Submission Number: 00340
Received: 2/18/2011 7:35:39 AM
Commenter: Marvin Miller
Organization: AeroMetric, Inc.
Agency: Federal Trade Commission
Initiative: A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers"
Attachments: No Attachments
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful
affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or
“precise geolocation data”. This would adversely impact consumers, geospatial firms, and government
programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the
proposed regulations will have broad and harmful unintended consequences.
The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations
will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities
that have not been identified as a problem or pose any privacy concern to citizens.
The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency
response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning
system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it
would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens
prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important valueadded,
integration and application activities.
Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would
FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should
not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and
applications that meet the economic demands of consumers and citizens.