Tag: "public comment"

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... Read more

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... Read more

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... Read more

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.

... Read more

Posted October 6, 2014 by lgonzalez

The Coalition for Local Internet Choice (CLIC) has announced that Christopher Libertelli of Netflix has joined the Board of Advisors. Libertelli joins a group of policy leaders, including ILSR's Chris Mitchell, to advance the rights of local communities to have authority over their own broadband decisions.

From the CLIC announcement:

Mr. Libertelli has been Vice President of Global Public Policy at Netflix since December 2011. During his time at Netflix, he has been a champion for a variety of internet policy issues including efforts to increase competition among internet providers. Prior to joining Netflix, Mr. Libertelli managed Skype’s government relations programs in the U.S., Canada, and Latin America.

Netflix has been a strong and consistent supporter of local internet choice. 

Netflix has been very helpful in advocating for the right of communities to build their own networks if they so choose. They filed comments [pdf] in the Wilson and Chattanooga petitions and have been listing some of the larger municipal networks in their monthly speed rankings. We are very grateful for their assistance in these important matters.

Posted August 26, 2014 by tanderson

The Institute for Local Self Reliance has joined with Public Knowledge, Common Cause, and the Open Technology Institute, in submitting reply comments to the FCC last week as the Public Interest Spectrum Coalition (PISC). The issue at hand is the FCC’s proposal of new rules for how to govern the 3.5 GHz band, a range of the electromagnetic spectrum useful for many different types of communication. 

The PISC comment focused on the importance of getting away from the long-standing FCC policy of simply auctioning off big slices of spectrum for telecom companies to use exclusively, which inhibits innovation and enables a monopolization of the communications marketplace. Verizon and AT&T, who hold licenses to large swathes of the spectrum already, are lobbying to FCC to keep the status quo in place. PISC (and ILSR) support a more open arrangement, allowing multiple users to share the same underutilized spectrum segment, while still avoiding interference. The full text of the comment is available here. 

The language and policy of spectrum management can seem arcane to people unaccustomed to it, but how we regulate and use the electromagnetic spectrum has wide ranging consequences for almost all the technology we use in our daily lives. For a general primer on the importance and possibilities of a more open spectrum licensing policy, see the wireless commons articles we published earlier this summer.

You can view the full text of the PISC comment through the link below.

Posted August 24, 2014 by rebecca

The Electronic Comment Filing System (ECFS) on the FCC website has been working overtime in the last few months, so we decided this would be a good time to “Roundup” the various petitions that are open for comment regarding Internet rules, give a brief rundown of the timeline, and let you know how you can make your voice heard. There are a couple of key deadlines this week, so make sure to get your comments in! Below is a quick summary of some of the petitions and filings you should be aware of, their deadlines, and next steps.

Net Neutrality (14-28)

After extending the deadline for Initial Comments on Net Neutrality, the FCC received more than a million comments asking them to preserve the open Internet. ILSR submitted its petition July 18, focusing on the issue of paid prioritization, reclassification, and regulation of content. The FCC also extended the deadline for reply comments to September 15.

The commission is expected to establish net neutrality rules by the end of 2014.

Local Authority on Municipal Networks

Wilson, North Carolina (14-115) and Chattanooga, TN (14-116) filed petitions with the FCC July 24th asking them to remove restrictions on their ability to expand and offer services to nearby communities. On July 28th, the FCC opened a public comment calendar for the request.

ILSR stands firm in its support of these communities, and others that have built their own networks. We are not alone. The US Conference of Mayors, several communities, the American Public Power Association, a... Read more

Posted August 13, 2014 by tanderson

Section 702 of the 1996 Telecommunications Act requires the FCC to report annually on whether "advanced telecommunications capability is being deployed to all Americans in a reasonable and timely fashion." The FCC kicked off its tenth such report on Tuesday by releasing a "Notice of Inquiry," (NOI) in effect asking individuals and groups around the country to offer relevant data and comments. 

This process amounts to a kind of crowdsourced "State of the Union" on broadband issues. In addition to determining how many people in what areas have broadband access, this NOI also asks the critical question of how exactly the FCC should define broadband. The current definition of 4mbps download capacity and 1mbps upload may have been sufficient in the past, but isn't adequate for even recreational household use by many Americans today, let alone the demands of running a business and conducting commerce online.

This NOI also asks some arcane but important questions about other aspects of broadband definitions, including latency (the speed of data moving within a network, a different measure than bandwidth) and the widespread use of data caps and other policies in the telecom industry. 

Obviously the answers to all these questions have significant implications for municipal networks. Inadequate or overly-loose definitions of broadband allow incumbents to claim that they are providing excellent service to just about everyone in a given area, when that is often far from the truth. Many restrictive state laws limiting municipal networks, as well as federal grant programs that may support such networks, are based on whether an area is defined as already served or underserved, which may be dependent on FCC benchmarks. As is often the case in regulatory issues, the devil is in the details.  

FCC Chairman Tom Wheeler introduced the NOI with the following statement:

Congress has instructed us that all Americans should have access to robust broadband services, no matter where they live. Because consumers demand increasing levels of bandwidth capacity to support the applications they want to use online, we are asking if it is time to update the benchmark broadband speed. And as more people adopt faster broadband speeds, we are asking if all consumers, even in the most rural... Read more

Posted August 1, 2014 by lgonzalez

The Institute for Local Self-Reliance recently submitted comments to the FCC as part of its Protecting and Promoting the Open Internet proceeding. ILSR focused on the issue of paid prioritization, reclassification, and regulation of content. We also provided some examples of municipal networks that provide fast, reliable, affordable service and do not rely on paid prioritization to serve customers.

From the ILSR comments:

The FCC should be extremely wary of any arguments that claim paid prioritization or other discriminatory practices are necessary to increase investment in next-generation networks. These networks are already being built and paying for themselves in both public and private approaches (as well as partnerships mixing the two). ILSR sees no reason to believe any additional revenues gained by discriminatory pricing would be reinvested in improving DSL and cable networks as the largest firms operating these networks generally face little competitive pressure to upgrade. That is the problem, not a lack of revenue in the current model.

Our reading of the various court decisions suggest the only option for the FCC to preserve the open Internet and prevent big cable and telephone companies from tinkering with the established principle of non-discriminatory carriage is reclassification and urge the FCC to take this step. However, we also urge the FCC to take actions to prevent any regulation of content. The FCC should concern itself with the transmission of information, regardless of what that information is, consistent with long-held Internet principles.

The Open Internet proceeding has inspired an estimated 1 million+ comments. The outpouring strained the FCC's system and as a result, the FCC extended the comment period to July 18th.

The full document is available below for download and available on the FCC's electronic filing system.

Pages

Subscribe to public comment