WTA Responds to FCC’s Annual 706 Inquiry

Today, WTA provided comments to the FCC in response to its Notice of Inquiry seeking information to complete its Nineteenth Annual Report concerning the deployment of advanced telecommunications capability as required under Section 706 of the Communications Act of 1996.

WTA advised the FCC to employ the “Gretzky test” – keep eyes on where the proverbial puck is going, not where it has been. To that end, WTA recommends the FCC continue to use both the short-term benchmark of 100/20 Mbps and the long-term benchmark of 1000/500 Mbps, and disagrees with the NOI’s proposal to abolish the use of a long-term benchmark.

On the question of “technological neutrality,” WTA stated that this principle does not require the FCC to ignore the different capabilities and limitations of different technologies.

With regard to data sources for fixed broadband, WTA supports continued use of the BDC information. While not without flaws, it is the best and most comprehensive information available. Among other flaws, it shows satellite broadband at 100/20 Mbps “available” everywhere, even though the shared, finite capacity among the system’s customers within a satellite footprint limits the number of total customers a LEO satellite system could actually serve at those speeds. In addition, the speed that is reported is the “advertised” speed, and if a range is advertised, then the high end of that range is reported. Thus, the map does not necessarily reflect the actual speeds customers will be able to enjoy if they subscribe to that service.

Finally, WTA provided several suggestions for steps the FCC should take to accelerate broadband deployment. In order to ensure that broadband services remain affordable, the FCC should continue and expand its universal service programs. In addition, reducing the number of unfunded mandates or providing sufficient support to cover those costs, would accelerate deployment.