Tag: "public comment"

Posted October 6, 2014 by Lisa Gonzalez

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 Tom Anderson

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 Toews

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 Tom Anderson

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 Lisa Gonzalez

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.

Posted November 4, 2009 by Christopher Mitchell

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...
Read more

Pages

Subscribe to public comment