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This document is also available in PDF Format.
July 18, 2007
The Honorable Kevin J. Martin
Chairman
Federal Communications Commission
445 12th St., SW
Washington, DC 20554
Re: Joint Filing of Technology Sector Organizations and Public Interest Organizations Concerning Open Access;
WT Docket Nos. 96-86 and 06-150; PS Docket No. 06-229.
Dear Chairman Martin:
This filing is also available in PDF
Format.
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Broadband Industry Practices
WC Docket No. 07-52
To: The Commission
Reply Comments of Public Knowledge, et al.
The full filing is available in PDF format.
In the matter of:
Service Rules for the 698-746, 747-762, and 777-792 MHz Bands:
WT Docket No. 06-150
Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHz Band:
PS Docket No. 06-229
Implementation of the Commercial Spectrum Enhancement Act and Modernization of the Commission's Competitive Bidding Rules and Procedures:
WT Docket No. 05-211
Development of Operational, Technical, and Spectrum Requirements for Meeting Federal, State and Local Public Safety Communications Requirements Through 2010:
WT Docket No. 96-86
SUMMARY
The Ad Hoc Public Interest Spectrum Coalition (PISC) applauds the Commission for including issues raised by PISC in the initial comment period.
The United States continues to fall further behind the rest of the world in broadband Internet access -- our markets lack the competition necessary to serve consumers with lower prices, faster speeds and universal access. Even as the broadband market has further consolidated -- leaving 96% of the market in the hands of two technologies -- our policy framework has only served to diminish opportunities for competition. The auction of the 700 MHz spectrum creates a new possibility for competitive broadband provision. It is imperative that we learn the lessons of the wireline market and make the appropriate policy corrections in the launch of the most promising wireless broadband markets.
The Commission simply cannot choose to let current market conditions and participants control the outcome of the upcoming auctions. To date, existing wireless broadband providers do not offer a useful "third pipe" for American consumers. Perhaps most importantly, this market for broadband capable mobile devices is dominated by the same incumbent firms that control the wireline broadband market. These incumbents make clear that they have no intention of offering broadband with the freedom to attach any device and run any application.
To foster real wireless broadband -- the fast, ubiquitous, and dynamic third pipe everyone agrees our country desperately needs -- PISC recommends that the Commission take the following steps both to ensure that new spectrum is offered on an open and nondiscriminatory basis and to bring in new entrants interested in challenging the current cozy wireless oligopoly and broadband duopoly:
The full comments are available in PDF format.
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of
Skype Communications S.A.R.L.
Petition to Confirm a Consumer's
Right to Use Internet Communications
Software and Attach Devices
To Wireless Networks
Docket: RM-11361
The Ad Hoc Public Interest Spectrum Coalition (PISC) file these comments in support of the Petition filed by Skype Communications to apply the Carterfone principles to wireless services. The undersigned concur in Skype's finding that carriers are harming consumers with restrictive practices. Carriers are leveraging their dominant position in wireless service and retail handset markets to engage in unsavory and anticompetitive practices that maximize their profits at the cost of reducing consumer welfare.
The complete filing is available in PDF Format
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of
Service Rules for the 698-746, 747-762, and 777-792 MHZ Bands (WT Docket No. 06-150.)
Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHZ Band (PS Docket No. 06-229.)
Implementation of the Commercial Spectrum Enhancement Act and Modernization of the Commission's Competitive Bidding Rules and Procedures (WT Docket No. 05-211.)
Development of Operational, Technical, and Spectrum Requirements for Meeting Federal, State and Local Public Safety Communications Requirements Through 2010 (WT Docket No. 96-86.)
To: The Commission:
Consumer Federation of America, Consumers Union, Free Press, Media Access Project, New America Foundation and Public Knowledge (collectively referred to here as the "Public Interest Spectrum Coalition" or "PISC"), file these ex parte comments urging the Federal Communications Commission ("FCC" or "Commission") to condition the award of licenses for at least half of the 700 MHz band on the licensees' compliance with open access principles. The auction of licenses in the 700 MHz band is a unique and critical opportunity to bring broadband to American consumers and open an avenue for competitive broadband providers. It is without question the best opportunity to open a legitimate "third pipe" for consumer broadband connectivity--long a goal of the Commission. Given the state of the market failure in US broadband and our unenviable position relative to international performance in broadband connections, a pro-competitive policy in the 700 MHz auction is imperative. The undersigned public interest groups urge the FCC to adopt our recommendations in order to maximize the opportunities for new, competitive entrants and promote greater broadband access in the United States. We recommend that the FCC require that a portion of the auctioned licenses be subject to a service condition of open access. This will create a competitive retail market for wireless broadband services in a national marketplace. It will bring innovative, competitive providers into the market that would otherwise never appear.
preserves
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