April 28, 2025: The National Association of Telecommunications Officers and Advisors (NATOA) filed Reply Comments in response to the Federal Communication Commission’s (“Commission”) Notice in the Matter of Delete, Delete, Delete, GN Docket No. 25-133.
NATOA files these comments to express our:
- Support for the Comments submitted by the National Association of Counties (NACo), the National League of Cities (NLC), and The United States Conference of Mayors (USCM) who identify rules that have “failed to deliver on their promised impacts and do not reflect the current real-world circumstances, which render them outdated or unhelpful.”
- Opposition to the Comments filed by the U.S. Chamber of Commerce (Chamber) regarding Cable Rate Regulations Rules, PEG Requirements, Cable Customer Service Obligation, Franchise Transfers.
- Opposition to INCOMPAS’ Comments regarding “access to public rights-of-way, accelerating approval of permits, and asking state and local governments, utilities, and railroads to charge fees that are based only on their actual, objectively reasonable costs.“
- Opposition to the NCTA – The Internet & Television Association (NCTA) comments regarding PEG access and a multitude of cable franchising obligations. And,
- Support for Cable, Broadband & Wireless Reporting and Customer Service Obligations.
NATOA supports and concurs with the Comments of NLC, NACO and USCM, the organizations representing America’s local government leaders, who have noted that the 2018 Small Cell Report and Order and Declaratory Ruling ”dramatically and inappropriately increased the extent to which the FCC directly imposed specific requirements on local permitting processes and limited local oversight of wireless infrastructure, by requiring specific shot clocks for permitting processes, limiting the factors communities may consider in permit applications, and dictating how localities may set fees for applications or use of public rights of way.”
NATOA objects to comments that undermine state and local governments’ authority to manage our public rights-of-way and our public safety role in land use.
We object to the mischaracterization and false assumptions that lead to local broadband permitting being described as an obstacle to broadband deployment. Broadband providers and deployers who suggest this are stepping on local governments’ role as guardians of public land which our citizens own and we manage, indeed, land upon which this industry seeks to build.
No one supports the successful deployment of broadband networks more than our local governments. We’ve a long and productive history of facilitating wireline deployment in our streets for generations of telephone, cable, broadband and wireless facilities. We continuously advocate for fast and affordable broadband service for all of our residents while at the same time addressing their needs and protecting their interests.
As former Commission Chairwoman Jessica Rosenworcel replied when asked about permitting in a June 2023 House Energy and Commerce Committee's Communications and Technology Subcommittee Hearing:
“I will tell you this: The biggest permitting problem now is on federal lands.
“Uncle Sam owns about 1/3rd of the real estate of this country and the standards for response back to those who want to build on those lands, we allow federal actors to take a lot more time to get back to someone who wants to build than we do state and local entities.
NATOA objects to Comments by NCTA – The Internet & Television Association and the U.S. Chamber of Commerce regarding PEG Access and cable customer service obligations bemoan a litany of statutory -- not regulatory -- obligations from the 1992 Cable Act. NATOA believes these comments are beyond the scope of this proceeding, Commission’s Docket No. 25-133.
NATOA firmly believes that PEG Access centers and their cable channels play a vital role in the local communities they serve. These commitments are negotiated in good faith with the cable operator through the franchising process. And, PEG support through cable franchising is an integral element of a communities’ compensation for use of its rights-of-way.
NATOA found little evidence of unnecessary burden in industry comments filed in GN 25-133 on Cable, Broadband & Wireless Reporting and Customer Service Obligations. Rather, we viewed the comments on consumer protections as efforts to diminish the disclosure and transparency of services purchased or contemplated and transaction culminated. The NCTA (cable association) listed pages of regulations that want removed, including franchise transfer rules and PEG regs.
NATOA urges the Commission to reflect on the intent of the regulations, requirements and obligations on America’s cable, broadband and wireless consumers and weigh the protections offered to our citizens against the harm caused by their elimination.
As we discussed a couple of weeks ago in our Policy, Chapter and Franchising calls, Andrew Schwartzman at the Benton Institute had a good take on the Notice and proceeding, saying: "It's couched as coming from the FCC but isn’t the result of a commission vote: The public notice was issued on delegated authority but isn’t associated with any bureau or office other than the Office of Media Relations."
In a joint filing, the National Association of Counties, National League of Cities and the U.S. Conference of Mayors called on the FCC to roll back three deregulatory orders issued between 2018 and 2020 that they say have undermined local control over broadband and wireless infrastructure deployment.
NLC, NACO and USCM said: “By repealing the above-mentioned orders, we believe that local governments will be better able to innovate, expand broadband infrastructure investment strategically, and protect residents’ health, safety, and rights.”
NATOA files Reply Comments in Delete, Delete, Delete, GN Docket No. 25-133
April 28, 2025: The National Association of Telecommunications Officers and Advisors (NATOA) filed Reply Comments in response to the Federal Communication Commission’s (“Commission”) Notice in the Matter of Delete, Delete, Delete, GN Docket No. 25-133.
NATOA files these comments to express our:
NATOA supports and concurs with the Comments of NLC, NACO and USCM, the organizations representing America’s local government leaders, who have noted that the 2018 Small Cell Report and Order and Declaratory Ruling ”dramatically and inappropriately increased the extent to which the FCC directly imposed specific requirements on local permitting processes and limited local oversight of wireless infrastructure, by requiring specific shot clocks for permitting processes, limiting the factors communities may consider in permit applications, and dictating how localities may set fees for applications or use of public rights of way.”
NATOA objects to comments that undermine state and local governments’ authority to manage our public rights-of-way and our public safety role in land use.
We object to the mischaracterization and false assumptions that lead to local broadband permitting being described as an obstacle to broadband deployment. Broadband providers and deployers who suggest this are stepping on local governments’ role as guardians of public land which our citizens own and we manage, indeed, land upon which this industry seeks to build.
No one supports the successful deployment of broadband networks more than our local governments. We’ve a long and productive history of facilitating wireline deployment in our streets for generations of telephone, cable, broadband and wireless facilities. We continuously advocate for fast and affordable broadband service for all of our residents while at the same time addressing their needs and protecting their interests.
As former Commission Chairwoman Jessica Rosenworcel replied when asked about permitting in a June 2023 House Energy and Commerce Committee's Communications and Technology Subcommittee Hearing:
“I will tell you this: The biggest permitting problem now is on federal lands.
“Uncle Sam owns about 1/3rd of the real estate of this country and the standards for response back to those who want to build on those lands, we allow federal actors to take a lot more time to get back to someone who wants to build than we do state and local entities.
NATOA objects to Comments by NCTA – The Internet & Television Association and the U.S. Chamber of Commerce regarding PEG Access and cable customer service obligations bemoan a litany of statutory -- not regulatory -- obligations from the 1992 Cable Act. NATOA believes these comments are beyond the scope of this proceeding, Commission’s Docket No. 25-133.
NATOA firmly believes that PEG Access centers and their cable channels play a vital role in the local communities they serve. These commitments are negotiated in good faith with the cable operator through the franchising process. And, PEG support through cable franchising is an integral element of a communities’ compensation for use of its rights-of-way.
NATOA found little evidence of unnecessary burden in industry comments filed in GN 25-133 on Cable, Broadband & Wireless Reporting and Customer Service Obligations. Rather, we viewed the comments on consumer protections as efforts to diminish the disclosure and transparency of services purchased or contemplated and transaction culminated. The NCTA (cable association) listed pages of regulations that want removed, including franchise transfer rules and PEG regs.
NATOA urges the Commission to reflect on the intent of the regulations, requirements and obligations on America’s cable, broadband and wireless consumers and weigh the protections offered to our citizens against the harm caused by their elimination.
As we discussed a couple of weeks ago in our Policy, Chapter and Franchising calls, Andrew Schwartzman at the Benton Institute had a good take on the Notice and proceeding, saying: "It's couched as coming from the FCC but isn’t the result of a commission vote: The public notice was issued on delegated authority but isn’t associated with any bureau or office other than the Office of Media Relations."
In a joint filing, the National Association of Counties, National League of Cities and the U.S. Conference of Mayors called on the FCC to roll back three deregulatory orders issued between 2018 and 2020 that they say have undermined local control over broadband and wireless infrastructure deployment.
NLC, NACO and USCM said: “By repealing the above-mentioned orders, we believe that local governments will be better able to innovate, expand broadband infrastructure investment strategically, and protect residents’ health, safety, and rights.”
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