9/27 FCC Reply Comments Highlighting Need for Robust Mobile Broadband Mapping Data

New America's Open Technology Institute wrote and submitted reply comments with the Federal Communications Commission (Commission) responding to arguments and suggested policy prescriptions for developing a nationwide mobile broadband map. Public Knowledge co-signed the reply comments, which followed an ex parte meeting and letter submitted by OTI and PK in tandem as well. In the reply comments, OTI and PK argue that the Commission's mobile broadband mapping effort must be as consumer-friendly as possible, and that challenges to disclosures from internet service providers must be made simple for individuals and organizations to undertake to promote a trust-worthy and tested mobile broadband map. An introduction is available below:

New America’s Open Technology Institute and Public Knowledge (“OTI and PK”) respectfully submit the following reply comments in response to the Commission’s Public Notice seeking comment on the Commission’s upcoming mobile broadband maps and the challenge process for validating provider data. The Commission’s rules concerning its mobile broadband maps will greatly determine whether or not this program effectively gives the public sufficiently accurate, relevant and transparent information on the availability of mobile service in the U.S.. Getting these maps right is critical since they will impact policymaking at all levels of government, as OTI and PK highlighted in an ex parte filing last month.

The record clearly demonstrates a crucial need for the Commission to implement rules for the challenge process that are as burden-free as possible, as Congress intended. The mapping process should empower the participation of all consumers, community anchor institutions, local governments, small providers, and any other entity reliant on broadband to participate and contribute to the integrity of the data. The Commission should minimize the burdens associated with challenging mobile broadband availability data. Additionally, the Commission should plan to include—if not initially then as a next step—a wide variety of information such as throughput speed, signal reliability, and the price for mobile broadband available in the U.S. for consumers, policymakers, and the public.

The record reflects skepticism that the mobile carriers’ data will be sufficiently reliable, signifying a clear need for the Commission to proactively validate availability information rather than outsourcing the task to the public. At the very least, the Commission should require providers to make consumers aware of the challenge process and ensure that everyone possible is empowered to act when suspicious that they are not receiving the service mobile providers claim to offer in a particular area.