Broadband Can’t Be Improved Unless It’s Measured.
August 21, 2017




On August 8, 2017, the FCC launched a new assessment of “whether advanced telecommunications capability is being deployed to all Americans in a reasonable and timely fashion,” (otherwise known as the “706 Report”).  This Report is long overdue, as the Report is supposed to be issued annually, but the last 706 Report was released on January 29, 2016.  

The Notice of Inquiry (NOI) properly seeks comment on both fixed and mobile broadband connections. It acknowledges that the two technologies have different technical characteristics and limitations, and that broadband providers choose to market their fixed and mobile products in different ways.  As Commissioner Clyburn notes in her concurring statement, fixed and mobile services are complements, not substitutes.  While some press accounts suggested that the FCC reached a tentative conclusion to equate the two technologies, it only sought comment on this question.  The FCC also sought comment on how the markets for fixed and mobile services differ, and it did not say that mobile broadband access is a replacement for fixed broadband.

To be clear, the SHLB Coalition does not believe fixed and mobile services are substitutes. Students cannot complete homework and seniors cannot apply for government services with just smartphones. While smartphones can help bridge the digital divide for individuals, they do not replace the gigabit speeds provided by fiber or fixed wireless technologies that anchor institutions need.  

Americans are demanding more and more out of their broadband connection.  As anchors seek more bandwidth, the FCC’s expectations should increase as well.  Nonetheless, the FCC proposed to maintain its existing speed benchmark of 25 Mbps download and3 Mbps for upload (25/3) for fixed broadband, which were adopted in 2015. Significantly for schools, libraries, and other anchors, the Notice also seeks comment on other potential benchmarks.  (see para. 12).  This provides the SHLB Coalition and others a chance to support establishing or improving the benchmarks for anchor institutions.  The 706 NOI discusses the broadband situation for schools (as is statutorily required) but does not discuss the broadband needs of or benchmarks for other anchor institutions.  As the saying goes, you can’t improve what you don’t measure.  The FCC established some benchmarks for schools and libraries in the E-rate program.  But there are no similar benchmarks for other anchor institutions, such as health clinics, community colleges, etc. 

Establishing benchmarks for anchor institutions, even if preliminary, could help to draw attention to the needs of all anchor institutions for better broadband.  Anchor institutions are the “third leg of the stool” for a healthy broadband ecosystem (in addition to business and residential), and ensuring that health providers, community colleges, public media, public housing and other anchors can obtain adequate broadband is important to ensuring that broadband is “being deployed to all Americans.”  If the FCC uses this proceeding to broaden its metrics to measure anchor institution broadband, the result could be significantly better broadband for all.

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