National Broadband Plan Comments Due

Comments are due Monday, June 8, at the FCC on the National Broadband Plan (NBP.) The Notice of Inquiry lists some 120 questions that the Commission would like filers to address, running the gamut from goals and benchmarks to open access to privacy to entrepreneerial activity to job creation. Anyone who compiles a list of so many questions clearly hasn't given much thought to the problem under discussion, so it's clear upon reading the NOI that we're many years away from a good NBP, although we may have some vague and probably counter-productive guidelines much sooner: the FCC is supposed to report a plan to Congress by next February. Bear in mind that it tool the US 20 years to convert from analog to digital TV, and we're not even there yet.

It strikes me that we'd be doing well if we had  a national dialog well underway by February on what a NBP would look like in terms of goals and measurements. The discussion up to this point has been dominated by weeping and wailing about the ranking of the US relative to countries where high-speed networks have been built with combinations of government subsidies and service restrictions. In Japan, for example, NTT was allowed to write off 100% of the costs of pulling fiber to the building (mostly apartments) as part of the deal that allowed it to private. Given the many demands on the federal treasury at the moment, that seems an unlikely path for the US. In South Korea, KT restricts the use of VoIP on its network to those who subscribe to its own service, to the dismay of American servicemen and women who want to use Vonage to phone home. Sweden and France have very low cost, government subsidized fiber networks, but only in the big cities.

And there's the question of what these rankings mean in a historical context. Will the massive investments that other countries have made in broadband networks be followed up by continuous service upgrades, or are they going down as one-time blips that will fail to live up to the hype? There's no way of knowing these things right now, although it is reasonably clear that the US is adding new fiber-to-the-home connections faster than any country except Japan (and even that's a bit uncertain, as the actual pattern there is fiber to the building and VDSL to the actual apartment.)   I'd like to see more fiber as much as the next guy, but I'm skeptical that the subsidy model is going to work very well in the US.

So it strikes me that the only questions worth answering in the FCC's laundry list are those that relate to goals and objectives. Rather than wringing our hands about where we stand compared to the rest of the world, we need to get very clear about WHY we want a national plan, more or less what applications we hope to enable with it, and how much taxpayer money we're willing to spend on it. Given those general outlines, we can begin to evaluate business and technology models so we can see what gives us the most bang for the buck.

I'd also like to know what people are doing with their super-fast broadband connections abroad. There's a suspiciously high correlation between the crappiness of local TV and broadband speed, so it may turn out that the value of fast broadband is mainly found in fast downloads of American TV shows and movies. If that's the case, a better broadband infrastructure in the US would simply duplicate the cable TV network and there's not much point in that unless you're an Internet advertiser.

But if it turns out that our overseas cousins are developing immersive gaming, telemedicine, and video-conferencing apps that enable new capabilities with massive social utility, I'll climb onboard the subsidy bandwagon.

As an engineer, I need the data before I make up my mind.

File your comments with the FCC's ECFS.