December 18, 2001


Josephine Scarlett,

Office of the Chief Counsel,

 National Telecommunications and Information Administration,

Room 4713 HCHB,

1401 Constitution Ave., NW

Washington, DC 20230


Re: National Telecommunications and Information Administration

RIN 0660-XX13  Notice, Request for Comments on Deployment of Broadband Networks and Advanced Telecommunications [Docket No. 011109273-1273-01]


ITAA Comments


ITAA welcomes the opportunity to submit this letter and attached “Positively Broadband” white paper in response to NTIA’s Request for Comments on Deployment of Broadband Networks and Advanced Telecommunications [Docket No. 011109273-1273-01]


The Information Technology Association of America (ITAA) provides global public policy, business networking, and national leadership to promote the continued rapid growth of the IT industry. ITAA consists of over 500 corporate members throughout the U.S., and a global network of 41 countries' IT associations. The Association plays the leading role in issues of IT industry concern including information security, taxes and finance policy, digital intellectual property protection, telecommunications competition, workforce and education, immigration, online privacy and consumer protection, government IT procurement, human resources and e-commerce policy. ITAA members range from the smallest IT start-ups to industry leaders in the Internet, software, IT services, ASP, digital content, systems integration, telecommunications, and enterprise solution fields.  For more information visit <>.


ITAA commends the attention that NTIA is directing toward broadband. ITAA views broadband technology as the next important high tech “change agent” for U.S. economic growth and expansion.  The U.S. embrace of the Internet for business-to- business and business-to-consumer commerce has been a model for the world to follow.  Moreover, the Internet has played a major role in helping companies gain highly cost effective control over enterprise-wide legacy data and applications.  This phenomenon has driven productivity, job growth, new business development, lower prices, greater convenience, supplier competition, choice and many other market and consumer benefits.  In short, the Internet has been an incredible boon to the overall strength of the U.S. economy.


Many small and mid-sized companies as well as consumers, however, connect to the Internet with slow-speed, dial-up connections.  This type of connection operates at speeds too low to take practical advantage of many online options.  Even so, consumers seem willing to make do.  A September 2001 ITAA survey of 1000 American voters found roughly half of American households with Internet access and a high-speed alternative stick to their dial-up modems.


We recognize that most of the questions raised in the notice are directed at “deployment or “supply” related policy issues.  Broadband service is available to over 70 percent of U.S. households, but the take up rate among consumers stands at about 11 percent.[1]  While telecommunications supply-side issues have dominated the debate for lawmakers and other interested parties, as a society we are in danger of missing the bigger picture.  If we want to take the Internet and, ultimately, the U.S. economy to the next level, we are going to have to give consumers better reasons for purchasing broadband service--better than faster email and web surfing.  Our comments are directed at these “demand” issues.


ITAA believes much of the problem is really about content.  Broadband Internet access is available to a majority of American households, yet consumers are hesitant to use it.  Part of the problem is cost.  Many people think broadband is just too expensive.  Part of the problem is service.  Stories of woe about customers attempting to add Digital Subscriber Line and other broadband services abound.  Broadband content and applications are simply not rich and varied enough today to attract a mass market of consumers.  To shift the public discourse about broadband from supply-side infrastructure build out to the steps necessary for demand-side broadband market development, ITAA has launched the Positively Broadband campaign. 


If broadband services are widely available but not yet popular, one must ask why this is so.  Broadband speeds make transmission of multiple communications signals available over a single circuit or frequency.  The additional bandwidth means networks can deliver a wide array of digital services over the same lines, make data intensive applications not just possible but practical, provide this service on an “always on” basis, and all this while allowing multiple family members or business colleagues to operate from the same network connection at the same time.


With broadband, the opportunity is now to move America’s online community and the overall economy to the next level of economic growth.    This will not be today’s typical uses of broadband—most of which consist of zippier web surfing and faster e-mail.  The power of broadband will be achieved by the rich content and sector-by-sector innovations that only high-speed networks make possible.  A better balance of value and cost will no doubt move more consumers to purchase broadband service.


ITAA also recognizes that even with the demand issue solved, consumers may still hang back if they do not feel as safe and secure in cyberspace as they do in their every day lives.  A positive, competitive broadband agenda must help build the privacy and security comfort zone around this new medium.  Consumers often confuse online “privacy” with security issues.  The differences between the two must be clarified and the risks of cyber crime put into appropriate perspective. 


Following the September 11 attacks on America, the public also needs to understand that the Internet is a critical national infrastructure and must be hardened as part of overall homeland cyber defense.  The enclosed white paper suggests practical steps for protecting both online privacy and security.      


A positive competitive broadband agenda must be built on a strong public policy foundation.  A principled approach must guide the construction process.  The building blocks of this agenda are:



Agenda building will also require the active engagement of stakeholders:  government, industry and consumers.  Roles for each must be well defined, balanced and appropriate. 


Federal, state and local governments can serve as early adopters in the delivery of highly innovate services to the citizen.  Lawmakers should consider demand-focused tax incentives in areas like e-work, e-health and e-education.  Targeted tax credits and federal loan guarantees, along with pilot programs, could help build consumer demand within rural areas.  Governments should continue support of public education and life long learning through the adaptation of broadband technology.   Beyond direct financial support of specific initiatives, governments should also consider support for mechanisms that communicate the benefits of e-education.  Government must help safeguard the nation’s high tech supremacy through future investment.  Making the R&D tax credit permanent would be an important step in this direction.  Governments should also eliminate defunct regulatory regimes and special interest policy barriers to broadband adoption.  These barriers exist in interstate commerce and reciprocity, copyrights, international treaties and radio frequency spectrum.


Governments must also play an active role in building the online comfort zone.  Active enforcement of existing laws is an absolute must.  Congress and state legislatures must consider whether cyber crime fighting organizations within government are adequately staffed and equipped to pursue criminal investigations effectively.  Criminality is not the only hazard in cyberspace.  Government must also help provide a level of consumer protection from questionable marketing practices and other excesses.  Broadband must meet the requirements for accessibility by the physically disabled as do other technologies.


Roles for industry in a positive, competitive broadband agenda include the responsibility to use broadband to create innovative solutions and to evolve these solutions as needs and interests change.  Companies must respond to competitive pressures for standards-based, interoperable approaches to broadband connectivity.  The standards are not just for infrastructure and device interoperability but must also advance the delivery of customer benefits in specific application domains.


Efficiency and productivity define the online experience and drive consumer satisfaction.  Companies must integrate gigabit speeds into ever more efficient business operations.  This will require the investment of considerable intellectual and monetary capital to achieve.  Companies must act to protect these investments by protecting the value of their intellectual property. 


Consumers must participate in the development of a positive, competitive broadband agenda by articulating needs and pushing industry to fulfill those needs.  Participation means a willingness to explore the benefits of broadband in multiple walks of life.


Shifting the public discourse from a supply- to a demand-side agenda represents many challenges but offers consumers many rewards.  The Positively Broadband campaign is intended to help stakeholders move beyond the current deployment impasse and accelerate market acceptance of this technology.  To this end, the campaign has made the following call to action:


Think about broadband service in new ways.  Consider its potential to transform how people live, work and play.  Look at how broadband technology can be leveraged to support conventional business processes and practices.  Work within companies, industry groups and other organizations to build a better value proposition for the American consumer.


Thank you for your careful consideration of these important issues.  If you have any questions about the matters raised above, please feel free to contact me (703/284-5340;, or Mark Uncapher (703-284-5344; of my staff.  ITAA stands ready to work with NTIA in building a positive, competitive broadband agenda.







Harris N. Miller




[1] Morgan Stanley Dean Witter, July 2001