ILSR submitted comments to the National Telecommunications and Information Administration (in the Department of Commerce) and the Rural Utilities Service regarding the Broadband Technology Opportunies Program – a program established by the stimulus package to distribute grants to build information networks and expand broadband networks.
We encourage the agencies to prioritize local networks that are accountable to the public. Public money should go to networks that are open to multipe competitors, where the network owner cannot monopolize services and access to subscribers.
To the greatest extent possible, BTOP should fund common carriage networks, which will facilitate competition by allowing multiple competing service providers to offer services over the same infrastructure. These projects offer more value for taxpayer money because competition ensures a higher level of service than would result from a monopolistic service provider, even one that does not engage in network discrimination.
Some networks (Burlington Vermont and Ashland Oregon) already abide by this commitment and other network builders support such a provision. As NTIA and RUS have far fewer funds than applicants, public money should go first to those who will maximize societal benefits by committing to common carriage principles.
Additionally, the program should require networks that can transmit at a minimum of 10Mbps in both directions.
Applicants should be able to demonstrate that they can scale up the network to 100Mbps per connection in the near future as experts agree that bandwidth needs are greatly increasing due to new applications and increased video services (including HD content from Internet sites). Any given connection is likely to support several devices, from TiVo’s that download video podcasts, to laptops using videochat, to specialized devices for telemedicine.
Buffed up DSL networks offering a 10:1 asymmetrical connection are not long-term investments. They are quickly becoming the new dialup. Cable companies are increasingly capping bandwidth usage – not because of the cost incurred by moving bits, but out of a recognition that they can no longer deliver promised speeds to subscribers on their aging infrastructures.
When using public money to build networks, we have an obligation to invest wisely. We should invest in fiber-optic networks, not obsolete technologies like DSL or last generation cable networks. Further, the grants should go to entities that are directly accountable to the community.
