NDIA recently submitted comments to the Federal Communications Commission suggesting several ways to make the agency’s public data on broadband deployment and adoption more useful to local digital inclusion efforts.

NDIA’s comments can be found here. They were filed in response to the FCC’s Further Notice of Proposed Rulemaking in the Matter of Modernizing the FCC Form 477 Data Program.

Form 477 is a report submitted to the FCC by regulated broadband providers every six months. Among other things, each provider must submit a count of its residential connections which meet or exceed certain speed benchmarks in each Census tract, and identify the technologies it’s using to serve homes in each Census block with the “maximum advertised” download and upload speed in that block for each technology.

The Form 477 reports are confidential, but the FCC makes some of the data public on its website 9 to 12 months after the providers file it. The public releases include Census tract data on the aggregate number of homes with “fixed” broadband subscriptions reported by providers, as well as block-by-block lists of providers, their fixed home broadband technologies and maximum download and upload speeds.

As the public’s only source of detailed information on broadband deployment and adoption, Form 477 data is a unique resource for NDIA, our affiliates, and other researchers, planners and digital inclusion advocates. For example, Form 477 Census block deployment data is the basis for NDIA’s groundbreaking research into AT&T’s “digital redlining” of low income neighborhoods in Cleveland, Detroit, Toledo and Dayton. It’s also a vital component of the Purdue Center for Regional Development’s Digital Divide Index, and of community broadband mapping initiatives like Kansas City’s.

But there are significant shortcomings in both the deployment and adoption data — shortcomings that the agency partially acknowledged in its request for comments. NDIA’s comments address several of these shortcomings,  suggesting specific “fixes” to make the data more useful to community users. Our suggestions include:

  • In the Fixed Broadband Deployment Data for Census blocks, list all the speed tiers available from each provider and technology in each block, with the number of households eligible for each tier.
  • In the Internet Access Services data (fixed connections as a share of total households in each Census tract):
    1) increase the speed reporting benchmarks from two speed tiers (200 kbps and 10 mbps down) to at least four, and
    2) report the actual percentage of households meeting or exceeding each benchmark, rather than the obscure quintile code system now in use (in which, for example, code 2 represents “between 200 and 399 connections per 1,000 households”).

NDIA’s comments also reiterate our opposition to any FCC change in the use or reporting of mobile wireless deployment  data that conflates wireless services with “fixed” wireline broadband access, or makes the agency’s public data on wireline availability, speed or adoption any less detailed and transparent.

NDIA Comments to the FCC on Modernizing the FCC Form 477 Data Program, 9/25/17

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