Reviewing comments on the Berkman Center's broadband study for the FCC

Last night the period for commenting on the Berkman Center’s broadband study for the FCC came to a close. We would like to thank those who took the time to provide substantive feedback and also to respond briefly to reports that incumbent broadband providers were negative in their assessments of our work.

We came out with a draft report that provided a comprehensive and multidimensional study of how relatively advanced economies are doing on broadband, and what sort of prices and quality -- in particular as measured in speed -- consumers in these different countries are seeing. The results we found for the US were less than inspiring. This by itself was likely to elicit disagreement. Looking at current planning documents in other countries, we also found that a broad consensus has emerged that open access policies played a constructive role in their own broadband development. We then did an extensive study, looking country by country and firm by firm, to try to see what the basis of this belief is. We showed that when you looked at who the market players were, and how and when they entered and created more competitive markets, these other countries had a real basis on which to rely when they thought that open access played a role in their broadband development and that they need to adapt it to the next generation transition. Neither set of findings is congenial to the major incumbent broadband providers.

Looking at the comments, most of which accumulated yesterday, it seems as though our report created a mini stimulus act for telecommunications lawyers and consultants. Hundreds of pages of comments were filed. Obviously, it will take time to read through them all and respond to them appropriately and carefully as we finalize our study. On first read, they range in style and quality from comments that will advance the debate -- professional, detailed comments on the interpretation of the histories of broadband regulation and deployment in various of the countries, the advantages and limitations of different international benchmarking techniques, or econometrics techniques -- all the way to the usual ad hominem, "discredit the witness" type that, it seems, you must come to expect when you agree to contribute your time and effort to matters of public concern. Comments that try to muddy the water are regrettable but apparently a fact of Washington politics. We look forward to working through the serious comments, which will take time to do thoughtfully, and to continue the process of taking a good long look at the experience of the past decade, which is appropriate when the FCC is developing a national broadband plan.