February 12, 2008

Chairman Kevin Martin

Commissioners Michael Copps                     Commissioner Jonathan Adelstein

Commissioner Deborah Taylor Tate              Commissioner Robert McDowell

Federal Communications Commission

445 12th Street, SW

Washington, DC 20554

Re: WC Docket No. 07-52

Dear FCC Chairman and Commissioners:

The Small Business and Entrepreneurship Council (SBE Council) works to influence legislation and public policy that enhances the environment for business start-up and growth. Obviously, the Internet plays a large role in the livelihood of our members, as well as U.S. entrepreneurs in general.  Small businesses have become reliant on the Internet in all stages of business development - from the start-up phase, to strategies and plans that help sustain and grow their enterprises.

Therefore, we corresponded with the Commission last year regarding our concerns about network neutrality.  Today, we want to recap our stance regarding the costs and unintended consequences of blanket regulation of the Internet.  We also request that the Commission avoid additional prohibitions on network management by providers. 

A stable, robust, and reliable Internet is critical to the success of the small business and entrepreneurial sectors of our economy.  As a result, we have been pleased with the recent developments and investments made by Internet broadband service providers.  Broadband is expanding, and networks are fast becoming more reliable. 

We attribute this recent success of the Internet to a "hands off" approach advocated by the Commission and policy-makers alike in Congress.  We hope this sentiment continues as you examine network management issues. 

Network management delivers to end users - small businesses and consumers alike - confidence in the network.  Whether a home healthcare consumer is receiving a medical x-ray from their doctor, or a small business harnesses VOIP technology to make marketing calls, network management practices by providers affords a seamless and efficient path for all these things to be accomplished and avoid data traffic jams on the

Internet's backbone.  For a successful economy and for the benefit of all consumers, this integrity of the network must be allowed to persist.

In the end, we urge the Commission to avoid extensive rule-making in this area.  Regulators and policymakers should practice caution when delving into network management and determining what constitutes and what does not constitute appropriate practices.  With the changing needs of an expansive IP network, the effort of crafting  regulation or policy could be rendered mute given how fast technology changes.

We appreciate the opportunity to share with you our thoughts on this matter, and we hope you keep in mind the needs of small businesses and entrepreneurs when examining this critical network issue.  

Sincerely,

Karen Kerrigan, President & CEO