Today, the Internet Innovation Alliance (IIA) filed comments in the Federal Communications Commission’s (FCC) Fifteenth Broadband Deployment Report proceeding under Section 706 of the Telecommunications Act. The annual report measures progress of deployment of advanced telecommunications services in a reasonable and timely fashion.

In its comments, IIA states that “the underlying trends in broadband deployment are overwhelmingly positive” while noting the gaps that remain and the urgency of addressing them. In particular, the majority of new broadband connections were in rural areas, “contributing significantly to narrow a persistent gap in broadband access.”

IIA also commented on two important issues on which the FCC sought outside views in its Notice of Inquiry. First, IIA is disappointed that the FCC maintained the current evaluative framework for fixed and mobile broadband, rather than regarding the two services as functional equivalents. Instead, “the fact is that, over the past two years, the broadband market has evolved rapidly and sufficiently to permit – if not demand – the conclusion that mobile and fixed broadband are full substitutes,” reads IIA’s filing. Looking at the question from the perspective of consumers – as IIA did in a 2018 report, “Evolving Preferences” – shows that consumers increasingly use fixed and mobile connections in similar ways, including for data-intensive applications such as watching sports or movies, applying for a job, or doing homework. In addition, as IIA writes, “Data traffic on mobile broadband connections appears to have already surpassed that on fixed broadband connections – a result that would have been impossible if consumers did not view fixed and mobile broadband as functional equivalents.  The market has evolved radically from Congress’ expectations in enacting Section 706 of the Telecommunications Act. . .The Commission should now recognize this fact.”

Second, IIA endorsed the position of the Notice of Inquiry to maintain the speed metrics used in 2019 for “advanced telecommunications services” to be measured in the 2020 Broadband Deployment Report. “Quite simply, there is a distinction between a standard for a government report and what is actually happening in the marketplace.” Broadband providers compete aggressively to offer higher broadband speeds, but “what Congress sought to measure – the deployment of advanced telecommunications services in a reasonable and timely fashion – is captured by the current measure . . . In 2019, as they have for years, broadband providers are constantly increasing speeds in response to competitive pressures and as a result of new deployments thanks to policies that promote investment.”

IIA joins all commenters, and the FCC itself, who agree that the work of closing the digital divide is not complete. Policies that encourage investment and innovation in broadband networks are the best way to reach that goal.

To read IIA’s comments, click here.