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FCC Reply Comments regarding a National Broadband Plan for our Future

Submission Date: 
07/21/2009

I. Introduction and Summary.

     In its initial Comments, ACA asked the Commission to draft a National Broadband Plan that will enable the universal availability of reliable, reasonably priced high-speed broadband service. ACA outlined seven issues the Commission must address to ensure all Americans receive broadband service: 

  • The need of broadband providers to have non-discriminatory access to all web-based content and services at reasonable rates, terms, and conditions.
  • The need of broadband providers to have non-discriminatory access to middle mile infrastructure at reasonable and non-discriminatory special access rates, terms, and conditions.
  • The need of broadband providers to have non-discriminatory access to pole attachments at reasonable and non-discriminatory rates, terms, and conditions.
  • The need for the Commission and other agencies to freeze or reduce regulatory fees on smaller operators.
  • The need to mitigate the harms caused to broadband providers who are also cable operators by the current wholesale practices of programmers and broadcasters.
  • The need for a complete national broadband map that includes an inventory of all existing “last mile” and “middle mile” infrastructure.
  • The need for any Broadband Universal Service Fund (“USF”) program adopted to be separate from the existing USF high cost program, and for cable operators to have equal access to the funds.

     In short, ACA’s Comments demonstrated the steps the Commission must take to enable the nationwide availability of reliable, high-speed Internet access at reasonable prices.

     ACA files this Reply to highlight the overwhelming support for its recommendations. Commenters agree that these steps are necessary to ensure broadband deployment to all Americans. Without these protections and limitations, content providers, pole owners and others will have ample opportunity to raise costs for consumers and harm broadband deployment in many of the smaller and rural markets served by ACA’s members.

     In this Reply, ACA also brings to the Commission’s attention two additional matters of concern to small and medium-sized cable operators. First, the lack of affordable, high-capacity middle mile infrastructure in many smaller markets and rural areas prevents new and existing broadband operators from providing low-cost next generation broadband services to consumers in these areas. Second, Congressman Eric Massa (D-NY) recently introduced a bill that would restrain broadband operators’ freedom to offer consumers lower cost broadband service tiers based on their consumption. Therefore, in addition to the recommendations in ACA’s Comments, the Commission must also highlight the following in the National Broadband Plan to Congress:

  • The need for additional government funding to build affordable, highcapacity middle-mile facilities in all areas that lack this infrastructure.
  • The need for broadband providers to retain the right to offer consumptionbased billing plans that will give consumers the ultimate control over their monthly spending on Internet access.
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090721 ACA Reply National Broadband Plan NOI Dkt GN 09-51 FINAL as filed.pdf63.89 KB

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