FCC Faces Tough Challenge Getting Broadband Benchmarks Right, Experts Agree
Establishing the right benchmarks to assess U.S. progress in deploying broadband must be viewed as a critical part of the FCC’s National Broadband Plan, said Public Knowledge Legal Director Harold Feld during a commission broadband workshop on benchmarks Wednesday afternoon. Other panelists warned that benchmarks themselves, especially those that rely on comparisons to the rest of world, could provide little meaningful data.
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Donald Stockdale, chief economist of the FCC Wireline Bureau, said the agency will look closely at various measures of deployment and adoption, speed and quality of service and of competition as it draws up the plan. “These benchmarks can be used to chart our progress over time, as well as to identify areas where additional effort is required,” he said.
Benchmarks are critical “so that we can know we're on track, we know we're moving in the right direction, that we're not going to wake up in five years and be surprised that we haven’t achieved our goals or that our goals are wildly off course or that our methods are wildly off course,” Feld said.
The benchmarks have to be informed by the goals of the American Recovery and Reinvestment Act, but the Act’s goals are “amazingly broad and complicated,” Feld said. “It’s universal, affordable broadband, used to its maximum utility, whatever that means, that has impact in advancing consumer welfare, civic participation, public safety, essentially every sector of our lives.” He said the temptation could be to “draw back and to go to what we know,” relying on narrow market metrics. “That may technically comply with a narrow reading of the statute, but it will fail,” he said. “We will end up where we are after the last broadband plan” in 2004.
“Benchmarks are good. Benchmarks are useful if they're done in an appropriate way,” said Gregory Rosston, deputy director of the Stanford Institute for Economic Policy Research. “People say broadband is good. More broadband is better. That’s great. But we also need to know how much does it cost.”
Rosston said one hot-button issue is how the U.S. compares to the rest of the world, particularly comparisons based on the rankings by the Organisation for Economic Co-operation and Development (OECD). “Adoption is something you can measure and it has been focused on because it’s easily measured, it’s easily understood, but does it tell us anything?” he asked. The FCC should focus instead on the benefits that would come from wider adoption, versus the costs. “If we find that the benefits of broadband do outweigh the costs, how do we then determine a reasonable and efficient way to pay for it?” Rosston asked. World rankings “are not an end in themselves,” he said. “Benchmarks should be used to understand what factors in the market are not working and how policy can be more effective.”
Benchmarks by themselves shouldn’t be an end, agreed Richard Clarke, assistant vice president of public policy at AT&T. “For broadband benchmarking to be useful, it’s essential that these benchmarks reflect accurately the clear policy goals of the commission,” he said. “You can expect providers to teach to the commission’s tests. If you set out a wrong benchmark you may get wrong performance as a result.”
Clarke also warned against relying too much on international rankings like those from the OECD. “Attempting to align U.S. benchmarks with benchmarks adopted in foreign environments should be approached with great caution,” he said. “The OECD’s benchmark for measuring fixed broadband penetration is lines per capita. But fixed broadband lines typically serve an entire household and [U.S.] households are generally larger than those in other OECD countries.” Even in the U.S., household sizes vary significantly by state, he noted.
Catherine Sandoval, assistant professor of law at Santa Clara University, said speed of connections by itself is not a good measure for assessing broadband or whether wireless connections should be viewed the same as wireline. Sandoval said she often asks audiences whether anyone would be willing to give up their personal computer and rely on a cellphone for Internet access. “The reason no one raises their hand is not just because of issues about the size of the screen and the size of the keyboard and worry about carpal thumb, but also the nature of the level of the Internet access which is provided,” she said. In assessing access, the FCC also needs to focus on limitations providers impose, such as restriction on downloading applications, application use, computer tethering and congestion policies and practices, she said.
Scott Berendt, director of research, evaluation and documentation at One Economy, urged creation of a broadband progress board, to be chaired by the FCC, which would include members from other parts of the government, private sector companies and public interest groups. “The intention of the broadband progress board would be to implement and monitor the national broadband plan and focus on the established benchmarks and performance measures that have been handed down,” he said.