The Broadband "Plan" - where's the beef or what's the beef

Last week's Independent Report did a good job at setting out what the "Plan" would have in it before it was publicly presented. The "Plan" should be copyrighted with those quotes around the word "Plan" to indicate that there is not much of a"plan." More like a lengthy, pretty book report about broadband and a "wish-list" without much about how to reach objectives.

This "Plan" was supposed to be data driven; the FCC staff promised. The "Plan" talks about wholesale changes to USF, but where is the data that demonstrates why change is needed? Is it needed in areas served by rural incumbents where the rural incumbent USF program has successfully fostered the investment in networks that support the very objectives the "Plan" espouses? There is no recognition or acknowledgment in the "Plan" that there is a system in place that works.

If the authors of the "Plan" had fulfilled their promise, they would have presented hard data demonstrating where broadband has been deployed in rural America. Carriers filed in their broadband reports (Form 477). The FCC has the data; the FCC spent $20 million on the "Plan." But, there is no specific area deployment data reported much less a report that ties the level of deployment to the various regulatory frameworks applicable to rural and non-rural carriers serving rural areas. The FCC could easily have looked at the USF monies spent in rural incumbent areas over the past 10 years and quantified the resulting cost of government programs needed to deploy identifiable broadband networks in rural high-cost areas.

But, there is no report; there is no analysis. There is no rigorous look at a comparison of the significant advanced network deployment in rural areas served by rural incumbents contrasted to the antiquated networks and services available in rural areas served by the large, non-rural incumbents. Instead, there are broad-brush descriptions and conclusions.

Two of the conclusions of the "Plan" stand out as especially absurd.

First, the "Plan" establishes a goal of 4 mgb download speeds by 2020. That goal is already reached in many areas served by rural incumbents. That "goal" is nothing but cover for an apparent "plan" to divert USF funding from rural incumbent areas where it is required to build more robust networks that can deliver services that are truly comparable to those available in urban areas - the very goal of the universal service provisions of the Communications Act.

The second absurdity is the "Plan's" conclusion that the FCC should end rate-of-return regulation. Let's take another look at the data the authors of the "Plan" promised - oh, that's right - it's not there. If it was there, it would show that in high-cost-to-serve rural areas, it is those areas that are served by rural incumbents subject to rate of return regulation where the regulatory framework has succeeded in fostering advanced network infrastructure deployment. But, the "Plan" decides to throw that framework away!

For the authors of the "Plan," it's going to be difficult to answer the question: "Where's the beef?" For critics of the "Plan," it will be all too easy to answer the question: "What's your beef?"

The real challenge ahead is to build a plan to deal with this "Plan."