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Summary:

This is the fourth and final post in a debate between Blair Levin, the writer of the National Broadband Plan, and Craig Settles, a broadband industry consultant. Levin is convinced critics of the plan gloss over the level of detail that went into its creation.

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Edit Note: This is the fourth and final column in a debate about the role of competition, broadband speeds and the goals of the National Broadband Plan between Blair Levin, the plan’s author and Craig Settles, a broadband consultant. The first post can be found here, followed by Levin’s response and Settles’ rebuttal.

Thanks for your response.

We’re making progress, but our discussion still has the problem of getting to a common agreement on what problem we are trying to solve. The National Broadband Plan team was trying to solve many problems (as directed by Congress) but the first problem, as explicitly stated by Congress, was ensuring “that all people of the United States have access to broadband capability.”

To do that, one has to define what level of broadband capability government should be willing to subsidize, how much it will cost and how the government will pay for it. So it’s difficult for me to take seriously any criticism of the plan that doesn’t provide concrete answers to those questions.

Mr. Settles doesn’t provide those answers, though in his latest discourse, he appears to be more willing to accept the 4 Mbps speed target for the subsidy for residential, as long as the plan allows for that goal to be reconsidered, which it does. If I’m reading Mr. Settles right, then perhaps on that issue, we don’t disagree, though if so, it undercuts his earlier attacks on the plan.

If I’m reading him wrong, then once he answers those three questions we can have a far more productive dialogue. Simply saying that there are a lot of cost models is true, but if one is going to say he has a better plan, then one should be willing to advocate a reliable cost model for it. Further, Mr Settles says he wants more than 4Mbps in the next 10 years but he continues to avoid ever addressing how he would pay for it. We writing the plan didn’t have that luxury.

As to changing Universal Service to have it be more of a grant program to local communities, that’s an intriguing idea, one that as a former municipal lawyer, I personally have some sympathy for. My experience, however, with Universal Service, as well as the implementation of the 1996 Act, reminds me that implementation details can spell the difference between where good ideas succeed and where they don’t. Without knowing the details of Mr. Settles’ proposal, it’s hard to comment, but based on what he has written so far, I stand by our recommendations as the best plan I’ve yet seen that would accomplish the congressional objective.

In any event, as the FCC will be considering a very significant reworking of Universal Service early next year, I would urge Mr. Settles to engage in that debate. I should note Mr. Settles failed to answer the question of whether he thinks we should continue to fund multiple competitive wireless voice providers in an area. The team believed there were higher priorities — such as getting broadband to unserved areas — but Mr. Settles can disagree as long as he’s clear about where funds for unserved areas will come from.

I admit to some amusement that Mr. Settles was “ecstatic” at the plan’s recommendation that state laws not impede municipal deployment efforts. When the plan came out, everyone had a choice of whether to focus on the recommendations they liked or the ones they didn’t like. In my view, the more sophisticated and serious players in the process understood that getting things done is much harder than stopping things, and therefore, it made sense to push the positive aspects of the agenda. For example, when the plan was released, there was significant early praise on such issues as spectrum, Universal Service and Rights of Way reform. Curiously, several municipal advocates choose to focus on the merits or demerits of aspirational goals (such as the 100 Mbps to 100 million homes) rather than use the release of the plan to build support for the municipal recommendation. As a result, not surprisingly, there has been some progress on those other issues, but not on the municipal issue. With respect, I think that was an unfortunate tactical mistake by Mr. Settles and others who I know care deeply about the issue.

On wireless, Mr. Settles continues the attack something we did not say: that wireless will replace wired for business connectivity. Our point was  our country needs both a robust wired and wireless ecosystem, and that business, like consumers, will increasingly rely on mobile functionalities. Mr. Settles, and rural, wired phone companies, don’t like us pointing that out. I understand why the wired companies prefer us not to mention it, but I’m confused by Mr. Settles’ comments. It is not a matter of policy preference; it’s a simple fact of where the market is going, and it led the team to focus on the critical need for spectrum reform, which we saw as critical.

The major difference appears to be that Mr. Settles wants to focus on improving connectivity for business users. We continue to have a factual disagreement on the current service level to business. We publicized our initial findings in September and November of 2009, and adjusted as new data came in. We also published an extensive appendix with our data on these issues. If Mr. Settles think our data is wrong, it would be good to have a data-driven critique.

I’m not sure we have a disagreement on what should be done about it, as Mr. Settles hasn’t been clear on how he’s proposing to meet the need he suggests exists. Is he suggesting government funding new networks, or regulating current providers to assure certain speeds and price points?

Rather than speculate on what the proposals are in this forum, perhaps GigaOM would sponsor a live webcast of myself and Mr. Settles discussing the issues. I’m quite sincere in believing that the plan is a living document that should be improved, but also quite adamant that critics owe the team that produced it a level of seriousness and detail similar to that which that team devoted to the effort.

Blair Levin, served as FCC Chief of Staff from 1993-1997, and returned to the FCC in 2009 to lead the team that wrote the National Broadband Plan. He is currently a fellow in the Communications and Society Program at the Aspen Institute.

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