An Open Letter To Blair Levin On The Subject of National Broadband Public Notices

Uncle! Twenty-six public notices in the National Broadband Plan proceeding are too many. For us policy wonks, it has been something like being a kid in a candy store with all the new data coming in and genuine interest on the part of staff to review data and discuss it on the merits. This, in turn, has encouraged many parties to bring substantive data and arguments to the table rather than simply rehash the same thin gruel of talking points over and over. In all seriousness, you (and everyone else involved) should be proud of your accomplishments on the process side. But, like a kid in a candy store, we are starting to get something of a stomach ache here. Because the plan is due February 17, 2010, the time frames on these Public Notices are very short. Worse, because you have now pared things down from the very high-level general questions to the much more interesting and specific questions, the Public Notices require significant expenditure of resources and time to develop meaningful responses. It does no good to ask very interesting questions if no one has time to give meaningful answers. This, in turn, runs the risk of diminishing the benefits of an excellent process. Too many Public Notices advantages the companies that have the resources to continue to respond at the rate required. As with all things, there are trade offs between having a process designed to solicit the best information and a process that allows for meaningful participation for everyone.