HomeMy WebLinkAboutTC Res 1995-07-19 (3)
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RESOLUTION NO. .lIJ.Q
A RESOLUTION OF THE TOWN COUNCIL
OF THE TOWN OF TIBURON ADOPTING
THE TENETS OF THE LEAGUE OF CALIFORNIA
CITIES' TELECOMMUNICATIONS POLICY
WHEREAS, the Town of Tiburon recognizes the importance of the emerging national
informational infrastructure; and
WHEREAS, the Town believes that development ofthis new infrastructure raises
important questions concerning social, economic and public policy; and
WHEREAS, the Town believes that development ofthis infrastructure will involve the use
of public rights-of-way, resulting in traffic disruption, noise and air pollution, and reduced
pavement life; and
WHEREAS, the Town believes that local governments should have a voice in
development of this new infrastructure; and
WHEREAS, the Town believes that local governments need to protect public rights-of-
way, receive compensation for the use of the street by private companies, and receive a fair
allocation of services, resources and bandwidth from companies developing this new
infrastructure; and
WHEREAS, the League of California Cities has adopted a Telecommunications Policy,
attached as Exhibit 1; and
WHEREAS, the Town fully supports and endorses the efforts of the League of California
Cities to preserve and protect the rights of cities to address their concerns with respect to this
infrastructure;
NOW, THEREFORE, IT IS RESOLVED by the Town Council of the Town of Tiburon
as follows:
L The Town ofTiburon supports and endorses the League of California Cities
Telecommunications Policy: and
2, The Town ofTiburon agrees with the tenets set forth in the Telecommunications Policy
and adopts the following tenets as policy for the Town of Tiburon:
a. Access to advanced telecommunications services must be available to all citizens,
as well as the commercial, education and government sectors.
b.
There should be an open, competitive marketplace for telecommunications.
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c, Local governments must have a role in the regulatory structure to preserve their
local authority over matters oflocal import,
d.
Local governments must be compensated for use of public rights-of-way and
negative impact on local infrastructure.
e, Local governments should help safeguard citizens against market inequities in the
advanced telecommunications marketplace by maximizing their ability to utilize
and facilitate access to telecommunication resources, including the option of
becoming providers,
f, Local governments should be allocated adequate spectrum capacity for public
safety, emergency services, public works and other public use,
NOW, THEREFORE, IT IS FURTHER RESOLVED that the Town Clerk is directed to
transmit this resolution to the League of California Cities, to state and federal officials
representing the Town ofTiburon, and to the Mayors and City Councils within Marin County.
PASSED AND ADOPTED at a regular meeting of the Town Council of the Town of
Tiburon on July] 9, ] 995 by the following vote:
AYES:
NOES:
ABSENT:
COUNCILMEMBERS:
COUNCILMEMBERS:
COUNCILMEMBERS:
Nygren, Ginalski, Thompson, Wolf, Thayer
None.
None.
ad./~~
ANDREW THOMPSON MA
ATTEST: j/}; f}
I (I l(A~_
DIANE L. CRANE
TOWN CLERK
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EXHIBIT I
League of
California Cities
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Telecommunications
Policy
As GdDpl~d April, 1994
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Executive Summary ,
The 1990s will witness the rapid development and deployment of advanced
telecommunications services. The telecommunications industry Is developing digital
technology to enhance its traditional delivery systemoocopper wire for voice, coaxial cable
for video--to support a host of new services. These industries are also developing high
speed/high capacity networks, commonly referred to as broadband networks, that are
capable of integrating voice, data, video services along a single wire. The development
of advanced telecommunications infrastructure, often referred to as the if/jOm/Oliof/
superhighway, promises to increase competition and to stimulate economic development
as new products and services are introduced into the teleconununications marketplace.
California cities can look forward to using these ilUlovative technologies to enhancc
public setvices,and streamline government operations.
While the information superhighway presents considerable opportunities, it also carries
an clement of uncertainty and risk, and has significant Ciscal and policy implications for
cities, For example, under current law, cable operators are subject to municipal
franchise agreements, which include local control over rates and customer service
standards, as well as franchise fees. Telephone companies, on the other hand, are
exempt from these franchise provisions. As advanced telecommunications technology
makes telephone setvice less discernable from cable serJice, cities' franChising authority
may be in jeopardy.
The telecommunications industry is already leveraging to take advantage of the I=i},:lnges ,
in the marketplace, Regional telephone companies are merging with cable'lV"':'-: ' ..'..,:'
companies in order to circumvent the existing "cross. ownership' ban which prohibits
telephone companies from providing video services. and cable operators from providing
telephone setviee, In California, Pacific Bell has filed suit to challenge this ban as it
deploys a $16 billion plan to wire residential areas in the state with broadband capacity,
Furthermore, the Clinton Administration has stated its intent to remove regulatory
"barriers" at all levels of government in order to streamline the development of advanced
telecommunications services, As these events unfold, the regulatory powers cities enjoy
are becoll"ing increasingly vulnerable. and cities must take steps to ensure that their role
in protecting the interests of their communities is not sacrificed in the interest of
developing tbe information superhighway,
Principles that Guide Le::lgue Telecommunications Policy
The League of California Cities has developed the following principles that reflect the
interests of cities in the development of telecommunications policy:
Cities must have certain regulijtory powers over
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negative impacts of installing fiber'op~ic and other
telecommunications wire in city streets and in the public
right-of-way, Securing these revenues ",ill be especially
important if municipal franchises for cable service are
eliminated due to a softening of the existing regulatory and
franchise powers.
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Cities recognize that broadband capacity has considerab:e
value. in that it can be used both to support city operations
and to streamline delivery of a variety of public services.
Cities should receive an appropriate allocation of all
advanced telecommunications resources, such as bandwidth
on broadband r.elWorks,fiber-optie wiring, and spectrum on
the 800 Mh radio frequency, that operate within their sphere
of influence.
Summary of the Telecommunications Policy Statements
Universal Access
Legislation enacted to facilit:lle the development of the National Information
Infrastructure, and the California InformatiOn Infrastructure. should enS\lre that access to
advanced telecommunications services is available to all citizens, as well as the
. commercial, education, and government sectors,
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Role of City in Regulatory Structure
The League supports efforts to cstablish an open, competitive marketplace for
telecommunications scrvkes. jncluding the lifting of the cross-ownership ban and a level
playing field for telecommunications service providers. An integral component of this
open marketplace is the symmetrical application of regula:ions [0 all telecommunications
service providers. including wireless service providers, The League also supports the
preservation of local au thority over mailers of local impact.
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Telr.:communic.al,on~ Policy
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Compensation for Use of Public Rights-of.Way and Negative Impact on Local
Infrastructure
The use of public streets and rights-of-way via the installation of pipes, conduits and
wires to engage in private, for profit enterprise demands a fair payment for the use of
the public's asset, The League supports a symmetrical application of right-or.way fees
for all users of the public right-of-way, including telecommunications service providers,
Cities should also receive compensation for the short- and long-term negative impacts of
installing fiber-optic and other telecommunications wire in city streets and other
locations in the: public right-of-way.
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Cities as Users/Pro,viders of Telecommunications Services
TIJe Lc:~~UI: .L l;~oga.izt.3 thAt advc.nccd tclceom:munic:otioM reeourc.C hnve eons:idcf-abIe
value. Cities should help safeguard citizens against market inequities in the advanced
telecommunications marketplace by mall:imizing their ability to utjlize and facilitate
access to telecolnmunications resources.
Adequate Spectrum Capacity for Public Safety and Other Public Use
r" Cities should be allocated adequate spectrum on the 800 Mhz radio frequency for public
safety, emergency services, public works, and other public use.
FCC Certification of Local Franchising Authority
The League encourages cities to certify their local cable TV franchising authority to
protect the interests of their citizens. Federal and state law should secure the rights of
local franchise authorities to regulate cable service rates if they have received
certification from the FCC.
Privacy
The League 'supports the protection of privacy and security for consumers of advanced
teleC"Ommunications services.
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League of California Cities
TelecommunicatioDs Policy
Table of Contents
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Foreword , . . ' , . . , , . , ' . , . . ' , . , . . . . . . . , . . , . . . . , . . . . . . , . . . , , . . . . . . . . .. ii
Background .....,.....,.,..........,.........",.""........... -.. ... 1
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Telecommunications Policy at the Federal Level ...,.......,......,..., 1
Telecommunications Policy at the State Level .,...',."..........,.... '2
Telecommunications Policy at the Local Level ,...".......,..,..'..,., 2
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"A Telecommunications Framework for Cities" . . . . . . . . , . . . . . _ . . . . , . . . .. 3
Policy Statements, . , , . . . , ' . . . , . . . , , . , . . , , . . . , . . , , , . , , . , . , . . . . . . , , . , , . 4
Universal Access ..,., . . . , . . . . , . . , . . . . . . . , . . . . , . . . , . . . . . . . ' . . . . . 4
Role of the City in Regulatory Stmcture ..........."................ 5
Compensation for Use of Public Rights-of-Way
and Negative Impact on Local Infrastructure ,......,'...,...,..'...... 5
Cities as Users/Providers of Telecommunications Services .'..,....,...... 6
Adequate Spectrum Capacity for Public Safety and Other Public Use ....,... 7
FCC Certification of Local Franchising Authority. . . , . . . . , . . . . , . . . . . . . . . 7
PriV<lCY ,..".,.'".'",.....,..,....",.",., :", . . , , . . , . . , , . . . 8
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League of Calirornia Cities
Tc:lccommunic..lio~ Policy
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Foreword
Rarely a day goes by that one does not hear some reference to the so called "information
~perhighway". The rapid development of advanced telecommunications resources, such
as fiber optic networks' that wlll carry voIce, video and data signals, cames the promise
of new economic prosperity and new tools for streamlining the delivery of both public
and private services. While California cities can look forward to enjoying these benefits
in the near future, we must also be mindful of the impact of the emergence of this
. spawning industry both on cities, and on the citizens they serve. To this end, the Leag'Je
l!f California Cities has developed a comprehensive telecommunications poliey that will
help cities define their roles as user, provider, regulator, and consumer advocate on the
information superhighway. '
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The policies outlioed in this report are a product of the knowledge, experience and
values of several dozen city officials who make up the Leagne's Telecommunications
Task Force. A primary objective of the TelecommunicatioJlS Task Force has been to
increase city officials' awareness of the relevance of teleco=unicstions policy in the
business of local goverrunent, The Task Force has spent the past five years addressing
telecommunications iSSues as they relate to cities, Over the years, their work has
included educational forums, pilot projects for telecommuting and facilities sharing, and
a comprehensive report entitled A' Telecommwlicario/lS Framework for Cities which was
developed by the Institute for Local Self Government aIld adopted by resolution at the
League Annual Conference in 1991.
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The policy statements contained in this report are the latest w(?rk product in a continuing
effort to develop meaningful resources for cities 10 use in dealing with the complex and
ever.changing arena of advanced telecommunicatio:J5, Cities sho:lld use these polides to
guide their discussions and negotiations with telecornIllunications providers who wish to
do business in their city.
While these policies cover a wide range of telecommunications issues, the League is
mindful that this is a "living" document that will change and evolve continuously to
reflect the evolution of the advanced telecommunications industry. The League ir.vites
cities to share ideas and concerns regarding it's telecommunications policy. Input from
the telecommunications industry, our partners in the development of a California
Information Infrastructure, is also welcome. Most important, the League urges cities to
participate in the work of the Telecommunications Task Force so that we can expand
both the scope and the depth of these policies.
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Background
Telecommunications Policy at the Federal Level
Tile National Information Infrastructure. The Clinton Administration, under the direction
of Vice President AI Gore, is promoting the development of the National Information
Infrastructure (NIl). According to its advocates, the NIl will be an integrated network
system that will 'ultimately connect the nation's businesses, residences, schools, health
care facilities, and other public information. and social service providers through a
broadband, interactive, telecommunications and jnformation network." Citing the need
for a new policy framework to streamline the development of the NIT, Vice President
Gore outlined a legislative agenda that will create a "flc::<ible. adaptable approach" to the
tc:Iecommunications industry, The Administration's initiatives reflect the following
objectives:
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Increase competition and private invcstme:Jl in
communications by removing unnecessary regulations and
artificial barriers to participation by private firms in all
communications markets. For example, the Administration
proposes to permit cable companies and others to provide
local telephone service;
Secure open access to the network for consumers and service
providers, For example, the legislation requires all local
telephone companies, upon reasonable request, to
interconnect their networks with the facilities of competing
providers on nondiscriminatory terms;
Preserve llnd advance universal service for all Americans
across all sectors of society, Because full and productive
participation in American society will inc~easir.gly depend on
access to Information, the Administration is committed to
promoting the availability of information resources to all
people at affordable prices;
Develop a new regulatory f:amework that is flexible and fair
by allowing the FCC to reduce regulation for
telecommunications carriers that lack market power.
1992 Cable ACI . In addition to establishing benchmark rate regulatioILS for cable TV
service, the 1992 Cable Act strengthened local governments' roJe in regulating cable
television by outlining local franchise authority over cable service. TIle Act allows local
governments to certify franchising authority with the FCC and, based on ::tpproval of
,~ certification, to regulate basic cable service rales in their area. Local franchise
authorities may also establish and enforce customer service swnda:ds and construction
schedules,
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T::lcco:'Jlmunic."\tioF1i Polky
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Telecommunications Policy at the State Level
California PUC Report - A November, 1993 report from the Califomia Public Utilities
Commission entitled "Enhancing California's Competitive Strength: A Strategy for
Telecommunications Infrastructure," makes the following findings:
'Public networks should be linked in an integrated,
interoperable infrastructure
Universal access is a key component of the infrastructure that
includes affordable applications, low cost customer
equipment, education and trail'Jng programs, Universal
service shOuld be tr:msformcd from a subsidized monopolistic
model to a competitive, multi-provider model.
Competitive forces should drive the infrastructure and
rrJnimize the potential for publicly.funded infrastructure,
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All telecommunications markets should be open and
regulatory process should be streamlined, The report
specifies a three.year time frame in which to eliminate cross.
domai,l barriers, The report also places the bulk of
regulatory authority Wilh the PUC.
The slate should crcate "open compelition zones" to assess
the impact of opcn competition in the telecommunications
market,
Telecommunications Policy at the Local Level
City EffortS to Comply with tire Cable Act - As stated previously, the 1992 Cable Act
outlines specific regulatory roles for local governments, A key issue facing local
governments is that cities must obtain certificalion from the FCC in order to secure
regulatory authority of basic cable service rates. , For many cities, the rate review analysis
required as part of the certifi,cation process has been complex and difficult to cO:Jlplete,
To date, approximately half of the cities in Caiifo:nia that could certify have done so.
While federal and state officials continue to urge cities to certify, the recenl statements
regarding removing regulatory barriers to a competitive telecommunications market raise
an important question: Does it make sense for cities to obtain FCC certification if the
reg-..llalory powers the certification process seeks to es;ablish are going to be eliminated
or significantly reduced to open the telecommunications markctplace?
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Lc,guc o( c.liro,r.i, Cilies
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Telecommunicalions Policy
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':.4 Telecommunlcations Framework for eilies"
This report, presented by the Telecommunications Task Force in 1991, outlines
telecommunications issues and trends, and provides options available to cities acting as
telecommunications user, consumer and pOlicy. maker. A Telecommunications FrameK,'Ork
for Cities prepared by the Institute for local Self Government makes the following
observation.~;
Effective use of teleconununications can increase efficiency
and provide new solutions to city problems.
Cities' current investment in telecommunications is significant
and will grolV, but lack of coordination among city
departments results in jnefficient use of these resources and a
lack of planning for future needs.
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Municipal governments are dependent now en transportation
and communications to conduct the public business while the
community depends on the same combination to access vital
services and information. This reliance of communications
will increase as city governments and citizens alike are forced
to find alternatives to automobile travel,
Many cities arc unprepared to utilize the fllll potential of
available telecommunications technologies effectively:
Current uses are cor.eentrated in a few departments. There
are few central resources for planning ant: implementing new
applications,
Consumer decisions are ofter, motivated by mistake
avoidance rather than meeting the needs crented by new
applications, Development programs are inhibited by the
lack of knowledge about total telecommunications com.
invested capitnl, and physical plant.
Local telecommunications policies beyond the cable ,
television franchise are rare, and cable lcievisiort polig, in
many cities feils to address community needs.
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Federal and Slale legislatures and rcgulatory agencies arc
changing the rules governing telecommunications markets to
create competition and spur innovation. Thc~e changes will
affect pricing and impact long-standing public policy. such as
universal phone service, Cilies lack a cohcre1C,
comprchensive position on the role of cities in a competitive
telecommunications marketplace.
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Policy Statements
Universal Access
One of the most important policy issues surro~nding telecommunications is that of
universal access to telecommunications services. Policy.makers at all levels of
government have eXJJre~ser.l concern over the potential for creating a system of
information "haves andhave.nots." However, while terms such as open access and
interoperability are used frequently in discussions of the National Information
Infrastructure, a working definition of universal access has not been adopted at any level
of government. The League's definition of universal access is reflected in its policy
statement;
Policy Statement - Legislation enacted to facilitate tire development of the National
/nfonnation/nfrastruClure, and the California Information Infrastructure, should /
ensure that access to advanced telecommunicarions services is available to all
dtizen.s, as well as the commercial, education. and gOIJernment sectors. Elements of
universal access should include:
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Open access to consumers as well as service providers
Connectivity /0 business Clnd govemmem, as well as residential
areas
Unifoml and indiscriminale wiring of all locations in a business
or residential area
Affordability OfJeNicas, equipment and training
Flexibility of service options and delivery me:hanisms 10 reflect
the needs of individual communi:ies
Competitive choice in consumer seNice options
Fees or charges to fund universal sefVice provision
Ability to send and receive infonnation altransmission rales
that are adequate for broadband application..l
Ability to communicate with any individual OIl a network
(addressable communicatlon.s)
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lThc Lc..ZUC: recommends ~ minimum bandwidth of ten (10) mcg;)bytes per second, bi~djrc~cion.dJ)'.
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Role of the City in Regulatory Structure
The impetus for removing regulatory barriers to a competitive telecommunications
marketplace is strong. Recent federal and state policy reports suggest that regulatory
authority over service delivery, rates, and customer service standards should be
coru;olidated either at the federal or state level. While there are sound arguments for
streamlining regulations, the fact remains that telecommunications services will be
delivered locally and the nature and scope of these services will be different from
community to community. The deployment of advanced telecommunications networks
will also ha'/e considerable impact on the economic: development and vitality of
communities, as well as ar: impact on local infrastructure. Hence. the League's policy on
streamlining regulation seeks to preserve cities' ability to secure telecommunications
services that reflect the needs of their communities and to preserve and enhance city
infrastructure.
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Policy StRtemcnt . The League Suppons effons to establish an open, competitive
marketplace for telecomnwnicarions services, ineluding the lifting of the cros;;.
olVnerslr~D ball and a level plCl'Jing field for telecommunications sendce providers. All
illtegral component of this open marketplace is the symmetn'cal application of
regulations to all telecommullica/io11S service providers. including H:ireless service
providers, The League also supports the preservation of local authority over malters
of local impact, illcluding:
Constfuctioll standards', pennirting, schedullng. and cosr
recovery
Customer service standards
. Rare regulation for cities that choose to regulate
. Negative impact on local infrasrmcrure alld cost recovery
City use of /elecommunlcationsresources (Ioca! PEG access, I.
Nets)
Method of ins/al/arion (pedestais, overhead, llnder.ground)
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Compensation for Use of Public Righls-of.W.1Y nnd Ncgatil'c Impact en Loc;'!1
Infrastnlcture
The traditional right of franchising includes the power of a dty to choose who may enter
the market by granting or withholding a franchise. Franchising powers contain implicit
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llnclude, the provisions of Californi. pue R"lc 20A, (Undcrgroundina Program) whioh would require
Ic!ccommur:iC;ltions fiJcililics to p;lrlicip:ltc: by placing Underground ~Jl oycrht:ad rJ.ciIilies within any underground
districl Icsisl.ted by a cily.
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legal barriers to market entry,'which sOllle ar~'Je are inconsistent with the policy of an
open and competitive market. One tr.echanism that has been proposed to remove the
legal barriers to telecommunications markets, while preserving the regulatory powers
cities need to protect the interests of their communities, is to replace the franchise fee
element of the 1992 Cllble Act with a right-oC-way ,compensation ,statute. In addition to
compensation for use of right.of.way, cities should receive compensation for the shon-
and long-term negative impacts of installing fiber-optic and other telecommunications
wire, such as street degradation and the increased maintenance costs that occur when
streets are opened.
Policy Statement. The use of public streets and rights-of-wUj via the installation of
pipes, conduits and wires to engage in private, for profit enterprise demands a fair
payment for Ihe use of the public's asset, The League SUppOTtS a symmetrical
J application of right-oJ-wl1J' fees for all users of the public right.of-way, including
telecommunications service providers, Cities should also receive compensation for the
short- and long-teml negative impacts of installing fiber,optic and other
telecommunication.s wire ill city streets and other locations in the public right.of-way.
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Cities as Users/Providers of Telecommunications Services
One element of many c:.bJe franchise agreements is the development of institutionJI
networks (I-NETs) that give municipalities cable TV facilities and'other
telecommunications resources, Advanced telecommunications techr.ology will make
many of these I.NET systems obsolete. However, cities have the opportunity to acquire
a portion of a broadband network (commonly referred to as bandwidril), as well as other
advanced telecomll1unications resourceS through franchise or other ag,eements,
Acquiring bandwidth on a broadband network would allow municipalities to develop a
wide range of telecommunications-based applications beth for internal use, and for
providing services to their communities. City-provided tele~onununications services
could also help mitigate market inequities in the telecommunications market. For
examDle, if the costs of installing and operating broadband networks prices the access to
these' networks beyond the incomes of certain citizen groups, cities could create public
access systems, such as information kiosks or library tenrJnals to facilitate access.
Policy Statement. The League recognizes that advanced telecommunications
resources have considerable value, Cities should help safeguard citizen.s againsr
market inequities in the advanced telecommunications marketplace by maximizing
their ability to utilize and facilitate access to telecommunications resources, Strategies
to accomplish these objer:live:r include:
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Negotiate for all appropriate allocation of all advanced
tdecommunicalions resources, ifleluding bandwidth on
broadband networks, fiber. optic wiring, and spectrum on rile
800 M/IZ radio frequency, thai operate within tile city's sp/lere of
influence.
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In.stall and operate city,owned broadband networks, alld/or
fonn partnerships to install and operaJe regional broadband
networks.
Explore and develop public service applicattons thaJ employ
advanced telecommunications capabilities, so that these
resources can be put to lLSeas SOOIl as tlley are available.
Secure public access 10 advanced telecommunications networks
by wily of existing PEG access requirements.
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Identify and inwmtory lInused and/or abandoned cOl1duilthat
aisrs in the public right-ol-wIly, in easements, or on property
oWl1ed by the dry, ond develop strategies to leverage the ILlt of
these reSOl/rces,
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A.dequate Spectrum Cnpacity for Public Safety nnd Olher Public Use
During the conversion of city police, fire, emergency and public works radio services to
the 800 Mhz spectrum, not enough spectrum was allocated to ciries, As a result, in
metropolitan oreas, there has been a deterioration in transmission quality and the ability
for police, fire, and public works departments to broadcast. W;th the coming of
enhanced wireless, ceJIular. and personal communications services (PCN/PCS). cities
may lose again if adequate specrrum for these services is not reserved for city uses,
Policy Statement. Cilies should be allocated adequate spectrum on the 800 Mhz
radio frequency for pu/;lic safety, emergency services, public worb, ond olher public
use.
FCC Certilication of Local Franchising Authority
As stated previously, the 1992 Cable Act outlines the requirements and procedures for
cities to request certification as local franchising autho;ity in crder to regulate basic
cable TV service rates. In the interest of protecting the interests of their citizens. it is
desirable for dties to continue to regulate cable scrvice rates in their communities,
However, for many cities, the rate review analysis reqllired as p:m of the certification
process has been complex and difficult to complete. Cities must aiso decide if it makes
sense to obtain FCC certification if their regulatory powers are going to be preempted by
new federal or stale Jaws.
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Policy Statement - The League encourages cities 10 celtify their local cable TI/
franchising awhoriry to protect Ihe interests of Ihdr citi:ens. Federal alld state law
sflould secure the rights of local franchise authorities 10 rCF{J.lme cable service rales if
they have rtceh'ed certificatioll from the FCC.
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Privacy _.
A fundamental Issue surrounding the development of the National Infermation
Infrastructure (Nn) is the need to assure the privacy and security of ilS users. While
cities may not playa primary role in enforcing laws that govern privacy, they can be
active participants in the policy debate.
Policy Statement - The League supports the fOllowing principles that go_em the
issi.J/lS of privacy and security for COnsUme~ of advanced telecommunications s/lIViceJ:
Protectiol'! and reliable identification of the "digital signature"
that identifies the sender and recipient of electronic transactions
Transaction security for financial and other personr;;;J
transactions /
Concrol over ,he sale of subscriber illformation
Freedom of choice in the USe of encryptir;m technology to ensure
privacy and security
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