Letters of Support

CWA: FCC’s Proposal Will Have a Negative Impact on Jobs and Workers’ Living Standards

Excerpt from a letter sent by Christopher M. Shelton, President of the Communications Workers of America (CWA), to FCC Chairman Tom Wheeler:

The Communications Workers of America (CWA) represents thousands of employees who build and service the networks over which incumbent carriers provide business data services. The outcome of the Commission’s current rulemaking on Business Data Services (also called “special access”) has huge implications for good jobs and investment, particularly in rural areas.

investinbbandCWA: FCC’s Proposal Will Have a Negative Impact on Jobs and Workers’ Living Standards
READ MORE

NCTA: Verizon/INCOMPAS Proposal “Will Hamper New Investment” and Undermine Competition

Excerpt from a letter sent by Steven F. Morris of National Cable & Telecommunications Association (NCTA) to FCC Secretary Marlene Dortch:

As the record in the Commission’s special access/business data services (BDS) proceeding continues to grow, it is becoming more and more apparent that concepts included in the Verizon/INCOMPAS proposal are completely unsupported by the evidence and should not be adopted by the Commission. Specifically, key principles outlined in that proposal, including application of the same regulatory framework to all BDS providers regardless of their market power and imposition of onerous ex ante rate regulation on BDS providers in virtually every census block in the country, have been thoroughly refuted on legal, policy and economic grounds.

investinbbandNCTA: Verizon/INCOMPAS Proposal “Will Hamper New Investment” and Undermine Competition
READ MORE

USTA Warns FCC Action ‘Will Raise Costly Barriers to Investment and Innovation’

Excerpt from a letter sent by Jonathan Banks and Diane Griffin Holland of United States Telecom Association to FCC Secretary Marlene Dortch:

The Commission’s business data services (BDS) data show with relative clarity where competitors are and how far their competitive influence on pricing extends. We have built a test based on that evidence. The test proposes that the FCC step back from dictating prices for BDS services wherever two competitors exert competitive discipline over pricing. The Commission has already concluded that competitors at a distance of up to one-half mile (2,640 feet) have a material influence on pricing. Because there are over 1 million BDS locations, we have devised a simplified, but extremely accurate way to test for competitive influence consistent with that conclusion.

investinbbandUSTA Warns FCC Action ‘Will Raise Costly Barriers to Investment and Innovation’
READ MORE

Rainbow PUSH Coalition Urges FCC to Consider Unintended Consequences of Final Rulemaking Affecting the “Business Data Services” Market

Excerpt from a letter sent by Reverend Jesse L. Jackson, Sr., Founder & President of Rainbow PUSH Coalition, to FCC Chairman Tom Wheeler:

On behalf of the Rainbow PUSH Coalition, we urge the Commission to consider the unintended consequences of any final rulemaking affecting the “Business Data Services” (BDS) market. We respectfully request the Commission to consider its impact on American workers and small business, from whom the lifeblood of our
economy flows. As an organization committed to these entities, we have a very distinct interest in this matter.

investinbbandRainbow PUSH Coalition Urges FCC to Consider Unintended Consequences of Final Rulemaking Affecting the “Business Data Services” Market
READ MORE

Southern Christian Leadership Conference Letter to FCC

Excerpt from a letter sent by Dr. Charles Steele, Jr, President/CEO of the Southern Christian Leadership Conference, to FCC Chairman Tom Wheeler:

On behalf of the Southern Christian Leadership Conference, we urge the Commission to consider the unintended consequences of any final rulemaking affecting the “Business Data Services” (BDS) market. We respectfully request the Commission consider its impact on American workers and small business, from whom the lifeblood of our economy flows. As we prepare to celebrate the 50th Anniversary of Dr. King’s Poor Peoples’ Campaign, we are working tirelessly to make sure our voices are heard on any issue that affects the ability of Americans to participate in this economy and pull themselves out of poverty.

investinbbandSouthern Christian Leadership Conference Letter to FCC
READ MORE