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FCC Bandwidth Forum--January 23, 1997

"Affordable Access--The Three Pillars of Universality"

Peter F. Harter, Global Policy Counsel

Netscape Communications Corporation

I. Overview

Universal Service: Affordable Internet access requires competitive, efficiently priced POTS

Universal Design: Internet services and applications should be accessible to persons with disabilities

Universal Access: Global Internet access requires open, interoperable and competitive international telecommunications regulatory policies

II. Universal Service

Internet is a system of open standards protocols for packet-switched data networking

The Internet "rides on top of" the PSTN; efficient and competitively neutral POTS universal service mechanisms promote universal Internet access

Schools, libraries and health care providers should receive technology neutral subsidies--no "lock in" to rapidly obsolete network or access technologies

Support obligations should also be competitively neutral, requiring ISPs and OSPs to contribute in proportion t their telecommunications revenues

Competitive market opportunities, jump-started by 254(h) subsidies, will unleash technological innovation for K-12 classrooms

Netscape proposal for disaggregation of Internet access (connectivity) from Internet services (enhanced information services) under Section 254(h)

Promotion of high-bandwidth access technologies without discriminating against dial-up K-12 access

Access charges for ISP/OSPs cannot be addressed at least until universal service system for telecom services is reformed

Market competition is better approach to ubiquitous and affordable Internet access than general subsidies for ISPs/OSPs

III. Universal Design

Section 255 requires accessible telecommunications services, equipment and CPE if readily achievable

Universal design policies create new functionalities and markets for telecommunications products and services (e.g., talking Caller ID, payphone volume controls, etc.)

Commission policy should maintain unregulated Computer II treatment of information services while pursuing new policies more suited for digital convergence ("Internet I")

CPE includes telecommunications software applications--software is CPE, not Title II common carriage

American firms and technologies can remain global leaders in product design

Internet technologies allow people with disabilities to communicate in ways that enhance commerce, community and social integration

IV. Universal Access

Foreign PTTs and national telephone monopolies apply telecom pricing and interconnection policies that thwart affordable global access to the Internet

State PUCs apply protectionist, circuit-switched policies (common carrier regulation, taxes, etc.) that impede growth and development of Internet

International telecom organizations (WTO, ITU, etc.) pursue standards favoring circuit-switched technologies and government control of open Internet standards

FCC and U.S. government leadership required to assure:

Competitive market-entry liberalization

Efficiently priced telecom services (loops, dedicated services) used for Internet access

Non-regulation of TCP/IP alternatives to telephone monopolies

De-linking of Internet from use of international telecom "accounting rates" as source of POTS subsidies

Domestic U.S. policies can serve as role model for foreign regulators:

Forebear from common carrier regulation of Internet "telecommunications" applications (ACTA Petition)

Preempt state PUC regulation of Internet services and ISPs/OSPs

Promote competitive, efficient international telecom services and open, non-governmental, "bottoms up" Internet standards

Preliminary White House "GII Framework" meets some of these objectives, but still undermines U.S. international Internet competitiveness

Saturday, November 15, 2008