This statement is also available in PDF format.

March 23, 2009

We're here today because our friends at NTIA will be allowed to spend up to $350 million for a broadband map. I emphasize "up to" because by one learned estimate, that of Jane Patterson from North Carolina, that's about double what you need to complete the task. I have no doubt there will be takers for every dime, and the agency's goal is to make sure that the task is done correctly and the money is well spent.

Mapping is a complex undertaking, and this is no exception. Start with a basic question: Does a complete map take into account the backbone and middle-mile transport, or only the last mile to a residential customer?

NTIA is going to have to work hard to impose some uniformity on the process. Without that discipline, we will end up with as many different measurements of speed and service territory (to name a couple of factors) as there are maps. Integration will be impossible; the map will be useless. The broadband map will have to fit into existing mapping data sharing standards and protocols.

For now, though I want to leave the technical issues and focus on a couple of larger questions.

I want to frame the issues surrounding the map in a series of choices:

Will a map be accurate and complete, or inaccurate and incomplete?

Will it be done in the public interest, or in the private interest?

Will it be done with carrier cooperation, or without?

These are not frivolous questions. They go to the most central potential weakness in the data collection and mapping process, and that is the information submitted by telecommunications carriers.

Carriers, either themselves or through proxy organizations, have cloaked their data submissions in existing mapping projects in the veils of proprietary and confidential information. It's not information on future business plans, upgrades or deployments being sought. Around the country, states want to know what is in the ground now. How fast it is, and how much it costs. Carriers have resisted supplying all but the most rudimentary information with every fiber of their being, you should pardon the expression. And what they do supply is on restrictive terms and under absurd non-disclosure agreements.

In fact, last year, in the nadir of the debate, Comcast's Maryland lobbyist testified against a bill to require just such a reporting and mapping exercise by telling the House of Delegates Economic Matters Committee, that "9/11 wasn't that long ago. We don't want to make it easier for them to take out the network." He added that the legislation requiring fuller disclosure could point to where vital public safety resources were, particularly in the wireless network.

What information that is reported is frequently based on assumptions on the availability of service from central points, like wire centers or cell towers. But the data is secret, so no one can see the basis on which the maps were made.

Maps made from selective data put forward grudgingly by telecom carriers that can't be verified are useless. Maps compiled by organizations supported by telecom carriers, likewise. You might as well not spend the money.

The easy way to a good map is for the carriers to cooperate in providing good, accurate, granular data. But the agency should think about a Plan B, to gather data without the carrier cooperation. One survey in North Carolina used students going door to door and found broadband penetration 10 percent to 15 percent lower than the information carriers had supplied.

To sum up from my one, not fancy slide,

NTIA's Mapping Will Be Successful If Done:

• By a Public Agency
• On Behalf of the Public/ No Conflicts of Interest
• With transparent and verifiable data
• Using uniform standards
• Including comprehensive information