The New America Foundation’s Open Technology Initiative (OTI) submits comments regarding the Commission’s broadband policy study conducted by the Berkman Center for Internet and Society. OTI applauds the Commission efforts to examine key telecommunication and Internet policies in other advanced nations and believe the draft report provides vital insights into important strategies and policies that can be utilized in the Commission’s forthcoming National Broadband Plan.

Among the countries the Berkman study points to as an exemplar for the U.S. is Japan, where its policy framework and e-Japan strategies successfully have made it one of the most technologically advanced countries.

In this brief comment, OTI seeks to supplement the findings of the draft Berkman study and add to the proceeding additional specifics regarding Japan’s open access policies as well as other policies that have allowed Japan to become a international broadband leader. These include:

• Open access and interconnection rules for fixed-line broadband services

• Wholesale access and interconnection requirements for mobile broadband operators

• Open access to public and private infrastructures such as conduits and tunnels

• Grant funding for open municipal fiber networks.

OTI believes that it would be beneficial for the Commission to seriously consider these policies as part of developing a national broadband plan.