The New York State Department of Financial Services’ (NYSDFS) is currently considering regulations for virtual currencies (e.g. Bitcoin). While ITIF believes that the State of New York is likely the wrong entity to address these important policy issues, we have offered a number of recommendations should it continue to pursue these regulations. To strike the right balance that helps protect customers and root out illegal activity without stifling innovation or competition, New York should foster new entrants and budding virtual currencies without burdening their adoption with heavy-handed reporting requirements. Virtual currencies may be the next wave of innovation in our country’s financial services or they may be just a flash in the pan. Only time and a light regulatory touch will tell.
Testimony and Filings
ITIF Comments on Connected Cars
ITIF submitted comments with the National Highway Traffic Safety Administration, recommending that it wait until DSRC and unlicensed devices can confidently share the 5.9 GHz band before mandating DSRC technology. We believe a mandate may well be appropriate to overcome the initial adoption hurdle, but the spectrum coexistence question should be resolved first.
ITIF Submits Comments to the National Science Foundation Regarding a National Privacy Research Strategy
To ensure the potential benefits of data-driven innovation are attained, the U.S. federal government should support research efforts to address the most pressing privacy and security research questions faced by industry and government. This filing describes five areas—healthcare, transportation, criminal justice, education, and social media—where additional research is needed on how to share data while best preserving privacy.
ITIF Files Comments in Support of AT&T – DirecTV Merger
In comments to the Federal Communications Commission (FCC), ITIF argued the merger of AT&T and DirecTV will create a stronger broadband competitor, providing enhanced value to consumers and offsetting a reduction in the number of competitors in the relatively crowded urban video market. In addition, fears over anti-competitive control over interconnection by access networks are unfounded.
GMO Labeling is Unwarranted and Unnecessary
Val Giddings testified before the New Jersey Assembly’s State and Local Affairs Committee arguing that a proposed bill mandating labels for genetically modified foods is unnecessary and based on ideology and commercial interests not on safety or better informing consumers. GMO foods receive unprecedented testing and review from multiple government, non-governmental and international organizations making state labeling initiatives redundant and costly without providing any additional benefits to consumers.
Testimony in Opposition to Pennsylvania’s Mandatory GMO Labeling Bill
Giddings testified before the Pennsylvania House of Representatives’ Agriculture and Rural Affairs Committee in opposition to HB 1770, a bill which would mandate warning labels on foods derived from crops improved through biotechnology. Giddings argued GMO labeling is redundant and unnecessary due to the the global consensus on the safety of biotech improved seeds and the comprehensive reviews and oversight of GMO crops and foods that are already being undertaken by multiple federal agencies. He also noted that labeling legislation is driven by fear, ideology and commercial interests not on a concern for consumers or safety.
ITIF Responds to White House Strategy for American Innovation RFI
The Obama Administration has requested public comment as it begins a process to author a second Strategy for American Innovation. ITIF commends the Administration as it begins to undertake this effort. ITIF's response to the RFI notes that a successful strategy for American innovation must promote both technological-based and non-technological-based (i.e., institutional and organizational) innovation throughout all layers of an economy, including the private sector, government agencies, and non-profit organizations. In other words, the strategy should not only address innovation in government; rather, its chief aim should be to fundamentally change private sector activity and behaviors to spur greater levels of innovation.
ITIF Files Comments on Universal Service for the House Communications Act Update
ITIF commented on the Communications Act Update whitepaper on universal service, recommending a technology neutral program focused on economically efficient subsidies for wireless, broadband, and voice. ITIF recommended against supporting duplicative overbuilds, and encouraged an expansion of low-income support to broadband.
ITIF Files Open Internet Reply Comments
ITIF filed open Internet reply comments Monday, urging the Federal Communications Commission to develop flexible regulation under section 706, allowing for innovation both at the edge and within the network itself. Many of the assumptions underlying arguments for Title II, utility-style regulation are ill-founded. Instead of giving in to over-blown fears, the Commission should allow for commercially reasonable prioritization that enables networks to support the ever-growing variety of Internet applications.
ITIF Files Comments Urging the FCC to Not Encourage Municipal Broadband Overbuilds
In Comments filed with the Federal Communications Commission today, ITIF urged the Commission to not encourage municipal broadband overbuilds. This high fixed-cost industry is driven by economics that cannot sustain increased competition through an injection of public money without imposing negative externalities on others. This fact, combined with the poor track record of attempted municipal networks as well as the availability of alternative opportunities to reduce the costs of deploying or upgrading networks means state laws restricting these networks are usually good policy and should not be preempted. Doug Brake, telecom policy analyst at ITIF, said, "when analyzing state restrictions on municipal networks you have to ask whether these networks benefit or harm the surrounding area. Where networks duplicate existing private infrastructure, it is likely they end up raising costs on others, justifying state restrictions."