May 4, 2009
National Broadband Policy needs concrete goals to succeed
On April 8, 2009 the FCC issued its Notice
of Inquiry (NOI), "A National Broadband Plan for Our Future", seeking input to
inform the development of a national broadband plan. The focus of the plan is to
enable the build-out and utilization of high-speed broadband infrastructure with
the goal of enabling every American citizen and every American business access
to robust broadband services. This National Broadband Plan is required as part
of the American Recovery and Reinvestment Act (ARRA) of 2009 and must be
delivered to Congress by February 17, 2010. The NOI is allowing 60 days for
comments and an additional 30 days for reply comments, leaving the Commission
just seven months to develop a plan that will undoubtedly have a profound impact
on the entire Telecommunications industry.
Based on the volume of requested input it seems unrealistic that the FCC could
develop such an important piece of legislation in such a short period of time.
Additionally, it seems impractical to develop a National Broadband Plan without
the benefit of data collected by the Broadband Data Improvement Act (BDIA),
which will not be available until early 2011. But perhaps the more relevant
issue is the continuing lack of focus. Is the goal to increase availability of
broadband or to increase the usage and adoption of broadband?
Successful National Broadband Policies across the globe have three distinct
features: (1) Definitive goals to provide "x" bandwidth to "x" percent of
population by "x" date; (2) some form of government financing; and (3) telecom
policy that supports the goals of the plan. In addition, many of the plans also
have specific goals related to broadband adoption, not just availability, and
develop government policy and programs to support those goals.
Another key element of most National Policies is the fact that a market analysis
detailing the competitive environment, the market position of the incumbents,
availability and affordability of broadband has been undertaken ahead of policy
making.
Although the United States is tackling some of these issues, the components are
out of synch. The broadband mapping component is absolutely critical to the
development of any plan or policy – yet it will not be available until February
2011. Furthermore, there is no current agreement on exactly what type of data
should even be collected.
Without a clear understanding of the true "state of the market" how is it even
possible to decide what needs to be done? Additionally, unlike most countries
which developed their policies during the early stages of broadband deployment,
the United States has chosen to undertake theirs when over 70 million broadband
lines have already been deployed and penetration is at 60 percent. This is a
massive undertaking considering that the United States is the second largest
broadband market, the 3rd largest housing market and has a geography that is one
of the most diverse in the world.
The broadband stimulus has been a catalyst for the U.S. to revisit its broadband
programs. Although the FCC and Congress have long recognized the value of
broadband to the economy, its regularly changing broadband policy over the last
decade has done little to reduce prices and/or increase the quality of broadband
services. In fact, my own monthly broadband fee has steadily increased over the
last 10 years.
What is the role of the states within this
National Broadband Plan? Will the FCC be given authority to overrule any
regulation that impedes a National Broadband Plan, such as the varying rules
related to municipal telecommunication networks?
At this stage, there are more questions than answers. Nonetheless, the FCC and
the U.S. government have the rare opportunity to press the restart button and
finally set a policy and plan that can truly place the U.S. in a leadership
position.
A U.S. National Broadband Plan must focus not only on the fixed broadband
infrastructure, but fully account for the ongoing developments in wireless
broadband, particularly LTE and WiMAX. As such, this plan must detail near, mid
and long-term goals with respect to not only the desired services, but the
infrastructure and associated parameters required to support them. This plan
must focus beyond the last-mile and take into perspective the entire end-to-end
broadband infrastructure. Similar to Korea, any network that is part of the
National Broadband Plan should be a Quality of Service-guaranteed multi-media
network that offers integrated services of communications, broadcasting and
Internet ubiquitously, continuously and securely.
Given the large investments most likely to be required, it will be important for
the FCC and Congress to clearly define the roles of both Government and private
industry, because any National Broadband Plan will require some form of
public-private partnerships to work and must be supported by ubiquitous policy
(same across all states) to insure its success.
From a financial perspective, the National Broadband Plan will require tax
incentives, such as credits or accelerated depreciation schedules, to spur the
necessary investment required for what will likely be a highly advanced
next-generation broadband infrastructure. An example is Malaysia, in which the
Government recently approved a 100 percent investment allowance on capital
expenditure incurred by the last mile network facilities providers for broadband
infrastructure to provide broadband services. This incentive is applicable for
investment made and equipment purchased from 8 September 2007 until 31 December
2010 – the time frame for the build out of its National High Speed Broadband
Network.
While broadbandtrends applauds the FCC's effort to deliver a national broadband
plan that seeks to ensure that every American has access to broadband
capability, it must take further steps. Access itself is not enough; it must
focus on increasing adoption as well.
Instead of sifting through what is likely to be thousands of pages of comments,
perhaps the FCC should have establish a blue-ribbon task force with participants
from all facets of the broadband industry – equipment vendors, broadcasters, CPE
manufacturers, Internet Service Providers, ILECs, CLECs, MSOs, etc. to develop
its plan.
Additionally, it would be prudent for all parties involved to delay the delivery
of such a plan until data from the BDIA is available so that the FCC has the
most accurate inputs before setting any benchmarks.
Without this, the FCC should instead focus on delivering a framework for a
National Broadband Plan rather than the plan itself.
Teresa Mastrangelo is principal analyst with broadbandtrends.
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