ON
NTIA INQUIRY INTO BROADBAND DEPLOYMENT
I.INTRODUCTIONThese
comments are filed on behalf of Hughes Network Systems (HNS), a division
of Hughes Electronics Corporation.HNS
provides a broad range of satellite services, including the recently introduced
DIRECWAY two-way consumer satellite broadband service.In
the near future, HNS will provide its
DIRECWAY services via a next
generationmore
advanced two-way satellite broadband platformservice
called SPACEWAY.HNS is committed
to providing broadband services throughout the United States and has a
great interest in the policies of NTIA, the FCC and other government agencies
regarding the deployment of broadband services.[1]
These
comments discuss the substantial benefits to the public from broadband
deployment and propose some government policies to encourage that development.In
particular, these
comments discuss onetwo
of the five “guideposts” for government policy discussed by NTIA Director
Victory in a recent speech.[2]HNS’
comments focus on the need to encourage facilities-based competition to
cable and telephone companies as the most effective means of providing
broadband to all of America---urban, suburban anHNS’s
commentsfocus
on:
1)
the
importance
of vigorous competition among competing networks of providers in order
toin
the effective delivery of high-quality broadband at competitive prices;
and rural.
Special
emphasis should be placed on encouraging the development of satellite systems
to foster competition in the provision of broadband service and regulatory
obstacles to the deployment of satellite systems should be eliminated.
2) the importance of recognizing that market forces do not operate similarly
in all geographic areas.
Both of these considerations point toward greater reliance on satellite
systems in providing broadband service and the need to remove regulatory
obstacles to
the effective deployment of these systems.
II.THE VALUE OF BROADBANDIt is generally accepted that the widespread availability of broadband telecommunications capability brings substantial economic benefits.A recent paper by Robert Crandall and Charles Jackson traces the productivity growth in the economy and its relation to the information technology revolution of the 1990’s.[3]Their contention is that continued national economic growth requires extensive Internet connectivity, which can build upon pastinvestment in telecommunications networking equipment and can facilitate IT networking. The paper quotes Vinton Cerf, Chairman of the Board of the Internet Corporation for Assigned Names and Numbers, as stating that the “Internet will be the 21st century’s telecommunications infrastructure.”
The
study envisions a future with greatly expanded uses of the Internet, including
“network aware” appliances connected to databases via high-speed access.Such a
networks will
require the “always on” characteristic associated with broadband services
in order to maximize new services and productivity.Consistent
with numerous government statements, the paper demonstrates that broadband
access to the Internet will offer tremendous benefits to a broad cross-section
of the public.
Crandall
andJackson use demand functions
to estimate the consumer surplus of high speed Internet access,
based on an assumption that the service is priced at $40.00 dollars per
month.UtilizingBased
on reasonable characteristics of the demand function, the
authors estimate a consumer surplus ranging from a low of $284 billion
to a high of $427 billion per year.They
also estimate the benefits of broadband access using another methodology
by identifying specific gains to consumers from access to broadband such
as the replacement of second phone lines, improvement in the feasibility
and performance of activities such as telecommuting, and the introduction
of other, completely new services and applications.Based
on this methodology, the authors estimate benefits to consumers ranging
from a low of $272 billion to a high of $520 billion annually.The
authors also estimate the increase in the “producer surplus” that would
result fromlower costs as efficiency
improves, could amount to another $100 billion annually.
For
the purposes of the NTIA inquiry, it is important to note that the size
of theseprojected benefits turn
on the extent of broadband service deployment. Crandall
and Jackson note that “uUniversal
diffusion” of broadband will lead to substantially higher consumer benefits.For
example, their study
calculates athe
difference in the
total “surplus” captured by consumers if there isbetween
a fifty ninety-four percent
broadband penetration of households
(the current penetration rate for telephone service) and that
with a aninety-four fifty
percent penetration rate
( the current penetration rate for telephone service).The would
be a gain in consumer surplus if
this additional number of households have broadband access is of $200
billion per year withand
a related gain
in producer surplus of about $50 billion per year.In
other words, the marginal value
ofgain
from nationwide availability- in
and of itself
-is
almost as large as the entireconsumer
surplus at a 50% household penetration
rate.This is a variation of the
principle underlying Metcalf’s Law that the value of a network is proportional
to the square of the number of devices attached to it.
III. CURRENT U.S. BROADBAND
DEPLOYMENT
In
order to place the Crandall-Jackson study in context, it is useful to consider
the recent report by the Federal Communications Commission on high-speed
services for Internet access, which evaluated the
extent of broadband deployment as of December
31, 2000.[4]Without
providing a specific definition of “broadband,” the FCC used two categories
of service availability: 1)
“high-speed services,” which involve “transmission at a speed in excess
of 200 kbps in at least one direction”; and 2) “advanced services,” which
are defined as “transmission in excess of 200 kbps in each direction.”
The
FCC report indicates
that broadband availability using either of these measures is growing rapidly
and that full economic benefits are likely to be achieved in the short
term.The report notes that seventy-five
percent of the country’s zip codes have at least one high-speed provider
and that these seventy-five percent of zip codes incorporate ninety-six
percent of the population.The
report is related to a discussion of policy issuesin
an FCC Notice of Inquiry.[5]
Although the report is optimistic, the absolute numbers of subscribers
shown in the report isshould
be less encouraging. According to the FCC, the number of high-speed
connections at the end of 2000 was 7.1 million lines, of which 5.2 million
were residential and small business subscribers.Advanced
services accounted for a total of 4.3 million lines.The
5.2 million combined total for residential and small business subscribers
can be compared to a recent Census Bureau count of 105 million residential
households, suggesting resulting
in a penetration rate of about 5%.Including
small businesses would result in an even lower penetration rate.
BAn
additional concern is that the broadband capacity currently
provided in the United States is predominantly coaxial cable, ADSL, and
“other” wireline.Significantly,
newer technologies such as fiber optic cable and broadband satellite account
for a relatively
small percentage of the provision
of broadband service s
in both categories.This low percentage
reflects the facts that deployment of fiber in telephone networks is costlyquite
new, that cable-based broadband is growing at a very high
rate, and that two-way consumer satellite broadband service
was only initiated this year. All
of these technologies will be major factors in the future of broadband
deployment if government policy fully supports the development of these
alternative networks.
The
Commission’s Third Notice of Inquiry divides broadband infrastructure into
four general categories, which are quite useful in understanding current
barriers to broadband deployment: 1) backbone; 2) middle mile; 3) last
mile; and 4) last one hundred feet (to the end user terminal).A
recent paper published by the Discovery Institute draws upon the FCC classification
and insightfully
makecontributes
some significant insights
a .[6]The
paper begins by making a distinction between unused bandwidth
and unusable bandwidth and states that “a network connection is no broader
than the narrowest segment of an end to end link5.”The
central point is that blockages in the provision ofbroadband
in the last mile or even last one hundred feet, prevent the effective utilization
of the significant broadband trunk capacity that already exists.
The
high costs of wireline,
last mile networks is clearly athe
primary reason for the low broadband penetration rate.Evaluating
these costs provides a basis for understanding better the policy issues
that must be addressed in any national policy to support broadband technologies.The
Phoenix Center utilizes statistics of RCN (
a large cable operator in the North East) to estimate network
costs in a recent analysispaper.[7]Their
conclusion is that wireline networks cost $1,750 per house passed and
$2,500 per marketable home. Phoenix estimates that even for
fiber optic networks in urban areas, the cost of installation is $3 million
per mile.Although the report does
not indicate how costs vary based on population density, it is obvious
that the costs per house passed and
per marketable home would consequently be much higher
in rural areas.
The
Phoenix Center concludes that if,
every home in the United States were to be connected via fiber optic cable,
the overall cost of the infrastructure would be approximately $300 billion.Given
this high sunk cost, a significantreasonable
penetration level would be necessary to recover the costs of the network.
Accordingly, the
financial risks of extending service to these areas is very high, especially
if there has not been a demonstration of an effective market by another
technology with different
cost characteristics..
This
risk is reflected in the actual deployment of cable and DSL in the United
States.Utilizing data from the FCC
report mentioned earlier, the Futron Corporation has determined that only
four metropolitan areas in the country have over 200,000 cable
and DSL lines and only four Basic Trading Areas reach ten percent
household penetration (see Appendix A). While
this limited deployment is understandable
for wireline technologies, fixed wireless networks also are deployed almost
exclusively in heavily populated areas.Futron
Corporation has examinedAn
examination of the eight fixed wireless operators that dominate
the market and
has determinedindicates
that they are licensed in fifty-seven percent of the country’s Basic
Trading Areas but operate in only sixteen percent
(see Appendix B).
Satellites,
however, by having wide-area
and a
nationwide ‘footprints’,’
can offer full national coverage as soon as service is provided. Accordingly,
satellites have the capability of introducing broadband services into rural
and underserved areas more rapidly than terrestrial systems which must
build separate, regionalgeographic
networks.
IV. BROADBAND SERVICES
VIA SATELLITES
In
June 2001, Hughes DIRECWAY introduced its Ku-band satellite-return (two-way)
consumer broadband service,
which meets the FCC’s definition of “high-speed” services by providing
Internet access at speeds comparable to DSL and cable.DIRECWAY’s
download speeds exceed 400 Kbps and uplink speeds are approximately 128
Kbps. This asymmetric speed of service supports HNS’ experience that the
downlink speed – getting information to the customer – is of highest importance
and use to residential and small business users who wantrapid
access to information, but have far
less need to send large quantities of information at high speeds.
In
addition, Hughes will soon launch its new SPACEWAY Ka-band geostationary
satellite system, which will far exceed the FCC’s standard for advanced
services. The SPACEWAY satellite platform will provide super-fast download
speeds of starting at 30 Mbps and uplink rates from 512 Kbps for the smallest
earth terminals for individual users, and from tens
of Mbps for businesses and hubs. SPACEWAY will make this service available
nationwide in 2003.
SPACEWAY
will utilize a“mesh”
network configuration that will provide directconnectivity
between each and every consumer obtaining service, eliminating the need
to transmit signals through a central hub or pass through speed-choking
nodes and lines. SPACEWAY will support services such as videoconferencing
and telemedicine applications.Telemedicine
applications can include teleradiology and “virtual meetings” for medical
consultation as described by the Office for the Advancement of Telehealth
in the Department of Health and Human Services.[8]SPACEWAY
will also support connection to Wi-Fi wireless LAN services such as IEEE
802.11b, 802.11a and 802.11g.
HUGHES
believes that its DIRECWAY and SPACEWAY satellite systems
– along with other broadband
satellite systems – are
likely to be major providers
of broadband technology for small businesses and consumers in the United
States.The NRTC has stated that
“if current business and technology trends continue, Ka-band services could
reach rural homes before most urban areas have access to extensive fiber
networks, fixed wireless, or 3G mobile networks.”[9]Terrestrial
broadband deployment is highly focused on larger businesses, metropolitan
areas and affluent suburbs.The cost
of either DSL or cable, as noted by the Phoenix Study, generates financial
risk in areas with low population density.
However,
broadband service will not
be limited only to rural areas.Satellites
will offer vigorous competition to other providers in urban areas as well.The
ability of satellites to compete with terrestrial networks is demonstrated
by the factthat approximately fifty
percent of the satellite TV customers arein
urban areas.Accordingly,
broadband satellitesshould
be seen as universal competitors
to
terrestrial providers throughout the United States.
V.THE
NEED FOR CLEAR SPECTRUM
In
the Third NOI, the Commission asks what it can do to fulfill its statutory
mandate to encourage the deployment of advanced services deployment. For
Hughes and other satellite broadbandproviders
in this capital intensive sector, the central problem is lack of
sufficient unshared spectrum that is suitable for the
two-way broadband services.To
provide the greatest number of urban and rural users with affordable, advanced
services, Hughes and other broadband satellite providers must have sufficient
spectrum that is allocated exclusively for satellite use.Failure
to accessobtain
clear spectrum makes it much more difficult for satellite providers to
become a competitive alternative to terrestrial broadband service throughout
the country,
including rural and other underserved areas.
Hughes
is currently
facing significant challenges in obtaining rights
to clear
spectrum in both the Ku and Ka bands.For
example, Hughes has urged the FCC not to authorize wireless technologies
to share spectrum with satellite services in the Ku-band.The
recent MITRE study indicates that there would be “significant interference”
to small, ubiquitous satellite television terminals if the spectrum is
shared with terrestrial wireless operators unless providers adopt far-reaching
“mitigating factors.” The mitigating factors identified by MITRE are neither
practical not conducive to the development of a nationwide broadband network.
HNS
has confronted similar
difficulties in obtaining clear spectrum in the Ka band.SPACEWAY
satellites arewill
be some of the most efficient spacecraft ever built with regard to spectrum
usage.A single SPACEWAY satellite
will offer
more capacity of
as much asthan
ten conventional satellites today.Nevertheless,
the amount of available bandwidth directly tly
affects the capacity of each SPACEWAY satellite and determines
the number of users that can be accommodated
at a given orbital position.In
the FCC’s Ka-band spectrum and licensing proceeding,
Hughes had requested 1000 MHz of clear spectrum in the Ka-band, but was
granted only 500 MHz of useable,
clear spectrum for use before 2010..[10]8
This decision significantly reduced the number of users that can be served
from a single orbital slot. In
doing so, the decision negatively impacts the economics of satellite
service by limiting the allocation of development costs to a smaller number
of spacecraft.
Ruby
Ranch in its comments to the Third NOI makes this exact point that satellite
providers have insufficient access to clear spectrum.9[11]It
states: “[I]f everyone in the US who wants advanced telecommunications
services…were to sign up tomorrow for satellite Internet service, the service
would slow to a crawl.There is
nowhere near enough bandwidth available in present satellites to serve
a substantial fraction of US households or businesses.” (emphasis added)In
sum, when asked what government can do to speed broadband deployment,Hughes
does not suggest that satellites can or should be the only way that wireless
Internet service is provided, but Ruby Ranch correctly observes that additional
spectrum is needed to support the provision of broadband satellite services.Hughes
reasserts its call that at least 1 GHz of clear Ka band spectrum be made
available for ubiquitously- deployed satellite broadband terminals.The
failure to do so will constrain the ability of satellite broadband operators
to provide much needed broadband services to the greatest number of Americans.
VI. CONCLUSION
Congress
and the Administration can adopt policies that promote the rapid deployment
of broadband services throughout the United States.Such
deployment will be increasingly linked to local and national economic development.The
country is at the earliest stages of this technological development curve,
yet dramatic advances are already on the horizon. Facilities-based competition,
notably between cable and satellite systems , will be a major driver in
rapidly facilitating
broadband deployment.It
is essential that we adopt policies that facilitate the development of
competing technologies so that, wherever possible, consumers have choice
among competing networks.
Federal
policy should be as neutral in supporting these different technologies
and should not place
an undue emphasis on one technological approach or business model over
another.We believe that the satellites
– as long as they are not precluded by regulatory barriers or discriminatory
government policies – will takes their place alongside DSL, cable modem
and other technologies as a major competitor in the provision of broadband
service in both rural and urban areas.
All
broadband technologies have certain advantages.It
is important for Congress ad the Administration to recognize the particular
advantages that stem from delivering broadband through a limited number
of spacecraft, including the low marginal costs to serve new communities,
the efficient delivery of service in low-density areas, and the ability
to offer services quickly to a very large service area once the spacecraft
is deployed.Satellites providers
have the ability to speed up the deployment of broadband because service
does not have to wait for the deployment of terrestrial infrastructure.
Despite
the great promise of satellites, they cannot reach their full potential
unless they are allowed to operate free of unnecessary regulatory barriers
and they have access to the essential resources needed
to operate.The single most important
resource satellite providers must have is sufficient, clear spectrum in
which to transmit signals.Without
clear spectrum, event
the most advanced satellite system cannot reach users with high-quality
transmissions.Limiting spectrum not
only reduces,
not only the quality of service, but the capacity of individual satellites
as well.HNS has previously urged
the FCC to allocate 1 GHz of clear spectrum in the Ka-band for the next
generation of broadband satellites. By doing so, the FCC would go far to
promote the rapid deployment
of broadband networks and allow the marketplace to push applications, services
and technology.oyment
of broadband the national policy goal of vigorous competition by alternative
networks in both urban and rural communities across the United States.