Commenters Give NTIA Ideas for Improving Broadband Data, Mapping; Cite Some Limitations
Commenters said NTIA could improve broadband data quality and accuracy to help mapping efforts, including by using geocoding, but some also noted limitations. An NTIA notice "recognizes that the starting point for any discussion of broadband mapping is the FCC’s Form 477 data program," said NCTA, urging NTIA to work closely with the FCC without duplicating its work. "NTIA could augment the FCC’s broadband availability data" to "ensure that any future national broadband map includes information on locations where providers have committed to future construction in exchange for government subsidies." NTIA hasn't yet posted comments due Monday, but some parties forwarded us their filings.
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Robust data is vital to "informed policymaking informed policymaking and efforts to close America’s persistent digital divide," said New America's Open Technology Institute and 10 other groups. "Establish a program that improves upon prior attempts to gather broadband access and adoption data. Commenters support efforts to aggregate datasets and then identify and fix gaps that exist in those datasets, but the ultimate goal of NTIA’s work in this area should be for the agency to create, or lead the creation of, a comprehensive data collection scheme."
"More granular broadband mapping could accelerate closing the digital divide, [but] our experience suggests that there is no 'silver bullet' ... and unfortunately the issues with mapping run even deeper than simply plotting broadband availability -- the locations that lack broadband are often themselves unmapped," USTelecom said. "The biggest problem is not an inaccurate view of where broadband exists, it is that unserved locations are not mapped." The group recommended "NTIA concentrate its limited resources on augmenting the National Broadband Map with a more fulsome set of rural geocoded locations that may exist in the hands of other government entities."
The American Cable Association "knows of no existing database that has a complete listing of all US households by address or by latitude and longitude of the premises," it said. "Government cannot produce a complete and accurate broadband map without first having the complete data set of housing unit locations. After that is accomplished, the government can then move on to examining the data required."
NTIA should partner with the Census Bureau, "to leverage the 2020 Census to gather geolocated broadband availability data with the precision warranted to foster informed broadband policymaking," ITTA said. NTCA saw potential benefits and drawbacks to the efforts. "An accurate database would benefit all Federal, state and local agencies who rely on broadband deployment data for issuing funding for new broadband deployment; providers looking to expand into unserved areas; and broadband providers who would only need to report their deployment data to one agency," it said. "Even with the most carefully crafted methods for reporting broadband deployment data, however, a challenge process will still be essential to allow data to be confirmed and errors to be corrected." It said new reporting "must not impose any new burden," particularly on small businesses.
Hughes Network Systems says improved data accuracy is badly needed. The FCC's national broadband map "has become woefully out of date, reflecting information as of December 2016," Hughes said. "The map does not reflect Hughes’s current service offerings," including "25/3 Mbps throughout the country." It urged the FCC to update the map with "new information within a reasonable period of receipt, such as within ninety (90) days of the filing date of the relevant Form 477 reports."
The Computer & Communications Industry Association believes NTIA should prioritize "1) protecting and promoting the free flow of information online, including by addressing jurisdictional challenges ... 2) safeguarding and supporting the multistakeholder approach to Internet governance; 3) fostering international coordination in digital privacy and security issues; and 4) furthering an international regulatory environment that encourages innovation in emerging technologies," it said.
The Wireless ISP Association backed better mapping but also voiced concern changes to FCC Form 477 data "or other data-collection efforts that seek broadband deployment at the sub-census block level will create new burdens on small broadband providers that will be ill-quipped to provide information at a more granular level." Carefully consider such costs, WISPA said.