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MMTC’s Broadband Law and Policy Work

Annual Broadband and Social Justice Summits:

Go here to learn more about MMTC’s Broadband and Social Justice Summits held from 2009 to 2019.  

Reports and Filings on Broadband Deployment; Rural Broadband; Unlicensed WiFi; Universal Service Fund; Broadband Infrastructure; National Broadband Plan; Broadband Opportunity

 FCC Emergency Broadband Benefit Program Comments, February 2021

The FCC adopted an order to establish the Emergency Broadband Benefit (EBB) program, a $3.2 billion federal initiative that will provide broadband services and devices to help low-income households stay connected during the COVID-19 pandemic. MMTC and the National Urban League filed comments in support of the EBB program. Learn more about the FCC’s EBB Program Order here. Visit the FCC’s EBB website here. Read MMTC’s reply comments here. Read MMTC and the National Urban League’s EBB comments here.

Go here to read MMTC Vice President Dr. Fallon Wilson’s comments on the FCC’s outreach efforts in the Morning Consult article, “FCC’s New Broadband Subsidy Hits Sweet Spot for Lower-Income People of Color’s Internet Bill Needs.”

Digital future for most disadvantaged: we need a permanent broadband subsidy by MMTC Vice President Dr. Fallon Wilson, Tennessean, June 22, 2021 

Congress must enact broadband equity for low-income families by MMTC President Robert Branson, Reno Gazette Journal, August 3, 2021

5G Fund Supporters’ Rural Broadband Comments, June 2020

The FCC sought guidance on whether to undertake reverse auctions to distribute high-cost support for 5G services in rural America. The 5G Fund Support helped ensure that rural Americans enjoy the same benefits from our digital economy as their urban counterparts. The NPRM contemplated the subsidizing of 5G service to rural communities using low population density as the prioritization criterion. See p. 2. However, MMTC et al recommended that the FCC should prioritize low income minority rural communities. See pp. 3; 5-6. In addition, MMTC urged the FCC to extend the 1993 Cable Procurement Rule to other technologies besides cable. The rule had eliminated cable systems’ exclusive reliance on the “old boy network” that fed information about potential opportunities only to select companies. Specifically, it ensured that cable companies would provide contract opportunities broadly, thus guaranteeing that all qualified applicants can learn about and apply for the procurement opportunities. MMTC et al reported that extending the rule to wireless would be straightforward since the needs and opportunities presented by the deployment of wireless are similar to the needs and opportunities presented by cable. Finally, MMTC et al recommended that the FCC’s Designated Entity program be used to ensure that small carriers have the opportunity to bid for spectrum at a discounted price. 

6GHz Support Letter, April 2020

MMTC expressed its support for the FCC’s proposed plan to open the 6 GHz band. This plan would provide 1200 MHz of additional bandwidth to accommodate rapidly increasing Wi-Fi demand, as well as next generation Wi-fi innovation, to lower-income and minority groups. MMTC contended that the FCC should help close the digital divide by opening all 1200 Mhz for unlicensed use. Enabling the latest-generation Wireless LAN standard, Wi-Fi 6, to operate on 7 channels that can facilitate easy deployment of future generations of Wi-Fi on this band. MMTC encouraged the FCC to take all necessary action to ensure that all Americans benefit from the reallocation and to move forward with opening up the full 1200 MHz of bandwidth in the 6 Ghz band for unlicensed use. 

Broadband Infrastructure Support Letter, September 2018

MMTC supported the FCC’s efforts to move forward with its plans to identify and remove barriers to wireless and wireline broadband deployment. MMTC encouraged the FCC to update outdated regulations where possible; as millions of Americans still do not receive any broadband coverage. See p. 2. MMTC recommended that the FCC remove unnecessary barriers, so that 5G deployment in rural areas and low-income urban areas can proceed expeditiously. MMTC urged the FCC and industry to ensure that all communities have basic telephone service and basic broadband service, and to discourage the use of the regulatory process to facilitate deployment of 5G to the wealthiest communities.

Universal Service Fund Broadband Comments, December 2009

MMTC et al submitted comments in response to the FCC’s Universal Service Fund and Intercarrier Compensation in the National Broadband Plan. The Universal Service Programs ensured that all Americans are provided with high-quality and affordable advanced telecommunications and information services. MMTC et al commended the FCC’s current actions of exploring a more expansive definition of universal service. These comments highlight how increasing universal service funding will ensure that the opportunities presented by broadband are available to all Americans and allow these programs to encompass broadband related objectives. See pp. 4-6. MMTC et al urged the FCC to consider restructuring universal service programs similar to those proposed and developed during the DTV conversion process, allowing consumers to be able to decide which products and services best meet their needs. 

Broadband Deployment Support Letter to FCC Chairman Michael Copps

MMTC et al applauded the decision of the FCC’s Acting Chairman, Michael J. Copps, to initiate a comprehensive review of the FCC’s role in formulating a “national broadband plan.” An effective policy plan required an interdisciplinary, interagency approach. In this letter, the strategies MMTC et al identified would increase adoption of broadband services in vulnerable communities, such as how healthcare institutions could embrace telemedicine services and ensure patient privacy. Further, a national broadband plan could encourage businesses to adopt more telework/telecommuting policies to reduce traffic and harmful vehicle emissions, while increasing employee productivity. Finally, MMTC et al. recommended that the national broadband plan enable the Department of Education to create a unified e-learning policy that can help ensure that a world-class education would be available to every child in America.

Rural Broadband Comments, March 2009

In 2009, MMTC submitted a response to the FCC’s Report on Rural Broadband Strategy. Generally, when deploying a rural broadband service, carriers first construct along the main highway, then branch out broadband service from that backbone to communities adjacent to these major thoroughfares. However, this approach harms rural minority communities, as they are expected to bear the cost of building a node to itself from the backbone line. See p. 2. MMTC contended, where a rural community lacks broadband service, the federal government should assign it the number one priority for funding to receive broadband access and adoption. Additionally, the FCC determined broadband availability by the number of providers within a given zip code. In a rural area, zip codes tend to be large resulting in data that does not reflect the availability of broadband. MMTC argued, the FCC should employ more granular broadband mapping data to determine the rural areas in which broadband adoption rates are low. See pp. 4-5. As such, eliminating the historical and structural effects of racial discrimination of rural minority communities should be the FCC’s broadband’s policy focus.

Report from the First Broadband Opportunity Summit, February 2009

MMTC et al presented its perspective at the first Broadband Opportunity Summit. This Report summarized the results of the Summit and attempted to capture some specific recommended outcomes. The meetings represented a call to action to create policy recommendations for the Obama Administration on how broadband technology can advance the interests of members of the communities of color. Each expert showcased ways in which broadband can further education, healthcare, and energy and environmental goals as they relate to these communities. Afterwards, a number of overreaching issues would guide the group in working towards specific policy recommendations. See pp. 13-21. Furthermore, MMTC et al recommended issues-specific “Task Forces” dedicated to formulating specific policy proposals, reconvening as the “Broadband Opportunity Coalition” and inviting others to participate.