Because mobile wireless broadband service is a separate product market, WCAI urged NTIA to define areas in which mobile wireless broadband service is unavailable as “unserved,” even if fixed broadband is available. In this proceeding there seems to be a misperception that, with the advent of IP-enabled services, all communications services now participate in a single ‘broadband’ product market. During the roundtable phase of the public comment period, many commenters appeared to assume that the only differentiator of broadband services is speed. However, the differences between wireless and wired networks are more than purely technical or speed-related – the ability of wireless networks to offer mobility places mobile wireless broadband in an entirely separate product market.
Fortunately, there is no need for the Agencies to define the relevant broadband product markets anew to implement the ARRA. The FCC has already delineated between mobile and fixed broadband product markets in the context of its orders addressing various merger and other transactions. The Agencies should rely on this body of precedent when implementing the ARRA.
Other WCAI recommendations include:
- The Agencies should consider separate speeds for mobile wireless broadband networks.
- NTIA should define areas in which mobile wireless broadband service capable of delivering at least 3 mbps downlink and 768 kbps uplink speeds is unavailable as “underserved.”
- The Agencies should reject requests to limit initial rounds of funding to “unserved” areas only and instead consider both “unserved” and “underserved” areas simultaneously.
- Projects that receive funding should represent the optimal mix of capabilities and cost.
- The Agencies should provide funding to “middle mile” only projects where appropriate, because delivering broadband to end users often requires a complementary backhaul solution.
- The Agencies should give substantial consideration to the views of the States, but the Agencies should not delegate wholesale their responsibility to review and rank applications.
WCAI Comments to the National Telecommunications and Information Administration and the Rural Utilities Service: http://www.wcai.com/images/pdf/2009_wcai4-9.pdf.
WCAI Comments to the Federal Communications Commission: http://www.wcai.com/images/pdf/2009_fcc4-9.pdf.