Request for Comments on Deployment of
and Advanced TelecommunicationsRIN 0660-XX13
Comments
of PanAmSat Corporation
PanAmSat Corporation (“PanAmSat”) respectfully
submits these comments in response to the National Telecommunications and
Information Administration’s (“NTIA”) request for comment on broadband
deployment in the United States.[1]PanAmSat already has joined in the comments
that were filed by the Satellite Industry Association (“SIA”), but seeks to add
its own perspective on the issues presented by NTIA.
PanAmSat has long been a supporter of increased
competition in the communications marketplace and believes that government can
play a significant role in this effort, not by regulating, but by creating the
conditions for competitive entry and then encouraging such entry.Competition rather than regulation has
transformed the international telecommunications market.
PanAmSat owes its very existence to government
efforts promoting competition, when, during the Reagan Administration, the U.S.
government relied on competition to eliminate the Intelsat monopoly over the
provision of international satellite services.PanAmSat was the first international satellite
services competitor to Intelsat.Subsequent to PanAmSat’s entry into the market
many other global and regional operators followed, thus leading to an explosion
of satellite capacity and services around the globe.
The U.S. government’s leadership in removing the
legal barriers to competition and encouraging new entry have resulted in the
deployment of several hundred new geostationary satellites that provide many
times the capacity of the original monopoly network for a fraction of the
cost.Further, there is virtually no
populated area of the world that does not have access to satellite
infrastructure and services.This
experience is relevant to the issues presented by deployment of broadband
networks and advanced telecommunications services.
Nationwide
Deployment
Although nearly 80 percent of Americans now have
access to broadband services, the full benefits of broadband have not been
realized.PanAmSat believes, therefore,
that there is a role for government in promoting increased deployment of
broadband infrastructures.In promoting
broadband deployment, however, government policy-makers must keep in mind that
broadband infrastructures are comprised of a variety technologies and offered by
a variety of facilities-based service providers.
Accordingly, the principal governmental
involvement should be to promote both intra-modal and inter-modal competition
and to assure that this is done in a technologically neutral manner that does
not favor deployment of any single technology.
With respect to satellite technology, multiple
providers currently use Ku-band satellites to offer coverage to virtually all of
the U.S. for both one-way and two-way broadband services.Yet, technology-neutral tax credits and
modification of the satellite spectrum licensing rules to allow unused
terrestrial spectrum to be used by satellite operators with minimal restrictions
could spur increased deployment.This
would allow for more efficient use of spectrum and for reduced cost in broadband
deployment.
Spur
Demand
Broadband deployment and penetration would
provide a significant benefit to the U.S. economy by stimulating demand for
infrastructure and services and by improving overall efficiency.Nonetheless, PanAmSat is wary of government
programs that favor one technology or provider over others by tilting the
regulatory playing field or subsidizing certain providers of broadband
services.
There are, however, ways that government can
help in stimulating demand for broadband that would avoid these pitfalls.As SIA pointed out in its comments, low
interest loans and loan guarantees targeted at the broadband consumer would be
an effective way to spur broadband adoption and reduce the long-term cost of
user equipment.Accelerated investment tax
credits for broadband systems that serve rural and underserved communities is
another alternative for encouraging investment.
Government also can spur demand by employing
broadband services in its own operations and programs by improving its
Internet-based service delivery programs to use broadband networks more
effectively.This could be for both
government procurement programs and well as government service delivery
programs.Government also could encourage
telecommuting for the federal work force by subsidizing broadband connections to
the home.Government buildings, housing,
military installations as well as government-sponsored schools, libraries,
hospitals etc. should be equipped with broadband connections to permit advanced
telecommunications services.In short, the
federal government can lead by example and do much to spur demand for broadband
infrastructure and services, which, at the same time, will stimulate and benefit
the U.S. economy.
Respectfully submitted,
/s/ Kalpak Gude
Kalpak
S. Gude
Vice
President of Government and Regulatory Affairs and Associate General
Counsel
PanAmSat
Corporation
email:
kgude@panamsat.com
Phone:
202-223-3511
Fax:
202-861-4368