Groups Offer Support, Ideas in Comment on FCC Strategic Plan

The plan outlined 6 general goals: (1) Affordable access to broadband. (2) Competition. (3) Efficient spectrum use. (4) Media regulations promoting competition and facilitating transition to digital. (5) Reliable, interoperable public safety communications. (6) Modernizing agency operations.

Commenters generally supported the goals but often cast that support in terms of how their pet regulatory proceedings could further the goals. The Satellite Industry Assn. said FCC action “to facilitate the continued development of satellite communications” could help achieve most of the goals. “Satellites will play an essential role in helping the Commission achieve its goals,” SIA said. “Unfortunately, in recent years, the Commission has reallocated critical spectrum used for satellite communications, including spectrum that the Commission had specifically identified as essential for broadband for rural America and for public safety users.” TerreStar, which is developing a satellite/terrestrial mobile satellite service said its system “will contribute uniquely to the Commission’s ability to realize four crucial goals set out by the strategic plan” -- broadband, competition, spectrum efficiency and public safety. TerreStar is seeking a spectrum assignment for the service.

The National Telecom Co-op Assn. (NTCA) and Harris Corp. urged additions to the FCC plan. NTCA said the Commission should add “universal service” to its agenda and add language to the spectrum category ensuring wireless carriers serving rural areas gain access to spectrum. Harris said the FCC should include cybersecurity as a homeland security objective: “Harris supports the Commission’s objectives in the homeland security arena especially as they relate to developing policies that promote access to effective communications services in emergency situations [but] Harris believes that securing the Internet by incorporating cybersecurity into the Commission’s homeland security objectives is important as well.” Harris also urged the FCC to “include coordination with foreign governments and international entities as a critical component of the homeland security objectives.”

The National Assn. of State Utility Commission Advocates (NASUCA) said the FCC goals should stress consumer needs: “The perspective should not be primarily driven by the business plans of service providers, whether large or small.”

The National Council on Disability (NCD), a U.S. agency that advises the President and Congress, said it wants more “vigor in FCC’s enforcement and… monitoring” of disability access rules. NCD said it also is “concerned that captioning may be undermined by concerns about its accuracy and quality.” The FCC should act soon on a petition by advocacy groups raising questions about captioning quality, NCD said.

Cingular Wireless said the FCC should follow 3 “guiding principles” to meet its goals: (1) “Imposing regulations only when there is an identifiable market failure.” (2) “Providing regulatory certainty by guaranteeing incumbent licensee rights and providing consistent protection from harmful interference.” (3) “Protecting public safety and homeland security by ensuring that safety-related communications systems have access to dedicated public safety spectrum and protecting the ability of commercial services to provide important public safety services such as E-911 and Wireless Priority Service.”

CTIA pushed for federal regulation of wireless service, urging the Commission “to consider the importance of exclusive use licensing in promoting efficient use of spectrum.” It suggested the FCC, when coordinating with other agencies on public safety and homeland security “explore ways to encourage government agencies to take advantage of the vibrant and diverse market for commercial wireless services.”

Verizon said the FCC ought to expand its strategic plan by identifying “the remaining actions that it will take to accomplish those goals,” including broadband deployment by 2007. “This should include the prompt elimination of the remaining unnecessary economic regulations for all broadband services, regardless of whether they are used to provide Internet access,” Verizon said.

Kyle Dixon, Progress & Freedom Foundation senior fellow, said in a blog Fri. the comments were “as unsurprising as they may be unhelpful in the long run.” Dixon said as would be expected “parties did a good job of defending their regulatory interests… but they failed to shed much light on how the FCC can cope with, or, better yet, conquer the challenges of regulating in the digital age.” He said it might be more useful for commenters to take a page from management theory such as the field of “organization development” by focusing on how the FCC could be more effective.