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.

To network the nation, go back to the future

By Rick Boucher, honorary chairman, Internet Innovation Alliance (IIA) - 04/26/13 11:30 AM ET

A little less than two decades ago, in a bid to stoke competition and create more choices for consumers, Congress rewrote the law that governed telephone and cable TV communication. It was a difficult, bipartisan, multi-year effort as we weighed the advice of policy experts, listened to competitors’ concerns and looked for the best way to serve consumers. That focus and a lot of hard work created a landmark accomplishment that stimulated competition and consumer choice in the local telephone, long-distance and cable television markets.

Today, the development of the Internet has brought us to another critical juncture in communications policy as we consider how to complete the transition from the bygone era of plain old telephone service to the digital bonanza of the 21st century. It’s a critical transition, given the Internet’s increasingly dominant role in every part of our economy, as well as its ability to improve lives and help achieve important national goals. It’s also something that just about every stakeholder, including the Federal Communications Commission, regards as inevitable. As we move forward, the guiding principle must be to put consumers first.

When complete, this Internet transformation will mean that every telecom service will move over the fastest, most reliable broadband networks built specifically for Internet-based delivery of voice, video and data rather than antiquated networks that were designed for phones wired to the wall.  Every app, every smartphone and tablet, every desktop computer will smoothly connect consumers to the online experience of their choice – telemedicine services for better health, virtual classrooms for lifetime learning, their legislators’ offices for civic engagement, a job opportunity, a sporting event, a movie, friends and family across town or on the other side of the world.  That’s the first goal – delivering the services consumers want. Indeed, that move is already under way led by consumers themselves, about three quarters of whom have left the old wired phone network for services provided with digital tools.

Ideally every consumer – in the rural communities of Southwestern Virginia, the mountains of Colorado, and the poorest neighborhoods of the inner city – should have access to this advanced network. The principle of universal service, which ensured basic telephone service for every American, may be even more important in the Internet age. As FCC Commissioner Jessica Rosenworcel explained:  “No matter who you are or where you live, prosperity in the 21st Century will require access to broadband services.”

But providing access to the service isn’t the whole job. We also must boost adoption rates, educating every American about what the transition means, how it will affect them and why they should use broadband to improve opportunities for themselves and their family. We can’t afford to leave any American in the dark about the value of broadband; we can’t leave anyone behind.

A competitive marketplace that enables consumers to choose among different providers, technologies and service options is another core goal, because competition provides consumers a better deal. That principle guided our work on the Telecommunications Act of 1996. In today’s context, FCC Commissioner Mignon Clyburn has it exactly right: “We must also ensure that competitive alternatives are available to consumers and that all providers continue to invest and innovate – pushing one another to offer consumers the best services at the lowest prices.” Competition thrives where a level playing field exists and consumers understand the rules of the road. Basic consumer protections are vital to guard against deceptive and abusive practices.

The Internet has prospered in large part because of decisions dating to the Clinton administration to steer clear of excessive rules about matters such as terms of service and pricing. While the tradition of light touch regulation of the online space should continue, regulators must remain on guard against potential abuse and make sure that consumers receive the services they’re paying for.

Protecting public safety also remains a vital goal. Next generation networks must be reliable so that consumers can communicate in times of greatest need. Disruption of 911 in Hurricane Sandy made clear that we have work to do to achieve this goal. Ensuring access to first responders on new networks is one reason that I support proposals like one by AT&T for field tests. Market trials of IP technology will enable carriers to identify potential problems and find solutions before the final transition from the old networks to the new. Every American must have the means to reach 911 in times of emergency in this digital era.

Finally, there is the matter of outdated regulation, specifically legacy rules adopted decades ago for the old phone system. Without prejudging specifically what rules should go and what rules should stay, our nation’s regulatory system must be just as modern as the networks it governs. Over the past decade, regulators have correctly recognized that new technologies require new rules. As outgoing FCC Chair Julius Genachowski observed last December in creating the Commission’s technology transition task force, “[T]he ongoing changes in our nation’s communications networks require a hard look at many rules that were written for a different technological and market landscape.” A national dialogue moderated through an FCC proceeding should summon a broad range of stakeholders from consumer groups to broadband providers to focus on the rules that are appropriate for a time when all communications are Internet-based.

To be clear, modernizing regulations for the transition does not mean a regulation-free zone. What’s needed is smart regulation appropriate to protect consumers and public safety, promote competition and support universal service, while also encouraging significant and sustained private investment in America’s next-generation communications networks. Again to quote Commissioner Rosenworcel, “Our policies in these transitional times must do two simple things. They must promote confidence for private investment in digital age infrastructure – and they must promote confidence for consumers to realize the full potential and opportunity that our digital world provides.”

I couldn’t have said it better myself.

Source URL: http://thehill.com/blogs/congress-blog/technology/296399-to-network-the-nation-go-back-to-the-future#ixzz2RaHI8axi

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.[1]

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.[2]

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.[3] 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.[4]

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[5], 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:
Lauren DuBois
(917) 573-2485
.(JavaScript must be enabled to view this email address)

[1] http://www.sportsbusinessdaily.com/Journal/Issues/2013/03/11/In-Depth/Timeline.aspx
[2] http://www.cbssports.com/info/aboutus/press/2008/march1008mmod
[3] http://www.akamai.com/html/about/press/releases/2011/press_040711.html
[4] http://www.multichannel.com/distribution/more-devices-consumer-comfort-authentication-drive-turners-march-madness-live/142175
[5] http://www.multichannel.com/distribution/more-devices-consumer-comfort-authentication-drive-turners-march-madness-live/142175

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.

Sincerely,

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.

IIA Releases Broadband Guide for the 113th Congress

Guide Includes Critical Information to Help Policy Makers and Leaders Make Informed Decisions about Internet Policy

WASHINGTON, D.C. - January 23, 2013 - The Internet Innovation Alliance (IIA) today released the “IIA 2013 Broadband Guide for the 113th Congress.” The Alliance created the 21-page Guide to provide the next generation of policy makers and leaders with the information they need to make informed decisions about Internet policy. It includes six major sections complete with answers to common questions, definitions of technical terms and background on the importance of the Internet Protocol (IP) evolution.

“Few American innovations have changed the world more profoundly and positively than the Internet,” said IIA Honorary Chairman Rick Boucher, who served as a Member of the U.S. House of Representatives for 28 years. “Today more than 2.5 billion people are connected to the Internet and have access to information and opportunities that did not exist 20 years ago.”

Boucher - also co-founder of the House Internet Caucus and former chair of the Subcommittee on Telecommunications & the Internet - added, “It’s critical that policy makers be well-informed as they make decisions affecting the Internet in order to promote and encourage the expansion of Internet investment, access and adoption.”

The Guide also includes broadband-related data points such as:

• Over the past three years, American smartphone adoption has increased from 16.9 percent to 54.9 percent, according to Nielsen.
• One out of three American homes now relies on wireless-only technologies, according to the U.S. National Health Interview Survey (NHIS).
• The tech industry added nearly 100,000 jobs from January to June 2012, a 1.7 percent increase, according to TechAmerica Foundation’s Competitiveness Series.
• As of April 2012, 66 percent of American adults had a high-speed broadband connection at home versus 11 percent a decade earlier in March 2002, according to Pew Research.
• The app economy, which didn’t even exist five years ago, now employs more than 500,000 Americans, according to research by Economist Michael Mandel.

“Innovations in broadband technology are not exclusively relegated to the wired world,” commented Bruce Mehlman, IIA founding co-chairman and former assistant secretary of commerce for technology policy in the George W. Bush Administration. “Today, mobile devices act as general-purpose computers, complete with nearly 1.5 million available apps. Massive amounts of data are necessary to operate these mobile devices, and the future of lightning-fast, mobile communications depends on migrating America’s communications networks away from outdated legacy phone line networks and toward IP-based infrastructure.”

The vast majority of network upgrades and day-to-day operation of the Internet are overseen by private businesses, universities and organizations, yet governments - domestic and international - continue to exert influence over the environment in which the Internet evolves. To learn more, access the full Guide at http://www.internetinnovation.org/guide, where a PDF of the handbook can be downloaded. 

IIA Endorses USTA Petition

IIA Endorses USTA Petition Urging FCC to Modernize Regulations for Switched Services amidst Clear Competition

Says outdated requirements for maintaining antiquated public-switched networks siphon investment away from next-generation IP infrastructure

WASHINGTON, D.C. – December 19, 2012 – Following the filing of a petition by US Telecom Association (USTA) with the Federal Communications Commission (FCC) asking the Commission to make a “Declaratory Ruling” that incumbent ILECs no longer possess market power when providing switched access local phone services to residential and business customers, the Internet Innovation Alliance (IIA), a broad-based coalition supporting broadband access and adoption for all Americans, today issued the following supportive statement:

“The vast majority of the nation now benefits from a highly competitive telecommunications marketplace. Consumers have an abundance of wireless and wireline options for telephone communications and are taking their pick from an array of technologies.

“Policy makers should prioritize the modernization of regulations, eliminating rules that are inappropriate to apply in today¹s dynamic and robust marketplace. In places where there is clear competition in the offering of local voice telephone service, the “dominant carrier” status now accorded to local phone companies should be repealed.

“Outdated requirements focused on maintaining antiquated, public-switched networks slow Internet transformation by siphoning investment away from the next-generation broadband infrastructure that is meeting consumers’ evolving needs. Advancement by the FCC of a national conversation on the IP Transition is paramount to keeping innovators innovating, businesses growing, consumers choosing and America competing.”

To learn more about the IIA, visit http://www.internetinnovation.org/.

FCC’s Special Access Data Collection Order Is Necessary

FCC’s Special Access Data Collection Order Is Necessary to Shed Light on Today’s Highly Competitive Marketplace

Today’s Special Access Market Is Quickly Leaving Outdated, TDM-Based Technology Behind - It’s Time for the FCC to Refocus its Priorities for America on How Best to Make the Transition to Next-Generation IP Networks for the Benefit of Consumers and Businesses Nationwide

WASHINGTON, D.C. – December 18, 2012 – In response to the Federal Communications Commission’s (FCC) unanimous approval and release of its Special Access Order, the Internet Innovation Alliance (IIA), a broad-based coalition supporting broadband access and adoption for all Americans, today issued the following statement:

“Moving forward with comprehensive data collection and analysis of the special access market to evaluate competition and infrastructure investment is a step in the right direction; the new data is expected to show that the market has grown highly competitive due to Fiber/ethernet network build-out by competitors and is dramatically different today than just five years ago. The demand for TDM-based services is declining with customers choosing to use high-speed IP-based services. Given this trend, it’s time for the FCC to refocus its priorities for America on how best to make the transition to next-generation IP networks for the benefit of consumers and businesses nationwide.  Policies regarding special access were put in place in the 1990’s when incumbent telephone company copper lines were the only available option, and clearly this is no longer the case.”

“Unfortunately, the FCC appears to be moving forward prematurely with its FNPRM on how to conduct its market analysis. Data should be collected first so that any future analyses will be based on a foundation of facts that reflect the current state of the marketplace. However, the FCC should be asking itself whether it is worthwhile to undertake such a large examination of competition for a service that is rapidly being replaced by an IP-based technology and whether its resources would be better spent creating a clear path forward for the deployment of this newer technology across America. 

To learn more about the IIA, visit http://www.internetinnovation.org/.

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About The Internet Innovation Alliance

The Internet Innovation Alliance was founded in 2004 and is a broad-based coalition supporting 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:
Lauren DuBois
(917) 573-2485
.(JavaScript must be enabled to view this email address)

WEBINAR: “The App Economy: Endless Possibilities that Start with More Spectrum and Investment”

What: Webinar hosted by the Internet Innovation Alliance (IIA) and Entropy Economics to discuss Entropy Economics President Bret Swanson’s new report “Soft Power: Zero to 60 Billion in Four Years.” “Soft Power” is the phenomenon that has resulted from the colossal number of smart mobile devices and their connectivity to each other and to broadband, which has created a market so large and so diverse that the economic forces of innovation and specialization are supercharged, reflected by the App Economy.

When: Tuesday, December 11th at 11:30am ET/8:30am PT

Where: https://www1.gotomeeting.com/register/155959473

Why: Because more spectrum and more investment in the apps economy will increase consumer benefits and lead to greater positive economic effects like job creation

With the added ingredient of broadband communication, software has entered a new era. Apps are the new American software industry. In just four years, since the opening of the Apple App Store in the summer of 2008, the number of available mobile apps has grown from essentially zero to 1.425 million.

The App Economy boom has hugely benefited consumers, as well as fields like health care and education. Soft Power has generated more than half a million jobs in the U.S., but the App Economy’s dependence on the cloud will require ever-increasing network coverage and speed, i.e. more spectrum and investment.

Members of the media will have the opportunity to present questions during the webinar, and questions may also be submitted beforehand to .(JavaScript must be enabled to view this email address). The discussion can be followed on Twitter using the hashtag #SoftPower. Presenters will include:

• Bret Swanson, president of Entropy Economics LLC, a strategic insight firm specializing in technology, innovation, and the global economy

• Bruce Mehlman, founding co-chair of the IIA and former Assistant Secretary of Commerce for Technology Policy (moderator)

*Members of the media can RSVP for the teleconference and receive dial-in information by emailing .(JavaScript must be enabled to view this email address).*

IIA Applauds Effort to Make Spectrum Screen Better

IIA Applauds Effort to Make Spectrum Screen Better, More Predictable & Transparent, But Notes More Spectrum Is the Key Issue for 2013

Weighs in on ways to spur investment and growth in mobile with comments for FCC’s Mobile Spectrum Holdings NPRM

WASHINGTON, D.C. – November 23, 2012 – Responding to the opportunity to offer comments on the Federal Communication Commission’s (FCC) Notice of Proposed Rulemaking (NPRM) focusing on FCC policies regarding mobile spectrum holdings, the Internet Innovation Alliance (IIA), a broad-based coalition supporting broadband access and adoption for all Americans, today released the following summary and statement from its comments filed with the FCC:

1. Uncertainty Is Undermining Economic Growth & Job Creation.
2. Mobile Broadband Offers Extraordinary Potential to Drive Sustained Economic Recovery and Innovation.
3. Government Policy in 2013 Should Focus on Making More Spectrum Available for Private Use and Providing Greater Certainty for Investors.

“IIA believes the existing unpredictable, non-public process for changing spectrum screens undermines economic growth by failing to provide investors with the transparency, predictability and flexibility needed to properly consider wireless broadband investments. While freeing more spectrum for mobile broadband use remains the most important new policy priority, creating an open and predictable process for evaluating the amount of spectrum carriers will be allowed to possess is essential to promoting investment and growth in commercial mobile services.

“Today’s wireless marketplace is highly competitive, with nine out of ten consumers having a choice of five or more service providers in local markets across the nation.  Future spectrum screen analyses should acknowledge such competitiveness, in addition to recognizing differential values of spectrum with varying propagation characteristics.  Criterion should not disqualify or impair any carriers from participating in the upcoming Incentive Auctions or future auction of new spectrum. Clarity – both in the screen and knowledge that it will not unexpectedly change in mid-stream – should be sought to encourage more robust secondary markets.

“Spectrum screen decisions by the FCC should be made through the regular rulemaking process including the provision of notice, the issuance of proposed rules, an opportunity for interested parties to comment and judicial appeal from the final promulgated rule. Such a process assures that the rules will not be changed after carriers have made substantial investments in reliance on current screens. That certainty, which the present spectrum screen change process lacks, will stimulate investment and promote planned and orderly growth to the market for mobile services.”

To read IIA’s full comments on the FCC’s website, go to http://apps.fcc.gov/ecfs/comment/view?z=3yy3u&id=6017139763. To learn more about the IIA, visit http://www.internetinnovation.org.