Free Press Research Director Derek Turner plans to tell Congress that the broadband deployment figures in the FCC's national broadband plan are "suspect," probably overstate deployment in rural America, and suggests the FCC's deployment strategy is based on a "house of cards."
In prepared testimony obtained by B&C for a House Communications Subcommittee hearing, Turner commends the commission for its goal of universal service, but counts the "flaws" it in its proposed execution, which include incorrect assumptions about what cable modem technology is being deployed and the capabilities of DSL, he says, and "ignorance of middle-mile data transport constraints" that translate into overstatement of the quality of last-mile (customer-facing) service.
Turner says his group has concerns about "the assumptions that underlie the analytical foundation of this transition plan."
In particular, he is concerned about the report's finding that "95% of U.S. housing units" have access to broadband at speeds of at least 4 Mbps downstream and 1 Mbps upstream. "If true," he says, "this would mean that our broadband infrastructure challenges are far more manageable than previously thought."
But it is not true, he charges. "Upon close examination, it is quite apparent that this determination of broadband deployment is built upon a house-of-cards of assumptions."
He says the FCC is basing its deployment figures on the assumption that cable modem service is available wherever cable service it deployed, and assumes Docsis 2.0 is fully deployed, neither of which are givens.
Turner suggests the FCC needs to collect better data on which to base its plan. "The problems with this estimate only serve to highlight the fact that the FCC currently lacks adequate information on the actual state of broadband availability, despite years of public and Congressional pleas for better data," he says. "Good data is a requirement for good policy."
While the plan recognizes the need to collect more data, it will likely not be able to do so and analyze it before early 2014, says Turner, which would be moving forward on a plan "absent adequate data." That, says Turner, "raises serious questions about the FCC's commitment to sound, fact-based, data-driven policy making..."
Turner also weighed in on the BitTorrent case, pushing for classifying broadband as a Title II telecommunications service.