IIA Gives Regards to Wheeler and O’Rielly in Light of Senate Confirmations
Encourages new FCC Chairman and Commissioner to get down to business on spectrum auctions, IP Trials and ConnectED
WASHINGTON, D.C. – October 30, 2013 – The Internet Innovation Alliance (IIA) today issued the following statement in response to Senate approval of Tom Wheeler and Michael O’Rielly for Chairman of the Federal Communications Commission (FCC) and FCC Commissioner, respectively, by unanimous consent:
“IIA sends its best wishes to Tom Wheeler, an astute, technology-industry veteran who is well-equipped to take the reins of the FCC at this important juncture in time. We also warmly welcome Michael O’Rielly to his post as FCC Commissioner and look forward to his valuable contributions on highly important policy issues standing before the federal agency. There are both great opportunities and challenges before the FCC and, given the exponential growth in wireless broadband use and the larger technology transition to IP-enabled services that is underway across the country, their vision and influence will be instrumental in redefining and shaping America’s communications sector for decades to come.
“We urge Wheeler and O’Rielly to quickly roll up their sleeves on the IP transition, spectrum policy and ConnectED. To jumpstart network modernization, the Commission should give the green light on IP trials that will pave the way for a smooth transition to next-generation networks. With wireless users multiplying and available spectrum at a standstill, it’s critical that more spectrum be made available for commercial mobile services in short order, before demand hurdles supply. The FCC should take swift action to conduct open incentive auctions, approve secondary market transactions, and repurpose federal spectrum.
“And for the benefit of communities across the nation, Wheeler and O’Rielly should crystalize a vision for ConnectEd, an initiative that should help ensure access to high-speed broadband for our nation’s students both at school and at home. Technology is the fuel of the modern economic engine.”
REPORT: Broadband Delivers Over $9,300 in Annual Savings to American Consumers
Move to next-generation networks and additional spectrum for mobile services will help more American families achieve Internet-enabled cost savings
WASHINGTON, D.C. – October 29, 2013 – High-speed Internet – and, increasingly, mobile broadband – allow Americans to save an average of $9,363.85 a year on household spending, the Internet Innovation Alliance (IIA) today announced. Potential Internet-enabled savings increased nearly $500 from last year, along with a rise of 3.5 percent in average annual expenditures in 2012 reported by the U.S. Bureau of Labor Statistics. Authored by Nicholas J. Delgado, certified financial planner and principal of Chicago-based wealth management firm Dignitas, “Mobile Broadband and Money: Top 10 Ways to Save” is the fourth edition of the annual financial analysis. This year, the IIA-identified cost savings – achieved by having access to and using broadband – were calculated with the mobile consumer in mind.
U.S. Must Modernize Regulatory Framework to Spur High-Speed Broadband Deployment
95% of U.S. households no longer rely solely on the traditional home telephone to stay connected, leaving the current regulatory framework lagging behind marketplace realities and diverting investment away from 21st century broadband infrastructure
Outdated regulations that force companies to build and maintain obsolete copper-based legacy telephone networks are unnecessarily diverting investment away from modern broadband networks and services that 95% of U.S. households prefer, desire and use.
Policy scholar and communications industry analyst Dr. Anna-Maria Kovacs authored a new 45-page analysis, “Telecommunications Competition: The Infrastructure-Investment Race,” that examines the existing regulatory framework’s impact on the communications marketplace.
The report finds that the overwhelming majority of U.S. consumers have a plethora of choices to meet their voice, video, and Internet-access communications needs. They rely on the use of smart wireless devices, cellphones, wired Internet-enabled VoIP services, and over-the-top Internet-enabled applications (i.e. Skype), far more than on traditional telephony to stay connected in today’s digital age.
IIA Co-Chair Mehlman Comments on PPI Investment Heroes Report
IIA Co-Chair Mehlman Comments on PPI Investment Heroes Report, Says Government Should Create Environment for Sustained Investment
Emphasizes that FCC wireless spectrum auctions should proceed in open manner and allow all carriers to bid equally and without restrictions
WASHINGTON, D.C. – September 19, 2013 – The Internet Innovation Alliance (IIA) today issued the following statement from Co-Chairman Bruce Mehlman in response to the Progressive Policy Institute releasing its 2013 list of Investment Heroes, in which – this year, like last year – the telecom and cable sector is a big winner:
“AT&T and Verizon once again lead the way in domestic investment, and telecom is second only to the booming energy sector in total U.S. investment. PPI shows that these two companies combined invested nearly $34.5 billion to build-out nationwide high-speed broadband networks and infrastructure. AT&T alone invested almost $19.5 billion. As a sector, telecommunications and cable invested $50.5 billion last year, over a third of the nearly $150 billion invested by the Fortune 150 last year. Such levels of investment are remarkable, but not surprising. With each passing day, Americans witness and benefit from the emergence of the nation’s “data-driven economy,” all fueled by U.S. telecom and technology company capital investment. Our data-driven economy is at the forefront of creating new jobs in entirely new industries—like mobile apps—and is a driving force in improving cost structures and the delivery of services in sectors such as healthcare, education, and agriculture.
“Broadband providers have done their part to improve the path to economic recovery, demonstrated by their significant investments in America. The progress we’ve seen, however, needs to continue. Billions of dollars of additional private investment is necessary to bring ubiquitous high-speed broadband to every American.
“For this to take place, government should adopt policies that create an environment for sustained investment. As PPI notes, government can ensure that upcoming FCC wireless spectrum auctions proceed in an open manner and allow all carriers to bid equally and without restrictions. No one company should be given favored treatment to the disadvantage of its competitors. Moreover, government can also proactively promote additional investment by eliminating existing regulatory barriers and helping to speed the upgrade and modernization of our nation’s antiquated telephone networks, so that more Americans can benefit from the high-speed Internet and video services that next generation broadband networks offer.
“It is uncertain that the nearly $50.5 billion in existing telecom and cable investment will continue unless government helps promote additional regulatory and business certainty by adopting wise and timely pro-market investment policies. In the meantime, we owe our gratitude and thanks to the tech and telecom companies who invest in America and help spur innovation, create jobs, and contribute to the nation’s economic growth.”
IIA Urges FCC to Move Forward to Approve “Real-World Trials”
IIA Urges FCC to Move Forward to Approve “Real-World Trials” to Accelerate Transition to High-Speed Broadband Internet Services across America
Says regional market trials will provide FCC with evidence to develop forward-looking, pro-investment, pro-consumer policies for build out of next-generation, IP-enabled networks and services
WASHINGTON, D.C. – August 7, 2013 – The Internet Innovation Alliance (IIA) today issued the following statement based on its Reply Comments to the Federal Communications Commission’s (FCC) request for input on the proposed “real-world trials” designed to advance the transition toward nationwide consumer access to next-generation Internet Protocol (IP)-based networks and services:
“Local market trials provide the next step toward speeding the modernization of America’s legacy telephone networks. Initiating market trials for IP network deployment would continue innovation and enhance economic growth resulting from the deployment of next-generation technologies. The Commission’s principal focus should be on how high-speed broadband networks should replace antiquated telephone networks and how market trials can contribute to the development of a new regulatory model that promotes broadband growth, increases subscribership and maintains fundamental and essential consumer protections.
“Real-world market trials offer the best means for assessing the costs and benefits of accelerating the IP Transition and should not be used to help advance certain outmoded business models. Fear of theoretical and unproven harm to certain competitor business models dependent on never-changing regulatory mandates is simply not a compelling reason for inaction. The trials represent a unique window of opportunity to gather information to ensure that the IP Transition will occur with minimal disruption to consumers.
“Market trials should proceed under the same lighter regulatory framework applied to other rapidly-proliferating IP networks, rather than the outmoded and shrinking TDM-based networks. Any market trial should enable IP-based networks to demonstrate their capabilities and the impact of the transition on consumers subject to the same real-world environment in which all other IP networks currently operate. A regulatory hand applying pressure on the scale and conditioning the trials toward certain outcomes is, of course, a prescription for trials that will not be truly scientific and will fail to achieve their basic purpose. Just as we seek to avoid locking in old technology, such as the rotary phone or dial-up Internet service, the nation cannot afford to permanently lock-in old rules that would ultimately harm innovation, job creation and economic growth.”
To read the IIA’s full comments, go to http://bit.ly/18ahAEr, or the FCC’s website. To learn more about IIA, visit http://www.internetinnovtion.org.
Reply Comments to the FCC
Comments of Internet Innovation Alliance
On behalf of the Internet Innovation Alliance (IIA), we appreciate the opportunity to submit Reply Comments to the Federal Communications Commission’s (“FCC” or “Commission”) request for input on the proposed “real-world trials” designed to advance the transition toward nationwide consumer access to next-generation Internet Protocol (IP)-based networks and services.2 In this pleading, IIA responds to significant issues raised by commenters. Our comments focus exclusively on the TDM-to-IP transition (the IP Transition).
Download IIA’s full Reply Comments (PDF)
IIA Congratulates Wheeler on Nomination to Be Next FCC Chairman
Recommends modernization, innovation and humility as goals for regulators
WASHINGTON, D.C. – May 1, 2013 – The Internet Innovation Alliance (IIA) today issued the following statement in response to President Obama’s nomination of Tom Wheeler to be the next Chairman of the Federal Communications Commission (FCC):
“Tom Wheeler is well-equipped to lead the Federal Communications Commission during a time that is crucial to the continued expansion and advancement of Internet technology. We congratulate him on his selection to serve as the next chairman of the Commission.
“In this new role, we hope he focuses on enabling the infrastructure investments required to put high-speed broadband access in the hands of more Americans. This resource is critical for education, health and entrepreneurship, and government and business must work together to increase its availability.
“As the leadership transition at the FCC takes shape, we look forward to our continued work with FCC Commissioner Mignon Clyburn who has been named interim Chair of the Commission. Her strong vision and focus on driving programs that will help bring high-speed broadband to more Americans is critical to the Administration’s technology policy goals.”
“As no one can predict the outcome of technological investments made today, modernization, innovation and humility should be the focus of regulators.”
To learn more about the Internet Innovation Alliance (IIA), visit http://www.internetinnovation.org.
FCC Fails to Acknowledge Success of Wireless Market to Justify Future Regulation, Says IIA
Commission should focus on making more spectrum available for commercial mobile services to meet skyrocketing consumer demand
WASHINGTON, D.C. – March 22, 2013 – The Internet Innovation Alliance (IIA) today issued the following statement in response to the Federal Communications Commission (FCC) releasing its 2013 Wireless Competition Report:
“Rather predictably, the FCC has once again avoided concluding that the wireless market is competitive, despite the fact that four out of five consumers have a choice of five or more wireless service providers. In 2010, the Commission reversed the findings of six successive reports that acknowledged the mobile market’s success.
“More Americans are choosing smartphones when they purchase a new phone (67 percent in 2012), and more are using them to go online (104 million in 2011). And according to today’s FCC report, ‘It is estimated that U.S. mobile data traffic increased 270 percent from 2010 to 2011, and that it has more than doubled each year for the past four years.’
“The Commission is painting a picture of the market with this shade of gray to leave room for justification of future wireless regulation. But interestingly enough, FCC Chairman Julius Genachowski this morning stated: ‘Today, the U.S. broadband economy is thriving. The United States has regained global leadership in key areas of broadband innovation and infrastructure. Thanks to innovative American companies and entrepreneurs – and smart government policies – the U.S. is now the envy of the world in advanced wireless networks, devices, applications, among other areas.’
“When measured by availability of consumer choices, options for consumer plans, device alternatives, apps or services, the American wireless market is extraordinarily competitive, far more so than practically any other sector of our economy. Failing to find ‘effective competition,’ as the FCC has again done in this report, is not reflective of market realities.
“Federal policy makers should redouble their efforts to make additional spectrum available for auction to commercial broadband providers by quickly conducting incentive auctions, approving secondary market transactions, enacting spectrum sharing arrangements and initiating a process to repurpose additional federal spectrum.”
IIA Chairmen Commend Genachowski and McDowell on Successes upon Departure from FCC
Say Genachowski has helped pave way for FCC consideration of IP Transition, McDowell for future innovation and tech-led growth
WASHINGTON, D.C. – March 22, 2013 – Responding to the news that Federal Communications Commission (FCC) Chairman Julius Genachowski will be departing from the Commission and that FCC Commissioner Robert McDowell will be leaving, as well, the Internet Innovation Alliance (IIA) today released the following two statements from its Chairmen:
On Genachowski’s departure, from IIA Honorary Chairman Rick Boucher:
“Chairman Genachowski has provided a valuable service as FCC chairman. He oversaw the adoption of a comprehensive reform of the federal universal service fund. He has set the stage for the FCC’s consideration of the transition to all Internet Protocol networks. I commend him on his success and wish him well in his future endeavors.”
On McDowell’s departure, from IIA Founding Co-Chairman Bruce Mehlman:
“Rob exemplified the very best traditions in his years on the Commission, serving with honor, intelligence, humor and grace. He had a hand in shaping a great number of policies that improved American competitiveness and helped lay the groundwork for future innovation and tech-led growth. He will be missed.”
BROADBAND & BASKETBALL
Evolution of March Madness Consumption Underscores Importance of IP Transition, Sound Federal Spectrum Policy and Regulatory Modernization
WASHINGTON, D.C. – March 19, 2013 – In conjunction with the kick-off of the NCAA Men’s Division I Basketball Championship, one of the most online-watched sports events in America, the Internet Innovation Alliance (IIA) today released a timeline detailing the evolution of March Madness consumption. Beginning in 1996, the same year that Congress passed a landmark Telecom Act that referenced the Internet just once, the timeline shows how consumer demand for March Madness has exponentially increased the need for Internet Protocol (IP)-enabled services like real-time online video and mobile data, underscoring the need for a move to next-generation networks and sound federal spectrum policy.
“While many things in college basketball have not changed over the years – games are still 40 minutes, upsets are guaranteed and Duke remains the team you love to hate – how consumers follow their favorite teams has radically and rapidly evolved,” observed Bruce Mehlman, IIA founding co-chairman. “Telecommunications policy makers should take note of the vastly different market landscape. Rather than trying to force-fit legacy telecom rules to the broadband era, policy makers should show humility and address today’s dynamic marketplace.”
Timeline: Evolution of March Madness Consumption
1996: The NCAA creates the first online computer page for the Final Four.
2003: CBSSports.com, CBS Sports, and the NCAA first partner to produce NCAA March Madness on Demand, the official online platform of the tournament offering basketball live feeds, as well as on demand video streaming.
2005: CBS begins a two-year deal with CSTV.com for exclusive Internet video streaming rights for out-of-market game coverage for the first 58 games of the championship.
2006: March Madness on Demand sees 19 million video streams and 5 million visits.
2007: Due to 2006 traffic, CBS Sportsline doubles its bandwidth capacity for March Madness on Demand, which offers free live Internet streams of each game of the first three rounds of the championship.
2008: CBSSports.com and March Madness on Demand launch a developer platform that allows more than 200 websites to carry live video of the championship online, including sites such as ESPN.com, Yahoo, SI.com, YouTube and Facebook. CBS allows users to watch all 63 games that it telecasts during the tournament for the first time, and sees the total number of unique visitors from first-round games through the regional championship games grow from 1.75 million to 4.33 million.
2011: Akamai’s global network is used to provide live and on-demand streaming video across broadband and mobile applications. Akamai delivers live games and on demand content to more than 1.9 million unique visitors per day on broadband sites and more than 680,000 daily visitors to mobile applications. By the event’s end, there is a 63 percent increase in total visits across the 2011 NCAA March Madness on Demand broadband and mobile products, and a 17 percent increase in online video consumption throughout the tournament compared to the previous year. This year, for the first time, live streaming video of every game of the tournament is available online.
2012: The Android phone is added as a viewing platform for NCAA March Madness Live (formerly March Madness on Demand). NCAA.com/March Madness Live, CBSSports.com, SI.com, TruTV.com, TNT.tv and TBS.com deliver over 220 million visits across online and mobile platforms. This marks an 11% increase from 198 million in 2011.
What’s in store for 2013?
“From March Madness to the Olympics and the Super Bowl, consumers are increasingly relying on a high-speed broadband Internet connection to tune into their favorite sporting events,” said IIA Co-Chairman Jamal Simmons. “Moving to all IP networks is a promising way to expand services like the online delivery of real-time video consumers want and services like remote health monitoring consumers need.”
Simmons added, “With smartphone adoption continuing to climb, mobile consumption is sure to boom during the 2013 tournament. It’s clear that demand will soon outpace supply, and policy makers should thoughtfully tackle spectrum policy now.”
In Multichannel News, Mark Johnson, Turner Sports vice president of business operations explains, “Broadband connections at work on that first Thursday (3/21) and Friday (3/22) are still huge for us. On those two days, we’ll do forty to fifty percent of our streams.” From the article: “Whereas broadband dominates the aforementioned days, when it comes to weekends March Madness Live on mobile is the fashion, as people are ‘running to the mall, or their kids’ soccer practice. They are checking the scores, looking at streams. Mobile has become the weekend device,’ said Johnson.”
According to IIA Honorary Chairman Rick Boucher, the first step to meet this challenge is to conduct a successful Federal Communications Commission (FCC) incentive spectrum auction that will be open to all bidders and provides additional spectrum for consumer mobile broadband services:
“History has shown that when the FCC has tried to pick winners and losers in the wireless market, American consumers have lost. Past attempts by the Commission to favor certain bidders and/or impose rigid regulations on auction winners have drastically diminished auction proceeds, left major blocks of spectrum unused, and led to what FCC Chairman Julius Genachowski himself has labeled ‘America’s looming spectrum crisis.’
“Only through truly competitive, open spectrum auctions will America’s wireless industry continue to thrive. After all, the best way to ensure competition is to encourage everyone to compete. Ultimately, sound spectrum policy translates into a win for America’s consumers and economy.”
To learn more about what policy makers can do to help accelerate the transition to all-IP networks and make more spectrum available to meet consumer demands, visit http://www.internetinnovation.org.
About The Internet Innovation Alliance
The Internet Innovation Alliance was founded in 2004 and is a broad-based coalition supporting high-speed broadband availability and access for all Americans, including underserved and rural communities. It aims to ensure every American, regardless of race, income or geography, has access to this critical tool. The IIA seeks to promote public policies that leverage the power of entrepreneurs and the market to achieve universal broadband availability and adoption.
For more information contact:
IIA Says Proposed Beta Trials Are Best Way to Move Forward with IP Transition
Emphasizes that consumer trends and explosive broadband growth have ended ILEC dominance in voice market
WASHINGTON, D.C. – February 25, 2013 – The Internet Innovation Alliance (IIA) today issued the following statement regarding its reply comments on AT&T’s Internet Protocol Transition Petition and its comments on the United States Telecom Association’s (USTA) Petition calling on the FCC to declare incumbent local exchange carriers (ILECs) as non-dominant in the provision of switched access services:
“AT&T’s proposed limited beta trials epitomize sound policy-making and will provide an open and transparent process in which the FCC can accelerate the transition to all-IP networks and services in America. Initial comments fail to make a compelling argument on why the FCC should not move forward with the beta trials. Consumer trends, particularly the overwhelming preference for wireless and Internet-based services as the primary means of communications over plain old telephone service, demonstrate that ILECs are no longer dominant in thevoice market. The evidence suggests the consumer benefits associated with the IP transition far outweigh any potential costs identified by opponents.
“Failing to acknowledge the dynamic innovation, economic growth, and overall benefits the broadband market offers to consumers and businesses as a result of a ‘light touch’ regulatory approach ignores the primary reason why the Internet has flourished in the U.S. Despite this success, certain commenters now seek torevisit the FCC’s previous forbearance decisions by looking for ways to bring ‘old rules to all networks.’ To continue expanding the array of social and economic benefits for American business and consumers, the Commission should ignore the call of entities seeking to expand legacy regulations in an all-IP world.”
To read the IIA’s full comments, go to http://www.internetinnovation.org/files/IIA-comments-2-25-13.pdf, or the FCC’s website.
IIA Applauds FCC Decision to Make More Spectrum Available for Unlicensed Devices in the 5 GHz Band
Multi-pronged solution to spectrum crunch required
WASHINGTON, D.C. – February 20, 2013 – Today in response to the Federal Communications Commission’s (FCC) notice of proposed rulemaking (NPRM) that seeks to explore the possible future release of frequencies in the 5 MHz band for Wi-Fi, the Internet Innovation Alliance (IIA), a coalition backing high-speed broadband access and adoption for allAmericans, released the following statement:
“As more Americans continue to depend on the anytime, anywhere advantages of mobile technology – the nation faces new opportunities and challenges in making next-generation services more widely accessible to the public. Explosive growth in wireless broadband services continues as consumers’ demand for the latest mobile devices, services and applications increases the need for additional spectrum in the wireless market. Government must take a multi-pronged approach to alleviate the imminent spectrum crunch to advance the benefits of wireless broadband for all Americans.
“Allocating the 5 GHz band for unlicensed Wi-Fi devices makes sense, given that it provides limited geographic coverage to avoid radio frequency interference. Consumers stand to benefit from this unlicensed spectrum through increased speeds and decreased congestion at a variety of locations including airports, Internet cafes and community anchor institutions across the nation.
“Beyond this proceeding, the FCC should move quickly to launch its incentive auction to unlock additional spectrum for high-speed wireless broadband for both licensed and unlicensed spectrum use to maximize the benefits for America’s businesses and consumers.”
IIA Says FCC “Measuring Broadband America” Report Supports Case for IP Transition
FCC findings reinforce that broadband marketplace is extremely competitive and consumers want higher speeds
WASHINGTON, D.C. – February 15, 2013 – Commenting on findings in the newly-released Federal Communications Commission (FCC) “Measuring Broadband America” report that 1) “most broadband providers continue to closely meet or exceed the speeds they advertise” and 2) “consumers of broadband providers covered by the report are continuing to migrate to faster speed tiers and receiving faster speedsthan ever before,” the Internet Innovation Alliance (IIA), a broad-based coalition supporting broadband access and adoption for all Americans, todayreleased the following statement:
“Today’s FCC report reinforces two very important realities about the broadband marketplace: it is highly competitive with natural market forces driving private investment that is rapidly upgrading America’s network infrastructure, and consumers want higher speeds that unlock opportunities within education, health care, entertainment, entrepreneurship and more.
“Consumers across the nation – all ages, races and socioeconomic statuses – are abandoning outdated technologies. Florida, for example, has the largest proportional share of Americans over the age of 65, but only 19 percent of all (IIA member) AT&T customers there still subscribe to legacy, copper wire service. And the FCC-reported fact that nearly half of consumers who subscribed to speeds of less than 1 Mbps six months ago have adopted higher speeds makes clear that slower, outdated networks no longer suffice for the technology-driven world of today.
“A nationwide transition to all-IP networks will allow telecom providers to concentrate their investment dollars in building out technology of the future, rather than maintaining technology of the past. This move will alleviate the cost burden for consumers footing the bill to maintain outdated networks without the benefit of access to new services provided bynext-generation networks being built at the same time.
“The FCC data makes crystal clear: this is not your father’s telecom market. Times have changed. Luckily, the FCC has the capacity to change with the times, forbearing from imposing yesterday’s regulations on tomorrow’s technologies and networks. The Commission has prudently exercised such restraint previously, declining to regulate investment in fiber-based facilities. Future growth demands additional forbearance, and market conditions warrant such humility and restraint. The FCC now has the data to prove it.”
To learn more about the IIA, visit http://www.internetinnovation.org/.
IIA Calls for Comprehensive Reform of Monopoly-Era Regulations
IIA Calls for Comprehensive Reform of Monopoly-Era Regulations Inhibiting the IP Transition in Comments to FCC on AT&T Petition
Says Requiring Carriers to Maintain Dual Networks Is Counterproductive, Siphoning Investment away from Next-Generation Networks
WASHINGTON, D.C. – January 28, 2013 – In comments on the Federal Communication Commission’s (FCC) Notice of Proposed Rulemaking (NPRM) focusing on the November 7, 2012 petition by AT&T, the Internet Innovation Alliance (IIA), a broad-based coalition supporting broadband access and adoption for all Americans, offers recommendations to accelerate the transition to an all-Internet Protocol (IP) network:
IIA believes the Commission’s long-term goals should be:
(1) Accelerating the IP transition by removing regulatory barriers that no longer make sense,
(2) Encouraging investment in advanced infrastructure and broader deployment of IP to all Americans, and
(3) Ensuring no consumers are “left behind,” losing access at least as good as they already have.
From the Alliance:
“The evolution from circuit-switched TDM telephone networks to capacious, IP-enabled platforms is transforming the telecom marketplace and creating extraordinary consumer opportunities. The world of ‘plain old telephone service’ is long-gone. In its place, today’s telecom consumers enjoy incredible innovation and furious cross-platform competition. The FCC should combine the IP transition elements of the various FCC proceedings into a single, logical framework that would enable all interested parties to have a clear understanding of, and better ability to participate in, the FCC’s proceeding.
“While the era of the telecom monopoly is long over, monopoly-era regulations persist. One of the most counterproductive, monopoly-era regulations still on-the-books is the requirement for legacy carriers to continue maintaining redundant legacy copper (non-IP) networks, even when they are no longer needed for the carrier to serve its customers. Faced with an extensive series of legacy obligations, incumbent network operators can either continue maintaining dual networks, siphoning investment away from IP networks, or work with policy makers at the Commission and in Congress to modernize telecom regulations to better fit with actual market realities and technological trends.
“To accelerate the IP transition this year, the FCC should quickly approve AT&T’s proposed plan to establish demonstration project trials in selected communities, much like the closely-observed Wilmington, North Carolina market trial in advance of the nationwide, digital TV broadcasting switchover in June 2009. Beta trials are the norm in industry when it comes to the initial roll-out of products and services. They enable market participants to test and better understand consumer acceptance and reactions, leading to more robust future offerings. We can only benefit from such a look-before-we-leap.”
To read the IIA’s full comments, go to http://internetinnovation.org/files/IIA_ATT_Petition_Comments.pdf, or check the FCC’s website.
IIA Comments to the FCC on AT&T’s Petition Regarding IP Transition
Chairman Julius Genachowski
Commissioner Robert McDowell
Commissioner Mignon Clyburn
Commissioner Jessica Rosenworcel
Commissioner Ajit Pai
Federal Communications Commission 445 12th Street, SW Washington, DC 20554
Re: GN Docket No. 12-353 January 25, 2013
Dear Chairman Genachowski and Commissioners McDowell, Clyburn, Rosenworcel and Pai:
On behalf of the Internet Innovation Alliance (IIA), we appreciate the opportunity to offer comments on the Federal Communication Commission’s (FCC) Notice of Proposed Rulemaking (NPRM) focusing on the November 7, 2012 petition by AT&T. In summary, IIA believes an acceleration of the transition to an all-IP network is in the public interest and can be achieved by authorizing trials of the rapid movement of as many people as possible from TDM to IP networks in selected wire centers and through consolidation into a single proceeding of elements from multiple FCC open dockets.1
Comprehensive reform of monopoly-era regulations that inhibit the IP transition is essential – one of the two most impactful ways the Commission could advance broadband investment, availability and consumption. (The other high-impact opportunity is making significantly more spectrum available for commercial broadband services. Such spectrum could come either from government transition of spectrum it currently occupies, which requires coordination across the Executive Branch, or from accelerated approval of secondary market transactions in the private sector.)
I. The Shift to All-IP Networks Is Transforming The Telecom Marketplace and Creating Extraordinary Consumer Opportunities.
Few aspects of our society are transforming as rapidly and completely as our telecom infrastructure and marketplace. While automobiles have added significantly more electronics than their predecessors and recently improved their fuel efficiency, cars today are still strikingly similar to the cars of 1983. They perform the same core function at the same speed for the same purpose, driving over the same highways and with basically unchanged operator controls. Likewise, air transportation has evolved over the past 30 years, but in a recognizable and fundamentally-modest fashion: planes still take you from one city to another via hub-and-spoke networks in roughly the same amount of time.
By contrast, the telecommunications systems and markets of 1983 are practically unrecognizable today. Thirty years ago, there was one telephone company in each community delivering voice service over circuit-switched networks. No cell phones, no smartphones, no texting, no apps. Telephone service was important, but hardly the essential engine driving global productivity, employment or new business formation. Through an elaborate structure of regulations and cross-subsidies, policy makers ensured this single, slow-moving monopoly accomplished desired social outcomes, such as universal service of voice calling and affordable pricing for residential consumers.
Simply put, the world of “plain old telephone service” is long-gone. In its place today’s telecom consumers enjoy incredible innovation and furious cross-platform competition. For example, one out of three American homes no longer pays for a wired phone,2 having cut-the-cord with the former incumbent telephone company in favor of cable, wireless or other alternatives. Nine out of 10 wireless consumers have the choice of five or more providers,3 and there are now more Internet-connected devices than people in the U.S.4 We see fierce competition for broadband-delivered video from multiple providers over multiple platforms. Beyond mobile carriers, robust voice-video- and-data “triple play” packages are offered by cable companies, satellite companies, new telecom companies and over-building broadband companies.
This “Cambrian Explosion” of new services and possibilities was enabled by profound innovation in communications technology. Specifically, new robust Internet Protocol (or “IP”) networks allowed for two-way transmission of data-based information previously impossible. As circuit-switched TDM telephone networks evolved into capacious, IP-enabled platforms, the services available likewise proliferated, in the process fundamentally transforming the way people across the globe send and receive information and creating an opportunity for electronic commerce that has revolutionized the economy. The benefits for both consumers and the global economy are already enormous, and they have only just begun.
Medical patients today receive real-time health information, communicate live with distantly-located care providers, benefit from electronic medical records and connect to monitoring devices that give them new freedom and security. Students of all ages are now free to learn at their own pace, regardless of where they live, where they go to school or when they want to learn. The shift from 2G to 3G wireless services alone created nearly 1.6 million jobs across the U.S. between April 2007 and June 2011,5 according to a study by NDN. TechAmerica Foundation says the U.S. high-tech industry employed nearly six million people as of June 2012,6 and Economist Michael Mandel concluded that more than 500,000 Americans work in an “App economy”7 that did not exist in 1983, nor even 2003. Broadband services delivered over IP networks help rural areas overcome challenges of distance and help low-income Americans save money, learn new skills and exploit new economic opportunities. OECD analysis has found that each 10 percent increase in broadband penetration yields a 0.25 percent increase in GDP growth.8
Technologically, our future is very bright. And nearly all observers agree that IP networks are the key to realizing this positive future. Indeed, the FCC’s Technical Advisory Council recommended that the FCC sunset the public-switched telephone network precisely to accelerate and enable this shift towards all-IP networks. The question before the Commission is how best to enable this trend, either by adding incentives or removing barriers.
II. While Consumers and Competitors Are Moving Full-Speed toward All-IP Services, Legacy Regulations Inhibit Investment & Transition.
While the era of the telecom monopoly is long over, monopoly-era regulations persist. In some ways this is predictable, since markets move faster than government, and entrepreneurs innovate more rapidly than policy makers. By way of example, one of the most counter-productive, monopoly-era regulations still on-the-books is the requirement for legacy carriers to continue
maintaining redundant legacy copper (non- IP) networks even when they are no longer needed for the carrier to serve its customers. While these rules made sense at the dawn of the Internet era when little, if any, competition existed, voice remained the essential product and telephone networks had been built via government-guaranteed-rate-of-return exclusivity, they have long been overtaken by events. For example, in many regions incumbent telephone companies have retained less than 30 percent of the customers,9 yet they are still required to cover 100 percent with their pre-IP, voice-grade networks. Voice is today just another application delivered over multiple IP platforms.
To their credit, policy makers over the past decade understood that “new wires” demanded “new rules.” As a result, today the more advanced broadband infrastructure faces fewer regulatory barriers and obligations and enjoys far greater levels of investment. Yet legacy regulations persist, with change coming piecemeal and inconsistently. Some important progress has been made. For example, the Commission has now begun the effort to shift universal service support from exclusively voice networks to broadband alternatives. But the Commission’s process is diffuse and begs for greater focus. Multiple proceedings currently before the Commission address various pieces of this IP transition and its implications.
III. The Commission Has the Authority to Facilitate the Trials Proposed by AT&T and Can Hasten Our Broadband Future by Consolidating the Various Proceedings that Touch upon the IP Transition.
Faced with the plethora of proceedings and extensive series of legacy obligations, incumbent network operators can either continue maintaining redundant networks, siphoning investment away from IP networks, or work with policy makers at the Commission and in Congress to modernize telecom regulations to better fit with actual market realities and technological trends.
The Internet Innovation Alliance believes the submission by (IIA Member) AT&T offers an excellent opportunity to consider and address the challenge of regulatory modernization. We believe the Commission’s long-term goals should be (1) accelerating the IP transition by removing regulatory barriers that no longer make sense, (2) encouraging investment in advanced infrastructure and broader deployment of IP to all Americans, and (3) ensuring no consumers are “left behind,” losing access at least as good as they already have. The AT&T petition suggests an appropriate and measured first step toward the eventual goals. We believe the Commission has the authority to facilitate the trials proposed by AT&T in its petition, and such trials seem like a reasonable method for assessing a path for achieving the Technical Advisory Council’s objective for an all-IP network. Finally, IIA concurs with those who suggest a single, consolidated proceeding is far preferable to multiple proceedings, each touching on individual elements of the “IP transition.”
As noted by both the Chairman and Commissioners McDowell & Pai, shifting from TDM to IP networks is already proving an incredible boon for consumers and for the American economy. AT&T has proposed to the Commission a thoughtful plan to accelerate the transition by establishing demonstration project trials in selected communities, much like the closely-observed Wilmington, North Carolina market trial in advance of the nationwide, digital TV broadcasting switchover in June 2009. Beta trials are the norm in industry when it comes to the initial roll-out of products and services. They enable market participants to test and better understand consumer acceptance and reactions, leading to more robust future offerings. And the knowledge gained from TDM-to-IP trials will enable the Commission in future years to proceed with confidence in a nationwide sunset of the TDM network in favor of an all-IP national network. Geographically-diverse-but-limited trials will give policy makers a real-time look at the impact of copper retirement and deployment of new IP infrastructure in a controlled setting. We can only benefit from such a look-before-we-leap. The establishment of pilot projects would enable major strides in our understanding and planning. The process should begin this year with approval of the AT&T plan.
Once again, IIA appreciates the Commission opening this important proceeding. We have a real opportunity to move beyond legacy regulations that no longer benefit consumers and embrace market realities that encourage investment, consistent with President Obama’s regulatory efficiency instructions to federal agencies in June 2011. The trials proposed by AT&T are a prudent first step. And looking to combine the IP transition elements of the various FCC proceedings into a single, logical framework would enable all interested parties to have a clear understanding of, and better ability to participate in, the FCC’s proceeding. IIA looks forward to continue working with the Commission and interested stakeholders on these important questions.
Rick Boucher, Former Congressman (D-VA) and Honorary Chairman, Internet Innovation Alliance
Bruce Mehlman and Jamal Simmons Co-Chairmen, Internet Innovation Alliance
1 Letter from Thomas Jones, Counsel to Cbeyond, Inc., Earthlink Inc., Integra, Inc., and tw telecom, inc., to Marlene H. Dortch, FCC, WC Docket Nos. 10-90 et al. Filed December 4, 2012. http://apps.fcc.gov/ecfs/document/view?id=7022073195
2 Blumberg, Stephen and Julian Luke. “Wireless Substitution: Early Release of Estimates from the National Health Interview Survey, January–June 2012,” Centers for Disease Control and Prevention, December 2012. http://www.cdc.gov/nchs/data/nhis/earlyrelease/wireless201212.pdf
3 Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, Annual Report and Analysis of Competitive Market Conditions with Respect to Mobile Wireless, including Commercial Mobile Services, WT Docket No. 10-133, Fifteenth Report, 26 FCC Rcd 9664, 9669 (2011).
4 Molina, Brett. “Survey: U.S. Web-connected devices outnumber people,” USA Today, January 3, 2013. http://www.usatoday.com/story/technologylive/2013/01/03/internet-connected-devices-usa/1806565/
5 Rosenberg, Simon. “NDN/NPI Releases New Paper: The Employment Effects of Advances in Internet and Wireless Technology,” January 18, 2012. http://ndn.org/blog/2012/01/ndnnpi-releases-new-paper- employment-effects-advances-internet-and-wireless-technology
6 Kazmierczak, Matthew. “Tech Industry Adds Nearly 100,000 Jobs in 1st Half of 2012,” Tech America Foundation, October 2012. http://www.techamericafoundation.org/content/wp- content/uploads/2012/10/CS_Midyear_Employment_2012.pdf
7 Mandel, Michael and Judith Scherer. “The Geography of the App Economy,” CTIA, September 20, 2012. http://southmountaineconomics.files.wordpress.com/2012/11/the_geography_of_the_app_economy-f.pdf
8 “The Impact of Broadband on the Economy: Research to Date and Policy Issues,” ITU, April 2012. http://www.itu.int/ITU-D/treg/broadband/ITU-BB-Reports_Impact-of-Broadband-on-the-Economy.pdf
9 Petition of USTelecom for Declaratory Ruling that Incumbent Local Exchange Carriers Are Non- Dominant in the Provision of Switched Access Services, WC Docket No. 12-, December 19, 2012. http://www.ustelecom.org/sites/default/files/documents/UST elecom-Non-Dom%20Petition-FINAL.pdf
Our statement will also be available on the FCC website.