TLPC Partners with Network Security Researchers and Public Interest Organizations to Call for Greater Cell Network Security

(by TLPC student attorneys Parker Nagle, Andrew Leddy, and Kennedy Smith)

On behalf of a coalition of independent network security researchers and public interest organizations, the Samuelson-Glushko Technology Law and Policy Clinic at Colorado Law filed reply comments on the FCC’s 2019 National Security Supply Chain Order and Further Notice of Proposed Rulemaking calling for greater cell network security. The TLPC worked with the coalition to draw attention to the many vulnerabilities plaguing cell networks that the Order did not address and to outline the broad but underutilized, authority the FCC has to advance meaningful solutions. The coalition included CU-Boulder researchers Dr. Eric Wustrow, Dr. Dirk Grunwald, and Dr. Sangtae Ha, mobile security researchers Joseph Hall, Yomna Nasser, Marcus Prem, and Ashley Wilson, and public interest organizations Electronic Frontier Foundation (EFF), Public Knowledge, and Eye on Surveillance.

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TLPC Partners with CU Engineering to Comment on New Satellite Regulations

The TLPC, partnering with Dr. Scott E. Palo and CU Engineering, worked in close collaboration to influence important national policy for small satellites at the Federal Communications Commission. The Samuelson-Glushko Tech Law and Policy Clinic at Colorado Law, led by Colorado student attorneys (now alums) Galen Pospisil and Megan Chavez, and Jake Stephens, accompanied by Stefan Tschimben a PhD candidate in the Technology, Cybersecurity, and Policy Program (TCP), worked under the supervision of Colorado Law Associate Clinical Professor Blake E. Reid to represent Dr. Palo, Professor in the Smead Aerospace Engineering Sciences Program to comment on the FCC’s rulemaking process.

The CU-led comment was the result of collaboration with distinguished small satellite researchers at universities across the U.S, including the University of Florida, the Massachusetts Institute of Technology, the University of Michigan, and others. The collaboration between TLPC and Palo allowed the comment to offer thoughtful commentary on a variety of complex issues, including satellite deployment heights, propulsion requirements, application fees, wireless spectrum requirements, and more.

The CU comment had a significant effect on the FCC’s rulemaking, helping lead the FCC to significantly lower deployment height, ensuring university researchers would maintain a range of small satellite licensing options, and more. For example, the comment successfully argued that the FCC’s proposed deployment rules would hinder university researchers from conducting important climate and space weather research.

“It’s critical that university researchers can launch critical scientific and other public interest missions that take advantage of the decreased size and cost of the small satellite form factor. It’s a privilege for the clinic to work with Dr. Palo and his colleagues to ensure the ability for university researchers to have access to space for their important work,” Professor Reid said.

“This project was a great example of how a collaboration between the College of Engineering and Law School can be impactful while educating student. As subject matter experts, the engineers provided specific details about the technical challenges and the law students used this information to create a convincing argument,” Dr. Palo said. “The TLPC took the lead on creating the filing and insured the documents were succinct and professional.”