PUBLIC NOTICE Federal Communications Commission 445 12th St., S.W. Washington, D.C. 20554 News Media Information 202 / 418-0500 Fax-On-Demand 202 / 418-2830 TTY 202 / 418-2555 Internet: http://www.fcc.gov ftp.fcc.gov DA 09-2018 Released: September 4, 2009 COMMENT SOUGHT ON TELEWORK NBP Public Notice #3 PLEADING CYCLE ESTABLISHED GN Docket Nos. 09-47, 09-51, 09-137 Comment Date: September 22, 2009 One of the many possibilities broadband creates is transforming the way we work, enabling employees to work wherever and, often, whenever.1 For instance, the Government Accountability Office (GAO) was able to implement a significant telework program without diminishing its output after many of its employees were displaced as a result of an anthrax scare in Congress. More than half of the Patent and Trademark Office (PTO) employees telework and the PTO claims a savings of $2 million in fuel cost and 14,000 tons of carbon emission savings from its program.2 As we continue to work toward the development of a National Broadband Plan, we seek tailored comments regarding telework. 1. Broadband and Telework. Telework is not a new concept, but the capabilities of broadband may increase the practicality and remove limitations on telework. a. How does broadband increase the effectiveness of telework currently (i.e., what can employees do now with broadband that they could not do with a phone or a fax machine)? Has this been quantified? What empirical data and studies are available? b. How can employers use telework to increase output during events such as natural disasters, outbreaks of disease, or other contingencies that limit employees’ ability to be physically at a particular location? c. What technologies, processes, regulations, and capabilities need to be in place to allow government, businesses, and employees to quickly shift to telework effectively and economically in case of natural disasters, outbreaks of disease, or other contingencies? d. Going forward, how could broadband change telework? e. What applications do teleworkers most frequently use? How do the applications used change across different industries and user types? f. What broadband characteristics are essential for teleworkers to be able to use those applications and succeed in telework (e.g., low latency, consistent data rates, mobility, reliability, etc.)? g. How will these characteristics evolve? What is the impact of improved hardware and software and increased capabilities for compression and signal processing? 1 See, e.g., Vivek Kundra, Presentation at the E-Government and Civic Engagement Broadband Workshop (Aug. 6, 2009) (presentation available at http://www.broadband.gov/docs/Fcc_OpenGov_CIO_Kundra.pdf; transcript available at http://www.broadband.gov/docs/ws_01_egov_transcript.pdf); Telework Coalition Comments at 1–3; Women Impacting Public Policy Comments at 1–2; Mike Taylor Comments at 1. 2 See Kundra, supra note 1. 2 h. How do efficiencies and employee capabilities scale with increased data rates or other broadband enhancements? i. What do the data suggest about the benefits or harms of current telework programs?3 j. What do the data suggest about the benefits or harms of telework programs if these programs were more widely used? 2. Telework and Economic Development. a. How have telework programs helped attract jobs or companies to economically struggling areas? How has telework factored into local or regional economic development efforts? b. What examples of local and regional practices, policies, or incentives have been most effective at stimulating the creation of net new jobs through telework? c. Are there effective examples of regions developing “telecottages” or other shared workspaces for teleworkers that created economic benefit? 3. Programs. a. What percentage of private, public, and non-profit entities have telework programs? b. What percentage of employees use telework programs on a regular basis? What demographics of employees typically take advantage of telework programs? c. How have telework programs helped in employee retention? d. What telework program policies have been particularly successful or unsuccessful? e. What have been the direct costs and benefits of telework programs, including methodologies for calculating savings and other benefits? f. What international examples of practices, policies, or incentives should we consider as illustrations of the most effective or ineffective ideas? g. What are the general characteristics of successful telework programs? h. What programs, policies, or incentives have been most effective at training individuals so that they are ready to telework? How have communities and employers addressed digital literacy skills and job readiness prior to enabling employees to telework? i. What barriers, other than lack of broadband, exist that impede the development of successful telework programs?4 j. How can telework best be used to create opportunities for currently underutilized potential segments of the work force such as the elderly, disabled, or family caretakers? k. What telework programs exist to assist members of disadvantaged and disabled communities to work more effectively and efficiently?5 This matter shall be treated as a “permit-but-disclose” proceeding in accordance with the Commission’s ex parte rules. See 47 C.F.R. §§ 1.1200, 1.1206. Persons making oral ex parte presentations are reminded that memoranda summarizing the presentations must contain summaries of the substance of the presentations and not merely a listing of the subjects discussed. More than a one- or two-sentence description of the views and arguments presented generally is required. See 47 C.F.R. § 1.1206(b). Other rules pertaining to oral and written ex parte presentations in permit-but-disclose proceedings are set forth in section 1.1206(b) of the Commission's rules, 47 C.F.R. § 1.1206(b). 3 See, e.g., Digital Energy Solutions Comments at 2 (reducing CO 2 output); Mobile Future Comments at 5 (consuming less energy). 4 See, e.g., National Urban League Comments at 2 (citing “data privacy, liability for at-home accidents, and employee monitoring” as potential barriers to telework programs). 5 See, e.g., Telecommunications for the Deaf Comments at 4 (citing telework as a possibility for deaf individuals who receive functionally equivalent broadband services). 3 All comments should refer to GN Docket Nos. 09-47, 09-51, and 09-137. Please title comments responsive to this Notice as “Comments—NBP Public Notice #3.” Further, we strongly encourage parties to develop responses to this Notice that adhere to the organization and structure of the questions in this Notice. Comments may be filed using (1) the Commission’s Electronic Comment Filing System (ECFS), (2) the Federal Government’s eRulemaking Portal, or (3) by filing paper copies.6 Comments filed through the ECFS can be sent as an electronic file via the Internet to http://www.fcc.gov/cgb/ecfs/ or the Federal eRulemaking Portal: http://www.regulations.gov.7 Generally, only one copy of an electronic submission must be filed. In completing the transmittal screen, commenters should include their full name, U.S. Postal Service mailing address, and the applicable docket or rulemaking number. Parties may also submit an electronic comment by Internet e-mail. To get filing instructions for e-mail comments, commenters should send an e-mail to ecfs@fcc.gov, and should include the following words in the body of the message, “get form.” A sample form and directions will be sent in reply. Parties who choose to file by paper must file an original and four copies of each filing. Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-class or overnight U.S. Postal Service mail (although we continue to experience delays in receiving U.S. Postal Service mail). All filings must be addressed to the Commission's Secretary, Office of the Secretary, Federal Communications Commission. · The Commission’s contractor will receive hand-delivered or messenger-delivered paper filings for the Commission's Secretary at 236 Massachusetts Avenue, N.E., Suite 110, Washington, D.C. 20002. The filing hours at this location are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held together with rubber bands or fasteners. Any envelopes must be disposed of before entering the building. · Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743. · U.S. Postal Service first-class mail, Express Mail, and Priority Mail should be addressed to 445 12th Street, S.W., Washington, D.C. 20554. People with Disabilities: To request materials in accessible formats for people with disabilities (Braille, large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or call the Consumer and Governmental Affairs Bureau at (202) 418-0530, (202) 418-0432 (TTY). For further information about this Public Notice, please contact Randy Clarke at (202) 418-1500. - FCC - 6 See Electronic Filing of Documents in Rulemaking Proceedings, 63 Fed. Reg. 24121 (1998). 7 Filers should follow the instructions provided on the Federal eRulemaking Portal website for submitting comments.