Comment on the Federal Communications Commission’s Covered List
Today, I filed a comment to the Federal Communications Commission on several docket items, all focused on protecting the United States from national securities threat. The comment references our recent report on 5G Based Back-Ups and various CCP-linked companies that influence FCC proceedings.
October 23, 2025
VIA ECFS
Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
45 L Street NE
Washington, DC 20554
RE: Protecting Against National Security Threats to the Communications Supply Chain Through FCC Programs (WC Docket No. 18-89); Protecting Against National Security Threats to the Communications Supply Chain through the Equipment Authorization Program (ET Docket No. 21-232); Protecting Against National Security Threats to the Communications Supply Chain through the Competitive Bidding Program (EA Docket No. 21-233); Promoting the Integrity and Security of Telecommunications Certification Bodies, Measurement Facilities, and the Equipment Authorization Program (ET Docket No. 24-136)
Dear Ms. Dortch:
The Bull Moose Project applauds the FCC’s focused and ongoing work to combat threats to the national security of the United States and its citizens, including the issuance of its most recent National Security Advisory in these dockets. We also believe it is essential for the FCC to continue its work to explore GPS complements and backups to make our country more secure from threats from adversaries like China.
As America charts a path to fortify its PNT capabilities, one option stands out for its technical advantages, speed of deployment, and market-driven scalability: a terrestrial PNT system that rides on the infrastructure of modern 5G wireless networks. Given the extensive potential of a 5G-based GPS complement and backup, we were surprised to see such a robust and often negative discussion within the FCC dockets, seemingly designed to stall progress rather than solve a major national security threat.
Following an extensive investigation by the Bull Moose Project into this issue, a pattern emerged. Some opposition appeared less concerned about interference and more about stalling competition, favoring alternative approaches, or protecting China’s strategic edge and keeping America vulnerable to a single point of failure.
The attached report highlights troubling connections between several opposing groups and Chinese entities. These groups include the LoRa Alliance, RAIN Alliance, Security Industry Association, Wi-Sun Alliance, and Z-Wave Alliance. They count among their members Chinese companies such as ZTE Corporation, Shenzhen Makerfabs Corporation, Zhejiang Chint Electrics, Ningbo Dooya Mechanic & Electronic Technology Co., and Taixin Semiconductor Co. Representatives of these groups have been vocal in the FCC’s PNT proceeding, including as recently as September, when representatives of all of these groups met with senior FCC staff, including the Chairman’s senior staff, seeking to stop the FCC from moving forward with a proposal to enable 5G-based PNT.
The FCC National Security Advisory released this month makes clear that entities on the FCC’s Covered list, including ZTE Corporation, “have been determined to pose unacceptable risks to the national security of the United States and its citizens.” Yet ZTE remains a prominent member of the Z-Wave Alliance, which is seeking to influence policy in the United States.
We urge the FCC to explore these connections more deeply, and hope that our report can be helpful in informing the FCC’s ongoing work to identify threats and secure our nation’s communications networks and global PNT leadership.
Sincerely,
Aiden Buzzetti
President
The Bull Moose Project
Washington, DC
