Promote Investment and Good Jobs in the Telecom Industry

The Communications Workers of America submitted the following comment to the Federal Communications Commission in October 2009 in response to the FCC's plans to regulate the telecommunications industry under the auspices of "net neutrality":

The Commission has announced that it will issue at its next open meeting a Notice of Proposed Rulemaking (NPRM) on policies to preserve a free and open Internet.

The Commission undertakes this rulemaking at a time of 10 percent unemployment. The Commission must ensure that this rulemaking does not have an adverse impact on investment and job creation in what continues to be one of the few dynamic sectors in an otherwise dismal economy.
We cannot afford a repeat of the near-freeze on capital investment by telecom companies that took place in the early part of this decade in response to a regulatory framework that ignored market realities. We are still paying for that decline as we play catch up to other nations in high-speed broadband deployment.

It is imperative that the Commission begin this rulemaking process with an NPRM that encourages thoughtful dialogue. The NPRM should lead to reasoned discussion among all stakeholders about the technical requirements of network management and the economics of broadband build-out to ensure continued private sector investment in advanced high-speed Internet networks while protecting an open Internet.

CWA was initially encouraged by the balanced approach Chairman Genachowski articulated in his Brookings speech. But we are concerned about what we are hearing will be the starting point for discussion in the open Internet NPRM. Proposed rules that take an extreme position will discourage the reasoned dialogue that is necessary to achieve an appropriate balance between openness and investment.

We know that private capital will build next-generation wireline and wireless networks, and create and maintain jobs in the industry.  A comparison of two market leaders is instructive.  Despite the fact that Google has a larger market cap than AT&T, Google employs 10 times fewer people. Google invests 1/10 the capital in the infrastructure America needs for high speed broadband.  

In its recent status report, the Commission’s Broadband Task Force showed that private investment, plus Universal Service Funds, plus stimulus dollars fall short of Congressional objectives.  The investments made by the top network providers in 2008 ($63 billion) are five times as much as the federal programs combined. It is crucial that the Commission support the right policy mix of incentives to sustain and enhance these investments that are so critical to America’s future.

(Read the whole pdf document by clicking on the link below)