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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