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FirstMile.US Comments to FCC's
A National Broadband Plan for Our Future

Docket Number 09-51

FirstMIle.US comments were submitted to initial comment round on June 8, 2009. PDF Format, 25 pages PDF


Executive Summary

The legislated goal of the national broadband plan is to “ensure that all people of the United States have access to broadband capability.” We have reframed the goal of the broadband plan as this: universal adoption and usage of broadband. Merely having access to broadband is not enough to meet the desired outcomes: meeting the government policy goals and create the nation’s 21st century innovation engine.

Rather than trying to adapt our current communications policies and regulations to “fit” this new communications infrastructure, a clean slate approach is needed. The barriers to broadband access and adoption must be dissolved, in both the public and private sectors. Trying to retrofit the myriad of existing policies and regulations is a disservice to broadband users and a potential obstacle to the ongoing economic leadership of this country.

To simplify discussion, we use the following definitions:

  • Broadband = pipe
  • Broadband usage = pipe + devices + applications
  • Internet = primary set of broadband applications to meet government policy goals

The pipe should support a government-mandated minimum level of applications/services based on an experiential metric, focused on advancing government public policy goals. Any technology that will support the mandated minimum can be provisioned as the pipe.

We propose a user-centric definition of access in the context of the FirstMile.US Big Broadband Bill of Rights:
Access to broadband is adequate if a consumer can attach any consumer devices, computers and appliances to a broadband pipe that meets the mandated minimum federal standard. Through the pipe, devices will work effectively with any and all applications that support them, without restriction, within the scope of the law. The user experience should conform to generally accepted, scientifically-based usability criterion.

The important role that the national broadband plan should play is one of defining and finding ways to lower barriers to adoption – barriers that prevent building broadband pipes; barriers that prevent broadband value propositions that work for the underserved; barriers to application development that create broadband usage; barriers to accessibility by all users, devices and applications; and barriers to providing assistance to those need additional help in gaining the skills needed to embrace a broadband future.

The United States has two differentiators that must be taken into consideration when determining useful broadband access and adoption metrics – metrics that should be based on a principle of equity for broadband infrastructure. These differentiators are predictors of underserved broadband communities.

  • First, approximately one fifth of the US population lives in rural America.
  • Second, approximately one fifth of the US population lives in poor urban centers.

The definition for underserved must be tied to measurable, empirically verifiable criteria that are known predictors of low broadband adoption. These include but are not limited to:

  • No access to broadband pipes
  • Median income
  • Head of household education level
  • Whether English is second language
  • Concrete measures of the level of ICT literacy (homes with low adoption of technology)
  • Median age of residents
  • Mean, median, and modal education level within the household

Access to broadband services of first and last resort is imperative. A national broadband plan should emphasize and provide for publicly available resources while building on its goal of universal adoption.

Education level is a predictor of broadband usage.  Particular emphasis should be made in the broadband plan to provide for full inclusion of every classroom and educational institution in this country, both public and private.

Download the PDF Format, 25 pages