COMMENT SOUGHT ON IMPROVING INTERNATIONAL COMPARISONS REQUIRED BY THE BROADBAND DATA IMPROVEMENT ACT
Federal Communications Commission
445 12th Street, S.W.
Fax-On-Demand 202 / 418-2830
Washington, D.C. 20554TTY 202 / 418-2555
Release Date: August 27, 2010
COMMENT SOUGHT ON IMPROVING INTERNATIONAL COMPARISONS REQUIRED
BY THE BROADBAND DATA IMPROVEMENT ACT
PLEADING CYCLE ESTABLISHED
IB Docket No. 10-171
Comment Date: September 27, 2010
Reply Comment Date: October 12, 2010
collect data on the extent of broadband service capability in other countries to enable the Commission
to examine this information as part of its annual consideration of whether advanced telecommunications
capability is being deployed to all Americans on a reasonable and timely basis.
Specifically, section 103(b) of the BDIA provides:
(b) INTERNATIONAL COMPARISON.—
(1) IN GENERAL.—As part of the assessment and report required by section 706 of the
Telecommunications Act of 1996 (47 U.S.C. 157 note), the Federal Communications
Commission shall include information comparing the extent of broadband service capability
(including data transmission speeds and price for broadband service capability) in a total of 75
communities in at least 25 countries abroad for each of the data rate benchmarks for
broadband service utilized by the Commission to reflect different speed tiers.
(2) CONTENTS.—The Commission shall choose communities for the comparison under this
subsection in a manner that will offer, to the extent possible, communities of a population
size, population density, topography, and demographic profile that are comparable to the
population size, population density, topography, and demographic profile of the various
communities within the United States. The Commission shall include in the comparison
under this subsection—
(A) a geographically diverse selection of countries; and
1 Broadband Data Improvement Act of 2008, Pub. L. No. 110-385, 122 Stat. 4097 (codified at 47 U.S.C. §§
(B) communities including the capital cities of such countries.
(3) SIMILARITIES AND DIFFERENCES.—The Commission shall identify relevant
similarities and differences in each community, including their market structures, the number of
competitors, the number of facilities-based providers, the types of technologies deployed by
such providers, the applications and services those technologies enable, the regulatory model
under which broadband service capability is provided, the types of applications and services
used, business and residential use of such services, and other media available to consumers.2
The International Bureau recently released the first International Broadband Data Report (2010
IBDR).3 The 2010 IBDR presented basic data in three main categories for communities in 37 countries:
(1) publicly-available pricing information on broadband Internet access services available from Internet
service providers (ISPs); (2) population, education, and other demographic information; and (3)
descriptive information on regulatory structures, market conditions, and other media.4
This Notice seeks public comment regarding the preparation of next year’s IBDR, and how best
to build on the foundation of the 2010 IBDR. What improvements can be made to the data and analysis
used in the 2010 IBDR to make next year’s IBDR more useful, particularly for policymakers, including
for the Commission’s overall assessment regarding the reasonable and timely deployment of broadband
services to all Americans? Are there additional data and analysis that could better illuminate
similarities and differences between broadband technologies, markets, and policies in U.S. and
comparable foreign communities? Should we provide side-by-side comparisons of the price and
performance of popular broadband offerings in U.S. and foreign communities?5 We invite interested
parties to submit comments to assist this effort to improve upon the 2010 IBDR, including with respect
to analytic techniques or approaches to estimate the effects of competition on the availability,
capability, and adoption of broadband in foreign communities. As detailed below, this public notice
seeks specific comment on improving several data collections pertaining to the IBDR.
Broadband Service Demand and Supply:We seek comment on the approach used in the
2010 IBDR for identifying and selecting communities, which focused primarily on geographically-
defined communities at the state, regional, or sub-regional level, and whether that approach could be
improved. We also invite comment on what factors are likely to affect the supply of and demand for
broadband and whether an analysis of these factors will help identify “similarities and differences”
between communities with respect to the extent of broadband service capabilities. For example, is the
demand for broadband influenced by such factors as income, educational level, the percentage of
households with computers in their homes, the level of computer literacy, the age distribution of the
population, and other demographic factors? What factors are likely to affect the supply of broadband?
For example, to the extent that population dispersion or geographic conditions increase the cost of
broadband, one would expect that this would depress the level of broadband deployment, raise prices,
2 BDIA § 103(b); 47 U.S.C. § 1303(b).
3 International Comparison Requirements Pursuant to the Broadband Data Improvement Act, International
Broadband Data Report, First Report, GN Docket No. 09-47, DA 10-1348 (Int’l Bur., rel. Aug. 27, 2010).
4 The 2010 IBDR does not include all described data for all 37 countries because some data was unavailable.
5 We recognize that the characteristics and features of pricing plans can vary substantially. We seek comment
on how, after collecting data about plans, we can organize it in such a way that it can be most effectively
compared across communities.
and thereby reduce demand. What metrics can we use to estimate these supply conditions that affect
the cost of broadband?
We seek comment on identifying the best proxies for broadband penetration. Should we be
analyzing data on the number of subscribers per capita to broadband, or would analysis of the number
of households and businesses with broadband subscriptions be more useful? Should we collect data on
the number of non-subscribers who access broadband outside the home? We seek comment on sources
of consistent data for measuring both demand for and supply of broadband.
Market Structure:Market conditions may likewise affect the demand and supply conditions
for broadband. What is the best way to compare market structure and other market conditions, given
the limitations in international data? We note that our experience in gathering information for the 2010
IBDR suggests that most countries collect data not on a city or town level, but rather on national,
regional, and sub-regional levels. In order for us to conduct a useful community comparison, we must
have comparable data to analyze. We seek comment on how we might obtain more disaggregated, but
comparable, data so that we can do a more meaningful comparison of communities.
Regulatory Strategies:We also seek comment on the regulatory strategies that other countries
have used to spur broadband availability, deployment, subscribership, or adoption and whether these
strategies have proven successful. The regulatory environment can affect the demand and supply for
broadband, but to summarize detailed regulatory policies in simple metrics is difficult. How can we
best evaluate the impact of different regulatory policies?
Other Considerations:We seek comment on the value of working collaboratively with our
international counterparts in order to develop and obtain comparable subscribership data.6 In addition,
we seek comment on possible sources of data that the Commission should examine in the course of
implementing section 103(b) of the BDIA. Finally, we seek comment on any other factors or issues the
Commission should consider in implementing section 103(b) of the BDIA (e.g., the impact on
broadband deployment/adoption of public/private partnerships to fund broadband deployment, and
targeting non-adopters with digital training or subsidies).
All comments should refer to IB Docket No. 10-171. Comments may be filed using (1) the
Commission’s Electronic Comment Filing System (ECFS), (2) the Federal Government’s eRulemaking
Portal, or (3) by filing paper copies.7 Comments filed through the ECFS can be sent as an electronic
file via the Internet to http://www.fcc.gov/cgb/ecfs/ or the Federal eRulemaking Portal:
http://www.regulations.gov.8 Generally, only one copy of an electronic submission must be filed. In
completing the transmittal screen, commenters should include their full name, U.S. Postal Service
mailing address, and the applicable docket or rulemaking number. Parties may also submit an
electronic comment by Internet e-mail. To get filing instructions for e-mail comments, commenters
should send an e-mail to email@example.com, and should include the following words in the body of the
message, “get form.” A sample form and directions will be sent in reply. Parties who choose to file by
paper must file an original and four copies of each filing.
6 Obtaining such data posed a challenge in the 2010 IBDR.
7 See Electronic Filing of Documents in Rulemaking Proceedings, 63 Fed. Reg. 24121 (1998).
8 Filers should follow the instructions provided on the Federal eRulemaking Portal website for submitting
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail (although we continue to experience delays in receiving
U.S. Postal Service mail). All filings must be addressed to the Commission's Secretary, Office of the
Secretary, Federal Communications Commission.
All hand-delivered paper filings for the Commission’s Secretary must be delivered to FCC
Headquarters at 445 12th St., S.W., Room TW-A325, Washington, DC 20554. All hand
deliveries must be held together with rubber bands or fasteners. Envelopes must be
disposed of before entering the building. The filing hours at this location are 8:00 a.m. to
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail)
must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
U.S. Postal Service first-class mail, Express Mail, and Priority Mail should be addressed to
445 12th Street, S.W., Washington, D.C. 20554.
People with Disabilities: To request materials in accessible formats for people with disabilities
(Braille, large print, electronic files, audio format), send an e-mail to firstname.lastname@example.org or call the
Consumer and Governmental Affairs Bureau at (202) 418-0530, (202) 418-0432 (TTY).
For further information about this Public Notice, please contact Arthur Lechtman, Special
Counsel, Strategic Analysis and Negotiations Division, International Bureau at
Arthur.Lechtman@fcc.gov or (202) 418-1465.
– FCC –
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