The Institute for Local Self Reliance has joined with Public Knowledge, Common Cause, and the Open Technology Institute, in submitting reply comments to the FCC last week as the Public Interest Spectrum Coalition (PISC). The issue at hand is the FCC’s proposal of new rules for how to govern the 3.5 GHz band, a range of the electromagnetic spectrum useful for many different types of communication. 

The PISC comment focused on the importance of getting away from the long-standing FCC policy of simply auctioning off big slices of spectrum for telecom companies to use exclusively, which inhibits innovation and enables a monopolization of the communications marketplace. Verizon and AT&T, who hold licenses to large swathes of the spectrum already, are lobbying to FCC to keep the status quo in place. PISC (and ILSR) support a more open arrangement, allowing multiple users to share the same underutilized spectrum segment, while still avoiding interference. The full text of the comment is available here. 

The language and policy of spectrum management can seem arcane to people unaccustomed to it, but how we regulate and use the electromagnetic spectrum has wide ranging consequences for almost all the technology we use in our daily lives. For a general primer on the importance and possibilities of a more open spectrum licensing policy, see the wireless commons articles we published earlier this summer.

You can view the full text of the PISC comment through the link below.

Public Knowledge, The Utility Reform Network (TURN), and a long list of other public interest groups, recently filed a letter with the FCC urging the agency to launch an investigation. Specifically, the alliance asks the FCC to look into reports that Verizon is forcing customers to move from copper lines to fiber IP-based service. From the letter:

The Commission must begin investigating this issue quickly, lest inaction send carriers the message that abandoning customers in violation of their legal obligations is acceptable. Delay will only lead to carriers hanging up on more customers at a time when basic communications service is more important than ever.

In California, New York, New Jersey, and DC, large corporate carriers such as Verizon, AT&T, and Frontier are not maintaining traditional copper lines. Public Knowledge and TURN note in their letter that in Maryland, the state's Office of the People's Counsel found that "Verizon routinely migrates customers from the copper network to unregulated services with inadequate procedures for customer notice and consent."

We noted last summer that Verizon faced criticism for transitioning residents in the Catskills and in New York City to VoiceLink without disclosing the full limitations of the service. This was the tip of the iceberg. Verizon has failed to repair copper lines when requested. People in some areas of New York City have been told they must upgrade to FiOS in order to get phone service. There are even some customers who have been told they cannot order stand alone telephone service.

Because IP-based services are not yet regulated, carriers will not be obliged to provide services to everyone or to maintain communications infrastructure as they must with copper lines. 

The full text of the letter [PDF] and exhibits [PDF] provide details on Verizon's purposeful neglect of existing copper lines, customer service tactics to push customers on to IP services, and more about the company's nation-wide strategy. From the letter:

Public Knowledge, The Utility Reform Network (TURN), and a long list of other public interest groups, recently filed a letter with the FCC urging the agency to launch an investigation. Specifically, the alliance asks the FCC to look into reports that Verizon is forcing customers to move from copper lines to fiber IP-based service. From the letter:

The Commission must begin investigating this issue quickly, lest inaction send carriers the message that abandoning customers in violation of their legal obligations is acceptable. Delay will only lead to carriers hanging up on more customers at a time when basic communications service is more important than ever.

In California, New York, New Jersey, and DC, large corporate carriers such as Verizon, AT&T, and Frontier are not maintaining traditional copper lines. Public Knowledge and TURN note in their letter that in Maryland, the state's Office of the People's Counsel found that "Verizon routinely migrates customers from the copper network to unregulated services with inadequate procedures for customer notice and consent."

We noted last summer that Verizon faced criticism for transitioning residents in the Catskills and in New York City to VoiceLink without disclosing the full limitations of the service. This was the tip of the iceberg. Verizon has failed to repair copper lines when requested. People in some areas of New York City have been told they must upgrade to FiOS in order to get phone service. There are even some customers who have been told they cannot order stand alone telephone service.

Because IP-based services are not yet regulated, carriers will not be obliged to provide services to everyone or to maintain communications infrastructure as they must with copper lines. 

The full text of the letter [PDF] and exhibits [PDF] provide details on Verizon's purposeful neglect of existing copper lines, customer service tactics to push customers on to IP services, and more about the company's nation-wide strategy. From the letter:

Public Knowledge, The Utility Reform Network (TURN), and a long list of other public interest groups, recently filed a letter with the FCC urging the agency to launch an investigation. Specifically, the alliance asks the FCC to look into reports that Verizon is forcing customers to move from copper lines to fiber IP-based service. From the letter:

The Commission must begin investigating this issue quickly, lest inaction send carriers the message that abandoning customers in violation of their legal obligations is acceptable. Delay will only lead to carriers hanging up on more customers at a time when basic communications service is more important than ever.

In California, New York, New Jersey, and DC, large corporate carriers such as Verizon, AT&T, and Frontier are not maintaining traditional copper lines. Public Knowledge and TURN note in their letter that in Maryland, the state's Office of the People's Counsel found that "Verizon routinely migrates customers from the copper network to unregulated services with inadequate procedures for customer notice and consent."

We noted last summer that Verizon faced criticism for transitioning residents in the Catskills and in New York City to VoiceLink without disclosing the full limitations of the service. This was the tip of the iceberg. Verizon has failed to repair copper lines when requested. People in some areas of New York City have been told they must upgrade to FiOS in order to get phone service. There are even some customers who have been told they cannot order stand alone telephone service.

Because IP-based services are not yet regulated, carriers will not be obliged to provide services to everyone or to maintain communications infrastructure as they must with copper lines. 

The full text of the letter [PDF] and exhibits [PDF] provide details on Verizon's purposeful neglect of existing copper lines, customer service tactics to push customers on to IP services, and more about the company's nation-wide strategy. From the letter:

Public Knowledge, The Utility Reform Network (TURN), and a long list of other public interest groups, recently filed a letter with the FCC urging the agency to launch an investigation. Specifically, the alliance asks the FCC to look into reports that Verizon is forcing customers to move from copper lines to fiber IP-based service. From the letter:

The Commission must begin investigating this issue quickly, lest inaction send carriers the message that abandoning customers in violation of their legal obligations is acceptable. Delay will only lead to carriers hanging up on more customers at a time when basic communications service is more important than ever.

In California, New York, New Jersey, and DC, large corporate carriers such as Verizon, AT&T, and Frontier are not maintaining traditional copper lines. Public Knowledge and TURN note in their letter that in Maryland, the state's Office of the People's Counsel found that "Verizon routinely migrates customers from the copper network to unregulated services with inadequate procedures for customer notice and consent."

We noted last summer that Verizon faced criticism for transitioning residents in the Catskills and in New York City to VoiceLink without disclosing the full limitations of the service. This was the tip of the iceberg. Verizon has failed to repair copper lines when requested. People in some areas of New York City have been told they must upgrade to FiOS in order to get phone service. There are even some customers who have been told they cannot order stand alone telephone service.

Because IP-based services are not yet regulated, carriers will not be obliged to provide services to everyone or to maintain communications infrastructure as they must with copper lines. 

The full text of the letter [PDF] and exhibits [PDF] provide details on Verizon's purposeful neglect of existing copper lines, customer service tactics to push customers on to IP services, and more about the company's nation-wide strategy. From the letter:

Public Knowledge, The Utility Reform Network (TURN), and a long list of other public interest groups, recently filed a letter with the FCC urging the agency to launch an investigation. Specifically, the alliance asks the FCC to look into reports that Verizon is forcing customers to move from copper lines to fiber IP-based service. From the letter:

The Commission must begin investigating this issue quickly, lest inaction send carriers the message that abandoning customers in violation of their legal obligations is acceptable. Delay will only lead to carriers hanging up on more customers at a time when basic communications service is more important than ever.

In California, New York, New Jersey, and DC, large corporate carriers such as Verizon, AT&T, and Frontier are not maintaining traditional copper lines. Public Knowledge and TURN note in their letter that in Maryland, the state's Office of the People's Counsel found that "Verizon routinely migrates customers from the copper network to unregulated services with inadequate procedures for customer notice and consent."

We noted last summer that Verizon faced criticism for transitioning residents in the Catskills and in New York City to VoiceLink without disclosing the full limitations of the service. This was the tip of the iceberg. Verizon has failed to repair copper lines when requested. People in some areas of New York City have been told they must upgrade to FiOS in order to get phone service. There are even some customers who have been told they cannot order stand alone telephone service.

Because IP-based services are not yet regulated, carriers will not be obliged to provide services to everyone or to maintain communications infrastructure as they must with copper lines. 

The full text of the letter [PDF] and exhibits [PDF] provide details on Verizon's purposeful neglect of existing copper lines, customer service tactics to push customers on to IP services, and more about the company's nation-wide strategy. From the letter:

Public Knowledge, The Utility Reform Network (TURN), and a long list of other public interest groups, recently filed a letter with the FCC urging the agency to launch an investigation. Specifically, the alliance asks the FCC to look into reports that Verizon is forcing customers to move from copper lines to fiber IP-based service. From the letter:

The Commission must begin investigating this issue quickly, lest inaction send carriers the message that abandoning customers in violation of their legal obligations is acceptable. Delay will only lead to carriers hanging up on more customers at a time when basic communications service is more important than ever.

In California, New York, New Jersey, and DC, large corporate carriers such as Verizon, AT&T, and Frontier are not maintaining traditional copper lines. Public Knowledge and TURN note in their letter that in Maryland, the state's Office of the People's Counsel found that "Verizon routinely migrates customers from the copper network to unregulated services with inadequate procedures for customer notice and consent."

We noted last summer that Verizon faced criticism for transitioning residents in the Catskills and in New York City to VoiceLink without disclosing the full limitations of the service. This was the tip of the iceberg. Verizon has failed to repair copper lines when requested. People in some areas of New York City have been told they must upgrade to FiOS in order to get phone service. There are even some customers who have been told they cannot order stand alone telephone service.

Because IP-based services are not yet regulated, carriers will not be obliged to provide services to everyone or to maintain communications infrastructure as they must with copper lines. 

The full text of the letter [PDF] and exhibits [PDF] provide details on Verizon's purposeful neglect of existing copper lines, customer service tactics to push customers on to IP services, and more about the company's nation-wide strategy. From the letter:

The proposed Comcast/Time Warner Cable deal will be on everyone's mind for many months to come. Thanks to Harold Feld, it is now possible to follow the process as it moves forward. Feld began a series of posts earlier this month that map out the review as it moves from the Department of Justice Antitrust Division to the Federal Communications, and finally to Congress. As Feld notes, the entire process will last six months at least and could run for more than a year. 

In addition to drawing a process map, Feld provides insightful subtleties on the purpose behind each step in the review. He also offers political analysis that may influence the outcome. Feld gets into the unique review process, burdens of proof, and relevant definitions at each stop along the way. Highly recommended, especially for law students.

Part I - Introduction

Part II - Antitrust Review at the DOJ

Part III - Federal Communications Commission analyzes public interest

Part IV - The proposal moves through the committee process and the public has a chance to express themselves to their elected officials (including lobbyists)

The proposed Comcast/Time Warner Cable deal will be on everyone's mind for many months to come. Thanks to Harold Feld, it is now possible to follow the process as it moves forward. Feld began a series of posts earlier this month that map out the review as it moves from the Department of Justice Antitrust Division to the Federal Communications, and finally to Congress. As Feld notes, the entire process will last six months at least and could run for more than a year. 

In addition to drawing a process map, Feld provides insightful subtleties on the purpose behind each step in the review. He also offers political analysis that may influence the outcome. Feld gets into the unique review process, burdens of proof, and relevant definitions at each stop along the way. Highly recommended, especially for law students.

Part I - Introduction

Part II - Antitrust Review at the DOJ

Part III - Federal Communications Commission analyzes public interest

Part IV - The proposal moves through the committee process and the public has a chance to express themselves to their elected officials (including lobbyists)

The proposed Comcast/Time Warner Cable deal will be on everyone's mind for many months to come. Thanks to Harold Feld, it is now possible to follow the process as it moves forward. Feld began a series of posts earlier this month that map out the review as it moves from the Department of Justice Antitrust Division to the Federal Communications, and finally to Congress. As Feld notes, the entire process will last six months at least and could run for more than a year. 

In addition to drawing a process map, Feld provides insightful subtleties on the purpose behind each step in the review. He also offers political analysis that may influence the outcome. Feld gets into the unique review process, burdens of proof, and relevant definitions at each stop along the way. Highly recommended, especially for law students.

Part I - Introduction

Part II - Antitrust Review at the DOJ

Part III - Federal Communications Commission analyzes public interest

Part IV - The proposal moves through the committee process and the public has a chance to express themselves to their elected officials (including lobbyists)