Dear FCC…

By Bruce Mehlman

IIA has submitted its feedback to the FCC on the National Broadband Strategy. Below are some highlights.

Regarding the state of broadband access in America:

A large number of first-round comments to the Commission started from the premise that broadband in America is an unmitigated failure. We disagree. In roughly one decade our nation has gone from practically no broadband deployment or adoption to roughly 90% availability and 50% adoption. This is an astounding accomplishment. Indeed the Orszag Report found broadband usage in 2008 (66.6 million households) nearly six times that in 2001 (10.4 million households). Cross-platform competition continues to grow between wire line, wireless and cable offerings, with promising new technologies such as broadband over power lines emerging. Market players invest roughly $60 - $80 billion annually in infrastructure upgrade and expansion of footprints, with an even more robust and competitive market for online applications.

As for what the commission’s next steps should be:

Despite the thousands of pages of comments and years worth of reports, there is still plenty that we do not know. Through the broadband mapping, FCC surveys, upcoming Census Bureau efforts and private efforts such as Pew, we will continue to learn much more precise information about where broadband is and is not and who is adopting and who is not (and why). Preliminary actions should therefore focus first on what we do know.

We know roughly 10 million households have no broadband choices. As has been noted previously, the vast majority of Americans with no option for broadband Internet are those living in rural areas, where sparse population density and difficult terrain inhibit private investment. Initial efforts and investment by the government should address these market failures, catalyzing investment in unserved communities where private returns would not justify it. Societal returns from ubiquitous connectivity warrant some measure of public investment, though specific investments must always be weighed against alternatives for reaching other unserved users (such as digital literacy programs in urban centers).

We also know roughly 40 percent of households choose not to invest in broadband. They fail to see the value despite compellingly low connection costs, especially now in tough economic times.  That suggests the need for government efforts to promote digital literacy, lead by example in broadband-enabling government applications and educate consumers about the benefits and possibilities enabled by broadband Internet usage.

Read IIA’s full reply to the FCC (pdf).