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Boston Globe the Latest to Support Local Authority

Yet another major news outlet has endorsed the President's position in support of local telecommunications authority. On January 26th, the Boston Globe went on record to endorse the concept, urging the FCC and Congress to work together to ensure local communities have the right to make their own connecitvity decisions.

The Globe suggested that, rather than allowing the FCC to take the lead with the Wilson and Chattanooga petition decisions, federal lawmakers take action:

A better approach would be for Congress to settle the issue itself, by preventing states from interfering with cities and towns that want to start their own Internet services.

The Globe Editors note that rural areas are the hardest hit by large corporate provider indifference, that it is those same parties that drive the state barrier bills, and that, "This status quo is bad for customers everywhere."

Globe Editors get behind a bill recently introduced by Cory Booker, Claire McCaskill, and Ed Markey that wipes out state barriers in the 19 states where they exist and prevents state lawmakers from enacting new ones. The Globe acknowledges that the support is lopsided today...:

But this shouldn’t be a partisan issue, and it isn’t one on the local level. Red states like Georgia, Kentucky, Iowa, Oklahoma, and Utah all have successful municipal Internet programs. Politicians tempted by campaign contributions from the telecommunications lobby, or skeptical of any proposal backed by President Obama, should remember that consumer protection is an issue that voters of all stripes support.

Community Broadband Media Roundup - January 23

We continue to see reverberations from President Obama's speaking out in favor of municipal networks. The presidential nod sparked state lawmakers to propose bills, news organizations to write editorials, and to give communities a better sense of how they can take action locally.

As Claire Cain Miller with the New York Times wrote in her article for “The Upshot”:

“The goal is not to replace the big companies with small, locally run Internet providers. It is to give people more than one or two options for buying Internet – and spur everyone, including the incumbents, to offer more competitive service and pricing.”

Jeff Ward-Bailey reported on Obama’s interest in tech issues in the State of the Union, specifically the laws limiting local deployment of networks.

“Obama has said that he wants to end these laws, and the White House’s new broadband plan includes a program, BroadbandUSA, that will encourage communities to deploy their own high-speed networks. BroadbandUSA will offer guidance on planning, financing, and building municipal broadband networks, and even includes funding for “in-person technical assistance to communities.”

The always-worth-reading Harold Feld explained the significance of President Obama's short mention of Internet access in his address:

“Which brings me to the last point. Yes, the President is clearly signalling that Dems need to see investment in broadband infrastructure (including by local governments) and protecting the open Internet not as isolated issues or peripheral techie issues, but as part of a comprehensive plan to ensure that the United States has a robust 21st infrastructure necessary to support a prosperous nation with opportunity for all. At the same time, Republicans should stop thinking of this as “regulation of the Internet” and think of it in the same way we think of highway fund investment and maintaining public roads. This doesn’t have to be a partisan issue, and it didn’t use to be.”

Reactions from cities and news organizations around the country showed that people support the right to build networks for job creation, business development, education, and healthcare. 

Alex Keefe and Lynne Mccrea with Vermont Public Radio talked to Irv Thomas with central Vermont’s ECFiber for reactions to the president’s message. More than 30 percent of Vermonters did not have access to high download speeds in 2013 – that’s one of the highest percentages of any state in the nation. 

Community Broadband Efforts

Danielle Kehl and Patrick Lucey with the Open Technology Institute wrote about the significance of Obama’s announcement for other small cities that want to restore local authority to build networks: 

“The digital divide becomes even more pronounced when you compare access in urban and rural parts of America, or consider the fact that four out of five Americans who aren’t online live below the poverty line. A big part of the problem is competition: Most Americans live in areas where only a single provider offers truly high-speed connectivity (more than 25 megabits per second), and it often comes with a steep price tag.”  

Some states are wasting no time moving forward with their community Internet networks. Kudos to Sen. Cory Booker of New Jersey for his proposal. The Hill’s Mario Trujillo reports:

“Booker's legislation — the Community Broadband Act — would block any state "statute, regulation, or other legal requirement" that restricts cities from providing their own Internet network. His legislation to tweak the Telecommunications Act of 1996 will be introduced Thursday.”

Booker's office framed the issue as one that could help rural and low-income communities. At least 19 states around the country have laws on the books setting limits on the creation or expansion of municipal broadband networks. 

The state with some of the slowest Internet in the nation may have hope yet for high speed Internet access thanks to a huge push by state lawmakers. Maine lawmakers on both sides of the isle submitted a whopping 35 bills that could help the state make some serious moves up the list. Darren Fishell with Bangor Daily News covered the story.

“I think most people understand that in this day and age for us to be competitive, that’s one of the necessary tools,” [Rep. Norman] Higgins (a Republican) said, noting he’s found bipartisan support on the issue. “The question, I think becomes: How do we do it? And who does it?”

One of the key proposals is a change in definitions. Whit Richardson with The Kennebec Journal and Morning Sentinel writes that Maine’s broadband service authority is raising the standard of broadband from 1.5 Mbps to download and upload speeds of at least 10 Mbps. Currently just 20 percent of households there have access to those speeds. The new standard would mean about 80 percent of the state’s communities (up from just 5 percent) would be eligible for ConnectME funding and it be the most aggressive state in terms of requiring fast upload speeds - a boon to small businesses and people who work remotely.

But Broadband DSL Reports’ Karl Bode reports that the state may find they want to raise that bar even higher in coming months. He reports on Netflix CEO’s push for making 25 Mbps download the “new baseline.”

Another Minnesota broadband effort is nearing its financial goals. The Belle Plaine Herald report that RS Fiber’s 10 member cities re-committed to the fiber project this week. Backers are seeking another level of commitment before moving ahead with the sale of bonds in March. The first phase of building for the project is expected to begin in 2016.

Cleveland’s OneCommunity “Big Gig Challenge Grant” is going toward helping create a fiber network to connect several businesses, non-profits and the Cleveland Clinic. The West 25th Corridor project is earmarked to be municipally-led, community-wide fiber. 

“The impact of introducing fiber to this burgeoning district cannot be overstated,” according to OneCommunity CEO Lev Gonick. “Hospitals, industry and businesses of all sizes, regardless of their scope will benefit from the network. We are proud to be part of this major leap into the future as outlined by the West 25th Street Corridor Initiative.”

In Utah, UTOPIA is reaching a settlement that gives hope to the struggling network. Antone Clark with the Standard Examiner reported the good news for network, which had been running at a loss for several years. 

“Even as we speak, our revenue picture is frankly outstanding,” Paul Isaac, acting director of UTOPIA, told the Standard-Examiner recently when pressed on the operational status of the network as it heads into the 2015 year.”

Just “down the road” in San Francisco, you can access high speed Internet from all city parks, and many businesses.  Josh Harkinson with Motherboard reported on how the telecom industry has developed such a successful obstacle course for communities: 

“Like many cities, San Francisco already has a robust fiber network in place to serve government offices.  [Ron Vinson, the city's chief marketing officer] believes that the $1.7 million that the city has spent to outfit its network with public wifi (not including a $600,000 grant from Google) is totally worth it. "There's absolutely no downside being able to provide access to the internet, whether you are parking your car or waiting for a MUNI bus," he says. "It's one of those fundamental things. We fill potholes, we clean the streets, and yes, now we provide wifi. And our citizens expect that."

Seattleites hopes for a city-owned network were rekindled this week! KING5 News reported on a new group forming that will push for affordable Internet access across the city. If the group is successful, Seattle would be the largest city in the United States with a municipal network.

Missouri Considers Revoking Local Authority

Despite the positive news from the White House, another state— Missouri— will consider a bill that creates barriers for community broadband. Rep. Rocky Miller introduced the bill, Sean Buckley with Fierce Telecom.

"Miller's bill includes a provision that would require a town or city to make a majority vote to offer a "competitive service." If residents voted to build a community network, the municipality would not be able to use the revenue from other services like water and sewer to pay for the buildout of the network and services, which would create a challenge in being able to pay for the initial construction costs to extend services to homes and businesses."

Kansas City, Missouri, is concerned how the proposed legislation would stifle the torrent of tech startups and economic development activities that are tied to faster speeds. 

"[Communications litigation expert Robert] Cooper said that state laws that restrict municipal broadband deployment are "antithetical to those FCC mandates because they enshrine barriers to investment by local governments." There is "ample" evidence that advanced broadband capability is not being deployed in a reasonable and timely fashion."

U.S. Senator Cory Booker Introduces Community Broadband Act

Senator Booker has taken the lead in introducing the Community Broadband Act to the U.S. Senate along with Senators McCaskill and Markey. We are thankful for their leadership on the issue. As part of their announcement, they included the following statements:

“As Mayor of Newark, I saw firsthand the value of empowering local communities to invest and innovate. The Community Broadband Act provides cities the flexibility they need to meet the needs of their residents,” Sen. Booker said. “This legislation will enhance economic development, improve access to education and health care services, and provide increased opportunity to individuals in underserved areas. At a time when local governments are looking for ways to ensure their communities are connected and have access to advanced and reliable networks, the Community Broadband Act empowers local governments to respond to this ever-increasing demand.”

"Barriers at the state level are preventing communities from developing local solutions when there is little or no choice in their Internet service provider,” Sen. Markey said. “This legislation will support the ability of cities to decide for themselves whether or not they would like to build their own broadband networks and provide community members with high speed Internet service. I thank Senator Booker for his leadership introducing the Community Broadband Act, which will support more options in the broadband market and greater local choice. I also continue to urge the FCC to act now to use its authority to end any restrictions placed upon local communities to make these decisions for themselves.”

“Folks in small towns and rural communities should have the same access as everyone else to the Internet, and the jobs and business opportunities it brings,” Sen. McCaskill said. “Large Internet providers too often aren’t willing to offer service in rural America, so this bill ensures local communities can come together to provide their residents with access to the opportunities high-speed broadband offers.”

And we included this statement:

We believe these decisions about how best to expand Internet access are best made by local governments, who are most informed of the need and challenges. We applaud Senator Booker for this bill to ensure communities can decide for themselves if a partnership or an investment in network infrastructure is the right choice.

The Coalition for Local Net Choice was also included, saying:

Senator Booker has been a great champion of local communities, both as a longtime mayor and now as a member of Congress. As a former mayor, he clearly understands the importance of local decision-making regarding critical economic development infrastructure. CLIC applauds Senator Booker for his affirmation of local Internet choice and his support for the authority of local governments to work on next generation broadband networks with their private sector partners and local communities.

This bill (read it here) is effectively the same language from previous, bipartisan bills in 2005 and 2007. However, in the years since, many elected Republicans have changed their mind and others no longer want to be associated with an issue that President Obama supports.

Maine Legislature All About That Broadband in 2015

Maine continues to be a hot spot in the drive to improve connectivity as the 2015 state legislative session opens. According to the Bangor Daily News, 35 bills have been introduced that deal with broadband issues.

The story also notes that several lawmakers have introduced bills that propose funding from the state. House Republican Norman Higgins advocates broadband infrastructure in rural areas of the state:

“I think most people understand that in this day and age for us to be competitive, that’s one of the necessary tools,” Higgins said, noting he’s found bipartisan support on the issue. “The question, I think becomes: How do we do it? And who does it?”

He proposes allocating millions of dollars to expand the availability of grants to municipalities that want to build and own high-speed fiber-optic networks that would be open to companies that want to serve businesses and homes, similar to the model pursued by Rockport, South Portland, Orono and Old Town.

Momentum is growing outside the Senate and House Chambers as well. In December, Governor LePage asked the ConnectME Authority to consider redefining "underserved" for projects it considers funding. The Authority obliged, reported the Bangor Daily News:

The new standard set Friday includes for the first time speed requirements for uploads, which supporters of the change said would serve small businesses.

The new standard would qualify any areas with broadband connections slower than 10 megabits per second for both downloads and uploads — a 10-10 symmetric standard — as “unserved.”

For those working on the issue of broadband, the energy is contagious:

“It’s exciting as someone who cares about broadband that there’s so much energy around it,” [public advocate with the Maine’s Public Utilities Commission Timothy] Schneider said. “And it ties into this whole trying to figure out how to do economic development not based around Maine’s legacy industries.”

Bill to Establish Broadband Grant Program in Montana State Legislature

In Missoula and Bozeman, momentum is building for improved connectivity by way of community network infrastructure. As usual, funding a municipal network is always one of the main challenges, but the state appears uninterested in helping them. State Representative Kelly McCarthy recently dropped HB 14 into the hopper, a bill to create a broadband development fund primarily for private companies.

The bill authorizes $15 million in general obligation bonds for broadband infrastructure projects for middle-mile and last-mile connectivity in rural areas. Unfortunately, projects built and maintained by private entities have priority per the language of section 3(2)(b).

The state legislature would be wise to follow Minnesota's lead and establish a program that is available to all as in the Minnesota Border-to-Border Broadband Development Grant Program. Private entities are eligible to apply along with public entities and nonprofits, but do not receive special consideration.

If anything, the long history of success from cooperatives and local government approaches in infrastructure is favorable to the history of consolidation and poor services that big monopolies have offered in rural areas.

It never ceases to amaze us that people designing programs to use taxpayer money in expanding essential infrastructurel would earmark it only to subsidize entities that are the least accountable to the communities they are supposed to serve. Ultimately you have to wonder whether these programs are designed to benefit local communities or just the companies that can best afford lobbyists.

California Law Offers New Way to Finance Broadband Projects

On September 29th, California Governor Jerry Brown signed into law a bill that may make building community networks in his state just a bit easier. The memorably-named “Assembly Bill No. 2292” allows broadband projects to be included among the types of public works that can be financed using Infrastructure Financing Districts (IFDs).

IFDs are entities formed by regional coalitions of city, county, or other governmental units. They are designed to provide upfront funding for infrastructure projects that have broad regional benefits (highways, water systems, etc.), and are paid for by earmarking the increased property or other tax revenue the projects are expected to generate over a specified future period (usually decades). 

The idea behind IFDs - capturing future value to provide upfront funding to the projects that will create that value - is much like Tax Increment Financing (TIF) districts in other states. We have seen communities in other states turn to TIFs for broadband networks build outs, perhaps most notably throughout Indiana

The text of the bill is all of three lines long, and simply amends the existing authorizing law for IFDs to explicitly allow infrastructure financing districts to be used for “public capital facilities or projects that include broadband.” While the old wording of the statute did not explicitly reject using IFDs for broadband projects, it did not explicitly allow it either.

Removing the uncertainty around the issue should help encourage local governments to consider network investments, especially since one of the major unpredictable costs is incumbent lawsuits. This change will slightly reduce the opportunity for incumbents to slow a municipal network with a lawsuit.

The bill was written and sponsored by Representative Rob Bonta, who represents parts of both Oakland and San Leandro in the Bay Area. It is no coincidence that San Leandro is a city seeing the benefits of robust fiber optic infrastructure, and San Leandro mayor reportedly pushed the idea to Rep. Bonta, who made the case for the bill as an economic development driver:

Broadband provides cities and counties with an opportunity to stimulate the economic climate by providing businesses with the competitive advantage of being connected to high speed fiber optic networks. AB 2292 will help boost local economies, create local jobs and increase access for schools, libraries and other public facilities to state of the art telecommunications networks. 

While AB 2292 shows a growing awareness of the need for more public investment in broadband, it is far from a silver bullet. The political process necessary to create an IFD is cumbersome and challenging:

IFDs have to be approved by all the local agencies that would be contributing tax revenue, local property owners have to be consulted and then it goes through a series of public votes, including two – to form the IFD and then to issue bonds – that require a two-thirds majority to pass.

These are huge hurdles to clear for any major public project, and the California legislature recognized this by creating a new category of Enhanced Infrastructure Financing Districts (EIFDs) in this year’s session that are more flexible and lower the bar to a single public vote and 55 percent approval. Unfortunately, the bill creating EIFDs (SB 628) does not explicitly include or exclude broadband projects, falling into the same murky middle ground that the old IFD legislation did.

The end result of the California legislative session is a partial win for community broadband networks. They get new access to an existing financing tool, but only a taste of the new and improved system. The goal for the future should be clear: get next generation broadband projects definitively included in the Enhanced Infrastructure Financing District statute, so more local communities can start to enjoy the benefits of fiber the way San Leandro and Santa Monica do today.    

Local Businesses Suffer in Tennessee as State Prevents Chattanooga Expansion

As our readers know, the FCC is currently considering petitions submitted by Chattanooga and Wilson, North Carolina. Both communities want the ability to expand their ability to offer advanced telecommunications services, contrary to existing state anti-muni laws. As we glance through the comments, we notice that ISPs, advocacy groups, and local governments are not the only commenters with a vested interest in the outcome. 

There are also compelling stories from individuals, local businesses, and organizations that are looking for better options. In some cases they have one provider but are unhappy with the service so support municipal network expansion. In other cases, they have dial-up (or no service at all) and are maddeningly close to an EPB or Greenlight connection but state restrictions forbid service to them.

We recently spoke with Joyce Coltrin, owner of J & J Nursery located on the edge of Cleveland, Tennessee, in Bradley County. She is about 32 miles from the heart of Chattanooga but only 3/8 mile from the edge of the EPB fiber optic service area. Her only choice for Internet at her nursery is AT&T dial-up. Joyce tells us:

"I could walk right to it - it is the closest provider and we don't have any broadband access!"

Joyce submitted comments early in the proceedings. She choose to send her comments via snail mail because her email is so unreliable.

For the past 15 years, Joyce and other people in her community have requested better service from AT&T. They were told repeatedly it would be 3 months, 6 months, 9 months until they would get upgrades but it never happened. They finally decided to look for connectivity elsewhere. Joyce and her neighbors approached their electric provider, Volunteer Energy Cooperative, in the hopes that they could work with EPB to bring services to the area. Volunteer and EPB had already discussed the possibility, but when the state law was passed that prevented EPB from expanding, the efforts to collaborate cooled.

Joyce uses her cell phone to access the Internet while she is at work. Like some of the other business owners in Cleveland, Joyce pays $200 - $300 per month because she is constantly running over data caps to conduct business. There are others who live or work in areas near her that do not have cell phone coverage.

Another local business owner that runs a poultry business almost lost a large number of chicks when their alarm system, dependent on wireless Internet access through a Verizon "MiFi" personal hotspot, failed during cold weather.

Joyce does not plan on expanding to an online store but she finds it difficult to adhere to state business regulations without better connectivity. For instance, she must do business taxes online from home, where she has a little better Internet access.

She knows that Tennessee's anti-muni laws came from giant cable and telco lobbying efforts. She also recognizes the negative impact it is having on Cleveland. In her comments to the FCC, Joyce writes:

College students drive to McDonald's to use Wi-Fi and work from their cars to do homework and projects. This situation is choking business and making our children third class citizens.

I have always been for free enterprise, but when some businesses win due to unfair protection, free enterprise dies.

To read the rest of Joyce's comments, visit the FCC website.

ILSR Submits Comments to FCC in Support of Restoring Local Authority

The Institute for Local Self-Reliance recently submitted comments on FCC petitions filed by Wilson, North Carolina and Chattanooga, Tennessee. We have been following the proceedings that may prove to be the tipping point in the movement to regain local telecommunications authority.

Our organization collaborated with eight other groups and two D.C. Council Members to provide detailed comments for the Commission's consideration. Our group supplied examples of the benefits munis bring to local communities. In addition to providing connectivity where the incumbents fail to meet demand, our comments point out that municipal networks encourage private investment. We provide concrete evidence of both.

With our partners, we also addressed the fact that state restrictions like the ones in North Carolina and Tennessee are not needed. Local communities must go through a rigorous, transparent process everywhere before investing. State legislative barriers are the product of intense lobbying from the cable and telecommunications giants.

As we point out to the Commission, municipal networks are an important tool to bring ubiquitous Internet access to the U.S.:

The FCC is tasked with ensuring high speed access is expanded to all Americans on a reasonable basis and to remove barriers to broadband deployment. Local governments have proved to be an important tool in expanding access to high speed Internet access. Both Chattanooga and Wilson have neighbors that publicly want the local municipal network to expand access to them. Both Chattanooga and Wilson are prepared to invest in connecting their neighbors. Restoring authority to local governments, so they may decide for themselves if a municipal investment or partnership is an appropriate way to expand high speed Internet access, will result in a more rapid deployment of high speed Internet access.

We also filed comments alone to provide the FCC a small sample of the support people and organizations have shared with us. Even before the comment period, we heard from local governments and organizations that passed resolutions in favor of local authority, members of the business community that support local authority, and media outlets that endorse local decision making.

From our closing comments:

ILSR stands with local businesses, residents, media outlets, and many others in encouraging the FCC to grant this petition, restoring the capacity of local governments to invest in next generation Internet access or partner to the same effect, if they so choose. We have worked with communities across the nation and recognize that this is not a partisan issue at the local level. It is about jobs, education, and quality of life. Restoring the right of communities to invest in fiber networks will result in faster deployment of fast, affordable, and reliable Internet networks.

Oklahoma's Sallisaw Passes Resolution to Support FCC As It Considers Preemption

Sallisaw, home of DiamondNet, is the latest community to publicly express its desire to put telecommunications authority in the hands of the locals. On July 14, the Sallisaw Board of City Commissioners approved Resolution 2014-17 in support of the FCC's intention to preempt state anti-muni laws.

A Resolution Supporting Telecommunications Infrastructure For Local Governments

WHEREAS, local governments, being closest to the people are the most accountable level of government and will be held responsible for any decisions they make; and

WHEREAS, community/municipal broadband networks provide opportunities to improve and encourage innovation, education, health care, economic development, and affordable Internet access; and

WHEREAS, historically, the City of Sallisaw has ensured access to essential services by providing those services that were not offered by the private sector at a reasonable and competitive cost; and

WHEREAS, in 2004 the City of Sallisaw took steps to construct its own Fiber to the Premise telecommunications system and now provides the community with quality state-of-the-art broadband services including video, High Speed Internet and telephones services, that otherwise would not be available today; and 

WHEREAS, local government leaders recognize that their economic health and survival depend on connecting their communities, and they understand that it takes both private and public investment to achieve this goal; and

WHEREAS, the DC Circuit Court has determined that Section 706 of the Federal Telecommunications Act of 1996 unambiguously grants authority to the Federal Communications Commission (FCC) to remove barriers that deter network infrastructure investment;

NOW, THEREFORE, BE IT RESOLVED that the Board of City Commissioners of the City of Sallisaw, Oklahoma, supports FCC efforts to ensure local governments are able to invest in essential telecommunications infrastructure, if they so choose, without state-imposed barriers to discourage such an approach.

ADOPTED by the Governing Body on 14th day of July, 2014.

When City staff began researching the possibility of a municipal network in 2002, they discovered that dial-up was the only option for residents; businesses had the option of T1 connectivity. At the time, a coaxial or hybrid coax/fiber system were considered, but Sallisaw went with fiber to future-proof the network.

In an undated interview with the Oklahoma State University Cooperative Extension Service, network staff commented on the benefits for the community:

The key benefit of the City owning this system is that the revenue stays in the community. Our current annualized revenue is more than $1.5 million before expenses. As our customer base and revenue grows we will begin to see more net revenue after expenses, and that net will go to other non proprietary city services.

From DiamondNet FAQs:

The community of Sallisaw owns the FTTH system and its employees are residents of the community. In the past, the cable television provider in the community experienced numerous ownership and name changes, averaging about one every four years. DiamondNet will have one name and one owner for the life of the system. As your neighbors, we strive to provide you with excellent service. When you need help, just pick up the phone or come see us on the main floor at City Hall on Choctaw Street. We are here to serve you. 

Chattanooga and Wilson Comment Period Open; Tell the FCC You Support Local Authority

Last week, the communities of Chattanooga and Wilson, North Carolina, filed petitions with the FCC. Both communities requested that the agency remove state barriers preventing expansion beyond their current service areas. On July 28, the FCC established a public comment calendar for the request. It is imperative that all those with an interest in better access take a few moments to express their support for these two communities.

Opening Comments are due August 29, 2014; Reply Comments will be due September 29, 2014. That means you need to submit comments by the end of this month. If you want to reply to any comments, you can do that in September.

This is a pivotal moment in telecommunications policy. For months municipal network advocates have been following Chairman Wheeler's stated intentions to remove state barriers to local authority. Within the past few weeks, federal legislators - many that rely on campaign contributions from large providers - pushed back through Rep Marsha Blackburn (R-TN). Blackburn introduced an amendment to a House appropriations bill preventing FCC preemption if the amendment becomes law.

ILSR and MuniNetworks.org encourage individuals, organizations, and entities to file comments supporting the people of Wilson and Chattanooga. These two communities exemplify the potential success of local Internet choice. We have documented their many victories on MuniNetworks.org and through case studies on Wilson [PDF] and Chattanooga [PDF].

Now is the time to share your support for local decision-making. This is not about whether any given community should build its own network so much as it is about whether every community can decide for itself how to best expand and improve Internet access, whether by investing in itself or working with a trusted partner.

ILSR will be filing comments in support of Wilson's and Chattanooga's petitions. As a service to those who plan to express their support for local authority, we will continue to provide information, guidance, and resources throughout the comment period. In the near future, there should be a guide to help you submit comments. But if you are really enthusiastic or already know the process, here are some links.

File comments electronically for Wilson's petition at Proceeding 14-115; Chattanooga's petition is Proceeding 14-116. Petitions and exhibits are available at the filings pages or at the links below.