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Letter dated 03/05/10 - Federal Communications Commission

Before the
Washington, D.C. 20554

In the Matter of: A National Broadband Plan for Our Future GN Docket. No. 09-51


The Office of Advocacy of the U. S. Small Business Administration (“Advocacy”) submits these comments to the Federal Communications Commission (“FCC” or “Commission”) in the above-referenced docket. Advocacy commends the Commission for its efforts to produce a National Broadband Plan (Plan), and to define the broadband landscape for the foreseeable future. While hopeful that the Commission’s expertise will ensure the feasibility of the initiative, Advocacy would like to take this opportunity to make a few suggestions with respect to the Plan and small business.

Based on whether the framework in the Plan will accommodate the continued existence and growth of small business providers, Advocacy strongly suggests that the Commission start the process of redefining size standards with the U.S. Small Business Administration. This review is needed mainly to reflect the financial and technological changes that have occurred in the market.

Current size standards are set out as follows:

Subsector 517 -- Telecommunications

  • Wired Telecommunications Carriers 1,500

  • Wireless Telecommunications Carriers (Except Satellite) 1,500

  • Satellite Telecommunications $M 15.0

  • Telecommunication Resellers 1,500

  • All Other Telecommunications $M 25.0

Subsector 518 – Data Processing, Hosting, and Related Services

  • Data Processing, Hosting, and Related Services $M 25.0

Subsector 519 – Other Information Services

  • News Syndicates $M 7.0

  • Libraries and Archives $M 7.0

  • Internet Publishing and Broadcasting and Web Search Portals 500

  • All Other Information Services $M 7.0

As is evident from the chart above, there are three North American Industry Classification System Codes (NAICS) defining telecommunications and related services. Additional classifications may be needed to account for small broadband and telecommunications providers, as they are currently “lumped” with one of the categories above, and not explicitly accounted for. Moreover, in November of last year, Advocacy advised NTIA in its efforts to enhance the small business size standard definition for applications to the Broadband Technology Opportunities Program (BTOP). Advocacy is available to assist the Commission with the determination, if needed.

In conclusion, small telecommunications providers have seen their fortunes grow and disappear since the passage of the Telecommunications Act of 1996. Those still in existence, as well as new entrants, are anxiously waiting to see how competition will be defined by the Plan. Advocacy’s suggestions would help support and account for this important sector.

Respectfully submitted,
/s/ ___________________________
Susan M. Walthall
Acting Chief Counsel for Advocacy

/s/ ___________________________
Major L. Clark III
Assistant Chief Counsel

/s/ ___________________________
Radwan N. Saade
Regulatory Economist

Office of Advocacy
U.S. Small Business Administration
409 3rd Street, S.W.
Suite 7800
Washington, DC 20416

March 5, 2010

Chairman Julius Genachowski
Commissioner Michael J. Copps
Commissioner Robert M. McDowell
Commissioner Mignon Clyburn
Commissioner Meredith Attwell Baker

The Honorable Cass Sunstein, Administrator, Office of Information and Regulatory Affairs

via electronic filing
In the Matter of A National Broadband Plan for Our Future, GN Docket No. 09-51 (Rel. April 8, 2009). The three-digit codes define industry sectors, and the six-digit codes particular industries.

Office of Advocacy Comment
U.S. Small Business Administration GN Docket No. 09-51