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Broadband Full Panel Hearing Comments of TechNet
We appreciate the Commission’s leadership on the critical issue of broadband. Your draft report breaks new ground and contains important recommendations to move us forward. Broadband is a fundamental building block of the New Economy. The initial generation of broadband – with speeds measured in hundreds of kilobits per second – has created a platform for new technologies, like VoIP, and new business models, like online auctions, that did not exist even a decade ago. The next generation of broadband – a hundred and even a thousand times faster - will enable virtually instantaneous communication, high-quality video, data, and voice transmission that fundamentally transforms the way we work and live. Today, a Canadian doctor can use this capability to perform surgery on a patient hundreds of miles away. In Korea, dozens of people can simultaneously play interactive video games over the Internet, fostering a vibrant new industry in which Korea will be a clear leader. Unfortunately, theses applications are not occurring here. In broadband deployment, the United States is a generation behind. The draft report suggests that many Californians have access to broadband. According to the numbers we have seen, just over 1 in 4 households in California has such access. But the report does not explain that our speeds languish at a few megabits or less, while other countries are rolling out 20, 40 or even 100 megabit connections. As demonstrated in the attached chart, the U.S., which once ranked third among all countries in broadband deployment, recently slipped to 13th, according to the International Telecommunications Union.
Countries like Japan and Korea understand how broadband can strengthen competitiveness, and they have aggressively deployed it. For example, until recently, Japan lagged behind the U.S. But in just a few years, Japan has increased the number of homes served by fiber by 500%. 17 million Japanese are now connected at incredibly low prices: 100 kilobits of connectivity costs the average U.S. consumer over $3.50 – but the Japanese consumer pays just $.09. In capability and the ability to deliver dramatic savings in cost and productivity our network does not adequately compete.
TechNet has called for nationwide deployment of 100 megabit broadband, although we recognize that as new applications and technologies are developed, even faster speeds – 1 gigabit or more – will be needed. States have a crucial role in reaching this goal. In 2003 TechNet published a State Broadband Index ranking state broadband policies across the nation. California ranked only 14th. California had strong policies to boost demand - for example, the Teleconnect Fund, CENIC, the "My California" website and several digital divide programs. But California lagged because of its lack of a coherent deployment strategy and significant regulatory burdens. To address the core issues under this Commission’s jurisdiction, we support the report’s draft recommendations in at least four areas: 1. Make broadband a state priority. TechNet strongly supports making deployment of high speed broadband a state priority. Michigan is a good example of what states can do. After a 2001 study showed Michigan lagging in broadband, Michigan established several goals including improving access to public rights of way, encouraging private sector investment in underserved areas, and helping communities develop their own solutions. A first step was to develop a statewide map of broadband availability. Michigan then adopted a comprehensive policy based on these goals. Today, these efforts have improved broadband access in 45 counties and 150 cities. Michigan now boasts one of the country’s largest wireless broadband networks - over 10,000 square miles of northeast Michigan - with speeds up to 45 megabits. California can learn from this. We need a good map of where broadband is – and is not – and at what speeds, while protecting proprietary information. We need an ambitious deployment goal. We need leadership. And we need to foster facilities-based competition without favoring one technology over another. 2. Reduce Regulatory Burdens. Improving access to rights of way and reducing regulatory burdens can help reduce deployment costs and encourage investment. Because rights of way decisions are mostly made at the local level, companies often face inconsistent treatment among communities. Delay by just one community can stall a large project. Michigan – and states like Missouri and Indiana – have adopted several strategies. Michigan has established a standardized right of way application and limits ROW fees municipalities can charge. Each of these states imposes a time limit on municipal review of between 30 and 45 days. As proposed by Recommendations 9.5 and 9.6, we also encourage the Commission to streamline the procedures under its own jurisdiction, including the provision of categorical CEQA exemptions for certain broadband projects and streamlining the granting of certificates of public convenience and necessity. 3. Exercise Regulatory Restraint with respect to new technologies. In fostering new technologies like VoIP, policies of regulatory restraint have brought consumers big cost savings in their phone bills. Net-based services like VoIP are inherently interstate, and TechNet believes that their fullest potential can be realized if allowed to develop in an atmosphere of regulatory restraint, without a patchwork of inconsistent state rules. TechNet therefore urges the Commission to publicly support the FCC’s determination that VoIP is an inherently interstate service and therefore subject to federal regulation. We also support the Commission’s stay of the consumer protection rules and urge Commission to undertake a careful analysis to avoid adversely affecting new technologies like VoIP. 4. Encourage access to underserved communities. Besides increasing speeds, ensuring ubiquity and broad access to broadband must be another critical policy objective. TechNet supports making broadband ubiquitous and available to underserved communities through the use of resources like CENIC and a reformed and strengthened Teleconnect Fund. We also recommend that the Commission give more attention to demand aggregation strategies, whereby businesses, local governments and state agencies pool their demand to encourage providers to improve broadband service. One example is Berkshire Connect, a consortium of 55 businesses in rural Massachusetts which, with modest state support, successfully obtained broadband for 15 towns from a new provider at discounts up to 70%. In summary, California is not close to realizing the full potential of broadband. With defined goals and a comprehensive strategy, we can do so. We appreciate your hard work and would welcome the opportunity to work with you. |
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