Tag: "federal government"

Posted November 30, 2009 by christopher

I have just submitted comments from the Institute for Local Self-Reliance to both the the National Telecommunications and Information Administration (NTIA) and the Rural Utilities Service (RUS) regarding suggestions for rules in round two (the last round) of the broadband stimulus programs -- the Broadband Technology Opportunities Program (BTOP - administered by NTIA) and Broadband Initiatives Program (BIP - administered by RUS).

The two agencies previously posted a joint request for information [pdf] on lessons learned from the first round:

RUS and NTIA released a joint Request for Information (RFI) seeking comment on further implementation of the Broadband Initiatives Program (BIP) and the Broadband Technology Opportunities Program (BTOP). Comments must be received by November 30, 2009. The input the agencies expect to receive from this process is intended to inform the second round of funding.

We offered five pages of comments, responding directly to the questions - I am led to believe that this is the preferred way of responding to such requests for information. Thus, the format consists of a short introduction and then questions (in italics) followed by our responses.

Unsurprisingly, we generally encourage NTIA and RUS to better serve the public interest by requiring more transparency in the second round. We also call on them to stop accepting "advertised" speeds in their broadband definition and use actual delivered speeds in order to ensure communities are not discouraged from applying because their incumbent providers exaggerate the capabilities of their network.

Most importantly, we call on NTIA and RUS to encourage public sector entities to apply by ceasing to consider all private networks to operate in the public interest. As we previously documented here, NTIA subverted the intent of Congress with the rules from round one. The rules should prefer public and nonprofit entities as they are directly accountable to the public and should therefore be the first in line to receive public money for essential infrastructure.

As the number of applications to NTIA and RUS was far higher than expected, making the public interest requirements stronger should be a natural...

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Posted November 4, 2009 by christopher

The FCC is asking for comments on the contribution of federal, state, tribal, and local government to broadband [pdf]. Comments are due on Friday, Nov 6.

Take a look at the comment request above (it is only 5 pages long) and pick one of the areas in which they are interested - readers here may be most interested in #2 - "Government broadband initiatives."

a. Governments have engaged in various initiatives to increase broadband deployment and adoption in certain geographic areas. With regard to specific examples of federal, state, tribal, or local broadband initiatives, how did the initiatives come to fruition from start to finish? Please describe cost information, including planning, equipment, training, labor, and conclusion of the initiatives, as well as barriers that were overcome. What elements of the initiation, planning, or implementation were most critical to the success of the project? What factors impacted the technological choices made in the planning and implementation of the project? Were the projects sustainable, and have the projects continued beyond their initially conceived timeframes? What were the costs and the resulting empirically demonstrable benefits or harms of the implementation? How did costs and benefits differ from the original plan and why?

b. What conclusions should be drawn from any particular experiences (e.g., what efforts or practices should be replicated or avoided)?

c. Please provide examples of governments aggregating demand to encourage broadband deployment. Are such programs sustainable? Do these programs cause the deployment of network infrastructure that otherwise would not have occurred? Please provide data when possible.

d. How can successful broadband solutions be more widely shared or publicized to enable other governments to benefit? What should be the role for the federal government (and specifically, this Commission) in fostering the widespread adoption of ideas and initiatives that have worked?

e. Is there a role for non-profit or private sector partnerships in governmental broadband solutions?

Please provide examples from real-life initiatives.

You do not have to answer everything - feel free to just pick one aspect you want to bring to the FCC's attention and then:

  1. Go to the...
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Posted July 8, 2009 by christopher

I have been digesting the NOFA (the rules for broadband stimulus projects) and I am stunned at just how much I disagree with them. I think the National Telecommunications and Information Administration, a branch of the Department of Commerce in D.C., and the Rural Utilities Service have really done a disservice to this country.

Before I highlight some commentaries that I have found most interesting thus far, I want to note that this is why we take a bottom-up approach. In talking to many people working on community networks, most everyone is frustrated and the rest are really angry. It sure seemed like the feds were heading in the right direction, but the broadband stimulus rules show just how out of touch they are. We advise communities to find ways of being self-reliant. If they are able to get help from D.C., that is great; but they should never depend upon it.

We will have some more details of our reaction to the rules soon, but for now I wanted to highlight some of the folks that reacted quickly and offered interesting thoughts.

Starting on the positive side, Andrew Cohill at Design Nine thinks the encouragement for open access networks and transparency could ultimately be the defining characteristic.

This means networks that offer competitive pricing from more than one provider get preference--this is huge, and could have important long term consequences.

The rules also do something else quite important on the same page (page 66, line 1463), where there is explicit preference for open access transport, which in telecom jargon is "interconnection." The rules say that companies that post their interconnection fees publicly and agree to nondiscrimination will get preference.

If he is correct, the implications are great. However, the rules certainly could have demanded open access as a condition of public money being used rather than a limited form of extra credit for those who will encourage competition in a market suffering the utter lack of it.

Harold Feld, who rightly noted that good people struggled and worked on this, saw both positives and negatives in the rules. He defends the "broadband" speed definition from the FCC (768kbps down and 200kbps up):

I am in the minority in thinking they played this right. There are too many good projects...

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