Comments on a National Broadband Plan

In developing a national broadband plan to move the U.S. ahead in the 21^st century Federal Communication Commission (FCC) has an unprecedented opportunity to put in place polices that can both bring essential high-speed connectivity to those with limited or no access, and serve as the foundation for long-term broadband and technological innovation.  It is critical that a forward-looking national broadband plan focus on the underlying infrastructures necessary to spur ubiquitous high-speed broadband.  Public investment in fiber and public access to airwaves ("fiber in the sky") can serve as foundation for high-speed broadband deployment in communities across the country. 

To that end, NAF et al. have focused these comments on the policy priorities it believes will serve as essential building blocks to spur ubiquitous and pervasive high-speed broadband connectivity:

• Prioritize Open Fiber Networks Connecting Community Anchor Institutions

NAF et al. believes a key goal of the national broadband plan should be to deploy high-capacity fiber into every community with points-of-presence (POPs) at community anchor institutions including schools, libraries, hospitals, municipal/county buildings, and public safety operations.  In order to maximize the benefits of these publicly funded fiber POPs, community anchor networks must be required to provide open, wholesale access to excess capacity to any for-profit or non-profit provider - allowing the infrastructure to spur high-speed connectivity into the rest of the community. 

• Leverage Public Investment in Surface Transportation and Smart Grid toExtend Middle-Mile Fiber Access 

The U.S. can leverage the continuous construction and repair of infrastructure (e.g. highways, roads, bridges, tunnels, and railways) to extend the necessary to fiber infrastructure to every community across the nation.  As part of this effort, NAF et al. proposes a plan to fund and mandate the installation fiber-optic conduits and dark fiber bundles along all federally-subsidized and direct federal highway projects.  We can further integrate the build-out of neutral fiber-optic infrastructure into public investment in the smart grid - taking advantage of the efficiency of using a single infrastructure to facilitate connectivity for a multiplicity of services and applications.

• Map and Open Excess Capacity on Public Sector Fiber Networks

Broadband deployment, competition and affordability would also benefit enormously from a mapping of the public sector fiber networks used by federal, state and local public agencies nationwide.  Dark fiber and/or excess capacity on the public sector's own fiber line infrastructure, opened for wholesale access to any provider - commercial or non-commercial - including non-vertically-integrated cell phone carriers, WISPs, Rural LECs and muni- or community WiFi networks, could help to substantially increase middle-mile options in areas across the country.

• ARRA Broadband Mapping Should Include a Mapping of Public Spectrum Capability

NAF et al. recommends the Commission perform an Inventory of the Airwaves that maps how our public spectrum resource is being utilized or underutilized in various bands, by both commercial and government users.  Actual spectrum measurement data should be included in this White House-led initiative.  The Commission could draw upon funding from the American Recovery and Reinvestment Act to complete this inventory. 

• Build on the TV White Space Database to Open Access to Unused and Underutilized Frequency Bands

Although spectrum mapping would greatly facilitate the identification of bands that can be reallocated for more intensive and efficient use, the process of unlocking unused spectrum capacity should begin immediately on a band-by-band basis.  We believe that the most promising mechanism for making substantial new allocations of spectrum available for wireless broadband deployments and other innovation is to leverage the TV Bands Database that will be certified by the FCC for unlicensed access to vacant TV channels.

Together, these recommendations can provide a springboard for expanding high-speed broadband to all communities; benefiting a wide variety of providers, business models, and broadband solutions, while also promoting competition, increased speeds and lower prices, and ensuring the U.S. continues to be a leading innovator in the communication technologies of the 21^st century.

To read the full comments, download the PDF below.