Letters of Support

“The Best Decisions Can Only Be Made When a Wide Range of Quality Data Is Used to Inform the Process”

Excerpt from a letter sent by Governor Jack A. Markell (DE) to FCC Chairman Tom Wheeler:

Thank you for your efforts to try to improve wireless and wireline broadband access throughout the country. I write to you today in regards to the Commission’s Further Notice of Proposed Rulemaking (CFNPR) on business data services (BDS). I wanted to emphasize that as this process develops a new regulatory framework for BDS, it is important to utilize accurate and comprehensive data regarding pricing and availability of broadband within a given geographic area to inform the rulemaking process and ensure that private investment in broadband infrastructure remains strong.

By utilizing appropriate data, the commission would be ensuring it is properly measuring the level of competition for BDS within individual markets. The goal of limiting monopolistic practices is an important one, but it must be coupled with a smart strategy to properly identify when such conditions exist, and to encourage significant levels of additional investment in broadband technologies. To fail to do so risks a solution that is counterproductive to our shared mission of increased broadband access for our citizens.

investinbband“The Best Decisions Can Only Be Made When a Wide Range of Quality Data Is Used to Inform the Process”
READ MORE

Reps. Green and Flores: Federal Telecommunications Regulations Should Incentivize Greater Broadband Investment and Spur Greater Competition

Excerpt from a letter sent by Representative Gene Green (TX) and Representative Bill Flores (TX) to FCC Chairman Tom Wheeler:

We are writing in regards to the Further Notice of Proposed Rulemaking (FNPRM) on business data services (BDS) issued by the Federal Communications Commission on May 2.

Few things are as important in today’s economy as supporting ongoing investment in high speed data infrastructure. Business broadband is a key component for our nation’s economy and the source of tens of thousands of well-paying, middle class jobs around the country. Many services American consumers rely on daily, from connections to smart phones, to financial access at retailers and Automated Teller Machines, or to computer connections in the workplace, are built on top of BDS infrastructure. We are concerned that the Commission’s proposed rulemaking will slow the rate of investment in BDS and harm the services that rely on this critical infrastructure and we urge the FCC adopt final rules that will not reduce investment or deter growing competition in BDS.

investinbbandReps. Green and Flores: Federal Telecommunications Regulations Should Incentivize Greater Broadband Investment and Spur Greater Competition
READ MORE

CBC Letter of Support

Excerpt from a letter sent by members of the Congressional Black Caucus to FCC Chairman Tom Wheeler:

Thank you for your continuing efforts to improve broadband access for all American and to promote competitive broadband markets. We are writing to share our concerns about the FCC’s May 2 Further Notice of Proposed Rulemaking (FNPRM) on Business Data Services (BDS). Millions of consumers depend daily on BDS when they use their smartphone, visit a major retailer, withdraw cash from an ATM machine, or start their workday online. It is an essential service for all communities that rely on a broadband connection to support their business and stay connected. Moreover, the impact on investment to broadband and increased consumer access to technological advancement, including telemedicine and educational opportunities, speak to the need for the Commission to further promote infrastructure investment and not impose obstacles that stifle broadband deployment and adoption in the communities we represent.

investinbbandCBC Letter of Support
READ MORE

Morgan Lewis Competitive Fiber Providers Notice of FCC Ex Parte Meetings

Excerpt from a letter sent by Eric J. Branfman and Joshua M. Bobeck of Morgan Lewis to FCC Secretary Marlene Dortch:

On September 13, 2016, representatives of Lightower Fiber Networks I, LLC (“Lightower”), Lumos Networks Corp. (“Lumos”) and Unite Private Networks, LLC (“UPN”) (collectively, the “Competitive Fiber Providers”), along with Joshua M. Bobeck and the undersigned of Morgan Lewis, held separate meetings with (1) Commissioner Michael O’Rielly and Amy Bender, Legal Advisor; (2) Travis Litman, Legal Advisor to Commissioner Jessica Rosenworcel, (3) Nicholas Degani, Legal Advisor to Commissioner Ajit Pai; (4) Claude Aiken, Legal Advisor to Commissioner Mignon Clyburn and (5) Ambassador Philip Verveer, Senior Counsel to Chairman Tom Wheeler. The Competitive Fiber Provider representatives that participated in each of these meetings were Rob Shanahan, President & Chief Executive Officer, Eric Sandman, Chief Financial Officer, and David Mayer, Executive Vice President & General Counsel of Lightower, Timothy Biltz, President & CEO of Lumos and Jason Adkins, President of UPN.

investinbbandMorgan Lewis Competitive Fiber Providers Notice of FCC Ex Parte Meetings
READ MORE

CenturyLink: FCC Should Reject the Verizon-INCOMPAS Proposal

Excerpt from a letter sent by Melissa Newman, Vice President-Federal Regulatory Affairs of CenturyLink, to FCC Secretary Marlene Dortch:

CenturyLink and others have identified numerous flaws in the Verizon-INCOMPAS proposed framework for resolving the above-referenced proceedings. A recent filing by Verizon in another docket further demonstrates how unsound and unreliable that proposal is. In support of its proposed acquisition of XO Communications, Verizon submitted an economic study entitled “Whitepaper on the effect of Verizon’s XO acquisition on business data services.” The Whitepaper, prepared several months after Verizon and INCOMPAS first announced their strategic alliance, undermines the factual premises of the Verizon-INCOMPAS proposal. In stark contrast to the dour portrayal of competition that Verizon and INCOMPAS have advanced to justify their draconian regulatory proposals concerning business data services (“BDS”), the Whitepaper highlights the intense competition in the BDS marketplace. As such, the Whitepaper further highlights the points that CenturyLink and others (including Verizon, earlier this year) have been making throughout this proceeding, and undermines any claim that the Verizon-INCOMPAS proposal is an appropriate basis for regulatory action.

investinbbandCenturyLink: FCC Should Reject the Verizon-INCOMPAS Proposal
READ MORE