Via Electronic Mail to: broadband@ntia.doc.gov

Josephine Scarlett, Office of the Chief Counsel

National Telecommunications and Information Administration

Room 4713 HCHB

1401 Constitution Ave., NW

Washington, DC20230

Re:Request for Comments on Deployment of Broadband Networks and Advanced Telecommunications by December 19, 2001

Dear Ms. Scarlett:

Metromedia Fiber Network Services, Inc. (“MFN”) submits the following comments to the National Telecommunications and Information Administration (“NTIA”) pursuant to the above-referenced request.These comments were originally submitted to the Federal Communications Commission (“FCC”) on September 24, 2001 in response to the FCC’s own inquiry regarding the status of broadband deployment, conducted pursuant to Section 706 of the Telecommunications Act of 1996.

MFN’s comments address the NTIA’s question in this inquiry: “Are there local issues affecting broadband deployment that should be addressed by federal policies.”MFN’s answer is unequivocally “Yes.”There are significant local issues affecting broadband deployment that can and should be addressed by federal policies.

As outlined in MFN’s comments, difficulties obtaining access to public rights of way are a significant barrier to the deployment of broadband infrastructure.The rules regarding access to public rights of way can and should be clearly set forth in both federal law and policy.

Please accept MFN’s comments filed with the FCC as part of the NTIA’s record in this proceeding and please do not hesitate to contact me if you have any questions or concerns regarding the foregoing.

Very truly yours,

/s/ Traci Bone

Traci Bone

Senior Attorney

Metromedia Fiber Network, Inc.

Attachment:MFN 706 Comments

Cc:Robin Hauer, V.P. Legal and Regulatory Affairs

Jill Sandford, Senior Attorney