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 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 www.itaa.org
<http://www.itaa.org>.
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; hmiller@itaa.org), or Mark Uncapher (703-284-5344;
muncapher@itaa.org) of my staff. ITAA
stands ready to work with NTIA in building a positive, competitive broadband
agenda.
Sincerely,
Harris N. Miller
President
Attachment
http://www.positivelybroadband.org/