Sunday, September 6, 2009

Broadband Silobreakers: FCC Opens Telework Comment Cycle within National Broadband Plan Process 09/06/09 - The Federal Communications Commission (FCC) on Friday, September 4 announced the opening of a public comment period on telework in the American economy and society.

This comment cycle, like the Smart Grid comment cycle also announced on September 4, is part of the Commission's larger ongoing major rulemaking framing a
National Broadband Plan, pursuant to congressional requirements within the American Recovery and Renewal Act of 2009 (ARRA).

The Notice of Pleading Cycle was released today (download: .PDF). Public Comments are due by September 22, 2009.

We excerpt key elements of today's 3 page Notice:

NBP Public Notice #3


GN Docket Nos. 09-47, 09-51, 09-137

Comment Date: September 22, 2009

One of the many possibilities broadband creates is transforming the way we work, enabling employees to work wherever and, often, whenever. For instance, the Government Accountability Office (GAO) was able to implement a significant telework program without diminishing its output after many of its employees were displaced as a result of an anthrax scare in Congress.

More than half of the Patent and Trademark Office (PTO) employees telework and the PTO claims a savings of $2 million in fuel cost and 14,000 tons of carbon emission savings from its program. As we continue to work toward the development of a National Broadband Plan, we seek tailored comments regarding telework.

1. Broadband and Telework. Telework is not a new concept, but the capabilities of broadband may increase the practicality and remove limitations on telework.

2. Telework and Economic Development.

3. Programs.

This matter shall be treated as a “permit-but-disclose” proceeding in accordance with the
Commission’s ex parte rules. See 47 C.F.R. §§ 1.1200, 1.1206. Persons making oral ex parte presentations are reminded that memoranda summarizing the presentations must contain summaries of the substance of the presentations and not merely a listing of the subjects discussed. More than a one- or two-sentence description of the views and arguments presented generally is required. See 47 C.F.R. § 1.1206(b).

Other rules pertaining to oral and written ex parte presentations in permit-but-disclose proceedings are set forth in section 1.1206(b) of the Commission's rules, 47 C.F.R. § 1.1206(b).

All comments should refer to GN Docket Nos. 09-47, 09-51, and 09-137. Please title comments responsive to this Notice as “Comments—NBP Public Notice #3.” Further, we strongly encourage parties to develop responses to this Notice that adhere to the organization and structure of the questions in this Notice.

Comments may be filed using (1) the Commission’s Electronic Comment Filing System (ECFS), (2) the Federal Government’s eRulemaking Portal, or (3) by filing paper copies. Comments filed through the ECFS can be sent as an electronic file via the Internet to or the Federal eRulemaking Portal:

Generally, only one copy of an electronic submission must be filed. In completing the transmittal screen, commenters should include their full name, U.S. Postal Service mailing address, and the applicable docket or rulemaking number.

Parties may also submit an electronic comment by Internet e-mail. To get filing instructions for e-mail comments, commenters should send an e-mail to, and should include the following words in the body of the message, “get form.” A sample form and directions will be sent in reply. Parties who choose to file by paper must file an original and four copies of each filing.

For further information about this Public Notice, please contact Randy Clarke at (202) 418-1500.
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