Each year, the Federal Communications Commission (FCC) evaluates if advanced telecommunications services are being deployed to all Americans in a “reasonable and timely manner.” This annual proceeding typically addresses the status of broadband deployment and asks the public to comment on relevant issues such as the federal broadband speed benchmark, the evaluation of mobile service as separate from fixed home broadband, and broadband data collection. The process gives advocates an opportunity to weigh in on the status of connectivity across the country and the effectiveness of the FCC’s actions and policies to meet that goal.

On January 16, Next Century Cities joined a group of public interest advocates to meet with the FCC’s Wireline Bureau to discuss key points in the annual evaluation. The group made the following arguments:

  • The federal broadband speed standard should be increased. Technological innovation and consumer demand for faster broadband warrant the FCC to update its benchmark speed from 25 Mbps to 100 Mbps downstream.
  • Mobile connections are not a substitute for fixed home broadband. Currently, consumers do not view mobile and fixed broadband as substitutes. In fact, low-income Americans are more likely to exclusively rely on mobile broadband than those with higher incomes. Mobile is generally more expensive for consumers, less reliable (especially in rural areas), slower, and subject to data caps and expensive overage fees compared to fixed. Mobile is also increasingly reliant on fixed broadband for offloaded traffic and backhaul. 
  • Collecting data on the price of broadband service is critical. The FCC has stated many times that its top priority is to close the digital divide and to bring the educational, healthcare, social, and civic benefits of broadband to all Americans. For that to happen, the FCC must ensure that broadband is not just physically available, but economically accessible for all Americans. The FCC should engage municipal governments and other stakeholders who have developed methods for overcoming economic barriers to broadband adoption.
  • We should continue to work toward better data collection procedures. The group recommended that the FCC supplement its Form 477 data with other sources, such as data from organizations like M-Lab or state-collected data. In addition, the Commission can make Form 477 more reliable by adding additional metrics to what providers must report, such as actual broadband speeds (not only advertised speeds) and pricing data (including all below-the-line fees). The FCC can also enable a more robust challenge process for consumers as well as an independent verification process, helping to verify the Form 477 data and enforce penalties if the submitted information is inaccurate.

Find the full ex parte from the meeting here, and check out Next Century Cities’ comments and reply comments to the FCC on this proceeding. Find information about how to leave your own comments on FCC proceedings in our step-by-step guide here.