December 12, 2001

Ms. Josephine Scarlett

Office of the Chief Counsel

National Telecommunications and Information Administration

Room 4713 HCHB

1401 Constitution Avenue, NW

Washington, DC20230

Dear Ms. Scarlett;

The DSL Forum thanks the NTIA for the opportunity to provide comments on its recent Notice; “Request for Comments on Deployment of Broadband Networks and Advanced Telecommunications.”

DSL Forum is a consortium of more than 330 leading industry telecommunications, equipment, computing, networking and service provider companies, including incumbent and competitive carriers. Established in 1994, the Forum continues its drive for a mass market for DSL, to deliver the benefits of this technology to end users around the world over existing copper telephone wire infrastructures. Details about forthcoming events, DSL Forum and DSL are available at www.dslforum.org with information for end users at www.dsllife.com.

Throughout its seven years, the DSL Forum has worked on defining the core technology as it develops, providing inputs to international standards bodies and on establishing processes to deliver maximum effectiveness in the deployment and use of DSL. The Forum is focused on the complete portfolio of digital subscriber line technologies designed to deliver ubiquitous broadband services for a wide range of situations and applications that will continue the transformation of our day-to-day lives in an on-line world.

DSL is vital to providing broadband services to many areas. Approximately 3.8 million DSL customers in the United States were served by DSL in the third quarter of 2001.Independent data, including that from TeleChoice and Point Topic, indicate that by end of year 2001 at least 15 million DSL lines will be in use around the world.There are now more DSL broadband lines in use around the world than cable modem lines.In Europe alone, according to ECTA published data, several months ago there were twice as many customers connected by DSL broadband than by cable.Current deployment rates are likely to widen that gap.However in the United States, there are more cable modem subscribers than DSL customers currently.

DSL is one of the most attractive means for broadband access to areas currently lacking broadband access. 

The DSL Forum whitepaper entitled “DSL Anywhere”  (pdf format) identifies technical methods to enable broadband access to over 99% of customers.However, in some areas it will cost much more to provide the access facilities. The DSL Forum urges government entities and policy makers to encourage efforts to bring broadband services to more homes, as stated in the recent report of the National Academies' National Research Council.It is imperative to act quickly to build on the momentum in the DSL industry before the industry reassigns its resources elsewhere.Public policy activities should furthermore address DSL availability for areas without broadband access.

Broadband services, starting at about 200 kb/s, include high-speed Internet access, teleworker access, gaming, video/audio content, and high bit-rate services that will be developed in the future.Advanced services and e-commerce based on broadband access can be an important contributor to economic growth.Availability of a wider selection of broadband-based services and content via all methods of high-speed access can stimulate the broadband service take-rate.Since active competition exists between the various forms of broadband access, government regulations should treat all forms of access similarly.Countries, such as Korea, with government policies that exhibit minimal uncertainty and encourage and enable broadband deployment demonstrate the positive effects of a timely, stable, and well-defined regulatory environment.Please see the attached report from the United Kingdom Broadband Stakeholder Group.Addendum 2 from GIIF demonstrates the cross-elasticity between service price and take-rate.

The DSL Forum web sites (www.dslforum.org and www.dsllife.com) provide publicly available reference information that assists the understanding of DSL technology and its application.The DSL Forum invites the NTIA to refer to the following information at the web sites:

§DSL Tutorials

§DSL Glossary

§“DSL Anywhere” Whitepaper

§“Internet Security” Whitepaper

§DSL Forum Technical Reports 

§Current global statistics on the number of lines served by country 

The DSL Forum is working to enable broadband access to more customers.Please let the DSL Forum know how it could further help policy makers in this effort.

Sincerely,

William V. Rodey 

Chairperson, DSL Forum

Addendums: 

• Current list of DSL Forum Technical Reports
• GIIF graph 

Attachments:

• United Kingdom Broadband Stakeholder Group report
• DSL Forum “DSL Anywhere” Whitepaper. (.pdf)

Addendum: 1