WCAI Promotes Universal Wireless Broadband Access in Comments on ARRA Broadband Initiatives

As part of our mission to promote universal wireless broadband access in the United States, we at WCAI today submitted two separate sets of comments with the NTIA/RUS and the FCC to assist the Agencies in implementation of the American Recovery and Reinvestment Act’s broadband initiatives.

Because mobile wireless broadband service is a separate product market, WCAI urged NTIA to define areas in which mobile wireless broadband service is unavailable as “unserved,” even if fixed broadband is available. In this proceeding there seems to be a misperception that, with the advent of IP-enabled services, all communications services now participate in a single ‘broadband’ product market. During the roundtable phase of the public comment period, many commenters appeared to assume that the only differentiator of broadband services is speed. However, the differences between wireless and wired networks are more than purely technical or speed-related – the ability of wireless networks to offer mobility places mobile wireless broadband in an entirely separate product market.

Fortunately, there is no need for the Agencies to define the relevant broadband product markets anew to implement the ARRA. The FCC has already delineated between mobile and fixed broadband product markets in the context of its orders addressing various merger and other transactions. The Agencies should rely on this body of precedent when implementing the ARRA.

Other WCAI recommendations include:

• The Agencies should consider separate speeds for mobile wireless broadband networks.
• NTIA should define areas in which mobile wireless broadband service capable of delivering at least 3 mbps downlink and 768 kbps uplink speeds is unavailable as “underserved.”
• The Agencies should reject requests to limit initial rounds of funding to “unserved” areas only and instead consider both “unserved” and “underserved” areas simultaneously.
• Projects that receive funding should represent the optimal mix of capabilities and cost.
• The Agencies should provide funding to “middle mile” only projects where appropriate, because delivering broadband to end users often requires a complementary backhaul solution.
• The Agencies should give substantial consideration to the views of the States, but the Agencies should not delegate wholesale their responsibility to review and rank applications.

WCAI Comments to the National Telecommunications and Information Administration and the Rural Utilities Service: http://www.wcai.com/images/pdf/2009_wcai4-9.pdf.

WCAI Comments to the Federal Communications Commission: http://www.wcai.com/images/pdf/2009_fcc4-9.pdf.

WCAI Applauds FCC Move to Develop National Broadband Plan

The FCC today adopted a notice of inquiry seeking public comment on the national broadband plan that the Commission is required to prepare under the American Recovery and Reinvestment Act of 2009 (ARRA). We at WCAI are pleased to see the FCC take first step in this important process. Wireless broadband platforms should play a leading role in the Commission’s plan to ensure that every American has access to broadband capability. Wireless technology is the most cost-effective way to provide affordable broadband both to sparsely populated rural areas and urban centers. Moreover, as the only broadband platform that is capable of providing access everywhere, all the time, wireless broadband offers mobility – a connection to every person whether at home or on the go. These capabilities make wireless broadband essential to achieving the FCC’s goal of universal broadband connectivity.”