Monday, October 25, 2010

Comments Filed on Improving International Comparisons of Broadband Development

I filed comments in the FCC International Bureau's inquiry (IB Docket No. 10-171) into how it can improve data collection and assessment of international broadband development.  Here is a summary of my recommendations:

(1)        Rather than compare the United States with other nations using composite national data, disaggregate the international data into several geographic and demographic categories.  The International Bureau should benchmark urban, suburban, exurban and rural communities in foreign locales in terms of broadband cost, transmission speeds, download caps, and other variables.

(2)       Use a credible average of delivered broadband speeds rather than advertised speeds.  A variety of demand and technological factors affect broadband service performance.  Advertised bit rates typically contain a disclaimer stating that actual performance may vary.  Because nations typically do not sanction carriers for overstating what subscribers can expect, the Commission should try to determine what bit rates subscribers can reasonably expect to receive.

(3)       The FCC must separate the data collection process from policy making so that data collection can occur without implicit or explicit coercion to support a pre-determined outcome.  Rather than consider the data collections and statistical compilations of other organizations a threat or challenge, Commission staff should try to replicate such findings and identify factors contributing to any disparities.  U.S government officials have challenged the OECD and other organizations in efforts to save face, or mitigate the political damage from reports showing mediocre national performance.  Instead, the Commission should try to understand the basis for disparity in performance statistics.

(4)       Limit redactions, trade secret designations, and other sanitization of broadband information so that researchers have access to useable and replicable data.  No trade secrets would be disclosed if the Commission identified the types of carriers serving specific areas by technology used.

(5)       Expand broadband data collection and benchmarking in the context of overall broadband leadership, quality and national readiness to compete in information industries.  Commission staff should examine the variables used in the comparative assessments generated by such organizations as Cisco, the Internet Innovation Alliance, and the Information Technology and Innovation Foundation.

(6)       Balance more easily quantifiable supply-side measurements of the broadband market with demand-side measurements that attempt to assess national digital literacy, computer ownership and access, e-government and other technology incubation efforts, as well as private/public partnerships in stimulating interest in, and use of, Internet-mediated services.

(7)       Conduct a thorough literature research with an eye toward identifying best practices in broadband data collection and dissemination.  This exercise will help Commission staff determine what are the key variables for multi-year tracking.

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