Re: Docket No. GN Health Care Delivery Elements of the National Broadband Plan

Transcription

1 January 29, 2010 Marlene Dortch, Secretary Federal Communications Commission th Street, SW Washington, D.C Re: Docket No. GN Health Care Delivery Elements of the National Broadband Plan Dear Ms. Dortch, On January 27 and 28, the undersigned, on behalf of the Montana Telecommunications Association (MTA), met with the following: Christine Kurth, Legal Advisor to Commissioner McDowell; Jennifer Schneider, Legal Advisor to Commissioner Copps; Angie Kronenberg, Legal Advisor to Commissioner Clyburn; Christi Shewman, Legal Advisor to Commissioner Baker; Sharon Gillett, Tom Buckley, Alex Minard and Ernesto Beckford of the Wireline Competition Bureau; and Mohit Kaushal and Spencer Hutchins of the Omnibus Broadband Initiative (OBI) team. We discussed the attached slide presentation which summarizes MTA s comments filed on January 11, 2010, and provides recommendations based on lessons learned in Montana for revising rules pertaining to the Rural Health Care Pilot Program. MTA endorses guiding principles outlined in presentations by the OBI team in December, 2009, which stress the importance of building on attributes of the American broadband ecosystem; emphasizing private sector investment; better utilizing existing assets and considering unintended consequences. FCC rules implementing the Rural Health Care Pilot Program (RHCPP) have encouraged RHCPP projects to build duplicative broadband networks, with unintended negative consequences on the broadband ecosystem, circumventing existing broadband infrastructure and threatening to diminish private investment in rural communities in Montana.

2 Marlene Dortch GN National Broadband Plan January 29, 2010 Page 2 Should the National Broadband Plan propose continuation of the Rural Healthcare Pilot Program, MTA recommends revisions to implementing rules to require that applicants seeking support from Rural Health Care Program perform an analysis to justify why they would build new broadband infrastructure as opposed to better utilizing existing network infrastructure. MTA further recommends establishing a public comment period prior to applicants submission of applications for Rural Health Care Program support to enable parties to review and comment on applications. Respectfully submitted, /s/ Geoff Feiss, General Manager Montana Telecommunications Association 208 North Montana Avenue, Suite 105 Helena, Montana gfeiss@telecomassn.org Attachment cc Christine Kurth Jennifer Schneider Angie Kronenberg Christi Shewman Sharon Gillett Tom Buckley Alex Minard Ernesto Beckford Mohit Kaushal Spencer Hutchins

3 Rural Health Care Pilot Program Talking Points: Geoff Feiss, GM Montana Telecommunications Association

4 Rural Health Care (WC 02-60) Rural Health Care Program (RHC) $400M/yr authorized Approx. $40M/yr spent (i.e., 10% utilization) Rural Health Care Pilot Program (RHCPP) Approx $140M/yr over 3 years. 62 projects (69 original projects - 7 mergers) Good, Bad and Ugly Good: opportunity to enhance rural telecom infrastructure for advanced health care systems through partnerships with infrastructure providers Bad: FCC Rules that encourage duplication, waste Ugly: Pilot projects like Montana s HIEM (certainly not the only one) 2

5 National Broadband Plan Omnibus Broadband Initiative (12/16/9) recognizes benefits of leveraging existing infrastructure Building on attributes of American broadband ecosystem Private sector investment is essential; new funding is limited Better utilization of existing assets is required Consideration of unintended consequences OBI (9/29/9): Joint trenching saves as much as 78% of fiber build cost 3

6 National Broadband Initiative Maximizing use of existing assets Saves limited resources in delivering broadband capacity to health care networks Enhances scale and scope of network facilities Benefits both targeted anchor tenants (e.g., health care providers) and general public 4

7 Rural Health Care Pilot Program 47 U.S.C. Sec. 254(h)(1). A telecommunications carrier shall, upon receiving a bona fide request, provide telecommunications services which are necessary for the provision of health care services Sec. 254(h)(3). Telecommunications services and network capacity provided to a public institutional telecommunications user under this section may not be sold, resold, or otherwise transferred by such user in consideration for money or any other thing of value. 5

8 FCC RHCPP Rules Orders (9/26/6; 11/16/7; WCB letter, 10/24/8) Sustainability excess capacity fair share 6

9 Unintended Consequences Redundant, duplicative, inefficient overbuilding by entities whose core competencies are not managing telecom networks Anchor tenants leave PSTN Excess capacity encourages health care providers to compete with incumbent infrastructure providers to meet sustainability goals: more traffic leaves public infrastructure ROI, cap ex investment: weakened PSTN More pressure on USF, RUS loans USF (RHC) cannibalizing USF (HC) 2 USF-supported broadband networks in areas that often cannot sustain 1 without support (where have we heard that before?) Competition between telecom providers and HC providers Questionable long-term sustainability 7

10 A Tale of Two Projects Health Information Exchange of Montana (HIEM): $13.6 M (requested $27 M) New fiber build Unnecessary duplication of existing networks Frontier Access to healthcare in Rural Montana (FAhRM): $1.2M Cloud-based network using existing facilities/networks Wider reach covering larger area, more providers 8

11 RHCPP: Opportunity or Boondoggle? Recommendations Require lease v. build analysis Needs Assessment Build only as last resort; leverage existing infrastructure Ban subsidized overbuilding of existing bbnd infrastructure Enforceable due diligence review by stakeholders Do not duplicate USF support (as in RUS loans) Use RHC support for sustainability, affordability Expand RHC to include nonrural, pvt. telehealth participants 9