The FCC’s NOI lists hundreds of questions and areas of investigation considered by the FCC to support the development of a nationwide broadband strategy.

The scope of the questions offered in the NOI are breath taking.  Even the discussion of how to define broadband is complex.  As a first step the questions,

…the Commission currently uses the terms “advanced telecommunications capability,” “broadband,” and “high-speed Internet.” Should these definitions be unified, or should they have separate meanings for different purposes, keeping in mind that current and future broadband platforms will increasingly support “high-speed Internet” as one of several offered services including voice, video, private data applications, and the like?

and these

…should a different set of standards be used to identify mobile broadband services which allow mobility or portability but may have lower throughputs – and fixed broadband services? Should the definitions vary depending on whether the broadband service is used to serve residential or business customers and if so, how?

hint the complexity of ensuring semantic precision as required for rule making or regulation. Most of us have a shared understanding based upon common knowledge or perhaps marketing definitions of what is meant by broadband or high-speed Internet.  Of course, no one will go to court over the phrases used in various articles or conservations.

The Plan lists 12 policy goals of a national strategy.

1. Advancing Consumer Welfare
2. Civic Participation
3. Public Safety and Homeland Securtiy
4. Community Development
5. Health Care Delivery
6. Energy Independence and Efficiency
7. Education
8. Worker Training
9. Private Sector Investment
10. Entrepreneurial Activity
11. Job Creation and Economic Growth
12. Other National Purposes

Beyond the policy goals the NOI addresses various network technologies including  satellite, WiMAX, LTE, and fiber along with the availability of the new white spaces spectrum.  The focus of questions concerning specific technologies and this new spectrum availability is the role these networks can play in “ensuring access” to broadband for rural areas or areas where competition is limited.

The FCC also announces in the NOI plans for a comprehensive data collection effort to assess the true availability of broadband in the US. Previous and current data relies upon service providers to provide the FCC with self-determined metrics on the availability of broadband and high-speed Internet access. The methods used by ISPs to measure access has come under fire from a number of consumer and public interest groups.  It is critical that astroturf organizations like Connected Nation are balanced by response and data efforts which are independent. Connected Nation is campaigning through the comments process at both the FCC and the NTIA which is responsible for a large portion of the $7.2 billion broadband stimulus outlay.

There are so many areas to contribute through the FCC’s comment process that everyone – especially those in the technology industry and the new media industry must participate.  Independents and entrepreneurs have a direct stake in helping the FCC meet it’s goals to provide Congress with a National Broadband Plan that recognizes new economic realities of innovation coming from the network’s edge rather than just being broadcast out to the edge. The Plan recognizes this in part by covering “Entrepreneurial Activity as one of the commission’s policy goals.

Below are examples of comments to the FCC.  Simple position statements like “We must have Net Neutrality” while can achieve weight is received from tens of thousands of individuals likely wouldn’t receive the same level of attention and consideration from the commissioners as a thoughtful and substantive response.  This point was made clear in a recent interview with Kevin Werbach who has been a recipient of these communications when he served at the FCC in the mid 1990s.

The full interview with Werbach will be posted as a podcast on mobilejones.com this weekend.  Other interviews are also coming from those with a unique perspective on the importance of the FCC’s work to establish the National Broadband Plan.

FCC Comment

Organization: New America Foundation

Leadership:  Eric Schmidt, CEO Google

Comments on Rural Broadband Strategy

FCC Comment

Organization: Connected Nation

Leadership: ATT, National Cable and Telecommunications Assoc., CTIA – The Wireless Assoc., United States Telecom Assoc., Verizon, Comcast and others.