FR-5890–P–01 Narrowing the Digital Divide Through Installation of Broadband Infrastructure in HUD- Funded New Construction and Substantial Rehabilitation of Multifamily Rental Housing
2016-07-20 2016-07-20 2016-07-18 2016-07-20 2016-07-12 2016-07-20
HUD-2016-0050-0021 HUD-2016-0050-0009 HUD-2016-0050-0007 HUD-2016-0050-0014 HUD-2016-0050-0004 HUD-2016-0050-0020
04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00
https://api.regulations.gov/v4/comments/HUD-2016-0050-0021 https://api.regulations.gov/v4/comments/HUD-2016-0050-0009 https://api.regulations.gov/v4/comments/HUD-2016-0050-0007 https://api.regulations.gov/v4/comments/HUD-2016-0050-0014 https://api.regulations.gov/v4/comments/HUD-2016-0050-0004 https://api.regulations.gov/v4/comments/HUD-2016-0050-0020
Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous
Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous
On behalf of the National Association of Housing and Redevelopment Officials (NAHRO), I am are pleased to offer the following comments in response to the proposed rule (FR-5890-P-01) entitled Narrowing the Digital Divide Through Installation of Broadband Infrastructure in HUD-Funded New Construction and Substantial Rehabilitation of Multifamily Rental Housing. Please see comments from the National Housing Conference.  Comments of Webpass, Inc. on HUD Proposed Rule FR 5890-P-01Webpass is a San Francisco-based internet access service provider.  We own and operate our own Ethernet network and currently serve San Francisco, Oakland, San Diego, Miami, Chicago, and Boston. Google Fiber recently agreed to acquire our company.We urge HUD to adopt the Internet Franchise policy framework.  Webpasss proposed Internet Franchise policy  (https://webpass.net/franchise)  directly addresses the issues in this rulemaking. Creating a new set of rules for a small subset of properties--those supported by HUD--is not helpful. HUD should adopt broadly applicable internet access rules that can be a model for the whole country.  The Internet Franchise declares internet access service a public utility and offers franchise status to approved providers, creating a legal landscape where the best options flourish. The proposed rules include:   - high-speed internet-grade cabling in new buildings and major renovations   - access to properties for any franchisee requested by a tenant   - no kickback agreements or discriminatory riser management policies   - access to poles and conduit for approved franchisees   - streamlined local permitting. Professor Susan Crawford describes how the Internet Franchise can help, in her recent article at https://backchannel.com/the-new-payola-deals-landlords-cut-with-internet-providers-cf60200aa9e9#.vjp5ichiv.  Internet service in America is not what it should be. Most consumers have two choices, the phone company and the cable company. There is a lot more we can do to improve the competitive environment and internet service overall. The U.S. has the same technology as other countries with great internet service. Japan, South Korea, and the like dont have any unique access technology. Technology is not the difference. These countries are home to newer, denser cities, and that significantly lowers the cost of building and deploying a network. But that is still not the whole story.  Looking at the history of technology in the U.S., back when lots of small companies launched small telephone networks that served a geographic area, those networks did not have the legal authority to serve the entire area.  They needed to enter buildings and use the public rights of way for manholes, poles, and other structures to build the network efficiently. The problem was solved by creating telephone franchise rules, which authorized a telephone company to provide service inside a jurisdiction in return for serving everyone in the jurisdiction, or universal service. Almost every structure in the U.S. has access to a landline phone connection today, even though nobody really uses them anymore!Fast forward to the early 1970s, when the cable television industry started. Same problem, same solution. Many small cable companies needed access to public rights of way to build video networks. Again, new rules formed the foundation of video (cable) franchises. Over time, cable service spread to a majority of homes. Interestingly, the concept of universal service was not applied to video franchises, so cable companies can typically only install equipment in buildings with an owners permission.Fast forward again to today. Companies have been building internet networks for 20 years, but the concept of an Internet Franchise has never taken root. That means every internet provider must forge its own path to market without a clear legal framework. Meanwhile, the companies that hold voice or video franchises dominate the market, due to their established networks that were built for a franchised service and retrofitted for internet. New competitors like us can obtain a voice or video franchise, but that requires them to offer those services. Phone and cable companies are internet companies in everything but name, but they must retain their legacy classifications to protect their franchise rights.Cellular phone companies are also internet companies in everything but name. Since the introduction of the iPhone, they pass much more internet traffic than voice traffic, but they are bound by a third set of regulations that has not adapted to the realities of consumer choice. Meanwhile, fiber companies promise unlimited bandwidth, but they are regulated under a fourth set of rules that render fiber networks the most expensive to build, Google Fiber being the best example. Since launching six years ago, Google has rolled out the service slowly to a relatively small geographic footprint.The idea that you can regulate internet companies in four distinct regimeslandline phone service, video service, cellular carriers, and fiber providersis destined for the dustbin of history. The internet is the internet regardless of the technology used. We need an Internet Franchise framework to unite the regulatory environment. Ubiquitous connectivity is achievable, and HUD can show the way. --These views have been published at Xconomy.com.  NDIA represents leaders of community organizations, public libraries, local governments, housing authorities and other institutions working in our communities to reduce digital disparities among our neighbors. Our affiliates help millions of disadvantaged Americans to join the 21st century mainstream through digital literacy training, public Internet access, affordable home broadband services, and digital inclusion advocacy. On behalf of this unique network of experienced community leaders and practitioners, NDIA advocates digital inclusion policies based in our shared conviction that broadband adoption is most effectively promoted by collaborative, community-driven efforts that combine affordable home broadband service, public broadband access, and technology training and support provide by trusted community partners.NDIA does not, itself, possess special expertise or experience in the areas of affordable housing development and financing, so we will not comment independently on the specifics of the proposed rule.But we do wish to add our support for some key points made in comments submitted by two of our affiliates which do possess that kind of expertise and experience: The National Housing Conference, and the City of Seattle, WA. The Utah Governors Office of Economic Development submitted these comments for Docket No. FR 5891-P-01 and would like the agency to consider these comments in  FR 5890-P-01 as well.  Miss Doris A.  Thomas is requesting funding for the creation and development of HUD Funded New Construction and substantial rehabilitation of multi family rental housing for seniors, veterans, and women. Philadelphia , Pa has a significant vacancy rate in affordable rental housing due to the lack of developers for affordable homes. We desire to create affordable housing units with the installation of the Broadband Infrastructure. We have two vacant lots located in North Philadelphia and the Kensington section of Philadelphia. Our goal and mission is to end homelessness for veterans and create some new affordable housing units with the free or low cost  wifi service located in the persons home. 