The National Telecommunications and Information
Association's National Broadband Map may be imperfect, but it is good enough
for the FCC to use to determine where broadband is already being delivered and
should not be overbuilt.
That was the word from the American Cable Association to the
FCC in reply comments on the commission's second phase of broadband subsidies
in the Connect America Fund, which the FCC created to migrate traditional phone
support to broadband.
In reply comments to the commission, ACA, which represents
smaller and mid-sized cable operators, ACA said there were a number of reasons
to use the map even though it conceded it is a flawed "work in
First, it is the most accurate map that currently exists of
where service is already deployed, said ACA.
Small cable operators are concerned about the government
subsidizing incumbent carriers to overbuild where ACA members are already
deploying service or ramping up speeds via the next-generation DOCSIS platform.
ACA said that any inaccuracies could be quickly addressed
through a challenge process ACA is proposing where it would be up to incumbents
to prove an area is unserved.
The FCC has proposed raising the proxy speed for
high-speed broadband to 6 Mbps upstream/1 Mbps downstream, but ACA said it
should stick to the current DOCSIS 3/768 speed (itself a proxy for the 4/1 the
FCC is shooting for), or risk discouraging private investment.