Saturday, November 10, 2007

The FCC should extend its Media Ownership commentary period

The following is a letter I submitted to the FCC, for Docket 06-121. If you want to submit your own, instructions are posted here, on the FCC's Web site. Enter 06-121 in the "Proceding" field. You can upload a document containing your commentary or type it into the field provided.

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Honorable Commissioners,

As you traveled the country to attend the FCC's public hearings about the proposed relaxation of media ownership rules, an overwhelming majority of public testimony was about how America depends upon a free and open media and how a diversity of voices gives the public the information it needs in order to make well-informed decisions, as they participate in our democracy.

I propose that the FCC's vote in this matter be postponed, as proposed by Senators Lott, Dorgan, et al, in the "Media Ownership Act of 2007 (S.2332)," introduced on Nov 8, 2007, and also for reasons I describe below. I also propose that the FCC postpone its decision on media ownership, which appears to be targeted for December 18, 2007, or earlier.

I make these proposals because I believe that the discussion should be expanded to include the upcoming 700mhz wireless auction and Net Neutrality. The 700mhz band is essentially a new form of "airwaves" and has the potential of being dominated by a small number of large communications carriers - analogous to the issue driving the media ownership discussion, because, potentially, powerful communications carriers will be in a position to stifle competition and to control the content brought to Americans.

In 2003, communications carriers in the US were permitted by the FCC to build new networks without being obligated to rent them to third parties (counter to the original mandate of the Communications Act of 1996, which Chairman Martin pledged to uphold, in his comments at the Seattle media ownership hearing on November 9).

By contrast, in Europe, this is not the case. In France, at least six companies compete side-by-side on France Telecom's network to deliver broadband TV (IPTV) - over France Telecom's network. This example of robust competition is no longer practiced in the US. These competitors carry some content in common but at least some of the content is unique to each of the service operators.

Closed networks, on the other hand, be they fixed-line (copper or fiber), or wireless (but hopefully, not the 700mhz band), create the possibility of censorship. Already, it is a reality at AT&T, which has changed its subscriber contract to allow AT&T to kick subscribers off its network, who disparage AT&T. Other instances of carriers trying to control the content that their subscribers are putting over their networks are also being documented.

So I encourage the FCC to consider the telecommunications carriers and the Net Neutrality issue in its deliberations over media ownership. The lengthening of the commentary period to 90 days, as proposed by S.2332, can and should be used by the FCC to reflect on these additional areas. For the FCC to make its decision on or before December 18 simply not allow enough time to consider these complex issues together.

Thank you for your consideration of this proposal.

Sincerely,
Steven C Hawley
email: steve@tvstrategies.com

Editor
IPTV News magazine

Senior IPTV Analyst
Multimedia Research Group Inc

Principal Analyst and Consultant
Advanced Media Strategies

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