9/21 FCC Comments On Section 706 And Broadband Deployment

New America's Open Technology Institute filed comments with the Federal Communications Commission to provide input on the agency's analysis of broadband internet access service (BIAS) deployment. Specifically OTI explains why mobile BIAS is currently only a complement to fixed BIAS—not yet a substitute. OTI urges the FCC to increase its throughput speed benchmarks to reflect the changing nature of BIAS and the advent of services and applications that require more bandwidth. OTI also calls on the FCC to encourage the deployment of mobile BIAS in rural and other underserved areas through spectrum sharing such as the 3.5 GHz Citizens Broadband Radio Service band and fixed wireless services in the 3.7-4.2 GHz band. Below is an executive summary of OTI's comments:

Executive Summary:

In the current proceeding, the Commission should adopt forward-looking goals that ensure all Americans have access to robust broadband service. In these comments, the Open Technology Institute at New America explains why mobile BIAS is not a substitute for fixed BIAS and how spectrum sharing and increasing throughput benchmarks helps achieve the goal of broad, nationwide deployment of advanced telecommunications capability.

OTI strongly opposes the notion that mobile BIAS is a substitute for fixed BIAS. Mobile BIAS is typically more expensive, less reliable (especially in rural areas), slower, and subject to data caps and expensive overage fees. Moreover, mobile BIAS is typically accessed on devices with smaller screens and limited computational abilities that cannot complete the full range of functions of a desktop or laptop computer. Consumer behavior also shows that they do not view mobile BIAS as a replacement for fixed BIAS, as there is no recognizable trend showing Americans buying mobile BIAS while abandoning fixed BIAS. Mobile BIAS does not yet constitute “advanced telecommunications capability” and is, at best, a complement to fixed BIAS—not a replacement. As such, OTI urges the Commission to encourage deployment of Mobile BIAS in rural and other underserved areas through its proceedings on the 3.5 GHz Citizens Broadband Radio Service band and fixed wireless services in the 3700 - 4200 MHz band.

Lastly, the Commission should continue to steadily increase its speed benchmarks to reflect the changing nature of BIAS. In the last section 706 proceeding, OTI recommended a new benchmark of 50 Mbps/20 Mbps to reflect the new landscape. Since then, use of bandwidth- intensive applications has continued to grow, making robust speed benchmarks even more important. There is also extensive evidence that broadband throughput has improved rapidly. The Commission should establish benchmarks that recognize these improvements.