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CRE Letter to FCC Chairman Kennard on Cable Access July 21, 2000
Mr. William E. Kennard Dear Chairman Kennard: Enclosed is the Working Draft of the CRE paper "Market Driven Consortia, Implications for the FCC's Cable Access Proceeding" that discusses the development of consensus and non-consensus standards. CRE is a member of ANSI's Company Member Council. The CRE White Paper and Cable Access The draft CRE paper discusses a number of key issues regarding the development of private voluntary standards by both ANSI-accredited consensus organizations and by market-driven consortia. One of the issues discussed in the paper is the relationship between OMB Circular A-119 and the use in regulatory proceedings of private standards developed through consensus and non-consensus processes. You have announced your intention to request that the FCC begin proceedings on the issue of whether market forces will result in open access to cable television platforms for multiple internet access providers. In that standards used for interconnecting cable television systems with internet service providers will play a major role in implementing whatever policy is developed by the FCC, the development of these standards in integral to any broadband policy decision. The CRE paper discussing these issues is being placed on our website, www.theCRE.com, to ensure that it is well ventilated. The Center for Regulatory Effectiveness The Center for Regulatory Effectiveness (CRE) was established in 1996 after the passage of the Congressional Review Act to provide Congress with independent analysis of federal regulations. From this initial organizing concept, CRE has grown into a nationally recognized clearinghouse for methods to improve the federal regulatory process. The CRE receives guidance from the Center's Board of Advisors. The CRE's Board of Advisors is limited to former career chiefs of OMB's Office of Information and Regulatory Affairs. CRE has no members, but it receives, from time to time, financial support, services in-kind, and work product from trade associations and private firms. Consequently, at any one time, CRE benefits from the input or advice of literally hundreds of both small and large firms. The Exploratory Committee The Center for Regulatory Effectiveness is creating an exploratory committee to determine whether an ANSI Accredited Standards Committee (ASC) or a Market Driven Consortia (MDC) should be established for the purpose of developing standards for interconnecting cable televisions systems with the internet and other networks. As the committee proceeds with its deliberations, we will keep the Commission fully informed of its work. Sincerely,
Jim J. Tozzi
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