Josephine
Scarlett,
Office
of the Chief Counsel,
National Telecommunications and
Information Administration,
Room
4713 HCHB,
1401
Constitution Ave., NW
Washington,
DC 20230
Re:
National Telecommunications and Information Administration
RIN
0660-XX13 Notice, Request for
Comments on Deployment of Broadband Networks and Advanced Telecommunications
[Docket No. 011109273-1273-01]
ITAA
welcomes the opportunity to submit this letter and attached “Positively
Broadband” white paper in response to NTIA’s Request for Comments on Deployment
of Broadband Networks and Advanced Telecommunications [Docket No.
011109273-1273-01]
The
Information Technology Association of America (ITAA) provides global public
policy, business networking, and national leadership to promote the continued
rapid growth of the IT industry. ITAA consists of over 500 corporate members
throughout the U.S., and a global network of 41 countries' IT associations. The
Association plays the leading role in issues of IT industry concern including
information security, taxes and finance policy, digital intellectual property
protection, telecommunications competition, workforce and education,
immigration, online privacy and consumer protection, government IT procurement,
human resources and e-commerce policy. ITAA members range from the smallest IT
start-ups to industry leaders in the Internet, software, IT services, ASP,
digital content, systems integration, telecommunications, and enterprise
solution fields. For more
information visit www.itaa.org
<http://www.itaa.org>.
ITAA commends the attention that NTIA is directing toward broadband. ITAA views broadband technology as the next important high tech “change agent” for U.S. economic growth and expansion. The U.S. embrace of the Internet for business-to- business and business-to-consumer commerce has been a model for the world to follow. Moreover, the Internet has played a major role in helping companies gain highly cost effective control over enterprise-wide legacy data and applications. This phenomenon has driven productivity, job growth, new business development, lower prices, greater convenience, supplier competition, choice and many other market and consumer benefits. In short, the Internet has been an incredible boon to the overall strength of the U.S. economy.
Many
small and mid-sized companies as well as consumers, however, connect to the
Internet with slow-speed, dial-up connections. This type of connection operates at
speeds too low to take practical advantage of many online options. Even so, consumers seem willing to make
do. A September 2001 ITAA survey of
1000 American voters found roughly half of American households with Internet
access and a high-speed alternative stick to their dial-up
modems.
We
recognize that most of the questions raised in the notice are directed at
“deployment or “supply” related policy issues. Broadband service is available to over
70 percent of U.S. households, but the take up rate among consumers stands at
about 11 percent.[1] While telecommunications supply-side
issues have dominated the debate for lawmakers and other interested parties, as
a society we are in danger of missing the bigger picture. If we want to take the Internet and,
ultimately, the U.S. economy to the next level, we are going to have to give
consumers better reasons for purchasing broadband service--better than faster
email and web surfing. Our comments
are directed at these “demand” issues.
ITAA
believes much of the problem is really about content. Broadband Internet access is available
to a majority of American households, yet consumers are hesitant to use it. Part of the problem is cost. Many people think broadband is just too
expensive. Part of the problem is
service. Stories of woe about
customers attempting to add Digital Subscriber Line and other broadband services
abound. Broadband content and
applications are simply not rich and varied enough today to attract a mass
market of consumers. To shift the
public discourse about broadband from supply-side infrastructure build out to
the steps necessary for demand-side broadband market development, ITAA has
launched the Positively Broadband campaign.
If
broadband services are widely available but not yet popular, one must ask why
this is so. Broadband speeds make
transmission of multiple communications signals available over a single circuit
or frequency. The additional
bandwidth means networks can deliver a wide array of digital services over the
same lines, make data intensive applications not just possible but practical,
provide this service on an “always on” basis, and all this while allowing
multiple family members or business colleagues to operate from the same network
connection at the same time.
With
broadband, the opportunity is now to move America’s online community and the
overall economy to the next level of economic growth. This will not be today’s
typical uses of broadband—most of which consist of zippier web surfing and
faster e-mail. The power of
broadband will be achieved by the rich content and sector-by-sector innovations
that only high-speed networks make possible. A better balance of value and cost will
no doubt move more consumers to purchase broadband
service.
ITAA
also recognizes that even with the demand issue solved, consumers may still hang
back if they do not feel as safe and secure in cyberspace as they do in their
every day lives. A positive,
competitive broadband agenda must help build the privacy and security comfort
zone around this new medium.
Consumers often confuse online “privacy” with security issues. The differences between the two must be
clarified and the risks of cyber crime put into appropriate perspective.
Following the September 11 attacks on America, the public also needs to understand that the Internet is a critical national infrastructure and must be hardened as part of overall homeland cyber defense. The enclosed white paper suggests practical steps for protecting both online privacy and security.
A
positive competitive broadband agenda must be built on a strong public policy
foundation. A principled approach
must guide the construction process.
The building blocks of this agenda are:
Agenda
building will also require the active engagement of stakeholders: government, industry and consumers. Roles for each must be well defined,
balanced and appropriate.
Federal,
state and local governments can serve as early adopters in the delivery of
highly innovate services to the citizen.
Lawmakers should consider demand-focused tax incentives in areas like
e-work, e-health and e-education.
Targeted tax credits and federal loan guarantees, along with pilot
programs, could help build consumer demand within rural areas. Governments should continue support of
public education and life long learning through the adaptation of broadband
technology. Beyond direct
financial support of specific initiatives, governments should also consider
support for mechanisms that communicate the benefits of e-education. Government must help safeguard the
nation’s high tech supremacy through future investment. Making the R&D tax credit permanent
would be an important step in this direction. Governments should also eliminate
defunct regulatory regimes and special interest policy barriers to broadband
adoption. These barriers exist in
interstate commerce and reciprocity, copyrights, international treaties and
radio frequency spectrum.
Governments
must also play an active role in building the online comfort zone. Active enforcement of existing laws is
an absolute must. Congress and
state legislatures must consider whether cyber crime fighting organizations
within government are adequately staffed and equipped to pursue criminal
investigations effectively.
Criminality is not the only hazard in cyberspace. Government must also help provide a
level of consumer protection from questionable marketing practices and other
excesses. Broadband must meet the
requirements for accessibility by the physically disabled as do other
technologies.
Roles
for industry in a positive, competitive broadband agenda include the
responsibility to use broadband to create innovative solutions and to evolve
these solutions as needs and interests change. Companies must respond to competitive
pressures for standards-based, interoperable approaches to broadband
connectivity. The standards are not
just for infrastructure and device interoperability but must also advance the
delivery of customer benefits in specific application
domains.
Efficiency
and productivity define the online experience and drive consumer
satisfaction. Companies must
integrate gigabit speeds into ever more efficient business operations. This will require the investment of
considerable intellectual and monetary capital to achieve. Companies must act to protect these
investments by protecting the value of their intellectual property.
Consumers
must participate in the development of a positive, competitive broadband agenda
by articulating needs and pushing industry to fulfill those needs. Participation means a willingness to
explore the benefits of broadband in multiple walks of
life.
Shifting
the public discourse from a supply- to a demand-side agenda represents many
challenges but offers consumers many rewards. The Positively Broadband campaign is
intended to help stakeholders move beyond the current deployment impasse and
accelerate market acceptance of this technology. To this end, the campaign has made the
following call to action:
Think
about broadband service in new ways.
Consider its potential to transform how people live, work and play. Look at how broadband technology can be
leveraged to support conventional business processes and practices. Work within companies, industry groups
and other organizations to build a better value proposition for the American
consumer.
Thank
you for your careful consideration of these important issues. If you have any questions about the
matters raised above, please feel free to contact me (703/284-5340;
hmiller@itaa.org), or Mark Uncapher (703-284-5344; muncapher@itaa.org) of my
staff. ITAA
stands ready to work with NTIA in building a positive, competitive broadband
agenda.
Sincerely,
Harris
N. Miller
President
Attachment
http://www.positivelybroadband.org/