Read my filing here. Roslyn Layton Comm Act Update Universal Service
There is an important debate in the digital age about the commitments we keep to people of low-income and those who live in rural areas. There has been a notion of “universal service” through the history of telecommunications, but it has been defined and delivered differently depending on the needs of the time and the prevailing technologies. For example, universal service in the United States first referred to the interconnection of networks. Then it evolved to a notion of a telephone in every home. In the last generation it has had to do with ensuring that had basic access to either wired or wireless communications services. Now that we enter the broadband era where there are multiple networks (copper/DSL, cable, fiber, wifi, satellite etc) and multiple services (traditional voice, SMS, VOIP, and a range of over the top communication services), the notion of universal service is evolving again.
The House Energy and Commerce Committee of the US Congress has recently issued a white paper asking the public how it should universal service going forward. This is undertaken under the larger, holistic process to update America’s Communication Act from 1934, a bipartisan and transparent effort.
My own filing is based upon a recent paper, Debatable Premises in Telecom Policy, co-written with Gus Hurwitz, law professor at the University of Nebraska. Our key recommendation on universal service is to think of it not in terms of networks, but in terms of services and applications. The current focus on high speed networks to enable video is misguided. Indeed, ensuring universal access to video does not help the deaf or blind. There are many broadband networks in the US today, and creating universal service commitments for each would be unwieldy and inefficient. Instead, Congress should focus on ensuring that key services and applications for public safety, health, education, employment, egovernment and so on are designed to be consumed on low bandwidths. This will increase the likelihood of availability of essential services on any kind of broadband network, whatever it may be. Such a shift in thinking can also encourage improved innovation in application and service design.
Moreover because networks have evolved considerably since 1934, I urge the Committee to retire the silos to regulate networks envisioned some 80 years ago and to focus on a simple framework that applies equally to all networks, services, applications, devices, technologies and business models. If we want to realize the information and communications technologies of the future, we need to let go of the past.
Read my article about the recent call for papers on universal service and some other commentary on TechPolicyDaily.com.
Information on the Communications Act Update including the white papers and all commentary in response can be found on the #CommActUpdate website.