Sending a Comment to the FCC on the
National Broadband Plan 2

Figuring out how to navigate the Federal Communications Commission website or U.S. Rulemaking portal to submit comments for the FCC National Broadband Plan was frustrating, but I finally found an “express comment” page. Here it is.

There are options on other parts of the FCC website for attaching Word or PDF files, but the FCC system kept communicating to me that it didn’t recognize the document number I submitted (even though the FCC notice states this number must be used to submit a comment).

I sent this comment, in response to FCC numbered questions:

GN Docket No. 09-51
Response to Federal Communications Commission Notice of Inquiry, FCC 09-31, released April 8, 2009
Comments on items below:

43. … how can the Commission ensure that any measures to encourage wireless broadband service coincide with and complement other broadband platforms (and vice versa)?

In our neighborhood, we have two wireline providers of broadband service. Residents don’t need less efficient wireless broadband service. Federal law should not require municipalities to allow installations of wireless infrastructure where it is not needed for more phone line capacity and where wireline services provide faster broadband speeds.

Municipalities should be allowed to reasonably discriminate in favor of providers with less intrusive and more efficient technology.

48. … address the value of open networks, and specifically, the impact on investment, innovation and entrepreneurship, content, competition and affordability of broadband, among other things. … We ask … whether such a principle is necessary in light of the current state of competition and the four existing Internet policy principles….Should the underlying facilities over which service is provided have any impact on how open network policy should be applied to broadband providers?

Open networks are crucial to the free exchange and availability of information that is the promise of the internet. The Commission should adopt a fifth principle and find a way to codify the first four principles in law, and they should apply to all facilities over which service is provided.

50. Are there other policies or programs that the Commission should review as a part of its
analysis of effective and efficient mechanisms to achieve the goals of the Recovery Act? … to what extent do tower siting, pole attachments, backhaul costs, cable franchising and rights of way issues, as well as others, stand as impediments to further broadband deployments where such deployments would be made by market participants in the absence of any government-funded programs? We also note that the development of equipment and protocol standards is a key element in broadband deployment and seek comment on the appropriate role of the Commission in facilitating the development of such standards.

Section 704 of the Telecommunications Act of 1996, and California Public Utilities Code Section 7901 (with right-of-way privileges accorded to telecom providers) effectively prevent municipalities from denying permits for wireless broadband infrastructure, even if more efficient fiber optic, dsl, or cable service is already available. Our urban, developed neighborhood does not need more telecom infrastructure. These laws should be repealed, so wireless providers will focus their efforts in markets where broadband service is needed.

The commission should be crafting policies to encourage deployment of the fastest and highest-capacity technology, wireline fiber-optic cable, throughout the United States.

The FCC is asking for consumers’ input on the future of U.S. Broadband Policy; all comments must be submitted by June 8, 2009.