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Letter dated 03/05/10 - Federal Communications Commission
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of: A National Broadband Plan for Our Future GN Docket. No. 09-51
COMMENTS OF THE OFFICE OF ADVOCACY, U.S. SMALL BUSINESS ADMINISTRATION
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.
Susan M. Walthall
Acting Chief Counsel for Advocacy
Major L. Clark III
Assistant Chief Counsel
Radwan N. Saade
Office of Advocacy
U.S. Small Business Administration
409 3rd Street, S.W.
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