Today, I submitted comments opposing the petition for reconsideration and application for review (AFR) of the recent Federal Communications Commission Covered List expansion.

Introduction

The Foundation for American Innovation is written to oppose the petition for reconsideration and application for review (AFR) of the recent FCC Covered List expansion. Members of my organization, the Foundation for American Innovation, have continuously reported on the dangers posed by SZ DJI Technology Co. and Autel Robotics Co. With a focus on the intersection of policy and technology, we are well positioned to comment on the assertions made by the petition and AFR, both of which misconstrue their companies’ activities and deny the clear and present national security threats their U.S. presence poses. The Secure and Trusted Communications Networks Act of 2019 Section 2(b) specifies three capabilities that qualify an entity for the Covered List. The FCC must list an entity if its equipment or service can "[redirect] user data traffic or [permit] visibility into any user data” it transmits, if it causes “the network of a provider of advanced communications service to be disrupted remotely,” or if it “otherwise [poses] an unacceptable risk to the national security of the United States." DJI qualifies on all three counts; Autel on at least two. I and other members of my organization therefore welcome the FCC’s designation and oppose the corresponding petition and AFR promulgated by DJI and Autel.