Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554


In the Matter of:                                                   )
                                                                             )
A National Broadband Plan for Our Future        )	GN Docket. No. 09-51
						  


COMMENTS OF THE 
OFFICE OF ADVOCACY, U.S. SMALL BUSINESS ADMINISTRATION


      The Office of Advocacy of the U. S. Small Business Administration (“Advocacy”) 
submits these comments to the Federal Communications Commission (“FCC” or “Commission”) 
in the above-referenced docket.  Advocacy commends the Commission for its efforts to 
produce a National Broadband Plan (Plan), and to define the broadband landscape for the 
foreseeable future.  While hopeful that the Commission’s expertise will ensure the feasibility of 
the initiative, Advocacy would like to take this opportunity to make a few suggestions with 
respect to the Plan and small business.
      Based on whether the framework in the Plan will accommodate the continued existence 
and growth of small business providers, Advocacy strongly suggests that the Commission start 
the process of redefining size standards with the U.S. Small Business Administration.  This 
review is needed mainly to reflect the financial and technological changes that have occurred in 
the market.
      Current size standards are set out in the following chart:

Subsector 517 -- Telecommunications
Wired Telecommunications Carriers
1,500
Wireless Telecommunications Carriers (Except Satellite)
1,500
Satellite Telecommunications
$M 15.0 
Telecommunication Resellers
1,500
All Other Telecommunications
$M 25.0 
Subsector 518 – Data Processing, Hosting, and Related Services
Data Processing, Hosting, and Related Services
$M 25.0 
Subsector 519 – Other Information Services
News Syndicates
$M 7.0 
Libraries and Archives
$M 7.0 
Internet Publishing and Broadcasting and Web Search Portals
500
All Other Information Services
$M 7.0 

      As is evident from the chart above, there are three North American Industry 
Classification System Codes (NAICS) defining telecommunications and related services.   
Additional classifications may be needed to account for small broadband and 
telecommunications providers, as they are currently “lumped” with one of the categories above, 
and not explicitly accounted for.  Moreover, in November of last year, Advocacy advised 
NTIA in its efforts to enhance the small business size standard definition for applications to the 
Broadband Technology Opportunities Program (BTOP).  Advocacy is available to assist the 
Commission with the determination, if needed.

      In conclusion, small telecommunications providers have seen their fortunes grow and 
disappear since the passage of the Telecommunications Act of 1996. Those still in existence, as 
well as new entrants, are anxiously waiting to see how competition will be defined by the Plan. 
Advocacy’s suggestions would help support and account for this important sector.


      Respectfully submitted,
      /s/ ___________________________
      Susan M. Walthall
      Acting Chief Counsel for Advocacy
      
      /s/ ___________________________
      Major L. Clark III
      Assistant Chief Counsel 
      
      /s/ ___________________________
      Radwan N. Saade
      Regulatory Economist
       

Office of Advocacy
U.S. Small Business Administration
409 3rd Street, S.W.
Suite 7800
Washington, DC 20416

March 5, 2010

cc:
Chairman Julius Genachowski
Commissioner Michael J. Copps
Commissioner Robert M. McDowell
Commissioner Mignon Clyburn
Commissioner Meredith Attwell Baker

The Honorable Cass Sunstein, Administrator, Office of Information and Regulatory Affairs

via electronic filing
  In the Matter of A National Broadband Plan for Our Future, GN Docket No. 09-51 (Rel. April 8, 2009).
  The three-digit codes define industry sectors, and the six-digit codes particular industries.
 
 
 
 
Office of Advocacy		Comment
U.S. Small Business Administration		GN Docket No. 09-51