Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554
In the Matter of ) ) Promoting the Deployment of 5G Open ) GN Docket No. 21-63 Radio Access Networks ) )
COMMENTS OF THE NTT GROUP
Masahiko Nittono, General Manager and Chief Corporate Representative David Jeppsen, Vice President Washington DC Representative Office NIPPON TELEGRAPH AND TELEPHONE CORPORATION 900 17th Street, NW, Suite 610 Washington DC 20006 (202) 595-7855
April 28, 2021 TABLE OF CONTENTS
I. Introduction and Summary ...... 1 II. Discussion ...... 3 A. Technology Leaders such as NTT Have Made Significant Progress in Developing and Deploying Open RAN Technology...... 3 B. Development and Deployment of Open RAN Solutions Will Foster Substantial Public Interest Benefits with Respect to Technological Innovation and Competition, Network Performance, and Security...... 8 C. The FCC Should Take Steps to Facilitate Industry and Intergovernmental Collaboration to Promote Open RAN Development and Deployment...... 11 III. Conclusion ...... 12
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Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554
In the Matter of ) ) Promoting the Deployment of 5G Open ) GN Docket No. 21-63 Radio Access Networks ) )
COMMENTS OF THE NTT GROUP I. INTRODUCTION AND SUMMARY
The NTT Group (“NTT”) hereby provides comments in response to the Federal
Communications Commission’s (“FCC” or “Commission”) Notice of Inquiry in the above- referenced proceeding, in which the Commission seeks comment on technology and policy issues related to Open Radio Access Networks (“Open RAN”).1 Open RAN has the advantages of expanding market entry opportunities for start-up companies, enhancing competition, and improving network security and integrity. NTT appreciates the Commission’s focus on this important technology, and is pleased both to provide the Commission with information about the significant progress made with respect to Open RAN development and deployment in recent years and to help the Commission better understand the numerous public interest benefits that robust support of Open RAN can bring to the United States.
NTT is a global leader in the telecommunications space that is helping to build the communications services and capabilities of the future, including through the development and integration of Open RAN technologies. NTT is globally recognized as one of the world’s foremost telecommunications companies. In fact, NTT consists of major Japanese and overseas companies with over 300,000 employees world-wide. Its key businesses include NTT
DOCOMO, the pre-eminent Japanese wireless communications operator that also has vital
1 Promoting the Deployment of 5G Open Radio Access Networks, GN Docket No. 21- 63, FCC 21-31 (rel. Mar. 18, 2021) (“Notice of Inquiry”).
1 operations in the United States, including on Guam and the Northern Mariana Islands, as well as two regional telecommunication operators (NTT East and NTT West), long distance and international communications operators (NTT Ltd., a global operating company, and NTT
Communications, operating in Japan). Collectively, NTT operates in more than 190 countries around the world. In addition, NTT DATA is one of the world’s leading data communications service companies, and has built a systems integration offering that contributes to the security and reliability of 5G services, including those using Open RAN architectures. Its approach to innovation and technology has been highly collaborative and has focused on key policy areas facing emerging technology solutions, including areas of particular interest to the United States such as national security and supply chain issues.
With respect to Open RAN, in particular, NTT has been a technology leader and a coalition-builder. NTT DOCOMO, Japan’s leading mobile communications service provider with over 80 million subscriptions, launched the world’s first Open RAN standard-based commercial service in Japan in 2019. In addition to serving as a founding member of the
O-RAN Alliance and on the board of the Open RAN Policy Coalition, NTT is working with
U.S. companies to promote Open RAN, such as by launching the “5G Open RAN Ecosystem” with 12 companies, including U.S. vendors. NTT offers its perspective on Open RAN more fully in the discussion below, which tracks the following topics raised in the Notice of Inquiry:
(i) the state of Open RAN development and deployment; (ii) the public interest benefits of
Open RAN solutions; and (iii) steps the Commission can take to promote Open RAN and realize those benefits.
As President Biden and Prime Minister Suga explained in their Joint Leaders’
Statement following the Prime Minister’s visit to the White House earlier this month, “[t]he
United States and Japan recognize that digital economy and emerging technologies have the
2 potential to transform societies and bring about tremendous economic opportunities.”2 NTT shares their view about the need to “collaborate to enhance [both] countries’ competitiveness, individually and together,” with respect to technology development. NTT looks forward to this process with respect to Open RAN technologies, and hopes to be a resource for the U.S.
Government as policymakers, including the FCC, move forward on this important topic.
II. DISCUSSION
A. Technology Leaders such as NTT Have Made Significant Progress in Developing and Deploying Open RAN Technology.
The Commission’s Notice of Inquiry first seeks comment on “the state of Open RAN standards development,” including the “extent [to which] these standard-setting efforts [are] being driven by” different types of technology companies and providers, including established manufacturers, smaller operators, and new entrants.3 As the FCC recognizes, a group of global carriers “established the O-RAN Alliance to develop and promote Open RAN reference architectures and protocols that foster vendor interoperability,”4 and another group of global companies “formed the Open RAN Policy Coalition to promote government policies that advance the adoption of open and interoperable RAN technologies.”5 As a founding member of the O-RAN Alliance and a board member of the Open RAN Policy Coalition, NTT has played a leading role in developing specifications and standards for open and intelligent next- generation wireless access networks.6 NTT continues to contribute to the standardization
2 U.S.-Japan Joint Leaders’ Statement: “U.S. – Japan Global Partnership for a New Era” (Apr. 16, 2021), https://www.whitehouse.gov/briefing-room/statements- releases/2021/04/16/u-s-japan-joint-leaders-statement-u-s-japan-global-partnership-for-a- new-era/ (“Joint Leaders’ Statement”). 3 Notice of Inquiry ¶ 24. 4 Id. ¶ 24 & n.62. 5 Id. ¶ 24. 6 Press Release, NTT DOCOMO, Industry Leaders Launch ORAN Alliance (Feb. 27, 2018), https://www.nttdocomo.co.jp/english/info/media_center/pr/2018/0227_00.html.
3 occurring within these initiatives and elsewhere—Cyber Creative Institute Co. Ltd. recently estimated that NTT DOCOMO holds 9.5% of authentically 5G standards essential patents
(“5G-SEPs”).7
In addition to these efforts, NTT has collaborated with other companies to solve practical implementation issues associated with the development of Open RAN specifications and standards. In February 2021, NTT DOCOMO launched the “5G Open RAN Ecosystem” together with 12 vendors including Dell Technologies, Intel, Mavenir, NVIDIA, Qualcomm,
Red Hat, VMware, Wind River, and Xilinx to further promote and accelerate Open RAN.8
While the O-RAN Alliance has played a critical role in developing 5G specifications and promoting products that allow operators to more freely combine disaggregated base station equipment, the work does not stop there. Mobile operators that introduce Open RAN must troubleshoot issues that become apparent only after performing interconnection verification, in order to bring out the maximum performance using different vendor products. The 5G Open
RAN Ecosystem aims to package best-of-breed RAN technologies and to introduce, operate, and manage them based on demands from operators considering Open RAN introduction. This initiative also aims to commercialize a more flexible and highly expandable virtualized base station in 2022.
Building on the discussion of Open RAN standardization and specifications, the Notice of Inquiry also asks about actual and prospective deployment. In particular, the Commission seeks comment on “the current state of the Open RAN ecosystem,” including “which companies are offering baseband hardware, network virtualization, packet core functionality,
7 Press Release, Cyber Creative Inst. Co. Ltd, Essentially Evaluation of SEP Declared 5G Patents (Oct. 12, 2020), https://www.cybersoken.com/file/press_5G_Patents,5G- SEP_en.pdf. 8 Press Release, NTT DOCOMO, Creation of “5G Open RAN Ecosystem” to Accelerate Open RAN to Operators Globally (Feb. 3, 2021), https://www.nttdocomo.co.jp/english/info/ media_center/pr/2021/0208_00.html (“NTT DOCOMO 5G Open RAN Press Release”).
4 or other network components,” “[w]hat factors incentivize or disincentivize vendors from developing Open RAN solutions,” and “current and future opportunities that Open RAN generates for the U.S. wireless infrastructure industry.”9 The Commission asks “what lessons can be learned from successful deployments” and from “development efforts being undertaken in other countries.”10
NTT’s trail-blazing experience in the Open RAN space holds significant promise for the deployment of Open RAN technologies and 5G networks in the United States. In 2016,
NTT DOCOMO was the first carrier in the world to separate the hardware and software of its mobile communication infrastructure by applying virtualization technology to some functions of the core network, and to start commercial operation with devices from multiple vendors.11
In September 2019, NTT DOCOMO was also the first carrier in the world to start 5G operation with devices from multiple vendors by adopting an international standard for interfaces between base station devices. Currently, NTT DOCOMO builds and operates its 5G network with equipment from Fujitsu, NEC, Nokia and Samsung. NTT DOCOMO’s 5G service is available in 209 cities in Japan as of December 2020, and the number of 5G subscriptions in
Japan reached 1.41 million as of that time.12 In NTT’s experience, the fact that the Open RAN
9 Notice of Inquiry ¶¶ 25-26. 10 Id. ¶ 30. 11 Press Release, NTT DOCOMO, DOCOMO Develops First NFV Technology for Multi- vendor EPC Software—Commercial service on DOCOMO’s mobile network to start this March, NTT DOCOMO (Feb 19, 2016), https://www.nttdocomo.co.jp/english/info/media_ce nter/pr/2016/0219_00.html#:~:text=TOKYO%2C%20JAPAN%2C%20February%2019%2C %202016%20---%20NTT%20DOCOMO%2C,multiple%20vendors%20to%20enhance%20c onnectivity%20in%20high-volume%20areas. 12 Press Release, NTT DOCOMO, DOCOMO to Commence Deployment of World’s First 4G/5G Multi-vendor Radio Access Network Conforming to O-RAN Specifications (Sept. 18, 2019), https://www.nttdocomo.co.jp/english/info/media_center/pr/2019/0918_00.html; NTT DOCOMO, FY2020/3Q Financial Results (Feb. 5, 2021), https://www.nttdocomo.co.jp /english/corporate/ir/binary/pdf/library/presentation/210205/presentation_fy2020_3q_e.pdf; Naoki Tani, Exec. Vice President, NTT DOCOMO, The Dawn of the 5G Era and DOCOMO’s
5 ecosystem enables enormous flexibility and interoperability with a complete openness to multi- vendor deployments has made Open RAN an attractive opportunity for its vendors.
NTT has leveraged its success in Japan to foster Open RAN deployment globally. In
June 2020, NTT announced that NTT and NEC Corporation (“NEC”) agreed to form a capital and business alliance, pursuant to which NTT will invest approximately 64.5 billion Japanese
Yen in NEC to support the company entering the global Open RAN market. NTT and NEC set up a research and development structure focusing on the following objectives: (1) develop and sell globally a compact Digital Signal Processing (“DSP”) circuit and optical transmission equipment incorporating this DSP circuit; and (2) promote O-RAN Alliance specifications, together with global operators and communication equipment vendors, while developing and selling globally competitive products compliant with such O-RAN specifications.13
In addition, just this week NTT announced a strategic alliance with Fujitsu Limited
(“Fujitsu”) toward the “Realization of a Sustainable Digital Society,” leveraging their respective strengths to deliver innovation that contributes to the resolution of societal and environmental challenges.14 The two companies will conduct joint research and development activities toward the realization of a variety of energy efficient, sustainable technologies in
R&D Activities (Feb. 18, 2021), https://www.nttdocomo.co.jp/english/corporate/ir/binary/pdf /library/presentation/210218/presentation_210218_e.pdf. 13 Press Release, NTT Corp, Alliance for Joint Research and Development and Global Rollout of ICT Products Utilizing Innovative Optical and Wireless Technologies (June 25, 2020), https://www.ntt.co.jp/news2020/2006e/200625b.html. NTT’s alliance with NEC also will develop innovative technologies and optical/wireless devices contributing to the realization of Innovative Optical and Wireless Network (“IOWN”) initiative. Founded in 2019 by NTT, the IOWN initiative seeks to provide advanced capabilities of low-power consumption, ultra-wide bandwidth, large-scale simulations, and ultra-realistic UI/UX for future services by cutting-edge technologies such as next generation photonics-based technologies. NTT, together with Intel and Sony, founded the “IOWN Global Forum” in the U.S. in 2020. See IOWN Global Forum, https://iowngf.org/ (last visited Apr. 26, 2021). 14 Press Release, NTT, NTT and Fujitsu Embark on Strategic Alliance to Drive “Realization of Sustainable Digital Society” (Apr. 26, 2021), https://group.ntt/en/newsrelease/ 2021/04/26/210426a.html.
6 areas including open architecture optical transport and mobile communications, combined with disaggregated high-performance computing, all of which are made possible by photonics- electronics convergence device innovation. Especially related to Open RAN, in the field of optical transport communications, Fujitsu and NTT will work together to plan new optical devices based on an open architecture, build system products developed by Fujitsu, and control supply chain management. In the mobile communications field, the two companies will study the development and promotion of open interface-based technologies, as well as the development of global businesses based on the results of these activities. For example, the two companies will work on measures to improve performance, which remains a challenge for expanding the adoption of virtualized radio access network (“vRAN”), and will develop control technologies to optimize radio access networks. NTT will use these technologies to further enhance mobile network infrastructure in preparation for full-scale 5G deployment. While the two companies will openly promote these developments with various partners, NTT and Fujitsu will actively participate in these developments and leverage results from joint research into the optical transport and mobile communications with the ultimate aim of expanding into the global market and making sustainable network infrastructure a reality throughout the world.
Furthermore, in February 2021, NTT DOCOMO announced the establishment of the
5G Global Enterprise solution Consortium (“5GEC”) to provide 5G solutions, first in Thailand and later in other Asia Pacific countries with the possible inclusion of additional partners.
Commercial services are expected to launch in 2022, targeting vertical industries such as manufacturing and construction companies based in Thailand.15
15 Press Release, NTT DOCOMO, NTT DOCOMO to Establish a 5G Consortium in Thailand with Leading Partners (Feb. 3, 2021), https://www.nttdocomo.co.jp/english/info/me dia_center/pr/2021/0203_00.html. Initial partners include ACTIVIO, AGC, AIS, EXEO ASIA, Fujitsu, Loxley, Mobile Innovation, NEC, as well as NTT Group companies such as NTT Communications. Demonstration tests are planned in Thailand in the second half of this year.
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Finally, NTT DATA—which has a significant U.S. presence—is playing a critical role in 5G deployment worldwide, including with respect to Open RAN. NTT DATA has developed a 5G integration business in the U.S.; Europe including the UK, Spain, Germany,
France; and Latin American countries including Brazil and Peru. Leveraging strategic partnerships with VMware and Mavenir, NTT DATA develops and provides private 5G solution services and contributes to the promotion of highly reliable Open RAN globally.16
In short, NTT’s experience building networks utilizing Open RAN architectures in
Japan and expanding its reach more globally holds tremendous promise for carriers looking to emulate that model and deploy in the United States. NTT’s participation in global standards bodies and initiatives that include U.S. companies will facilitate these efforts in the U.S. and around the world.17
B. Development and Deployment of Open RAN Solutions Will Foster Substantial Public Interest Benefits with Respect to Technological Innovation and Competition, Network Performance, and Security.
The Notice of Inquiry asks several questions about the benefits that Open RAN deployment can bring with respect to competition, economic output, American innovation, service affordability, network security, public safety, and wireless network performance.18
Robust deployment of Open RAN architectures will foster measurable benefits in each of these areas. Fundamentally, the entry of diverse vendors, including those from different industries and emerging vendors, will revitalize the ecosystem and drive innovation. In addition, price competition between vendors is expected to drive down costs, thereby enhancing competition among service providers.
16 Press Release, NTT DATA, NTT DATA und Mavenir geben Kooperation für 5G- Campusnetze in der D-A CH Region bekannt (Aug. 13, 2020), https://de.nttdata.com/newsro om/2020/ntt-data-5g-campusnetzwerk-mavenir. 17 Please see the attached slides for more information regarding NTT’s activities with respect to Open RAN development and deployment. 18 Notice of Inquiry ¶¶ 31-48.
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Open RAN will foster tremendous benefits with respect to the integrity and performance of American communications systems, and will spur innovation and protect national security in the process. The openness and interoperability of Open RAN solutions will reduce dependence on specific vendors, leading to diversification of the supply chain.
NTT DOCOMO builds and operates a 5G wireless access network with multiple vendors, selects the best-of-breed products according to various use cases, and realizes flexible equipment construction. By way of example, NTT DOCOMO and NEC have expanded multi- vendor interoperability by interconnecting a new 5G base station baseband unit (5G-CU/DU), developed by NEC and Samsung Electronics and compliant with O-RAN Alliance specifications, with 5G base station remote radio units (5G-RUs) of other vendors on
DOCOMO’s commercial network.19
Vendor diversification will enhance technological competition and strengthen industrial competitiveness. Specifically, as products become more Open RAN compatible, operators will be able to select from various options, and opportunities for new vendors to enter into the market will increase. 20 In addition, innovation brought about by new entrants, including those from different industries, will lead to improved product performance. NTT expects that its 5G Open RAN Ecosystem will be utilized as a mechanism for both RAN vendors and operators to enjoy these benefits. Open RAN also improves the degree of freedom in selecting a vendor, and the operator can construct a flexible and efficient network. This vendor diversification phenomenon thus will drive the rapid and flexible development of 5G service areas.
19 Press Release, NTT DOCOMO, Expanded Lineup of 5G Base Stations using O-RAN Specifications (Sept. 30, 2020), https://www.nttdocomo.co.jp/english/info/media_center/pr/2 020/0930_01.html. 20 For example, Fujitsu has received an order for Dish’s Radio Units, and NEC participates in the Open RAN trial program in the U.K.
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The national security benefits stemming from this type of vendor diversification are two-fold: first, the ability to rely on multiple vendors makes it easier to replace particular vendors or parts that are determined to pose national security risks. Second, compared with virtually integrated architecture provided by a single vendor, the open interface architecture improves the visibility to monitor the network security, because mutual monitoring by multiple vendors is expected. Accordingly, as the Notice of Inquiry suggests, Open RAN considerably
“address[es] supply chain risk management issues and enable[s] the deployment of secure and reliable networks in the United States.”21
NTT understands the importance of supply chain integrity and secure networks. The company has been particularly focused on the security-related aspects of 5G deployment and
Open RAN integration. For instance, NTT participated in the Center for Strategic and
International Studies’ (“CSIS”) establishment of Trustworthiness standards,22 contributed to the Prague 5G Security Conference,23 and participates in the DHS/CISA ICT Supply Chain
Risk Management Task Force.24 NTT also has closely followed the U.S. government’s actions with respect to supply chain risk management and the identification of untrusted vendors of telecommunications equipment. Consistent with these governmental efforts, NTT, which has approximately 1,000 affiliates, has conducted a group-wide survey of equipment used by group companies around the world, and replaced tens of thousands of products supplied by such
21 Notice of Inquiry ¶ 40. 22 Center for Strategic and International Studies, Criteria for Security and Trust in Telecommunications Networks and Services: CSIS Working Group on Trust and Security in 5G Networks (May 13, 2020), https://www.csis.org/analysis/criteria-security-and-trust- telecommunications-networks-and-services. 23 National Cyber and Information Security Agency, Prague 5G Security Conference: Executive Summary and Draft Agenda, Sept. 23-24, 2020. 24 Cybersecurity and Infrastructure Security Agency, Information and Communications Technology (ICT) Supply Chain Risk Management (SCRM) Task Force (last updated April 26, 2021), https://www.cisa.gov/ict-scrm-task-force#.
10 untrusted vendors. Trusted and dedicated industry participants like NTT can play a vital role in realizing the two countries’ collective goals, including the U.S.-Japan Competitive and
Resilience (“CoRe”) Partnership objective to “[a]dvance secure and open 5G networks, including [Open-RAN], by fostering innovation and by promoting trustworthy vendors and diverse markets.”25
C. The FCC Should Take Steps to Facilitate Industry and Intergovernmental Collaboration to Promote Open RAN Development and Deployment.
The Notice of Inquiry asks about how the Commission can support Open RAN development and deployment.26 The absence of an integrator that drives verification and introduction of different vendor devices can be a hindrance to widespread use. NTT encourages the FCC to work with appropriate U.S. government agencies to establish an open verification environment and a collaborative framework to promote integration, similar to the
O-RAN Alliance’s Open Test and Integration Center (“OTIC”) and NTT DOCOMO’s 5G
Open RAN Ecosystem. These efforts not only will improve development and deployment in the United States, but will also allow for data sharing among allies with similar initiatives, further catalyzing innovation to the benefit of U.S. technology and consumers.27
Indeed, intergovernmental collaboration plays a critical in the development of technologies such as Open RAN, and NTT accordingly urges the FCC and the U.S.
Government to look to key allies like Japan as it develops Open RAN policy and explores the potential of this important technology. The Japanese government is actively developing
25 Statement and Release, The White House, Fact Sheet: U.S.-Japan Competitiveness and Resilience (CoRe) Partnership (Apr. 16, 2021), https://www.whitehouse.gov/briefing- room/statements-releases/2021/04/16/fact-sheet-u-s-japan-competitiveness-and-resilience- core-partnership/. 26 See Notice of Inquiry ¶¶ 60-70. 27 Testing & Integration, O-RAN Alliance, https://www.o-ran.org/testing-integration (last visited Apr. 26, 2021); NTT DOCOMO 5G Open RAN Press Release.
11 policies to promote Open RAN; for example, the government provides tax incentives to companies that procure Open RAN hardware and software. NTT DOCOMO and three other mobile operators (namely, KDDI, Softbank, and Rakuten) collaborate in order to fulfill the
Japanese government’s goal of developing OTIC in Japan. As President Biden and Prime
Minister Suga expressed in their recent Joint Leaders’ Statement, collaboration related to
“promoting and protecting critical technologies that are essential to our security and prosperity” is a critical aspect of the U.S.-Japan relationship.28 NTT encourages ongoing collaboration with Japan in the area of Open RAN technologies and 5G deployment, and looks forward to serving as a resource that can bridge the two countries given its success with Open RAN deployment in Japan and its significant investment in the U.S. technology ecosystem.
III. CONCLUSION
NTT appreciates the opportunity to provide the Commission with information about
Open RAN development and deployment and the benefits that this technology can bring to
American communications networks. NTT looks forward to working with the Commission as it develops policies in this area.
Respectfully submitted,
/s/ Masahiko Nittono
Amb. David A. Gross Masahiko Nittono, General Manager and Anna M. Gomez Chief Corporate Representative Sara M. Baxenberg David Jeppsen, Vice President WILEY REIN LLP Washington DC Representative Office 1776 K St. NW NIPPON TELEGRAPH AND Washington, DC 20006 TELEPHONE CORPORATION (202) 719-70000 900 17th Street, NW, Suite 610 Washington DC 20006 Counsel to the NTT Group (202) 595-7855
April 28, 2021
28 Joint Leaders’ Statement, supra note 2.
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NTT`s Activities for Realization of Open Network
【Open Interface】 ・Achievement of interoperability across multi-vendor LTE and 4G base stations and commercial introduction (2010). ・Completion of global standardizations at O-RAN Alliance based on the specifications defined by NTT (2019). ・Deployment of multi-vendor base stations conforming to O-RAN standards in the pre-commercial 5G service【World's first】(2019).
Base station Vendor F Vendor Z Vendor β Vendor Y Core network Vendor α Centralソフトウェア Unit(CU) Vendor C RU（無線機） Open I/F Vendor X Open I/F （仮想化） Software Vendor B Software Vendor A Open I/F
【Virtualization (Base station)】 【Virtualization (Core network)】 (*1) ・Standardization in progress. ・Commercial introduction of multi-vendor EPC software【World's first】(2016). ・Working on "5G Open RAN Ecosystem" to ・Completion of virtualization to 40% of total core network equipment by the end realize a virtualized base station with of FY2019 (to be completed 100% by the end of FY2024). excellent performance and lower expenditure. (*1)Evolved Packet Core (Equipment with functions of user mobility control, user authentication, billing etc.)
Copyright 2021 NTT CORPORATION 1 5G Open RAN Ecosystem ◼ NTT Docomo launched “5G Open RAN Ecosystem” with 12 companies in order to expand open RAN (Radio Access Network) globally. ◼ This initiative offers testbeds in Japan to verify interoperability among several different vendors’ equipment. Operators can access to the testbeds from abroad. Partners Dell Fujitsu Intel Mavenir Technologies
NEC NTT DATA NVIDIA Qualcomm
Red Hat VMware Wind River Xilinx
Red : US Companies Copyright 2021 NTT CORPORATION 2