As we enter the second year of the implementation of the National Broadband Plan (NBP), the FCC has taken two important steps to break down barriers to building and expanding the fixed and mobile broadband networks that are so essential to the Plan's goals. The Commission has clarified that mobile providers have "data roaming rights," and it has also reformed and updated the arcane regime under which providers of communications services compensate utility companies to attach network equipment to their poles.

There are many good reasons for the FCC to take these steps, but most important is reducing uncertainty around the economics of building and sustaining broadband networks. The National Broadband Plan recognized that the FCC should adopt certain regulatory policies to ensure that broadband infrastructure is efficiently deployed throughout our nation. The team that worked on the NBP found that more than seven million homes do not have access to broadband, which is consistent with NTIA's recent findings that between 5-10 percent of Americans lack access to broadband. The decisions reached by the FCC will help network operators to address this broadband availability gap.

As the National Broadband Plan makes clear, data roaming is critical to the future of mobile broadband because "[f]ew, if any, [mobile broadband] networks will provide ubiquitous nationwide service entirely through their own facilities, particularly in the initial stages of construction and in rural areas. In order for consumers to be able to use mobile broadband services when traveling to areas outside their provider's network, their provider likely will need to enter into roaming arrangements with other providers." To compete effectively in the wireless space, new entrants must be able to provide nationwide service from the start, and roaming will be a critical component of that ability. And sensible data roaming policies will catalyze further investment in mobile broadband networks, helping to bring us closer to President Obama's vision for reaching 98 percent of Americans with high-speed wireless networks.

As important as data roaming is to further investment in mobile wireless broadband, providing certainty and reforming parts of the pole attachment regime is critical to further investment in all forms of broadband infrastructure, particularly in rural communities. The National Broadband Plan noted that "[a]pplying different rates based on whether the attacher is classified as a 'cable' or a 'telecommunications' company distorts attachers' deployment decisions." We couldn't agree more. Last year, when the FCC released its proposal for reforming the pole attachment regime, the cable industry's trade association, NCTA, noted that "establishing rates at levels that are as low and close to uniform as possible... will eliminate known disincentives to investment and promote timely and robust deployment of broadband facilities."

We believe these two steps by the FCC will help ensure the continued rollout and expansion of competitive broadband services. And these two decisions clearly show that the FCC is treating the National Broadband Plan as a plan of action. We commend Chairman Genachowski and his colleagues at the FCC for taking these important steps.