Tag: "public comment"

Posted October 29, 2019 by lgonzalez

In August 2019, the Federal Communications Commission (FCC) announced that they would begin to restructure their data collection techniques forming the basis of national broadband availability maps. The nonprofit Free Press submitted comments, as did the Institute for Local Self-Reliance and other organizations that consider correct mapping data a key element to expanding access to broadband. In this episode of the podcast, Free Press Research Director Derek Turner and Christopher talk about the proceeding and different perspectives toward moving forward.

Christopher and Derek discuss current problems, suggestions for correcting them, and what the FCC should continue to do as part of data collection. At the heart of current FCC data collection is Form 477, which several broadband advocates suggest should be scrapped. Turner disagrees with starting from scratch, however, and explains that Form 477 still contains data that researchers find valuable beyond visualizations.

Derek talks about how we came to this point in history and the origins of Form 477, which explain many of the reasons why the FCC maps overstate actual broadband coverage. He and Christopher touch on rural data collection from Microsoft, which looks at subscriptions, and compare those results to FCC data.

You can read the comments to the FCC from Free Press here [PDF] and check out on their work...

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Posted October 22, 2019 by lgonzalez

If you're a regular reader of MuniNetworks.org, you've seen Karl Bode's name and it's almost certain you've read his work elsewhere. Karl has had his finger on the pulse of telecom, broadband, and related legislative events for a long time.

This week, Karl comes on the show to talk about how his career trajectory led to where he is right now, the surprising and unsurprising things he's seen, and how media coverage of telecom and technology has changed over the years. There are some issues, notes Karl, that should be handled more aggressively both in developing policy and in how the media covers them. The impact of large monopolistic Internet service providers, privacy concerns, and network neutrality are a few matters that affect us more than most people realize. 

Christopher and Karl talk about the FCC and corruption of the commenting system that surrounded the decision to retract federal network neutrality protections. They also talk about Washington D.C.'s different attitudes toward big tech companies such as Google and Facebook versus big ISPs like AT&T and Comcast.

We want your feedback and suggestions for the show-please e-mail us or leave a comment below.

This show is 32 minutes long and can be played on this page or via iTunes or the tool of your choice using this feed. You can listen to the interview on this page or visit the Community Broadband Bits page.

Read the transcript for this episode.

Listen to ...

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Posted October 15, 2019 by lgonzalez

When local communities apply for funding to improve local Internet infrastructure, grants and loans are often predicated on the need to deploy to unserved and underserved premises. Whether it's federal, state, or local sources, Federal Communications Commission (FCC) data determining whether or not a region has access to broadband is often the data that funding entities rely on. In recent years, it’s become apparent that FCC data grossly understates the lack of accessibility to broadband. Finally in August 2019, the FCC called for comments as they reconsider how to collect fixed broadband data. The Institute for Local Self-Reliance teamed up with Next Century Cities and several other organizations with whom we often collaborate, submitted both Comments and Reply Comments.

Fixing the Bad Data

We’ve covered this before, and the Commission has now decided to make changes. Traditionally, FCC data on broadband Internet access has been collected from Internet service providers (ISPs) that self-report on the areas they serve via Form 477. If a company has the ability to serve one premise in a census block they report to the Commission that they serve the entire block. Reality, however, often does not reflect such a high level of connectivity in one area.

When FCC data incorrectly determines that locations have the ability to subscribe to one or more Internet access companies, those areas lose eligibility for grants and loans for Internet network infrastructure. Sadly, these places are often caught in a strange purgatory between faulty FCC data and reality in which they can’t obtain funding to build out high-quality Internet access, and yet large Internet access companies don’t consider their areas a good investment due to low population densities.

logo-ilsr.PNG For years now, the Institute for Local Self-Reliance and other organizations have worked to bring attention to the problem. A few lawmakers have pushed for change and several states, including Georgia and...

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Posted November 28, 2017 by lgonzalez

The FCC is set to vote on whether or not to repeal network Neutrality under the deceptive guise of “Restoring Internet Freedom” on December 14th. Like others who study broadband and telecommunications policy, we’re distressed by the possibilities for the Internet and its users, should the Commission decide to repeal these protections. Because we use the Internet for so much in our daily lives, reversing network neutrality will give big ISPs like Comcast and Verizon undue power over what information we receive, our online business, and the result may negatively impact innovation. 

We’ve gathered together some of our earlier posts on network neutrality to help explain why the policy is so important. In this collection, we’ve included some of our own writings as well as media that we consider paramount to understanding why we need to preserve network neutrality.

The Basics At 80 MPH (Video):

An old but a goody. In this video, Professor Tim Wu explains network neutrality, including paid prioritization. The video is from 2016.

The Big ISP Perspective (Video):

Many of us consider a free an open Internet a necessity to foster innovation and investment, but the words from the lips of the big ISPs are changing, depending on whom they’re talking to. This video reveals what they tell the government about network neutrality versus what they tell investors.

The Small ISP Perspective (Audio):

Like other small ISPs and municipal networks that offer services to the public, Sonic takes the opposite view of Comcast, Verizon, and other big corporate incumbents - they believe network neutrality is important and should be preserved. Dane Jasper, Sonic’s CEO and Co-Founder explains why innovation needs network neutrality in episode 261 of the Community Broadband Bits podcast.

Artists Appreciate The Freedom of...

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Posted October 30, 2017 by lgonzalez

This fall, nonprofits and other organizations with an interest in constructive broadband policy have worked to help the new administration’s FCC through the public comment process. We’ve let readers know about opportunities to share their thoughts with the Commission and we’ve submitted comments separately and with other likeminded groups.

Modernizing the Form 477 Data Program

The Commission asked for comments on the method in which it collects data regarding where broadband is accessible. ISPs provide information to the FCC based on which census blocks they serve. We’ve often criticized this approach because it grossly overstates where coverage is available, especially in rural areas where census blocks tend to be large. 

Read our ideas for improvements to the Form 477 data collection, which include obtaining more detailed geographic information, minimum and maximum speeds, and pricing information.

Connect America Funding Phase II Bidding Procedures and Program

In order to help bring better connectivity to rural areas, the FCC distributes Connect America Funds (CAF) to entities such as companies and cooperatives to build broadband infrastructure. The process involves bids from these entities. The FCC is considering changes to the current process and bidding procedures, including what types of projects qualify for funding. The Commission asked for comment after proposing a long list of possible changes.

We recently spoke with Jon Chambers of Connexon, who provided more detail about the program and offered his thoughts on CAF and the possible changes.

Read our Reply Comments, that address issues we feel need attention, including the Carrier of Last Resort guarantee, more opportunities for rural cooperatives, and our concern that the FCC will attempt to equate subpar satellite and mobile broadband with high-quality connectivity. We filed our Reply Comments with Public Knowledge, Appalshop, and a long list of other organizations concerned about Internet access in rural America.

Deployment of Advanced...

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Posted September 20, 2017 by lgonzalez

September 21st is the last day individuals and organizations have to submit initial comments on the FCC’s “Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion,” Docket 17-199. As of this writing, more than 1,400 filers have submitted comments but the gravity of the policies the FCC is reviewing should have more input from all over the country. So far, people and organizations that have commented are not happy with the ideas of dumbing down the definition of "broadband" and letting mobile and satellite Internet access satisfy connectivity needs in rural America. What do you think? Let the FCC know.

Time and Speeds

The FCC released the Notice of Inquiry (NOI) on August 7th, asking for comments from the public on a broad range of issues. Many experts and organizations quickly zeroed in on a few topics that many thought would never become matters that would ever need to be argued again. Due to the magnitude of the issues to be decided, 13 organizations that work on telecommunications and digital divide policy requested that the agency extend the comment period, originally set for September 7th. Thirty days was just not enough time to address the numerous issues in the NOI.

speed-test.png The agency proposed reversing a policy established by the Obama administration’s FCC which raised the definition of “broadband” to 25 Megabits per second (Mbps) download and 3 Mbps upload. The 2015 change better reflected our forward direction in technology. Chairman Ajit Pai’s leadership has questioned that move and is considering reversing course to a 10 Mbps download/1 Mbps upload definition, which reflects speeds more in line with DSL connections. The 10/1 benchmark is already considered obsolete by policy experts who see DSL connections already overly stressed by multi-device households.

Many commenters express disdain with the idea of accepting slower speeds as “broadband,” especially those who live and work in rural areas. Mark...

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Posted August 22, 2017 by htrostle

Cell phones as a substitute for home Internet service? That’s what the Federal Communications Commission (FCC) suggested in an August 2017 document. Buried within the Notice of Inquiry for the Section 706 Report, the FCC quietly proposed that mobile service could be considered broadband deployment.

In a recent article, Jon Brodkin at Ars Technica dove into why that suggestion is laughable. Mobile Internet service, especially at speeds less than 25 Megabits per second (Mbps) download and 3 Mbps upload, is not equivalent to high-speed home Internet service. 

This proposal also raises concerns for rural communities exploring funding options.

Overstating Rural Connectivity Has Consequences

If the FCC treats mobile Internet access as broadband deployment, rural areas will suddenly look better connected. On paper, the FCC statistics will show that rural America has sufficient Internet access, but the reality in the trenches will remain as it is today - poor connectivity in many rural communities.

A similar situation has already happened in Iowa, where the inclusion of satellite Internet service is now considered broadband access. The interactive FCC 2016 Broadband Deployment Map clearly shows that almost all of Iowa has high-speed Internet access via satellite. One can use satellite service to browse the web, but it has significant limitations, especially when uploading data.

screenshot of Iowa

[Screenshot from August 2017 of FCC June 2016 Deployment Data of Iowa: Yellow = 25 Mbps/3 Mbps Internet access. Full map here.]

Despite the near-universal coverage shown by the FCC, rural communities in Iowa are still building fiber networks because they consider themselves lacking the connectivity they need to compete. In Iowa, it’s important to make sure that the agriculture community gets the high-speed...

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Posted July 12, 2017 by lgonzalez

During the Obama administration, the FCC under Chairman Tom Wheeler made bold steps to protect innovation and competition on the Internet by passing network neutrality rules. With new FCC Chairman Ajit Pai, network neutrality is in danger. In order to prevent the backward slide - or worse - we all need to comment to the FCC and tell them to preserve network neutrality protections.

Stepping Back In Time

Under Chairman Wheeler, regulations were put into place that prevented ISPs like Comcast, Verizon, and AT&T from slowing down specific websites or charging extra fees to certain sites, who then must pass along those fees to customers. Rather then turning the Internet into just another version of Cable TV, the FCC has preserved its neutrality - now those actions are at risk.

Chairman Pai announced soon after he was appointed that he wants to roll back the rules implemented during the Obama administration, which includes eliminating “Title II” of the Communications Act protections for broadband. Title II provides the legal basis that prevents blocking and throttling.

Let's Act

On May 18th, the FCC released a Notice of Proposed Rule Making (NPRM); comments are due July 17th. What does the mean? It means it’s time for you to contact the FCC here (Proceeding 17-108) and let them know that you want in network neutrality and that you believe existing rules should stay in place.

If you’ve never commented on an FCC proceeding, here’s an article from Gigi Sohn, former Counselor to Tom Wheeler, who can offer some tips on an effective comment. You can also read some of the other comments submitted by others.

Posted August 17, 2016 by KateSvitavsky

The U.S. Department of Housing and Urban Development (HUD) recently asked for comments about a proposed rule to expand low-income access to high-speed Internet. The regulations would require building owners to install high-speed Internet infrastructure in HUD-funded multi-family rental housing during new construction or substantial rehabilitation, improving Internet access by promoting competition. Because the Internet infrastructure is not owned by one company, many Internet Service Providers (ISPs) can compete to provide residents with better options.

A variety of individuals and groups provided feedback for HUD, including local governments, nonprofit advocacy groups, ISPs, and professional associations. The majority of comments support HUD’s proposed rule, with many encouraging HUD to go further in their efforts to close the digital divide.

We submitted comments with Next Century Cities to articulate the importance of having reliable Internet access in the home:

Although Internet access may be available at schools, libraries, and other locations away from home, families with children - in particular single-parent households - face barriers to accessing those facilities. There is no substitute for having high quality home Internet access, where all members of a household can use it with privacy, security, and convenience. This high quality Internet access is what our organizations work with mayors and local leaders to achieve for residents and businesses everyday, which is why we feel so strongly about the proposed steps to close the digital divide and allow more residents to connect online.  

HUD correctly notes that installing telecommunications equipment during major rehabilitations or as units are being built creates an opportunity to ensure high quality access without significantly adding cost to the project. The ongoing benefits from high quality Internet access certainly dwarf the one-time low cost of installing appropriate technology. --Next Century Cities and the Institute for Local Self-Reliance

Promote Competition

Google Fiber discusses the...

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Posted July 12, 2016 by KateSvitavsky

As part of a growing interest in expanding fast, affordable, reliable Internet access for low-income families at home, the United States Department of Housing and Urban Development (HUD) has proposed a new regulation requiring high-speed Internet infrastructure to be installed in HUD-funded multi-family rental housing during new construction or substantial rehabilitation. While the proposed rule doesn’t require developers to pay for Internet service subscriptions, it is a step in eliminating barriers that low-income families face in obtaining quality, consistent Internet access. Public comments are due July 18, 2016.

The proposed rule covers HUD’s rental assistance and grant programs, including its Section 8 housing assistance program, Supportive Housing for the Elderly and Disabled program, Community Development Block Grant program, and Choice Neighborhoods Implementation Grant program. Families living in multi-family housing can then choose to purchase full-priced Internet access from local providers or utilize other resources in their community, which include federal subsidy programs in addition to other state, local, and charitable programs.

Getting Wired Up

As for the actual infrastructure, several types of Internet access technologies satisfy the requirement. Developers can install either wireless (Wi-Fi, fixed and mobile wireless, satellite) or wired (digital subscriber lines also known as DSL, power lines or BPL, cable lines, or fiber) infrastructure. HUD expects most builders will elect to install wired access because of the rapidly changing nature of wireless technologies.

Additionally, wired access is more likely to provide meaningful competition between several Internet Service Providers (ISPs), lowering costs and improving service quality for multi-family housing residents. In an open access network, ISPs typically lease space on infrastructure owned by another entity rather than owning the physical infrastructure themselves. If HUD's new rule called for an open access model, multiple ISPs could utilize a building’s wired infrastructure to offer services to residents. According to HUD’s estimates, which are detailed in the proposed rule, the average construction costs for wired broadband access in its multi-family housing is approximately $200 per unit.

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