Solving the Rural Broadband Equation — Fund Infrastructure, Not Carriers.

A happy confluence of political circumstances has made rural broadband a hot topic and makes it possible to believe that perhaps, finally, the stars will properly align to do something more than the Connect America Fund. No offense to CAF, but everyone knows that CAF alone cannot provide quality, ubiquitous affordable broadband to all Americans. Not by a long shot.) Needless to say, Republicans and Democrats have rather different approaches to how they want to close the rural digital divide. I’ll save a comparison of what’s out there for a different post, because I want to take this opportunity to propose an entirely different approach than anything else out there at the moment.

 

It begins by recalling some wisdom I learned at my father’s knee. My father teaches tax law at Boston University. When grading student exams, he would often shake his head and sigh. “Answer the question asked,” he would say. “Don’t answer the question you want to answer because you have the answer, answer the question asked.”

 

What does that have to do with rural broadband? When we think about solving the rural broadband problem, nearly everyone tries to answer the question: “How do I find a carrier to serve rural areas.” But that’s not actually the problem we’re trying to solve. The problem we’re actually trying to solve is getting people access to quality broadband so they can participate in the modern digital economy and modern society generally. On the surface, that may look like the same thing. After all, you can’t get broadband access without some kind of carrier, right?

 

But if we start by framing the question in terms of a goal (get people broadband access) rather than a solution (find people a broadband carrier), we open a whole new world of solutions and approaches. As I discuss in more detail below, the reason rural communities don’t have broadband access is fairly straightforward: the communities in question are not sufficiently profitable to serve to justify the investment by profit maximizing firms (I’ll get to the importance of the word “sufficiently” below). If we then apply the skills we all (hopefully) learned back in high school math, we then break the problem down into solvable components. So we can either (a) raise the profitability of the target area; (b) lower the cost of deployment and operation; or (c) find entities that are either not motivated by profit or that are satisfied with much smaller profits.

 

We solved this one way back in the 20th Century. But the great virtue of the modern communications market, which allows us to break up the supply chain and bring in economies of scale from other markets, provides us with a bunch of new ways to solve the problem. Ideally, used in combination, we can have a solution that doesn’t lock rural areas in to a single, permanently subsidized provider, but instead closes the digital divide and enhances competition and potentially drives down everybody’s costs.

 

Short version — fund infrastructure, not carriers. And by “fund” I don’t just mean “throw money at,” although we need to be clear there is no way to avoid throwing money at this if we want to get the job done.

 

Lets break this out below . . . .

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What To Expect From The National Broadband Map.

Hey everyone, remember the National Broadband Map? As part of the Broadband Stimulus in the American Recover and Reinvestment Act (ARRA), Congress let the National Telecommunications Information Administration (NTIA) use a chunk of money to fund a national broadband map that they had ordered NTIA to create in 2008 as part of the Broadband Data Improvement Act (BDIA). Congress ordered NTIA to finish the project by February 17, 2011. NTIA handed out a chunk of change to make it happen back in 2009, and no one has heard much about it since.

NTIA has now leaked that they plan to release the first iteration of the map on February 17 – the day Congress ordered them to release it. This gives NTIA serious bragging rights at the next social get together with the Federal Communications Commission (FCC). “Yes, we got it done on time.” Asst. Secretary Larry Strickling, head of NTIA will say to FCC Chairman Julius Genachowski over a plate of nachos. “It would have been so awkward to have to ask for a month extension. We spent all our grant money on time as well, despite having to totally invent a multibillion dollar program and a tracking system from scratch. Really, staying on time isn’t that hard. You just need to have a plan. Speaking of which, how goes the National Broadband Plan implementation? Still on track?” At which point Genachowski will smile politely and head off for another mojito.

My predictions for the National Broadband Map below:

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Fairpoint Tries To Scuttle Maine Broadband Stimulus Grant

Ya know, if my state got a grant for $24.5 million to build out broadband networks in underserved areas, I would jump for joy. Not only does that mean jobs in the short term, but economic development in the long term. So why did Maine State Senator Lisa Marrache (D-Waterville) and Maine State Rep. Stacey Fitts (R-Pittsfield) introduce legislation to keep the University of Maine from participating in the $30 million partnership project with Great Works Internet (also based in Maine)? is it a coincidence that Fairpoint — that champion of rural private sector broadband which has proved the power of the private sector by defaulting on debt, declaring bankruptcy, and pissing off regulators — has been busy challenging this application and has been chanting the usual slogans about how the public sector should (a) keep out of broadband, and (b) hurry up with my Universal Service Fund bailout?

Without knowing whether Marrache and Fitts are direct recipients of Fairpoint’s campaign contribution largess, or merely ideologically sympatico with the notion of keeping federal money for job creation out of Maine and telling their constituents that they’ll get broadband when Fairpoint is good and ready to give it to them, this little incident provides a valuable reminder why Congress ought to finally pass the Community Broadband Act, which would prevent states legislatures from shafting their citizens in the name of ideological purity.

More below . . .

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An Open Letter To Blair Levin On The Subject of National Broadband Public Notices

Dear Blair:

I surrender! I admit defeat. I cry “uncle.” You win. Despite my earlier doubts, I am now prepared to say the National Broadband Plan process is the most open, transparent, comprehensive, bestest and wonderfullest proceeding ever in the entire history of the FCC since passage of the Communications Act of 1934! Just please, please PLEASE no more public notices. [break off into uncontrolled sobbing]

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Benchmarks and the Broadband Ecology.

As folks in broadband policy land know, thanks to the American Recovery and Reinvestment Act (ARRA), the FCC needs to present a National Broadband Plan to Congress by February 2010. The FCC has been holdng a bunch of workshops on various aspects of the plan as part of the inputs. I spoke last week at the Benchmarks Workshop. As I remarked to the sparse crowd, you can tell this is the deep uber-wonk stuff that only a handful of us find terribly interesting and vitally important while the rest of the world zones out and watches videos in their minds. For the short version, I include my latest “Five Minutes With Harold Feld.” Those more interested can watch the entire panel or read my written statement here. My more snarky comments (including my assessment of the panel) below.

More below . . .

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Will The Broadband Stimulus Package Get Strangled In The Craddle? And Why That Would Be A Disaster For Policy.

More and more, I’m feeling like a volunteer for the “Mark Sanford in 2012 Committee” finding out what “hiking the Appalachian Trail” really means. I have been a huge supporter of this program from the beginning. Even though I have had some concerns along the way, I have tried to keep the faith.

But the more I see about how this will get implemented, and the more deeply I delve into the details, the more I worry that a potentially great program capable of fundamentally altering our broadband future for the better to something so ridiculously screwed up that we will actually lose ground on both future funding and future policy.

The thing that finally broke my willingness to believe was this eyewitness report I got from my brother and business partner, Shmuel Feld, who attended the first NOFA Workshop held Tuesday, July 7 here in DC. A representative from RUS was explaining how applicants must fully document “unserved” and “underserved” at the census block level — but without access to any carrier data because carriers regard this as proprietary. Then, assuming the application survives to the NTIA/RUS “due diligence” round, the agency will invite broadband access providers in the area to submit confidential information to demonstrate that the area designated by the Applicant is not underserved or unserved. The applicant will have no opportunity to rebut any evidence submitted against the Application. From my brother’s report, this prompted the following exchange:

From Audience: If we, the people, do not know where the (BB) structures are or what the penetration numbers are and the big companies are not sharing these numbers or can deny them in the second round (when it is convenient) under the due diligence investigation, then how will we find out all of the information necessary for the application?

(Direct quote of RUS guy): Well that’s quite a challenge, isn’t it?

The RUS guy’s next line was a suggestion like “boots on the ground and canvassing a county” I could not hear him clearly because of the (I am serious) laughter.

OK, let me explain something to anyone from RUS or NTIA reading this. Giving Applicants an impossible task is not a “challenge.” It is a recipe for failure and a sign that you — NTIA and RUS — have screwed up big time.

I explore what I think is happening, and how it might still get fixed in time to save both the broadband stimulus package and the future of BB policy for the rest of the Obama Administration, below . . . .

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It's time for the NOFA Awards!

No, not the actual giving out of money, silly. My snarky commentary on yesterday’s unveiling of Broadband.gov.

I’ll preface by saying I absolutely still love and respect the folks I know on the inside who struggled with this stuff for months. I know how hard it is to actually implement this stuff, especially with this kind of ridiculous schedule and no one appreciating what it takes to coordinate among this many agencies and how utterly devestated the federal workforce was following 8 years of the Bushies refusing to invest in information technology, outsourcing everything to contractor cronies, and elevating political loyalty over actual talent.

Nor do I have much patience with those who are all “they sold us out blah blah blah . . .” Engineers don’t whine about how unfair it is that trees bloom in the spring and screw up line of sight with their leaves. You deal with it. Same in politics. You want good policy? Then you roll up your sleeves and get ready to fight for it rather than whining like little babies about how Obama the Deliverer failed to smite our enemies for us or persuade incumbents to put the public interest over their corporate interests and magically made all the problems of getting human beings to cooperate with each other go away. Because unless you’re willing to make some actual phone calls to members of Congress like Dittoheads do when Rush gives them the word, then I don’t want to hear it.

And the fact that there are some real issues does not negate all the good this NOFA will do. Anyone who claims that getting a less than perfect result means we pissed this away and it’s just as bad as Bush and blah blah does not know what they are talking about. I’d rather have this than more hymn singing from the worshipers of the gods of the marketplace. The fact that this turns out to be incremental rather transformative, a stepping stone rather than the whole edifice, doesn’t make it crap.

And finally, I promise to do real deep policy analysis soon.

But my selfish indulgence in unfair snarkiness below . . . .

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My Weekly Five Minutes of Fame — I Explain the National Broadband Plan In Five Minutes.

We are starting a new feature at Public Knowledge called “Five Minutes With Harold Feld,” wherein I will take insanely boring complicated wonkery and make it mildly less boring. This week, I explain the National Broadband Plan and the comments PK filed last night.

Stay tuned . . . .

Very Interesting Map Of Comments In BB Stimulus Proceeding

In my capacity of consulting with the Benton Foundation, I have been doing work with Kate Williams, a professor of informatix at University of Illinois. Williams has been doing some (IMO) critical work around broadband sustainability. In particular, Kate has been studying the old Technologies Opportunity Program to determine which projects had lasting impact and which didn’t — a rather important consideration for the new and improved BTOP program.

But what caught my attention recently is this very interesting map that Williams compiled based on the comments submitted to BTOP. It places the comments filed on a geographic map, with links to the actual comments themselves. The map includes the 58% of comments filed by the April 13, 2009 deadline which contained reliable information on the location of the commentor. The remaining 42% either gave no location or included location in an attachment which Williams considered insufficiently reliable to determine location.

Why do I find this interesting? Because it potentially provides a very interesting cross check on the state of broadband geographically, as well as who follows these proceedings. I have long lamented that the FCC (and other federal agencies) make so little use of the data they actually collect. At best, an agency may note submission by a class of commentors (e.g., broadcasters, MVPDs, ISPs) in the specific proceeding at issue. But no one tries to take the multiple data sets collected as comments in each proceeding, or in multiple proceedings, and tries to determine patterns and what they might suggest. williams grouping by geography is intriguing, and I cannot help but wonder what would happen if we applied a similar analysis to multiple FCC proceedings — including for comments generated by mass “comment engines” that have become common in some high profile proceedings. It would be very interesting to know, for example, if the people feeling passionate enough about media consolidation or network neutrality cluster geographically and, if so, do we see patterns of geographic interest which might tell us about the actual situation on the ground.

Of course the sampling from comments is not a pure scientific data set in that to comment, a commentor must (a) know about the proceeding, and (b) feel strongly enough to file comments. But the fact that the information has a particular set of biases does not render it meaningless, especially if one controls for this.

I hope researchers use Williams’ map, both to analyze the BTOP comments and as a model going forward for analysis of other proceedings.

Stay tuned . . . .