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FCC Comments regarding a National Broadband Plan for our Future

Submission Date: 
06/08/2009

I. Introduction.

In this proceeding, the Commission can build upon its analysis in its recent Report on a Rural Broadband Strategy, and draft a National Broadband Plan that will enable the universal availability of reliable, reasonably priced high-speed broadband service. In doing so, the Commission must ensure such a plan addresses the experiences of ACA members. As shown in these comments, ACA members are ideally positioned to help achieve the government's goals, particularly in the rural areas ACA members already serve.

Therefore, ACA recommends that the National Broadband Plan address the following seven points:

  • The need of broadband providers to have non-discriminatory access to all web-based content and services at reasonable rates, terms, and conditions.
  • The need of broadband providers to have non-discriminatory access to middle mile infrastructure at reasonable and non-discriminatory special access rates, terms, and conditions.
  • The need of broadband providers to have non-discriminatory access to pole attachments at reasonable and non-discriminatory rates, terms, and conditions.
  • The need for the Commission and other agencies to freeze or reduce regulatory fees on smaller operators.
  • The need to mitigate the harms caused to broadband providers who are also cable operators by the current wholesale practices of programmers nd broadcasters.
  • The need for a complete national broadband map that includes an inventory of all existing "last mile" and "middle mile" infrastructure.
  • The need for any Broadband Universal Service Fund ("USF") programĀ  adopted to be separate from the existing USF high cost program, and for cable operators to have equal access to the funds.
  • The need to apply only the four principles identified by the Commission in its 2005 Broadband Policy Statement.

In short, these comments demonstrate the steps the Commission must take to enable the nationwide availability of reliable, high-speed Internet access at reasonable prices.

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090608 ACA Comments National Broadband Plan NOI Dkt GN 09-51 FINAL.pdf62.15 KB

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