fair processes in standards-setting organizations; assist

19、 allies to see a larger market for trusted vendors; and protect IP rights for innovators. It is critical networks are built with secure components. A ban on Chinese 5G equipment makes sense; a ban on exports to Huawei does not. A better strategy should drive wireless innovation beyond 5G, with equip

20、ment from a diversity of suppliers. INFORMATION TECHNOLOGY a strong intellectual property (IP) protection system and support of the business models needed for the entities bringing research breakthroughs to market; and encouragement of fair voting and healthy institutional practices at standards-set

21、ting bodies such as the Third- INFORMATION TECHNOLOGY it may well be better to wait for the natural upgrade cycle. The United States should work with like-minded allies to ensure a large- enough market of trusted wireless equipment suppliers. The State Department should create an elevated position d

22、esigned for 5G-related and other international concerns around security and emerging technologies. Policymakers should support continued wireless R fiber fronthaul (connecting the radio antenna units to the baseband signal processing equipment) and backhaul (connecting that signal processing back to

23、 both the core network and the wider Internet or telephone network) must be installed. Advanced vRANs are no lessand often moredependent on the physical infrastructure. However, open vRAN equipment features several advantages, with lower cost, faster innovation, more supplier diversity, and more-eff

24、icient use of resources among them. INFORMATION TECHNOLOGY others tout remote-controlled robotic surgery.31 Some of 5Gs potential is at risk of being oversold. Gartner, INFORMATION TECHNOLOGY (2) utilizing localization targets and government procurement to favor domestic firms; (3) promoting Chinese

25、 technology standards domestically and internationally; (4) constraining foreign market access; (5) cultivating national champions (e.g., Huawei and ZTE); and (6) allegedly engaging in cyber espionage and IP theft.46 They could have added the policy from the 1990s and first decade of the 2000s that

26、INFORMATION TECHNOLOGY allegations of bribery or corruption; and sanctions violations, including allegations of re-exporting U.S. technology to Iran, Sudan, and Syria.57 The potential for cooperation with the Chinese government is generating considerable animus toward Huawei from the Trump administr

27、ation. Secretary of State Mike Pompeo made this equivalence between the company and the party clear, “Huawei is an instrument of the Chinese government.”58 Reports indicate the U.S. State Department has been sharing strong evidence that Huawei works directly with Chinese security agencies.59 It appe

28、ars the conversation has largely moved past whether or not there are backdoors or vulnerabilities to what should be done about them. Some countries believe the risk of using Chinese equipment in the so called “edge” (i.e., the RAN radio equipment) is considerably lower than using such equipment in t

29、he core of the network that provides the functionality of telecommunications services and connects users to the rest of the Internet. Most notably, U.K. rules cordoned off Huawei equipment to only the RAN in particular less-sensitive areas of their 5G networks.60 The United States, however, is of th

30、e position that, in the words of Deputy Assistant Secretary for Cyber and International Communications and Information Policy Robert Strayer, “There is no way that we can effectively mitigate the risk to having an untrustworthy vendor in the edge of the network.”61 There is also long-term concern th

31、at with the help of Chinese policy, Huawei may well continue its meteoric rise and eventually threaten the viability of other equipment manufacturing companies and become the predominant network provider globally. This monopolistic position would not only result in economic harmnot the least of whic

32、h would be higher prices and potentially less innovationbut significant vulnerabilities and dependencies. This could very well force Europe and its allies to consider plans now for what to do if Nokia or Ericsson fail. Long-Term Innovation Mercantilism in Wireless The short-term theoretical threat o

33、f trade-secret theft, espionage, and even sabotage from untrusted equipment in the 5G supply chain has captured a lot of attention in the media and political circles. However, a targeted ban on the use of high-risk vendors in the United States, combined with cost-effective risk-mitigation strategies

34、 undertaken by U.S. allies goes a long way toward mitigating that risk. In addition to those relatively straightforward concerns, policymakers INFORMATION TECHNOLOGY others are worth emulating. In any event, it is important to realize that at this point Huawei is a juggernaut of a company. Its treme

35、ndous economies of scale and scope, in a sector wherein they are incredibly important, mean the United States must think creatively. Global Competitiveness and 5G Adoption We cannot take for granted that there is sufficient initial demand for 5G services to drive the level of deployment that would b

36、e optimal for national competitiveness. These networks are expensive to deploy, and face something of a chicken-or-egg problem when cutting-edge applications that can take advantage of the jump in performance are not yet widely available and may well require significant efforts to be developed. Sout

37、h Korea, the United States, China, and Japan are expected to be leading adopters of 5G devices. In terms of the share of total connections (excluding Internet of Things), projections estimate 59 percent of South Koreas, 50 percent of the United States, and 48 percent of Japans connections will be 5G

38、 by 2025.89 Consumer surveys indicate demand for 5G devices is INFORMATION TECHNOLOGY sensing and measuring technologies; pervasive computing with drones; virtual and augmented reality; and automated control systems. 5G is an enabling platform that can best be leveraged only if policymakers support

39、a full digital transformation across an array of emerging technologies and application areas. This is a challenge, wherein applications that take advantage of the performance characteristics of next-generation wireless technologies require networks of adequate scale, but networks require sufficient

40、demand to justify the large investment needed to achieve widespread deployment. This chicken-or-egg problem is highlighted when comparing deployment in market-oriented economies such as that of the United States, and relatively non-market deployments, such as in China, which have been more willing t

41、o address this market failure. To achieve the full spillover benefits of advanced, next-generation deployments, policies should seek to spur the adoption and use of these networks, including through development of cutting-edge applications. OVERVIEW OF THE CURRENT APPROACH TO CHALLENGES U.S. officia

42、ls have examined the challenges to a successful, flourishing 5G future and decided on a number of tools, many of which appear to be aimed to thwart the rise of Chinese participants, with most of the concern focused on Huawei. It is probably fair to characterize the current approach as “scattershot,”

43、 with a variety of different actors throughout the government doing what they can to limit Huawei in the United Statesor even curtail its rise altogetherand the FCC acting to speed 5G deployment through infrastructure and spectrum policy. There are a lot of moving parts to the administrations 5G eff

44、orts. This section offers a summary overview of some of the current key government actions touching 5G and Huawei. INFORMATION TECHNOLOGY however, the administration is considering expanding their scope through changes to the de minimis and direct product rules.101 Over 160 major U.S. companies have

45、 applied forand at least some have received licenses to do business with Huawei despite the Entity List designation.102 Diplomacy The state department has been busy communicating with governments and mobile operators around the world, attempting to convince them to avoid using potentially risky equi

46、pment. This effort intersects with a variety of challenges posed by confronting China for unfair practices in trade and policy across a number of industries. Robert Strayer, the deputy assistant secretary of State for Cyber and International Communications Policy at the State Department has been a l

47、ead advocate abroad for the U.S. governments view of the 5G challenges. He and others have held discussions with numerous foreign countries in an attempt to convince them to forego Huawei equipment, with a goal of maintaining a large pool of demand for non-Huawei gear, and lowering the risk of doing

48、 business and sharing intelligence over allies communications networks. These attempts have seen varying levels of success. The decision of the United Kingdom to allow some Huawei equipment into its 5G networks provides a useful lens to understand the dynamics of international 5G diplomacy. There, t

49、he United Kingdom declined to follow the advice of U.S. representatives, and decided to effectively allow Huawei RAN equipment in about a third of its networkmostly the rural parts. While obviously the United Kingdom declined to follow the U.S. recommendation, this is not as big a loss as it might seem. After an analysis that determined only a modest risk in allowing Huawei to touch certain segments of its network, the United Kingdom formally designated Huawei as a high-risk vendorno small decisionand seems to be incli