Image: Dept of Commerce

The RNT Foundation submitted comments to the Department of Commerce this week regarding PNT-related dependencies and risks in the supply chain for the production information and communications technology (ICT) devices.

Production of ICT devices depends upon PNT services in two important ways, according to the submission.

First, PNT services are used in transportation, logistics, telecommunications, SCADA, and other systems that support all supply chains, including those for ICT device production.

Second, many ICT devices, such as network, digital broadcast, land mobile radio, and navigation equipment, are built to take advantage of and use PNT services. Thus, without extant PNT, there would be no reason to produce those devices in the first place.

As our readers would anticipate, RNTF comments focused on our concern that most all of America’s PNT is sourced directly or indirectly from GPS and the vulnerabilities associated therewith.

The comments were submitted in response to a request for information issued by the Commerce Department and posted in the Federal Register. The last day for the public to submit comments is the 4th of November.

Part of the Commerce Department’s request was for policy recommendations. RNTF’s primary recommendation was for the executive branch to follow the law and establish one or more backup capabilities for GPS in accordance with the National Timing Resilience and Security Act of 2018.

The comments were submitted with a wealth of supporting information. Much of it was identical to that previously submitted in response to a Request for Information issued by the Transportation Department about supply chains and the nation’s transportation industrial base.