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