Before the 


National Telecommunications and Information Administration

Washington, D.C. 20230

In the Matter of    

Request for Comments on Deployment of

Broadband NetworksDocket No. 011109273-1273-01

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


Phone: 202-223-3511

Fax: 202-861-4368

[1] Request for Comments on Deployment of Broadband Networks and Advanced Telecommunications, Department of Commerce, National Telecommunications and Information Administration, Notice, Docket No. 011109273-1273-01 (Nov. 19, 2001) (“Notice”).Comments were due on December 19, 2001; PanAmSat respectfully requests that its comments be accepted although filed beyond this deadline.