*Testimony to New York City Council on May 5, 2005 in Response to New York City’s Report to Mayor Michael R. Bloomberg “Telecommunications and Economic Development in New York City: A Plan for Action”:1*
Good morning. My name is Dana Spiegel and I am pleased to be here today to testify to the New York City Council’s Technology in Government Committee on behalf of NYCwireless, a non-profit organization that advocates for and enables the growth of free, public wireless networks in New York City, for which I serve as Executive Director.
Over the past four years, NYCwireless has been active in the deployment of free, public wireless networks in over ten New York City parks and open spaces through partnerships with local parks organizations and Business Improvement Districts (BIDs). We have also created community engagement programs that take advantage of wireless networks in Manhattan, such as our annual wireless arts festival, Spectropolis. NYCwireless is an all-volunteer organization with seven (7) board members, five (5) special interest working groups and approximately sixty (60) active members.
NYCwireless applauds the EDC, DoITT and the Department of Small Business Services working together with the Telecommunications Policy Advisory Group for their detailed report “Telecommunications and Economic Development in New York City”. We fully support the overarching principles of network reliability, access to broadband, and encouragement of innovation and entrepreneurship as goals in improving the City’s telecommunications infrastructure. In addition, we applaud the reports mention of emerging wireless technologies such as Wi-Fi and WiMax. In fact, many of the free, public wireless projects mentioned in the report were the work of NYCwireless in partnership with parks organizations and BIDs.
While we agree with many of the key recommendations in the report, I would like to highlight a number of areas where New York City’s plan for improving its telecommunications infrastructure could be strengthened. NYCwireless believes that there is a lack of true competition in broadband services in New York City and that affordable broadband options for small businesses, non-profit organizations and under-served areas are unavailable. We believe that this problem can only be solved by the active involvement of municipal government in stimulating competition in telecommunication infrastructure. Competition can come in the form of municipally owned open access telecommunication infrastructure (such as the Philadelphia project), non-profit projects (such as NYCwireless, BIDs, parks organizations) or private sector initiatives. In my testimony, I would like to highlight the work of NYCwireless, the value of non-profit organizations in providing alternative and redundant systems and the need for funds to help BIDs initiate their own projects. NYCwireless strongly believes that the encouragement of free, public wireless networks will help New York City realize it’s vision for the future of telecommunications infrastructure and economic development.
*NYCwireless Role in Wireless Hotspots*
NYCwireless has played an invaluable role in establishing the idea of public hotspots within public spaces within a City. Indeed, NYCwireless’ groundbreaking ideas and work first started this movement. By working in 2001 with local businesses, NYCwireless established Tompkins Square Park as the first Wireless Park in New York City. In 2002, NYCwireless brought this idea to the Bryant Park Restoration Corporation, and was successful in creating the City’s and the Nation’s most visible and popular Wireless Park. NYCwireless and Emenity, a small company that was created by NYCwireless co-founders Anthony Townsend and Terry Schmidt, worked with the Alliance for Downtown New York and the Union Square BID to create the extensive network of public hotspots in Downtown Manhattan and Union Square.
NYCwireless has developed an extensive and deep understanding of how to successfully create sustainable public hotspots in New York City. We continue to work with various City agencies and other non-profit organizations to expand New York City’s free, public hotspots. We are working to address digital divide issues, through partnerships with Community Access, a non-profit organization which provides transitional housing for mentally ill residents, to bring the internet to underprivileged residents, and are expanding the footprint of free, public hotspots into Brooklyn, The Bronx, and Staten Island. Additionally, since we are a non-profit organization, we are a highly valuable resource to all New York City organizations and individuals, providing Consulting, Education, Infrastructure Services, Deployment Support, and New Technology Development to all New York City inhabitants.
It is important that the work that NYCwireless has done and continues to do be recognized in this forum, since it is omitted from the Telecommunications and Economic Development in New York City Report.
Similarly, the report makes no mention of community organizations and non-profits as partners in implementing the reports recommendations. Just as NYCwireless represents a valuable asset to the City, so do the many other non-profit organizations that provide services to businesses and residents of the City. Wherever the report recommends a private company should provide service, recommends that the City should provide help to a private company, or recommends a public-private partnership, City non-profits should also be considered and included. This is particularly important when considering infrastructure or educational services, where non-profits already have extensive experience and the interests of the City are best served by socially oriented organizations.
In comparing New York City to other cities throughout the country and world with regards to broadband availability, the Telecommunications report does a laudable job of evaluating the City’s networks. The Report, however, omits an extremely important metric for broadband: Cost. Specifically, it states: “As of early 2005, the cost of basic residential DSL service in New York City was $29.95-34.95 per month, comparable to other American cities” (Page 20, Paragraph 2).
This statement, though factually accurate, leaves out important additional costs that effectively raise this rate to $50 and up. In the case of DSL, Verizon provides a low cost $29.95 service but requires that a Verizon provided phone line be installed as well. This costs an additional $8.60 per month for the most basic metered phone service, plus additional taxes and fees, as well as installation expenses, also charged through Verizon. In the case of Cable modem service, Time Warner Cable provides service for $29.95 per month as an introductory rate for 6 months. After 6 months, the rate rises to $44.95, plus taxes and fees.
Over the course of a 3-year period, broadband costs at least $1800. A resident can purchase and use a computer, for a cost of about $200 for those same 3 years. Current broadband conditions in New York City require a resident to spend 9 times as much on internet access as they do on their computer. This cost disparity is one of the most significant factors that leads to the lack of uptake of broadband services, and this is an issue regardless of a resident’s income level, though is felt most significantly by that population of the city that is underprivileged.
Additionally, the Report claims in a number of places that New York City is on par with other American cities for communications infrastructure for residents and small businesses. Though this is true as well, as the economic capital of America and leader among all Nations, we believe that New York City should be leading the rest of the country. With all of the fiber available in the City, and one of the most extensive and well-connected networks of Schools and Libraries, we should be setting the pace for broadband deployment, instead of merely keeping up. Our broadband availability, quality, speed, and cost should rival places like South Korea and much of Europe, where 10Mbps symmetrical and soon Gigabit symmetrical fiber connectivity can be had for the equivalent of $10-$30 per month.
*Network Security and Public Access*
Though not specifically mentioned in the Telecommunications Report, NYCwireless wishes to address the often-mentioned requirement that any City created emergency communications network must be separate from any general access and public access network. Current wireless technology has evolved significantly in the past few years such that the requirements of guaranteed service and security for first responder use of a City-wide network can be provided while still enabling the network’s extra bandwidth to be provided for public use.
Indeed, this type of network structure is exactly what is being implemented by Philadelphia’s Wireless Network and is a component of other municipal wireline and wireless implementations. In the same way that wireless networks are safely and securely used by the most secure of financial institutions and other companies, such security and availability can be provided over any Citywide network.
*DoITT Light Pole Licensing*
NYCwireless applauds the work that DoITT has done to enable more wireless service throughout New York City through its light pole licensing program. Unfortunately, the light pole program does have a few shortcomings, and its implementation will delay any possibility of using City light poles for Wi-Fi data networks, if such a service is ever deployed.
In the Telecommunications Report, “wireless” is often used to refer to both voice and data communications, which ignores some of the important differences between these two services. With respect to the DoITT light pole program, these differences are especially important. All of the light pole Licensees are large cell-phone oriented wireless providers or network operators, and especially considering Verizon’s recent announcement that it is abandoning Wi-Fi network plans in New York City, it appears that none of them are considering the light poles for use in a Wi-Fi data network deployment.
As implemented, the process of applying for and receiving a light pole usage License prevents many small businesses, non-profits, BIDs, and city agencies from using the light poles in any deployment strategy. NYCwireless has inquired about developing some networks that use the light poles, but the lack of License availability for a number of months (it is not clear at this time that further Licensees can even receive a light pole License), and the significant and onerous operational requirements have made this impossible. DoITT has created a scarce and expensive resource from an otherwise prevalent publicly funded one.
Furthermore, NYCwireless is concerned that the light pole Licensing program makes use of publicly funded resources for long periods without establishing a public service component of the Licenses, much as Independent Media Centers are funded through local franchise licensing. By making use of this public resource, we would like to see something given back to local communities by Licensors.
*BID Developed Hotspots*
The Telecommunications Report recommends BIDs take part in the build-out of hotspots within New York City. NYCwireless believes this is a critical recommendation of the report. Most of the hotspots that are available in Manhattan’s Public Parks are the result of BIDs working with NYCwireless, and having the foresight to see the beneficial effects of free, public hotspots on the economic development of New York City neighborhoods.
The BIDs that have sponsored hotspots in Manhattan are, in effect, the low hanging fruit. These BIDs—The DTA, The Union Square BID—and other similar organizations are the “haves” of the city. They are well funded, and have discretionary budgets that can be used to sponsor these hotspots, or at least partner with private companies, such as Intel, Google, and Wired Magazine to provide funding. Other BIDs that represent the majority of the business population in New York City, especially in Brooklyn, do not have the resources to pursue such hotspot initiatives. Thus, while Government provided guidance for these BIDs is helpful, it doesn’t address the issue of actually helping BIDs create hotspots throughout the rest of the City.
NYCwireless has first hand experience with such funding difficulties, working with the Montague Street BID in Brooklyn. We can provide education, and can be a knowledge partner for the build-out of public hotspots with these BIDs, however they still require the funding necessary to create and operate such networks.
NYCwireless recommends to the City Council that a “Technology Development Fund” be created that can be applied for by BIDs in order to gain the necessary funding to build hotspots.
Such funding would allow BIDs to pursue the growth of network infrastructure that existing BID based hotspots have shown to be an important economic growth driver for business areas. With funding, and guidance and best practices that NYCwireless can uniquely provide, BIDs will have the power to develop the economy and attractiveness of areas beyond Downtown and Midtown New York City.
*Wireless Networks as Business Continuity Backup Mechanisms*
Viewing Wireless Data Networks as a viable backup system for high-speed wireline networks is an informed perspective. It is notable that Wireless has grown so significantly in the past few years in terms of technology and availability that it can be considered a critical component of the City’s communications network. NYCwireless would like to provide further perspective on this point of view by highlighting how Wireless Data Networks, and in specific the hotspots that NYCwireless has enabled and built, can also serve as a viable backup service to many small businesses throughout New York City. To this end, we provide two brief examples of how NYCwireless and the hotspots that it has built have helped in the past few years:
* Immediately following the 9/11 terrorist attack, NYCwireless came to the aid of a few small internet companies in Downtown Manhattan. These companies were unable to get phone nor internet connectivity to their offices, and unlike the larger firms in the area, couldn’t rely on offices or partners in other areas of the City. Working with Pace University, NYCwireless was able to take the University’s internet connection, and beam it wirelessly to the offices of these companies in a matter of days. It would be weeks until Verizon was able to restore service in the area, but these companies were able to stay in business due to the innovative wireless solutions that NYCwireless provided.
* Two years ago, I was working for a small software company located at 6th Avenue and 23rd Street. Our internet connection was provided by a business DSL provider. While our connectivity and speed were generally fine, there were a handful of occasions when the DSL connection went down. Trying to get our line repaired, we discovered that the issue was actually with Verizon, who provided the local loop. We were offline for 4 business days while the CLEC and Verizon tried to repair the line (actually, all DSL serviced businesses in the building were effected by this outage). Lack of internet connectivity for an internet company can be disastrous. We had no alternatives, since the only available connectivity into the building was through Verizon (T1 or DSL local loop). Fortunately, we were located near Madison Square Park, where NYCwireless provided a hotspot. During our internet outage, I and my colleagues were able to use this hotspot to service our customers, thus keeping our company in business.
These stories, and many others like them, show how wireless hotspots can help provide backup and business continuity for small businesses as well, and can become essential even in non-emergency situations.
The Downtown Backup wireless network is a very worthwhile and important initiative, however the recommendation outlines the creation of an infrastructure that is owned by private industry. In the same way that we are now trying to undo the single dependencies and anti-competitive nature of fiber deployments in the city, we should learn from these lessons and ensure that any wireless network that is created should have carrier neutral and redundant infrastructure. Though we would like to believe that the wireless broadband companies that will be building and operating the backup service will exist in 5-10 years, it is prudent to recognize that market forces often result in many of these companies going out of business or being acquired.
NYCwireless recommends to the Council that any wireless backup network (a) be carrier neutral, (b) provide wireless redundancy from the outset, and (c) be owned by a neutral third party (such as a BID, non-profit, or city agency) that can maintain its operational continuity.
The City should ensure that the backup wireless system remains operational regardless of the disposition of the private companies that would operate it, since it will provide a necessary and critical component to New York City’s communications infrastructure.
Finally, NYCwireless looks forward to working with the Technology in Government committee, city agencies, other non-profit organizations and the private sector in order to make New York City’s vision for the future of its telecommunications infrastructure a reality. To that end, we urge that the City Council pass the resolution to create a new Broadband Task Force. Thank you very much.