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Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

October 2009: 

Telecommunications: 

Current Broadband Measures Have Limitations, and New Measures Are 
Promising but Need Improvement: 

GAO-10-49: 

GAO Highlights: 

Highlights of GAO-10-49, a report to congressional committees. 

Why GAO Did This Study: 

The Broadband Data Improvement Act, enacted in 2008, established a 
variety of initiatives intended to improve the quality of state and 
federal data on broadband (i.e., high-speed Internet) services and 
promote the deployment (the building of infrastructure over which 
broadband services can be provided) of affordable broadband services to 
all parts of the nation. The act required GAO to conduct a study to 
consider and evaluate additional broadband metrics or standards. This 
mandated report addresses (1) the measures generally available to 
consumers, industry, government and others, and (2) the limitations, if 
any, of the measures and how they could be supplemented or improved. To 
identify and evaluate the measures, GAO conducted a review of 
literature and related laws and interviewed and reviewed related 
documentation from stakeholder groups. 

What GAO Found: 

Multiple measures are generally available to consumers, industry, and 
government to assess broadband performance. Consumers can generally 
access measures of availability, price, advertised speed, and actual 
delivered speed from providers and third parties to compare services. 
Industry and government also have access to some measures that enable 
comparisons across segments of the United States to inform policy and 
guide investment. For example, the Federal Communications Commission’s 
(FCC) data from its semiannual reporting requirement for providers are 
the primary source for comparing the availability of and subscribers to 
broadband. Through a literature review and interviews with 
stakeholders, GAO focused on 10 measures that can be used to make 
international comparisons of broadband service to inform policy. Eight 
were composite indexes that are generally used to account for factors 
such as demographic and economic differences among countries, which, 
according to stakeholders, can affect broadband deployment and 
penetration (the number or percentage of subscribers per capita or per 
household). 

Through available documentation and discussions with stakeholders, GAO 
found that current measures have limitations, views were mixed on 
potential alternatives, and ongoing efforts need improvement: 

* According to some stakeholders, the lack of comprehensive measures 
from the government to compare price, actual delivered speeds, and 
service reliability data from providers is a limitation for consumers. 
FCC has open proceedings on requiring providers to report such 
information, but there was no consensus among stakeholders on the need 
for additional reporting requirements and measures. 

* Stakeholders told GAO that FCC’s semiannual data collection from 
providers does not include information on availability, price, or 
actual delivered speeds, which limits the ability to make comparisons 
across the country and inform policy or investment decisions. 
Stakeholders generally agreed that the Department of Commerce’s effort 
to develop a national broadband inventory map through its State 
Broadband Data and Development Grant Program would address some gaps 
and provide detailed data on availability, subscribership, and actual 
delivered speeds, but the department did not provide guidance to 
grantees on calculating actual delivered speeds or specific standards 
to verify the data collected. This could result in inconsistent data 
and limit the effectiveness of the effort. GAO has previously reported 
that consistency and data verification are important for reducing the 
risk of producing inaccurate data. 

* Finally, the measures used for international broadband comparisons 
have limitations for a variety of reasons, including socioeconomic 
differences that make the comparisons difficult. Despite the concerns, 
stakeholders found the measures useful to help inform policy. 
Stakeholders generally supported FCC’s efforts to develop international 
comparisons because the comparisons will be at a local level within 
each country, and could provide more relevant information. 

What GAO Recommends: 

To increase the data quality and subsequent results from the State 
Broadband Data and Development Grant Program, GAO recommends that the 
Secretary of Commerce examine the results of data collection and 
determine whether to develop specific guidance for grantees to improve 
the consistency and accuracy of the data collected under the program. 
The Department of Commerce generally agreed with GAO’s recommendation 
and stated it had begun taking actions to address the recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-10-49] or key 
components. For more information, contact Mark Goldstein at (202) 512-
2834 or goldsteinm@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Multiple Measures Are Available for Consumers, Industry, Government, 
and Others to Assess Broadband Performance: 

Stakeholders Reported Limitations with Current Broadband Performance 
Measures, but Views Are Mixed on Potential Alternatives and Ongoing 
Efforts Need Improvement: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Department of Commerce: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: U.S. Ranking in International Broadband Performance 
Comparisons: 

Table 2: Broadband Performance Measures Proposed by Stakeholders: 

Table 3: Stakeholder Arguments for and against Proposed Measures: 

Table 4: Stakeholders Interviewed: 

Abbreviations: 

3G: third generation: 

ADSL: asymmetric digital subscriber line: 

BAI: Broadband Adoption Index: 

BPI: Broadband Performance Index: 

BQS: Broadband Quality Score: 

CRS: Congressional Research Service: 

DSL: digital subscriber line: 

EIU: Economist Intelligence Unit: 

FCC: Federal Communications Commission: 

FTC: Federal Trade Commission: 

GDP: gross domestic product: 

ICT: information and communications technology: 

IDI: ICT Development Index: 

IEEE: organization previously known as the Institute of Electrical and 
Electronics Engineers, Inc. 

ITIF: Information Technology and Innovation Foundation: 

ITU: International Telecommunications Union: 

Kbps: kilobits per second: 

Mbps: million bits per second: 

MIT: Massachusetts Institute of Technology: 

NRI: Networked Readiness Index: 

NTIA: National Telecommunications and Information Administration: 

OECD: Organisation for Economic Co-operation and Development: 

OPASTCO: Organization for the Promotion and Advancement of Small 
Telecommunications Companies: 

OSTP: Office of Science and Technology Policy: 

TPI: Technology Policy Institute: 

Wi-Fi: wireless fidelity: 

WiMax: Worldwide Interoperability for Microwave Access: 

WISPA: Wireless Internet Service Provider Association: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

October 9, 2009: 

The Honorable John D. Rockefeller, IV: 
Chairman: 
The Honorable Kay Bailey Hutchison: 
Ranking Minority Member: 
Committee on Commerce, Science, and Transportation: 
United States Senate: 

The Honorable Henry A. Waxman: 
Chairman: 
The Honorable Joe Barton: 
Ranking Minority Member: 
Committee on Energy and Commerce: 
House of Representatives: 

Universal access to the Internet via broadband technologies--commonly 
referred to as broadband Internet access--is commonly viewed as a vital 
public infrastructure and a key driver of economic growth. For example, 
broadband technology makes it possible for patients to receive medical 
attention from specialists hundreds of miles away, students to access 
information not available from their local libraries, school systems to 
use one teacher to teach students in multiple schools, and small 
businesses to advertise and market their products and services to 
attract customers.[Footnote 1] The Broadband Data Improvement Act, 
enacted in 2008, established a variety of initiatives intended to 
improve the quality of state and federal data on the availability and 
quality of broadband services, and promote the deployment of affordable 
broadband services to all parts of the nation. The act required GAO to 
conduct a study to consider and evaluate broadband metrics or standards 
that may be used by industry and the federal government to provide 
consumers with better information about the cost and capability of 
their broadband connection, and compare the deployment (the building of 
infrastructure over which broadband services can be provided) and 
penetration[Footnote 2] of broadband across the United States and among 
other countries.[Footnote 3] 

Various policy makers believe that disparities in broadband access 
across the United States, including rural areas, could have adverse 
consequences for unserved or underserved populations.[Footnote 4] In 
the Telecommunications Act of 1996, the Federal Communications 
Commission (FCC) and state regulatory commissions were directed to 
encourage the deployment of advanced telecommunications capability, 
including broadband, to all Americans.[Footnote 5] As a result, FCC 
collects broadband deployment data from the private sector semiannually 
using the FCC Form 477, a standardized industry census.[Footnote 6] The 
Broadband Data Improvement Act cited a need for improved broadband data 
to help the government better understand the extent of broadband 
deployment, develop and maintain appropriate broadband policies, and 
direct limited financial resources.[Footnote 7] In addition, some 
broadband advocates have argued that broadband is an important 
international indicator of economic strength; thus the United States 
seeks additional measures of the nation's progress compared with that 
of other countries. To respond to the requirement in the Broadband Data 
Improvement Act that GAO evaluate additional broadband metrics or 
standards, this report addresses the following questions: 

(1) What measures are generally available to consumers, industry, 
government, and other stakeholders to assess broadband performance? 

(2) What, if any, are the limitations of these measures, and how can 
the measures be supplemented or improved? 

To identify the broadband performance measures available, we conducted 
a review of the literature and related laws and interviewed 
representatives and reviewed related documentation from the following 
stakeholder groups: academicians and think tanks, broadband providers, 
consumer advocacy groups, federal and state agencies and public/private 
partnerships, international organizations, and trade and industry 
groups. To evaluate the limitations, if any, of the measures, and how 
the measures could be supplemented or improved, we interviewed and 
reviewed related documentation from the stakeholders previously 
mentioned to obtain their opinions and analysis on the strengths and 
limitations of the measures and any potential options suggested. We 
identified potential stakeholders based on their expertise with 
broadband measures as evidenced by our literature review, previous GAO 
work, recommendations from our internal telecommunication experts, and 
suggestions by stakeholders we interviewed to develop knowledge of 
issues related to broadband performance measures.[Footnote 8] We also 
asked the stakeholders to discuss the validity and reliability of the 
measures and any potential improvements. 

We conducted this performance audit from February 2009 through October 
2009 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. See 
appendix I for more information about our scope and methodology. 

Results in Brief: 

Multiple measures to assess broadband performance are generally 
available to consumers, industry, and government, although these 
measures have limitations that we discuss later. Consumers can 
generally access performance measures of availability, price, 
advertised speed, and actual delivered speed from broadband providers 
and third parties to compare services and assist in their decision- 
making process. Some states have also completed broadband mapping 
efforts that provide consumers with information on broadband 
performance, including availability and advertised speed. Industry, 
government, and other stakeholders also have access to some broadband 
measures that enable comparisons across various segments of the United 
States to inform policy positions and guide broadband investment. For 
example, stakeholders told us that FCC's data from its semiannual 
reporting requirement for broadband providers are the primary source 
for comparing the availability and number of broadband subscribers 
across the country. Furthermore, industry, government, and other 
stakeholders can use a number of broadband performance measures to 
compare the quality and availability of broadband in selected 
countries. We focused on 10 such performance measures, 8 of which were 
"composite indexes," i.e., a combination of measures that are generally 
used to try to account for demographic, economic, and geographic 
differences among countries that can make international comparisons 
difficult. 

Despite the availability of various measures of broadband performance, 
many stakeholders told us that these measures have limitations, but 
views are mixed on potential alternatives and we found that ongoing 
efforts need improvement. More specifically: 

* According to some stakeholders, the lack of comprehensive measures 
from the federal government for consumers to compare price, actual 
delivered speed, and service reliability data from competing broadband 
providers was a limitation. These stakeholders believed that improved 
measures on price and actual delivered speed data from providers would 
help consumers make more informed decisions about broadband services. 
FCC has open proceedings to potentially require broadband providers to 
report measures on price and actual delivered speeds, but it currently 
does not collect such measures. While some stakeholders suggested 
additional measures, such as price per megabit per second, opinions 
were mixed on these alternatives, with consumer advocacy groups, 
academicians, and representatives from think tanks generally in favor 
of and broadband providers and related trade and industry groups 
generally against them. 

* Stakeholders told us that while industry and government use FCC's 
semiannual data collection from broadband providers to measure 
deployment and penetration, the form does not require broadband 
providers to report on price or actual delivered speeds, which limits 
the ability to make comparisons of broadband service across various 
segments of the country to inform policy positions or investment 
decisions. Furthermore, the data from FCC and the Pew Internet & 
American Life Project, which reports on home broadband adoption, do not 
provide enough detail to track subscribership in tribal lands or rural 
areas. The National Telecommunications and Information Administration 
(NTIA)[Footnote 9] has implemented the State Broadband Data and 
Development Grant Program, in an effort to develop a national broadband 
inventory map, which would provide detailed data on broadband 
availability, type of technology, and advertised and actual delivered 
speed by census block.[Footnote 10] As of September 9, 2009, NTIA had 
received applications representing all 50 states, 5 territories, and 
the District of Columbia. NTIA is currently reviewing the applications 
and plans to announce funding decisions beginning in early fall 2009, 
with the first data collection due by March 1, 2010. Although 
stakeholders agree the effort will provide more detailed data, NTIA did 
not provide standardized guidance to broadband providers on calculating 
actual delivered speeds. We have previously reported that consistency, 
or the extent to which data are collected using the same procedures, is 
a key dimension of data quality and a key attribute of a successful 
performance measure.[Footnote 11] NTIA officials told us they chose not 
to provide this guidance because each provider may have a different 
method for measuring speed, and they did not want to prescribe a 
standard method, given the multiple technologies used. However, this 
could result in inconsistent measurements across providers, limiting 
the effectiveness of the mapping effort in making comparisons across 
the country. In addition, while NTIA required grant applicants to 
provide a description of the methods the applicant intends to employ to 
verify data accuracy and provided an example in its guidance, it did 
not contain specific standards on how to do so. We have previously 
reported that both verification and validation of performance data are 
important for reducing the risk of producing inaccurate data; this 
additional information helps to place the credibility of an agency's 
reported performance data in context for decision makers.[Footnote 12] 
While it is too early to determine the effect, if any, of the limited 
guidance, the lack of specific standards for data verification could 
result in inconsistent data across states, limiting the effectiveness 
of the data in making comparisons across the country. To increase the 
data quality and subsequent results from the State Broadband Data and 
Development Grant Program, including a national broadband inventory 
map, we recommend that the Secretary of Commerce examine the first 
round of data collection and determine whether to develop specific 
guidance for grantees to improve the consistency and accuracy of the 
data collected under the program. 

* Although industry, government, and other stakeholders can choose from 
many measures to compare broadband performance, there are a variety of 
limitations, including socioeconomic differences among countries, which 
make international comparisons difficult. For example, the Organisation 
for Economic Co-operation and Development (OECD) reports broadband 
subscribers per 100 inhabitants rather than as a percentage of 
households. According to multiple stakeholders, household size alone 
explains most of the differences in this measure, since countries with 
larger households are likely to have lower per capita residential 
connections. In addition, according to Federal Trade Commission (FTC) 
staff and other stakeholders, because the socioeconomic status of 
individual countries and the historical nature of their telecom markets 
can vary widely, simple comparisons across countries may not be 
meaningful. Stakeholders also reported that the lack of reliable and 
uniform data can limit international comparisons. Despite the concerns 
raised about the limitations of the measures used for international 
comparisons, several stakeholders found the comparisons useful because 
they can help inform policy decisions. Stakeholders generally supported 
FCC's efforts to develop an additional international comparison of 
communities in other countries with comparable communities within the 
United States, because the comparison is to be at a more granular 
level, which could provide more relevant analysis.[Footnote 13] 

We provided a draft of this report to the Department of Commerce and 
FCC for their review and comment. The Department of Commerce provided 
written comments, which are reprinted in appendix II. In its written 
comments, the Department of Commerce generally agreed with our 
recommendation and stated that it had already begun taking actions to 
address the recommendation. More specifically, the Department of 
Commerce stated that immediately following the awarding of grant funds, 
it will investigate opportunities for improved data collection methods 
including qualitative and quantitative analyses of data collection and 
verification methods, as well as an assessment of which methods are 
cost-efficient and accurate. FCC responded that it did not have any 
comments on the draft report. 

Background: 

The Internet is a vast network of interconnected networks that is used 
by governments, businesses, research institutions, and individuals 
around the world to communicate, engage in commerce, perform research, 
educate, and entertain. The Internet became widely accessible to U.S. 
households by the mid-1990s. Early on, the primary means to access the 
Internet was a dial-up connection, in which a standard telephone line 
is used to make an Internet connection. A dial-up connection offers 
data transmission speeds of up to 56 kilobits, or 1,000 bits per second 
(Kbps).[Footnote 14] Broadband access to the Internet became available 
by the late 1990s. Broadband differs from a dial-up connection in 
certain important ways. First, broadband connections offer a higher- 
speed Internet connection than dial-up. For example, some broadband 
connections offer speeds exceeding 1 million bits per second (Mbps) 
both upstream (data transferred from the consumer to the Internet 
service provider) and downstream (data transferred from the Internet 
service provider to the consumer). These higher speeds enable consumers 
to receive information much faster and thus enable certain applications 
to be used and content to be accessed that might not be possible with a 
dial-up connection. The higher transmission speeds that broadband 
offers cost more than dial-up, and some broadband users pay a premium 
to obtain very-high-speed service. Second, broadband provides an 
"always on" connection to the Internet, so users do not need to 
establish a connection to the Internet service provider each time they 
want to go online. Although broadband often is referred to as a 
singular service, it is available in a wide variety of data speeds-- 
ranging from 768 Kbps to greater than 100 Mbps. FCC's current 
categories for collecting data on the number of broadband subscribers 
by advertised download and upload speeds range from greater than 200 
Kbps but less than 768 Kbps to equal to or greater than 100 Mbps. On 
August 20, 2009, as part of the proceeding to develop a National 
Broadband Plan, FCC posted a public request for comment on defining 
"broadband."[Footnote 15] 

Consumers can receive a broadband connection to the Internet through a 
variety of technologies that offer varying speeds of service, 
including, but not limited to, the following: 

* Cable modem. Cable television companies first began providing 
broadband service in the late 1990s over their cable networks. When 
provided by a cable company, broadband service is referred to as cable 
modem service. Cable modem service is primarily available in 
residential areas. Cable modem service enables cable operators to 
deliver broadband service by using the same coaxial cables that deliver 
pictures and sound to television sets. Most cable modems are external 
devices that have two connections, one to the cable wall outlet and the 
other to a computer or router. Although the speed of service varies 
with many factors, download speeds of up to 6 Mbps are typical. Cable 
providers are developing even higher-speed services. 

* DSL. Local telephone companies provide digital subscriber line (DSL) 
service, another form of broadband service, over their telephone 
networks on capacity unused by traditional voice service. To provide 
DSL service, telephone companies must install equipment in their 
facilities and install or provide DSL modems and other equipment at 
customers' premises and remove devices on phone lines that may cause 
interference. Most residential customers receive older, asymmetric DSL 
(ADSL) service with download speeds of 1.5 Mbps to 3 Mbps. ADSL 
technology can achieve speeds of up to 8 Mbps over short distances. 
Newer DSL technologies can support services with much higher download 
speeds. 

* Fiber. This technology, also known as fiber optic, converts 
electrical signals carrying data to light and sends the light through 
transparent glass fibers smaller than the diameter of a human hair. 
Fiber optic systems can transmit data at speeds far exceeding current 
DSL or cable modem speeds, typically by tens of gigabits per second. 
Fiber optic technology may be provided in several ways, including fiber 
to a customer's home or business or to a location somewhere between the 
provider's facilities and the customer. In the latter case, the last 
part of the connection to the customer's premises may be provided over 
cable, copper loop, or radio technology. Such hybrid arrangements may 
be less costly than providing fiber all the way to the customer's 
premises, but they generally cannot achieve the high transmission speed 
of a full fiber-to-the-premises connection. 

* Satellite. Three providers currently offer broadband service via 
satellite in the United States. These providers use geostationary 
satellites that orbit in a fixed position above the equator and 
wirelessly transmit and receive data directly to and from subscribers. 
[Footnote 16] Satellite companies provide transmission from the 
Internet to the user's computer and from the user's computer to the 
Internet, eliminating the need for a telephone or cable connection. 
Typically a consumer can expect to receive (download) at a speed of 
about 1 Mbps and send (upload) at a speed of about 200 Kbps. 
Transmission of data via satellite causes a slight lag in transmission, 
typically one-quarter to three-fourths of a second, thus rendering this 
service less suitable for certain Internet applications, such as 
videoconferencing. While satellite broadcast service may be available 
throughout the country, it generally costs more than most other 
broadband modes and its use requires a clear line of sight between the 
customer's antenna and the southern sky. Both the equipment necessary 
for service and recurring monthly fees are generally higher for 
satellite broadband service, compared with most other broadband 
transmission modes. 

* Wireless. Land-based, or terrestrial, wireless broadband connects a 
home or business to the Internet using a radio link. Some wireless 
services are provided over unlicensed radio spectrum and others over 
spectrum that has been licensed to particular companies.[Footnote 17] 
In licensed bands, some companies are offering fixed wireless broadband 
throughout cities. Also, mobile telephone carriers--such as the large 
companies that provide traditional cell phone service--have begun 
offering broadband mobile wireless Internet service over licensed 
spectrum--a service that allows subscribers to access the Internet with 
their mobile phones or laptops in areas throughout cities where their 
provider supports the service. A variety of broadband access 
technologies and services also are provided on unlicensed spectrum-- 
that is, spectrum that is not specifically under license for a 
particular provider's network. For example, wireless Internet service 
providers may offer broadband access in particular areas by 
establishing a network of subscriber stations, each with its own 
antenna that relays signals throughout a neighborhood and has a common 
interface to the Internet. Subscribers place necessary reception 
equipment outside their homes that transmits and receives signals from 
the nearest antenna. Also, wireless fidelity (Wi-Fi) networks--which 
provide broadband service in so-called hot spots, or areas within a 
radius of up to 300 feet--can be found in cafes, hotels, airports, and 
offices. Such networks generally use a short-range technology that 
provides speeds up to 54 Mbps. Some technologies, such as Worldwide 
Interoperability for Microwave Access (known as WiMAX), can operate on 
either licensed or unlicensed bands, and can provide broadband service 
up to approximately 30 miles. 

FCC has primary responsibility for regulating broadband. Section 706 of 
the Telecommunications Act of 1996 directs FCC to encourage the 
deployment of advanced telecommunications capability, which includes 
broadband, to all Americans.[Footnote 18] Under this authority, FCC has 
to date established a minimal regulatory environment for broadband 
Internet access services. In the past, FCC has stated that less 
regulation has encouraged providers to invest in broadband 
infrastructure. The Communications Act, as amended, allows FCC to 
classify services as telecommunications services[Footnote 19] or 
information services,[Footnote 20] the latter being subject to fewer 
regulatory restrictions. FCC, through a number of proceedings, 
classified broadband Internet access (regardless of the platform) as an 
information service.[Footnote 21] FCC does not have explicit statutory 
authority to regulate the provision of information services; however, 
FCC has the authority to impose regulations under what is termed its 
ancillary jurisdiction to regulate services that are reasonably related 
to its existing statutory authority.[Footnote 22] FCC also has the 
authority to adopt broadband regulations to ensure that broadband 
providers are capable of providing authorized surveillance to law 
enforcement agencies.[Footnote 23] 

As part of its responsibilities, FCC has periodically issued a report 
to Congress on the status of advanced telecommunications capability in 
the United States, including the quality of broadband data.[Footnote 
24] To assist in the preparation of this report, in 2000, FCC 
implemented the previously described broadband reporting form, a 
semiannual reporting requirement for facilities-based broadband 
Internet service providers.[Footnote 25] In November 2004, FCC modified 
its rules on filing this information, and the revised rules went into 
effect for the companies' second filing in 2005. Specifically, FCC 
removed existing reporting thresholds,[Footnote 26] and all companies 
were required to report their total state subscribership by technology. 
In 2006, we reported that the approach FCC then used to collect data on 
broadband deployment, which counted broadband service providers with 
subscribers at the ZIP code level, resulted in inadequate information 
about broadband deployment.[Footnote 27] Subsequent to our 
recommendation, in March 2008, FCC acted to increase the precision and 
quality of its broadband data by revising its methodology and requiring 
that broadband providers report the number of broadband connections in 
service by census tract.[Footnote 28] 

In addition to FCC's data collection effort using its broadband 
reporting form, the Broadband Data Improvement Act calls for additional 
actions to improve the quality of data available on broadband 
deployment.[Footnote 29] Among other things, the act directs FCC to: 

1) periodically survey consumers to collect information on the types of 
technologies used by consumers to access the Internet, the applications 
or devices used in conjunction with broadband service, and the actual 
connection speeds of users; 

2) collect information on reasons why consumers have not subscribed to 
broadband services; 

3) determine certain demographic data for geographical areas not served 
by any provider of advanced telecommunications capability (i.e., areas 
where broadband has not yet been deployed); and: 

4) provide information on the extent of broadband service capability, 
including the speed and price of broadband service in a total of 75 
communities in at least 25 countries. 

FTC also has regulatory jurisdiction over broadband services with 
respect to competition and consumer protection issues.[Footnote 30] 
FTC's jurisdiction over broadband services comes chiefly from its 
statutory mandate to prevent "unfair methods of competition" and 
"unfair or deceptive acts or practices in or affecting commerce" under 
FTC's enabling legislation, the FTC Act.[Footnote 31] Although this 
authority is very broad, certain limited market sectors are expressly 
excluded from FTC's enforcement authority. In particular, FTC's 
enforcement authority does not reach "common carriers subject to the 
Communications Act of 1934, as amended.[Footnote 32] However, since 
most broadband Internet services are not provided on a common carrier 
basis, they are generally part of the larger economy subject to FTC's 
general competition and consumer protection authority with regard to 
methods, acts, or practices in or affecting commerce.[Footnote 33] FTC 
has, where appropriate, investigated and brought enforcement actions in 
matters involving access to content via broadband and other Internet 
access services.[Footnote 34] Additionally, FTC has brought a variety 
of cases against Internet service providers that have engaged in 
allegedly deceptive marketing and billing practices.[Footnote 35] 

Two other federal agencies have responsibility for telecommunications 
policies. The Office of Science and Technology Policy (OSTP) within the 
Executive Office of the President has a broad mandate to advise the 
President and the federal government on the effects of science and 
technology on domestic and international affairs and has led 
interagency efforts to develop science and technology policies and 
budgets. NTIA is the President's principal telecommunications and 
information adviser and works with other executive branch agencies to 
develop the Administration's telecommunications policies[Footnote 36].: 

Multiple Measures Are Available for Consumers, Industry, Government, 
and Others to Assess Broadband Performance: 

Consumers Can Generally Access Measures of Availability, Price, 
Advertised Speed, and Actual Delivered Speed from Broadband Providers 
and Third Parties: 

Although there are limitations that we discuss later, consumers 
interested in broadband service can generally contact providers or 
search provider Web sites to determine the availability of service, 
advertised price, and advertised speed of broadband service in their 
area. For example, consumers can go to att.com or timewarnercable.com 
and enter their street address to learn about the availability of 
broadband service at their address, including price and advertised 
speeds. Each Web site also provides a phone number that consumers can 
use to reach a customer service representative to obtain information on 
availability, price, and advertised speeds of service. Consumers can 
then make their own comparisons of these prices and advertised speeds. 
In addition, third parties provide consumer Web sites, such as 
dslreports.com, that assemble this information for consumers to review. 

However, actual delivered speeds depend on multiple factors, such as 
the equipment of the consumer, the applications in use, and Internet 
traffic, and may not always match advertised speeds or the theoretical 
maximum speeds stated by the provider. Consequently, there are tools 
available to consumers to measure actual delivered speed. Consumers 
with broadband service have access to their actual delivered speeds 
through speed tests from broadband provider Web sites and third 
parties. Speed tests generally measure the "last mile" speed (download 
and upload) of the consumer's connection. Some third-party Web sites 
also provide information on actual delivered speeds of service and 
allow consumers to compare speeds. For example, speedtest.net allows 
individuals to compare their speed with that of other consumers by 
provider or in a set geographic region. 

Some states have also completed broadband mapping efforts that provide 
consumers with information on broadband performance, including 
availability and advertised speed. We previously reported that 12 
states had mapped broadband deployment, and 2 of these states, 
California and Massachusetts, had mapped both the speed and 
availability of broadband in their state and placed the information on 
their state's Web site.[Footnote 37] In its 2008 report,[Footnote 38] 
California also provided information on average delivered upload and 
download speeds aggregated throughout the state and advertised 
residential speeds by price.[Footnote 39] 

Industry and Government Have Some Broadband Performance Measures to 
Make Comparisons across Various Segments of the United States: 

The stakeholders we interviewed told us that FCC's broadband data, 
collected through its broadband reporting form, constitute the primary 
data source generally used to measure performance and make comparisons 
across various segments of the United States, although there are 
limitations, which we discuss later. The Commission has tracked 
broadband subscribership and deployment since 2000 through its 
broadband reporting form.[Footnote 40] In 2006, we reported that the 
approach FCC then used to collect data on broadband deployment, which 
counted broadband service providers with subscribers at the ZIP code 
level, resulted in inadequate information about broadband deployment. 
[Footnote 41] To improve this information, in 2008, the Commission 
revised the semiannual reporting requirements of the broadband 
reporting form. The Commission now requires most broadband providers to 
file subscribership information by census tract, including the number 
of subscribers by technology, speed tier, and business/residential 
connection.[Footnote 42] In addition, mobile wireless service providers 
are now required to report the number of connections in (1) individual 
states, (2) the census tracts that best represent their broadband 
service footprint, and (3) in a separate category, the number of 
subscribers whose device and subscription permit them access to the 
lawful Internet content of their choice. These changes are expected to 
result in data that are more detailed than what was previously 
collected. The first round of data filings under the new requirements 
was due on March 16, 2009. As of September 2009, FCC staff was still in 
the process of analyzing the information. 

Stakeholders also identified the Pew Internet & American Life Project's 
reports on home broadband adoption as a source for measuring adoption 
and making comparisons across the United States. The results in the 
reports are based on data from approximately 2,300 telephone interviews 
(on both landline and cellular telephones) conducted by Princeton 
Survey Research International over the course of a month. The 2009 
report included the following information that can be used to compare 
rural and nonrural areas:[Footnote 43] broadband adoption, broadband 
connection type, and, when applicable, reason for not having broadband 
access or Internet access.[Footnote 44] 

Industry, Government, and Other Stakeholders Have Many Performance 
Measures Available for Making International Comparisons: 

Through our literature review and interviews with stakeholders, we 
focused on 10 performance measures often used by industry, government, 
and other stakeholders to make international comparisons of broadband 
service, as summarized below (limitations of these measures are 
discussed later). These measures fall into two general categories: (1) 
broadband-specific measures and (2) more general measures that cover a 
wide array of information and communications technology (ICT).[Footnote 
45] 

The broadband-specific rankings measure a nation's broadband 
performance by focusing on the availability, penetration (or adoption), 
and quality of broadband in each country, and include those listed 
below (see table 1 for the U.S. ranking for each.) 

* Broadband Adoption Index. The Phoenix Center for Advanced Legal and 
Economic Public Policy Studies recently developed the Broadband 
Adoption Index (BAI), which proposes to compare the actual value that a 
society derives from broadband usage with that country's target level 
for adopting various broadband technologies based on maximizing 
societal well-being. These targets vary by technology, demographic 
group, and country. The index does not include an overall ranking of 
countries based on broadband performance, because each country has its 
own unique set of adoption targets. 

* Broadband Quality Score. The Oxford Saïd Business School in Oxford, 
United Kingdom (UK), in conjunction with the University of Oviedo in 
Oviedo, Spain, and Cisco Systems, Inc., created the Broadband Quality 
Score (BQS) in September 2008 to highlight each representative nation's 
ability to benefit from next-generation Web applications and services. 
According to the study, to establish broadband leadership, countries 
must focus on broadband availability, penetration, and quality. 

* Broadband Subscribers per 100 Inhabitants. OECD produces many 
broadband-related measures annually on its online broadband Web site. 
According to FCC and many of the stakeholders we interviewed, one of 
the most widely reported figures on broadband performance is OECD's 
count of broadband subscribers per 100 inhabitants by technology. OECD 
also collects comparative data from its 30 member countries on multiple 
broadband measures such as penetration, usage, coverage, prices, 
services and speeds, and choice and competition. However, unlike other 
stakeholders, OECD does not aggregate its data into a composite 
indicator of national broadband performance.[Footnote 46] 

* Broadband Performance Index. The European Commission recently 
implemented the Broadband Performance Index (BPI), which measures and 
benchmarks the overall broadband performance of European Union member 
states based on a range of factors, which could include speeds, rural 
coverage, affordability, innovation, and other socioeconomic 
dimensions. In particular, the BPI ranks the EU-27 countries plus 
Norway in terms of supply and demand factors that affect the 
penetration and use of broadband.[Footnote 47] 

* ITIF broadband rankings. For its broadband rankings, the Information 
Technology and Innovation Foundation (ITIF) measures three primary 
broadband indicators, household penetration (rather than subscriber), 
average speed, and price, to rank the broadband performance of OECD 
nations. ITIF notes the importance of non-policy factors on a nation's 
broadband performance, including demographic, economic, and broadband 
supply variables. 

In contrast to broadband-specific rankings, the other performance 
measures we identified were based on each country's development and use 
of ICT. These rankings are more general, focusing on the larger picture 
of how ICT usage, infrastructure, and skills can affect a country's 
economic growth. According to an official at the Technology and Policy 
Institute (TPI), broadband is but one component in the makeup of a 
country's ICT landscape, as ICT encompasses Internet usage along with 
other forms of telecommunications. According to FCC, these various 
measures demonstrate the value of understanding the broader context 
when making comparisons regarding broadband deployment and adoption. 
[Footnote 48] Examples of ICT-specific rankings include the following: 

* Connectivity Scorecard. The Dean at the Haskayne School of Business 
at the University of Calgary in Calgary, Canada, worked in 
collaboration with Nokia Siemens Networks and LECG (a global services 
and consulting firm) to release the first version of the Connectivity 
Scorecard in 2008. The scorecard measures the impact of ICT on economic 
growth in three key areas of society--the consumer sector, the business 
sector, and the government sector. The report presents separate sets of 
rankings for "innovation-driven economies" and "resource-and efficiency-
driven economies" while specifically focusing on each country's ICT 
infrastructure and usage.[Footnote 49] 

* E-readiness Ranking. The Economist Intelligence Unit (EIU) is the 
business information arm of The Economist Group, publisher of The 
Economist magazine. The EIU produces an annual E-readiness Ranking, 
which measures the quality of a country's ICT infrastructure as well as 
the ability of its consumers, businesses, and government to use ICT to 
their benefit. The EIU makes this assessment by specifically measuring 
a country's connectivity and technology infrastructure, business 
environment, social and cultural environment, legal environment, 
government policy and vision, and consumer and business adoption. 
Overall, more than 100 separate qualitative and quantitative criteria 
are considered. 

* Networked Readiness Index: The World Economic Forum,[Footnote 50] in 
cooperation with INSEAD international business school's eLab research 
center[Footnote 51] and Cisco Systems, Inc., produced the Networked 
Readiness Index (NRI). The NRI is used to assess the extent to which 
different economies benefit from the latest ICT advances based on their 
ICT environment, readiness, and usage while taking into account the key 
roles played by individuals, businesses, and governments. The NRI 
covers 134 economies worldwide and accounts for nearly 70 factors. 

* International Communications Market. In its 2008 report, Ofcom, the 
regulator for the UK communications industry, described developments in 
international communications markets, including information on 
broadband availability and usage.[Footnote 52] In the report, Ofcom 
aimed to provide statistically driven international comparative data 
for the UK communications sector by examining trend data from 2002 to 
2007 on how various countries' industries, consumers, and regulatory 
landscapes affect their communication markets. 

* ICT Development Index. The International Telecommunication Union 
(ITU), a United Nations agency, developed the ICT Development Index 
(IDI), which measures the development of ICT, the level of advancement 
of ICT, and the development potential of ICT in more than 150 countries 
worldwide, comparing their progress between 2002 and 2007. The purpose 
of the index is to track the global digital divide and to measure each 
country's progress toward becoming an "information society."[Footnote 
53] The primary index measures ICT infrastructure/access, use, and 
skills, while a separate index was created to capture the price of ICT 
relative to a country's income. 

Eight of the 10 performance measures listed above are "composite 
indexes," i.e., combinations of measures that are generally used to try 
to account for and normalize a variety of factors such as demographic, 
economic, and geographic differences among countries, which according 
to many of the stakeholders we spoke with can affect broadband 
deployment and penetration.[Footnote 54] Several of the stakeholders 
identified advantages to using composite indexes in making 
international comparisons. Officials from the European Commission 
reported that composite indexes are a useful tool to summarize the 
multidimensional issues, such as the socioeconomic differences among 
countries, which cannot be captured by a single indicator. According to 
ITU, compared with single indicators, composite indexes allow grouping 
several key performance indicators into one figure that captures a 
variety of information and provides a more comprehensive picture. While 
the various indexes differ on which demographic, economic, and 
geographic factors play a greater role in the supply and demand of 
broadband, income, age, education, population density, gross domestic 
product (GDP) per capita, and intermodal competition are generally 
considered important.[Footnote 55] According to ITIF, nonpolicy 
factors, such as demographic, economic, and broadband supply variables 
explain about three-quarters of the differences among nations' 
broadband performance in international rankings. The determination of 
which factors to include or exclude in a composite index can greatly 
affect a nation's ranking in a report, as demonstrated by the fact that 
the United States' broadband and ICT rankings vary greatly by study, as 
shown in table 1. 

Table 1: U.S. Ranking in International Broadband Performance 
Comparisons: 

Broadband-specific measures: 

Composite index or performance measure: BAI; Phoenix Center (2009); 
U.S. ranking: No ranking provided because each country has its own 
unique set of adoption targets; 
Top-ranked country: No ranking provided because each country has its 
own unique set of adoption targets 

Composite index or performance measure: BQS; Oxford Saïd Business 
School, University de Oviedo, and Cisco (2008); 
U.S. ranking: 16th out of 42; 
Top-ranked country: Japan. 

Composite index or performance measure: Broadband subscribers per 100 
inhabitants by technology; OECD (2008); 
U.S. ranking: 15th out of 30; 
Top-ranked country: Denmark. 

Composite index or performance measure: BPI; European Commission 
(2008); 
U.S. ranking: United States not included in ranking; 
Top-ranked country: Sweden. 

Composite index or performance measure: 2008 ITIF Broadband Rankings; 
ITIF, Robert Atkinson; 
U.S. ranking: 15th out of 30; 
Top-ranked country: South Korea. 

ICT measures: 

Composite index or performance measure: Connectivity Scorecard 2009; 
LECG, Nokia Siemens Networks, and Leonard Waverman; 
U.S. ranking: 1st out of 50 (for innovation-driven economies); 
Top-ranked country: United States 1st for innovation-driven economies; 
Malaysia 1st for efficiency-and resource-driven economies. 

Composite index or performance measure: E-readiness rankings 2009; 
Economist Intelligence Unit; 
U.S. ranking: 5th out of 70; 
Top-ranked country: Denmark. 

Composite index or performance measure: NRI; World Economic Forum and 
INSEAD (2009); 
U.S. ranking: 3rd out of 134; 
Top-ranked country: Denmark. 

Composite index or performance measure: International Communications 
Market 2008; Ofcom; 
U.S. ranking: Many rankings listed; United States 2nd in residential 
and small and medium-sized enterprise broadband connections per 100 
households; 
Top-ranked country: Many rankings listed: Canada 1st in residential and 
small and medium-sized enterprise broadband connections per 100 
households. 

Composite index or performance measure: IDI; ITU (2009); 
U.S. ranking: 17th out of 154; 
Top-ranked country: Sweden. 

Source: GAO analysis. Dates provided represent the published date of 
the report. 

[End of table] 

Stakeholders Reported Limitations with Current Broadband Performance 
Measures, but Views Are Mixed on Potential Alternatives and Ongoing 
Efforts Need Improvement: 

Price, Actual Delivered Speed, and Service Reliability Measures for 
Consumers Have Limitations, but There Are Differing Views on 
Alternatives: 

Even though consumers have access to measures, stakeholders told us 
that measures of price, actual delivered speed, and service reliability 
have limitations that may affect their usefulness for consumers: 

* Price. Stakeholders told us the available pricing measures for 
consumers are limited. For example, officials from the Consumer 
Federation of America and Pew Internet & American Life Project told us 
the lack of a comprehensive and consistent measure from the government 
for consumers to compare prices from providers was a limitation. They 
added that improved measures for prices would help consumers make more 
informed decisions about broadband services. Although FCC has open 
proceedings on requiring providers to include measures of price in the 
broadband reporting form, it currently does not collect this 
information.[Footnote 56] 

* Actual delivered speed. Stakeholders also identified limitations 
regarding the speed tests for consumers to measure actual delivered 
speeds. A representative from Akamai, a company that handles 
approximately 15 to 20 percent of all Internet traffic worldwide 
through its global server network, said one problem with speed tests is 
that the result can be significantly affected by the location of the 
server that is used to test the speed; the farther away the server, the 
less accurate the result. Many other factors can also affect a user's 
speed of service, such as congestion on the network, time of day, and 
other applications that the user may have open on the computer when 
testing. NTIA officials told us that the speed tests are not able to 
determine the Internet traffic congestion points, if any, along the 
chain of networks. An official from the Pew Internet & American Life 
Project told us the results of the speed tests are not verified by 
other parties. He also explained that some third-party Web sites that 
attempt to compare actual delivered speeds have limited numbers of 
respondents and do not have an independent party verify the results, a 
fact that decreases the utility of the information for making 
comparisons. Finally, an official from the Information Technology and 
Innovation Foundation said the lack of comprehensive data for consumers 
to compare actual delivered speeds from providers was a limitation for 
consumers in comparing service options and policy makers in monitoring 
broadband. Actual delivered speed can be an important measure for 
consumers because it can determine whether or not a connection can be 
used to originate and receive high-quality voice, data, graphics, and 
video. FCC has open proceedings on requiring providers to report actual 
delivered speeds on the broadband reporting form, but it currently does 
not collect this information. 

While broadband connection speeds that customers experience are 
generally not identical to the advertised speeds or theoretical 
maximums offered by the broadband provider, there is some evidence that 
consumers are not focused on this issue. Despite access to the tools to 
measure actual speed, one study found that few people actually know the 
speed of their broadband connections. In its report titled "Home 
Broadband Adoption 2006," the Pew Internet & American Life Project 
reported that 81 percent of broadband users did not know their home 
connection speed. In addition, the federal government has received 
relatively few complaints regarding broadband speed. From February 1, 
2008, through May 12, 2009, FCC reported receiving about 624,000 
informal complaints, of which only 157 were related to broadband 
speed.[Footnote 57] Further, FTC reported receiving approximately 147 
complaints that could be related to broadband speeds from January 2005 
through June 19, 2009.[Footnote 58] According to some stakeholders, 
such as the Information Technology and Innovation Foundation, consumers 
appear more concerned with their end user experience, such as the 
ability to complete transactions or use their applications. 

* Service reliability. Some stakeholders we contacted, including 
BroadbandCensus.com, IEEE (previously known as the Institute of 
Electrical and Electronics Engineers), the Internet Engineering Task 
Force, Akamai, an economist from the Massachusetts Institute of 
Technology (MIT), NTIA, and Wireless Internet Service Provider 
Association (WISPA) are concerned that there is no measure for 
consumers that addresses service reliability. A service reliability 
measure would provide information to consumers on factors such as 
transmission quality, which affects perceived speed and could be useful 
to consumers in comparing the reliability of broadband services. 
According to an official from Akamai, service quality is the most 
difficult performance measure to define, measure, and relay to a 
consumer. 

While consumers have measures of price, advertised speed, and actual 
delivered speed to make decisions regarding broadband service, some 
stakeholders suggested improved measures of price and actual delivered 
speeds for consumers, as shown in table 2. 

Table 2: Broadband Performance Measures Proposed by Stakeholders: 

Price: 

Proposed broadband measure: Price per megabit per second; 
Description: The price of a broadband offering by megabit per second. 

Proposed broadband measure: Average revenue per user; 
Description: A measure generally used by telecommunications companies 
that states how much money the company makes from the average user. 
This is the revenue from the services provided divided by the number of 
users buying those services. 

Actual delivered speed: 

Proposed broadband measure: Average actual delivered speed of last-mile 
connections; 
Description: The data transfer throughput rate from the end user point 
(home) to the first aggregation point in the networks used by 
facilities-based broadband providers. 

Proposed broadband measure: Contention ratio; 
Description: This is the ratio of the potential maximum demand to the 
actual bandwidth available. The higher the contention ratio, the 
greater the number of users that may be trying to use the actual 
bandwidth at any one time and, therefore, the lower the effective 
bandwidth or speed offered, especially at peak times. 

Service reliability: 

Proposed broadband measure: Latency; 
Description: This is the delay incurred in the processing of network 
data, which can decrease the effective bandwidth. A low-latency network 
connection is one that generally experiences small delay times, while a 
high-latency connection generally suffers from long delays. High 
latency can affect the ability to use certain applications, such as 
online gaming[A]. 

Source: GAO analysis. 

[A] Businesses use the term "quality of service" to refer to measuring 
and maintaining consistent performance on a network by managing both 
bandwidth and latency in a coordinated fashion. 

[End of table] 

As shown in table 3, stakeholders identified arguments for and against 
the proposed measures. 

Table 3: Stakeholder Arguments for and against Proposed Measures: 

Price: 

Potential measure: Price per megabit per second; 
Stakeholder arguments for the measure: 
* Provides a reliable indicator of the value of the broadband services 
purchased by the consumer; 
* Provides improved information to make comparisons of available 
services; 
Stakeholder arguments against the measure: 
* The measure is not sufficiently reliable, as a wide variety of 
factors affect price, including speed of service, term of contract, 
bundling with other services, and promotions, which can make it 
difficult to develop meaningful comparisons; 
* Collecting pricing data would impose significant and unnecessary 
burdens on providers; 
* Price does not necessarily reflect the quality of the service. 

Potential measure: Average revenue per user; 
Stakeholder arguments for the measure: 
* Provides a method for addressing temporary price discounts and 
bundled service; 
* Broadband providers already collect this information; 
Stakeholder arguments against the measure: 
* The measure is not relevant for consumers, because it is not linked 
to the price and speed of the consumer's service. 

Speed: 

Potential measure: Average actual delivered speed of last-mile 
connections; 
Stakeholder arguments for the measure: 
* This portion of the network is where the provider has the most 
control; 
* Providers are likely to have this information to help them manage 
their networks; 
Stakeholder arguments against the measure: 
* Actual delivered speed is a function of many factors, including 
wiring, computer equipment of the user, software and applications being 
run by the consumer, general Internet congestion, responsiveness of 
servers, and other technology-specific factors, that limit the 
reliability of the comparisons; 
* The existence of the various sites that measure actual delivered 
speeds suggests that this is an area in which market forces are 
disseminating the relevant information; 
* Collecting these data would impose a significant and unnecessary 
burden on providers. 

Potential measure: Contention ratio; 
Stakeholder arguments for the measure: 
* Contention ratios are a useful proxy for actual delivered speeds, 
because the higher the contention ratio, the greater the number of 
users that may be trying to use the actual bandwidth at any one time 
and, therefore, the lower the effective bandwidth or speed offered, 
especially at peak times; 
* Broadband providers are likely to already have this information to 
help them manage their networks; 
Stakeholder arguments against the measure: 
* A high contention ratio does not necessarily mean low speeds or a low 
contention ratio high speeds because the ratio does not account for the 
applications being used by the consumers, such as e-mail or downloading 
movies; 
* Measuring contention ratios would cost an enormous amount of time and 
money, and the information is likely to be proprietary and 
confidential; 
* Most consumers do not have a frame of reference for understanding 
contention ratios, and an extensive consumer education program would be 
required. 

Service reliability: 

Potential measure: Latency; 
Stakeholder arguments for the measure: 
* Would provide information on the quality of the access line; 
Stakeholder arguments against the measure: 
* Providers may consider this information to be proprietary; 
* Consumers may not be familiar with this measure. 

Source: GAO analysis. 

[End of table] 

It should be noted that while federal and state agencies and public/ 
private partnerships, academicians and think tanks, consumer advocacy 
groups, and trade and industry groups identified arguments for and 
against the proposed measures, broadband providers generally only 
provided arguments against the proposed measures. Thus, while 
stakeholders identified multiple alternatives, they differed on the 
need for FCC to develop additional reporting requirements to measure 
price, average actual delivered speed, and service reliability as 
follows: 

* Consumer advocacy groups and academicians and representatives from 
think tanks generally believed there was a need for improved 
information on price and actual delivered speeds to make comparisons 
and good decisions about service. These stakeholders preferred that FCC 
require broadband providers to report price per megabit per second and 
the averaged actual delivered speed of last-mile connections (from the 
home to the first provider node or aggregation point) to provide more 
consistent measures for consumers to make comparisons. These 
stakeholders generally believed that calculating price per megabit 
should be done using the published, stand-alone nonpromotional, 
noncontractual price. Some suggested providing an average price by 
speed tier, while others suggested providing the lowest and highest 
prices by speed tier. Finally, some consumer advocacy groups and 
academicians and representatives from think tanks also favored a 
measure on service reliability to provide consumers with information on 
the quality of their connections. 

* In contrast, broadband providers and trade and industry groups 
generally did not perceive a need for additional broadband measures 
because, in their opinion, price and speed information is readily 
available from providers and third-party sources. According to these 
stakeholders, additional reporting requirements would be an intrusion 
into a market that is working, as evidenced by falling prices for 
increased speeds. They added that additional reporting requirements 
would be an impediment to investment in infrastructure, as more 
resources would need to be devoted to data collection. These 
stakeholders also reported that price per megabit and the average 
actual delivered speed are difficult to measure (as previously shown in 
table 3), and that FCC is not likely to report the information in a 
timely fashion. For example, in the past, it has taken FCC close to a 
year to report the data from the broadband reporting form once it has 
been submitted by broadband providers. 

* While officials at federal and state agencies and public-private 
partnerships generally said more information is good, there were mixed 
opinions on the need for FCC to require additional broadband measures. 
None of the federal agencies we interviewed provided an opinion; an 
official with the California Public Utilities Commission was uncertain 
if additional requirements were needed because similar information is 
already available to the public; and of the two interviewed, one 
public/private partnership was for additional broadband measures and 
one was against. 

Finally, all stakeholder groups generally noted that FCC's efforts to 
develop periodic surveys, per the Broadband Data Improvement Act, 
[Footnote 59] and a voluntary registry[Footnote 60] for consumers to 
report information about their broadband service, could be used to 
collect and disseminate price and speed information for consumer use. 
However, stakeholders also cautioned that periodic consumer surveys and 
a voluntary registry may not provide reliable information because 
consumers are not informed enough about the price and speed of their 
broadband service to report accurate information, and they believe that 
this should be taken into consideration when reviewing the results. 
Additionally, consumers may not take the time to enter their 
information in a registry, as current voluntary registries for 
broadband data sponsored by third parties are sparsely populated. 

Current Data Sources for Industry and Government to Compare Broadband 
across Various Segments of the United States Have Limitations, and 
Stakeholders Generally Support Ongoing Efforts for Improvement: 

Despite FCC's efforts to improve the data collected through its 
broadband reporting form, comparisons of broadband service across 
various segments of the country still have the following limitations 
that diminish their usefulness in informing policy and investment 
decisions: 

* While FCC requires most broadband providers to report broadband 
subscribership on the broadband reporting form, it does not have a 
reporting requirement for these providers to report broadband 
availability.[Footnote 61] Additionally, although the majority of those 
we interviewed cited the change from reporting by ZIP codes to census 
tract as an improvement, some said the data still do not provide enough 
granularity to track subscribership in tribal lands or rural areas. In 
fact, according to FCC's report Bringing Broadband to Rural America: 
Report on a Rural Broadband Strategy, there are no accurate data on 
broadband deployment in rural America, including where broadband 
facilities are deployed, prices, speeds, and the number of subscribers. 
[Footnote 62] 

* FCC also does not require broadband providers to report price 
information for broadband services on its broadband reporting form, so 
it is difficult to measure how price varies across various segments of 
the country. The Commission has open proceedings concerning whether and 
how the Commission could collect price information for broadband 
services. For example, the Commission sought comment on requiring 
providers to report, for each state or each census tract in which they 
offer service, the monthly price the provider charges for stand-alone 
broadband service in each of the speed tiers used for the broadband 
reporting form, potential alternatives, and whether and in what form 
the Commission should use the reported service price information. 
[Footnote 63] 

* Similarly, FCC does not require broadband providers to include 
information on actual broadband connection speeds experienced by 
consumers, although the data from the revised broadband reporting form 
will provide information on the number of connections by advertised 
speed. As previously mentioned, actual delivered speed can determine 
the applications that can be run by consumers and could be useful in 
comparing broadband service across various segments of the country. The 
Commission also has open proceedings concerning how the Commission 
might require broadband service providers to report actual broadband 
connection speeds, and any alternative means, in addition to or other 
than requiring such service provider reporting.[Footnote 64] 

* Some stakeholders noted that FCC may overestimate the number of 
wireless broadband users. FCC's reporting requirement for mobile 
wireless broadband service providers collects data on the number of 
terrestrial mobile wireless subscribers whose subscription and device 
allow them to access the Internet content of their choice, not the 
number of consumers actually using broadband on the device. According 
to a Vice President and Senior Fellow at the Technology Policy 
Institute, it is unlikely that all persons whose subscription and 
device allow them to access the Internet actually use the service. As a 
result, counts of the number of terrestrial mobile wireless subscribers 
whose subscription and device allow them to access the Internet content 
of their choice may overestimate the number of wireless broadband 
users. However, other stakeholders, such as an official with the Rural 
Utilities Services, thought the reporting standard would produce 
accurate results, as they thought most consumers that paid for the 
service would use it. Stakeholders we spoke with generally 
characterized mobile wireless as a complement to and not a substitute 
for fixed wireline service. They added that this may change as the 
technology improves over time. Stakeholders also generally agreed that 
the mobile wireless counts should be kept separate from fixed wireline 
counts when determining deployment and availability. 

* Stakeholders also identified limitations with the Pew Internet & 
American Life Project data. While the survey collects information on 
cost, speed, availability, and usage, the data are limited because the 
sample size lacks the granularity needed for making comparisons at the 
state or regional level. 

Despite the concerns about FCC's data collected through the broadband 
reporting form, several stakeholders said they found the data useful. 
According to one academic expert, FCC's broadband data are the best 
publicly available data on the geographic dispersion of broadband 
services across the United States. In addition, an official with a 
consumer advocacy organization said FCC's changes to the broadband data 
collection struck the right balance between the need for detailed 
subscribership data and the burden to providers of gathering such 
information by choosing the census tract as the geographic unit for 
data collection. 

To address the limitations in broadband data, recently enacted 
legislation requires the Secretary of Commerce to obtain more complete 
data on broadband availability. The Broadband Data Improvement Act 
requires the Secretary of Commerce to establish a grant program for 
multiple purposes, including collection of state-level broadband 
data.[Footnote 65] The American Recovery and Reinvestment Act of 2009 
requires NTIA to establish a comprehensive nationwide inventory map of 
existing broadband service capability and availability in the United 
States that depicts the geographic extent to which broadband service is 
deployed and available from a commercial provider or public provider 
throughout each state.[Footnote 66] By February 17, 2011, NTIA must 
make the national inventory map available online to the public in a 
form that is interactive and searchable. The Recovery Act provides up 
to $350 million, pursuant to the Broadband Data Improvement Act, for 
developing and maintaining the national broadband inventory map. 

NTIA has used the grant-making authority provided under the Broadband 
Data Improvement Act to establish the State Broadband Data and 
Development Grant Program. Through this program, NTIA has solicited 
grant applications from states for projects designed to collect data, 
develop state maps, conduct state planning efforts, and deliver data to 
NTIA for the purposes of developing the national broadband 
map.[Footnote 67] As of September 9, 2009, NTIA had received 
applications representing all 50 states, 5 territories, and the 
District of Columbia. NTIA is currently reviewing the applications and 
plans to announce funding decisions beginning in early fall 2009. 
Applicants must demonstrate that they have the ability to provide a 
substantially complete set of all broadband mapping data on or before 
February 1, 2010, and to complete such data collection by March 1, 
2010.[Footnote 68] NTIA officials told us they are working closely with 
FCC regarding the development of the map. As part of its efforts, NTIA 
is requiring awardees under the State Broadband Data and Development 
Grant Program to provide, among other things, the following 
information:[Footnote 69] 

* for each facilities-based provider of broadband service, a list of 
all census blocks of 2 square miles or smaller in which broadband 
service is available in the provider's service area; 

* for census blocks of greater than 2 square miles, for each facilities-
based provider of broadband service, a list of all street segments in 
the census block in which broadband service is available in such 
provider's service area; 

* for wireless providers, geographical information system compatible 
polygonal shape files depicting areas in which broadband service is 
available; 

* technology type of service provided by census block, street segment, 
or shape file area, as applicable; 

* maximum advertised speed available across each service area or local 
franchise area, by metropolitan or rural statistical area; 

* actual delivered speed that can be consistently achieved during 
expected periods of heavy network usage by census block, or street 
segment, as applicable; and: 

* middle-mile connection points.[Footnote 70] 

Though the program does not require it, awardees may satisfy program 
requirements by providing address-level data. Awardees may also provide 
last-mile connection points, if available. Identification of a 
provider's name and its availability/speed at a particular address is 
considered confidential. However, identification of a service 
provider's specific service area, or "footprint," at the census block 
or street segment level is not considered confidential and will be 
displayed on the national broadband map. The initial period of 
performance for awards under the program was 5 years from the date of 
the award. However, on September 10, 2009, NTIA announced that it will 
fund the mapping and data collection efforts for 2 years from the date 
of the award and will assess lessons learned, determine best practices, 
and investigate opportunities for improved data collection prior to 
obligating funding for subsequent years.[Footnote 71] 

In the notice of funds availability for the State Broadband Data and 
Development Grant Program, NTIA noted that it reserved the right to 
request that FCC exercise its authority to compel any service provider 
subject to its jurisdiction to provide data. NTIA also explained that, 
to the extent possible, the service areas of individual providers will 
be aggregated with those of other providers of the same technology 
type. According to NTIA officials, this determination was based on its 
review of the comments, an examination of mapping methodologies 
employed at the state level, and consultation with FCC. 

Stakeholders generally agreed that the national broadband inventory map 
would help supplement gaps in FCC's broadband data by providing 
detailed data on availability and subscribership across the country. 
For example, a Pew Internet & American Life Project official told us 
that broadband mapping has the most potential for providing the 
granular and accurate information required to make comparisons across 
the country. Several stakeholders also explained that in order for the 
national broadband map to be effective, NTIA needs to develop data 
collection standards to help ensure that the data collected by each 
state are comparable across states. Some stakeholders also stressed the 
need for collecting information regarding demand side data (desire for 
service or usage). 

Despite the consensus among stakeholders regarding the potential 
benefits of broadband mapping, there are some concerns about the 
effort. We found NTIA did not provide guidance on how to calculate 
actual delivered speed that can be consistently achieved during 
expected periods of heavy network usage at the address. For example 
there is no guidance on the number of speed measurements that must be 
taken or a definition of heavy network usage. We have previously 
reported that consistency--the extent to which data are collected using 
the same procedures--is a key dimension of data quality and a key 
attribute of a successful performance measure.[Footnote 72] NTIA 
officials told us they chose not to provide this guidance because each 
provider may have a different method for measuring speed, and they did 
not want to prescribe a standard method, given the multiple 
technologies used. However, this could result in inconsistent 
measurements across grantees, limiting the effectiveness of the mapping 
effort in making comparisons across the country. 

While NTIA required applicants to provide a description of the methods 
the applicant intends to employ to verify data accuracy, it did not set 
out specific standards on how to do so. NTIA's notice of funds 
availability did provide the following example: "A project should 
propose to collect availability data by address...and should cross- 
check that data for accuracy by using at least one other metric." 
[Footnote 73] We have previously reported that both verification and 
validation of performance data are important for reducing the risk of 
producing inaccurate data; this additional information helps to place 
the credibility of an agency's reported performance data in context for 
decision makers.[Footnote 74] NTIA officials told us they chose not to 
specify how grantees should verify data because they did not want to be 
too prescriptive, as allowing states to develop their own data 
verification processes may yield best practices that can be used going 
forward. While it is too early to determine the effect, if any, of the 
limited guidance, the lack of specific standards for data verification 
could result in inconsistent data across states, limiting the 
effectiveness of the data in making comparisons across the country. 

The broadband providers we spoke with were generally concerned about 
the cost and burden of complying with any additional reporting 
requirements. For example, officials from Time Warner told us that some 
providers do not store data in an address-by-address format and would 
have to revise their existing data collection procedures, taking time 
and resources away from network upgrades. According to FCC, broadband 
providers already average 337 staff hours to complete the reporting 
requirements for the broadband reporting form. Other stakeholders, such 
as Connected Nation, Consumers Union, and the Organization for the 
Promotion and Advancement of Small Telecommunications Companies 
(OPASTCO), also acknowledged that additional reporting requirements can 
be particularly burdensome to small broadband providers in rural areas 
that do not have the staff and resources of larger broadband providers. 
In addition, the NTIA requirement to provide data on availability may 
overlap with FCC's requirement for broadband providers to report 
subscribership information through the broadband reporting form, 
because subscribership is a subset of availability. Service must be 
available for a consumer to be a subscriber. To ease the potential 
burden on broadband providers, NTIA has timed its future data 
collection efforts to coincide with FCC's broadband data collection. 

Finally, some stakeholders, including the Pew Internet & American Life 
Project, Consumer Federation of America, and Consumers Union, were 
concerned that some data underlying the state maps would not be 
publicly available for review. They explained that public-private 
partnerships often agree to nondisclosure agreements with broadband 
providers to facilitate data collection by easing provider concerns 
regarding what the providers consider to be the proprietary nature of 
the data. However, according to these stakeholders, this reduces the 
transparency of the maps and prevents other interested parties from 
analyzing the information. 

Again, stakeholders generally noted that FCC's efforts to develop 
periodic surveys (per the Broadband Data Improvement Act) and a 
voluntary registry could be used to collect and disseminate price and 
speed information to make comparisons of broadband service across the 
country. But they cautioned that information gleaned from these efforts 
is limited and therefore should be a supplement to other data 
collection efforts, because, as previously mentioned, consumers may not 
be well informed about the price and speed of their Internet service. 

International Broadband Comparisons Have Limitations for a Variety of 
Reasons, but Stakeholders Generally Support FCC's Efforts to Develop 
Additional International Comparisons: 

As previously discussed, stakeholders reported that socioeconomic 
differences among countries can limit the efficacy of international 
comparisons. For example, OECD and ITU report broadband subscribers per 
100 inhabitants rather than as a percentage of households.[Footnote 75] 
According to a senior official at the Technology Policy Institute, 
household size alone explains most of the differences in the broadband 
rankings of countries, since countries with larger households are 
likely to have lower per capita residential connections. As the Phoenix 
Center demonstrated, even if every home and business in every OECD 
country were wired with a broadband connection, the United States' per 
capita rank would fall from 15th to 20th because the United States has 
a larger average household size than countries, such as Sweden and 
Iceland, that rank above it.[Footnote 76] According to FTC staff, 
because the socioeconomic status of individual countries and the 
historical nature of their Internet access markets can vary widely, 
simple comparisons of individual indicators such as broadband 
deployment and adoption rates across countries may not be meaningful. 
[Footnote 77] 

In contrast to OECD's use of subscriber data, the composite indexes we 
previously described attempt to take into account the socioeconomic 
differences and other variables among countries when comparing 
broadband performance. However, according to stakeholders, even 
composite indexes provide limited analysis because of their complex 
nature and the number of variables they seek to measure. For example, 
one of the authors of the Connectivity Scorecard noted that composite 
indexes are "ultimately based on subjective decisions about which 
indicators to include or exclude and how to weight these indicators." 
[Footnote 78] The more factors or variables considered in a composite 
index, the more data must be collected, normalized, and weighted for 
comparative purposes. A spokesperson for the EIU's E-readiness ranking 
stated that more variables increase the room for error. Multiple 
variables also make it difficult to determine a causal relationship for 
policy-making purposes between the variable and its measured impact on 
the result, according to officials with the European Commission. For 
example, the EIU included nearly 100 quantitative and qualitative 
variables in its E-readiness Ranking Report in an attempt to measure 
the impact of a country's social, political, economic, and 
technological developments on its ICT usage and infrastructure. A 
representative of the EIU told us that there are limitations to this 
approach, and that some of the unit's data must be estimated because of 
the sheer number of variables the EIU attempts to consider for the 70 
countries in the E-readiness Ranking Report. 

Stakeholders also reported that the necessary data to improve 
international comparisons of broadband deployment and penetration are 
not available. OECD and others have noted that while supply-side data 
from broadband providers are both readily available and easily 
quantifiable, demand-side data from consumers for measuring broadband 
penetration are limited. Some stakeholders, such as officials with ITU, 
TPI, and ITIF, have noted the importance of collecting demand-side data 
through household surveys to more accurately reflect how consumers use 
their personal broadband service for economic or social gain. 
Governments are also increasingly recognizing the importance of 
collecting better demand-side data. For example, EU member countries 
are now required to collect household survey data on ICT usage. 

In addition, stakeholders reported a lack of uniformity and reliability 
with the data used to make international broadband comparisons, whether 
by composite index or single indicator. For example, although most of 
the countries that participate in international broadband ranking 
systems recognize broadband to be Internet service above 256 Kbps, 
there is no internationally agreed upon definition for broadband, which 
affects the comparability of the data collected. OECD and ITU have 
recommended uniform reporting standards among their member countries, 
but the standards are neither enforceable nor applicable to countries 
outside their membership. In addition, some of the organizations that 
develop international comparisons rely on participating countries to 
provide the needed data rather than independently gather the data 
directly from providers or in the form of household surveys, a fact 
that leads some to question its reliability. The officials we 
interviewed from the organizations that develop international 
comparisons told us they have limited ability to corroborate the data 
received from participating governments, outside of questioning and 
confirming a figure when a number appears out of line with trend data. 
Estimates are also made when the data are simply lacking for a 
particular country. 

Currently, discussions are also taking place on how to collect and 
differentiate among wireline, wireless, and mobile wireless broadband 
counts. According to OECD, wireless Internet connections at broadband 
speeds are increasingly available and particularly important in 
underserved areas around the world. Similarly Internet access via 
mobile cellular networks has grown rapidly with the increasing 
availability of third-generation (3G) networks and enabled devices that 
allow users to access the Internet over mobile cellular networks using 
a laptop, cell phone, or alternative mobile device. A representative 
from the Economist Intelligence Unit stated that mobile wireless 
Internet access is particularly important for individuals in developing 
countries, such as in Africa, where mobile access may be their primary 
Internet source. However, stakeholders noted that it is important to 
differentiate between 3G subscribers whose plan may allow them to 
access the Internet on their mobile device and those who actually take 
advantage of the service; current data usually do not differentiate and 
are therefore potentially misleading. OECD is in discussions with 
member countries to develop a common methodology to improve the 
collection of mobile wireless data. 

Despite the concerns raised about the limitations of the measures used 
for international comparisons, several stakeholders found the 
comparisons useful. As previously mentioned, OECD's count of broadband 
subscribers per 100 inhabitants by technology is one of the most 
reported figures. Representatives from the Consumer Federation of 
America, Free Press, and the Pew Internet & American Life Project said 
the OECD broadband comparisons provide valuable information to policy 
makers. In its guidance on developing composite indicators, OECD noted 
that composite indexes used by other organizations in making 
international broadband comparisons are recognized as a useful tool in 
policy analysis and public communication.[Footnote 79] The indexes 
serve the important purpose of raising awareness among policy makers 
and the public of areas that deserve particular attention in future 
policy decisions. 

FCC has noted that a more fully developed picture of broadband markets 
would provide more accurate and useful international comparisons. 
[Footnote 80] The recent Broadband Data Improvement Act mandated that 
FCC include in future 706 reports information that compares the extent 
of broadband service capability in a total of 75 communities in at 
least 25 countries abroad for each of the data benchmarks for broadband 
service under FCC's current speed tiers.[Footnote 81] The Commission 
was directed to choose international communities for the comparison 
that will offer a population size, density, topography, and demographic 
profile that are comparable to those of various communities within the 
United States. In May 2009, FCC officials informed us that they had 
already assembled a cross-bureau team of economists and attorneys to 
perform this international comparison. FCC staff is currently in the 
process of identifying and reaching out to a number of countries 
believed to have the relevant broadband data necessary to make such 
comparisons. According to the officials, they have sent letters to 37 
countries to request data.[Footnote 82] They are working under the 
assumption that the mandate will require them to communicate the 
results of their comparisons in the next Section 706 report, which is 
to be released in February of 2010. In addition, on March 31, 2009, FCC 
posted a public request for comment on the international comparisons 
component of the act.[Footnote 83] The majority of stakeholders we 
spoke with generally support FCC's efforts to develop an additional 
international comparison on broadband performance. Although the term 
"community" was not defined in the act and had yet to be defined by 
FCC, this level of analysis could be more granular and therefore more 
comparable than what is generally provided in current international 
comparison reports. Representatives from organizations such as 
Connected Nation and Free Press support data that are collected and 
analyzed at a more granular local level rather than at a national 
level, because they believe that such data make the comparisons more 
relevant. 

Conclusions: 

A wide range of measures to assess broadband performance is generally 
available to consumers, industry, and government. However, many 
stakeholders told us that the measures used by consumers and those used 
to make comparisons across the United States and among other countries 
have limitations. Reaching a compromise among broadband providers, 
consumer advocates, and others on improved broadband measures in the 
United States has proven to be difficult because they do not agree on 
alternatives for improvement. Nevertheless, all stakeholders are 
generally supportive of NTIA's State Broadband Data and Development 
Grant Program and its effort to create a national broadband inventory 
map, which could help fill some current gaps in data. NTIA has made 
progress in (1) implementing its State Broadband Data and Development 
Grant Program and (2) requiring grantees to collect data that have 
important implications for consumers, policy makers, and industry in 
measuring broadband performance. NTIA will begin receiving data by 
March 2010 as part of its new grant initiative to collect state-level 
broadband data and establish a national broadband inventory map. 
However, NTIA lacks specific guidance for grantees on calculating 
actual delivered speeds. Without such guidance, it will be difficult to 
ensure the consistency, and therefore the quality, of the data, 
limiting the effectiveness of the mapping effort in making comparisons 
across the country. In addition, while NTIA provided potential grantees 
with an example of how to verify data accuracy, it did not provide 
specific standards to verify data accuracy. Consequently, NTIA will 
need to determine whether the data provided in the initial submission 
are accurate, and if additional guidance is needed. Developing 
procedures to help ensure consistent and accurate data is critical, as 
NTIA begins to distribute funds to grantees and they begin their data 
collection. More importantly, this effort has the potential to provide 
consumers, policy makers, and industry with accurate and reliable 
information such as broadband availability, type, and advertised and 
actual delivered speed by census block, information that could be used 
by each in their decision-making process and help guide broadband 
investment in unserved or underserved populations. 

Recommendation for Executive Action: 

To increase the data quality and subsequent results from the State 
Broadband Data and Development Grant Program, including a searchable 
nationwide inventory map of existing broadband service capability and 
availability in the United States, we recommend the Secretary of 
Commerce examine the first round of data collection and determine 
whether to develop specific guidance for grantees to improve the 
consistency and accuracy of the data collected under the program. 

Agency Comments: 

We provided a draft of this report to the Department of Commerce and 
FCC for their review and comment. The Department of Commerce provided 
written comments, which are reprinted in appendix II. In its written 
comments, the Department of Commerce generally agreed with our 
recommendation and stated that it had already begun taking actions to 
address the recommendation. More specifically, the Department of 
Commerce stated that immediately following the awarding of grant funds, 
it will investigate opportunities for improved data collection methods 
including qualitative and quantitative analyses of data collection and 
verification methods, as well as an assessment of which methods are 
cost-efficient and accurate. FCC responded that it did not have any 
comments on the draft report. 

We are sending copies of this report to the Secretary of Commerce and 
the Chairman of the Federal Communications Commission. In addition, the 
report will be available at no charge on the GAO Web site at hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about his report, please 
contact me at (202) 512-2834 or goldsteinm@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Contact information and major 
contributors to this report are listed on appendix III. 

Signed by: 

Mark L. Goldstein: 
Director, Physical Infrastructure Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

To gather information related to both objectives, we reviewed related 
documentation and laws, including the Broadband Data Improvement Act, 
enacted in 2008; the legislative history of the act; the American 
Recovery and Reinvestment Act of 2009 and its legislative history; 
various Federal Communications Commission (FCC) proceedings; and 
reports from the Congressional Research Service (CRS). We also 
conducted a literature review to identify broadband performance 
measures, including international broadband comparisons.: 

To identify the broadband performance measures available to consumers, 
industry, government, and other stakeholders, we interviewed officials 
and representatives from several stakeholder groups. On the basis of 
the requirements of the mandate, the literature review, the judgment of 
our staff with expertise in broadband and telecommunications issues, 
and suggestions from the initial interviews held, we determined to 
include the following stakeholder groups in our analysis to ensure a 
variety of perspectives and views on broadband performance measures: 
academicians and think tanks, broadband providers, consumer advocacy 
groups, federal and state agencies and public/private partnerships, 
international organizations, and trade and industry groups. We used the 
same process to identify potential stakeholders for interviews. Table 4 
contains a detailed list of the stakeholders included in our study: 

Table 4: Stakeholders Interviewed: 

Stakeholder category: Academicians and think tanks; 
Name: 
Johannes Bauer, Co-Director, Quello Center for Telecommunications 
Management and Law, Michigan State University; 
Information Technology and Innovation Foundation; 
Dr. Bill Lehr, Massachusetts Institute of Technology; 
Pew Internet & American Life Project; 
Phoenix Center for Advanced Legal and Economic Public Policy Studies; 
Technology Policy Institute; 
Dr. Leonard Waverman, Dean, Haskayne School of Business at the 
University of Calgary. 

Stakeholder category: Broadband providers; 
Name: 
AT&T; 
Comcast; 
Qwest; 
Time Warner; 
Verizon; 
Wild Blue Satellite. 

Stakeholder category: Consumer advocacy groups; 
Name: 
BroadbandCensus.com; 
Consumer Federation of America; 
Consumers Union; 
Free Press. 

Stakeholder category: Federal and state agencies and public/private 
partnerships; 
Name: 
California Public Utilities Commission; 
Census Bureau; 
Connected Nation; 
e-NC Authority; 
Federal Communications Commission; 
Federal Trade Commission; 
National Telecommunications and Information Administration; 
United States Department of Agriculture, Rural Utilities Services. 

Stakeholder category: International organizations; 
Name: 
Economist Intelligence Unit; 
European Commission; International Telecommunication Union; 
Organisation for Economic Co-operation and Development. 

Stakeholder category: Trade and industry groups; 
Name: 
Akamai; 
IEEE (previously known as the Institute of Electrical and Electronics 
Engineers); 
The Internet Engineering Task Force; 
National Association of Regulatory Utility Commissioners; 
National Cable and Telecommunications Association; 
National Rural Telecommunications Cooperative; 
National Telecommunications Cooperative Association; 
Organization for the Promotion and Advancement of Small 
Telecommunications Companies; 
Satellite Industry Association; 
U.S. Telecommunications Association; 
The Wireless Association (CTIA); 
Wireless Internet Service Provider Association. 

Source: GAO. 

[End of table] 

To evaluate the limitations, if any, of the measures, and how the 
measures could be supplemented or improved, we interviewed and reviewed 
related documentation from the stakeholders previously mentioned to 
obtain their opinions and analysis on the strengths and limitations of 
the measures and any potential options identified. We also asked the 
stakeholders to discuss the validity and reliability of the measures 
and any potential improvements. 

Although representatives from the think tanks and academicians we 
interviewed identified limitations with the data that are used to make 
international comparisons, stakeholders generally use the same sources, 
thought the data were adequate, and support current efforts being made 
to improve the quality of the data. 

We conducted this performance audit from February 2009 through October 
2009 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the Department of Commerce: 

United States Department Of Commerce: 
The Secretary of Commerce: 
Washington, D.C. 20230: 

October 1, 2009: 

Mr. Gene L. Dodaro: 
Acting Comptroller General: 
Government Accountability Office: 
441 G Street, N.W. 
Washington, DC 20548: 

Dear Mr. Dodaro: 

Thank you for the opportunity to comment on the Government 
Accountability Office's (GAO) draft report, "Telecommunications: 
Current Broadband Measures Have Limitations, and New Measures
are Promising But Need Improvement" (GAO-l0-49). 

The Department of Commerce (Department) is committed to developing a 
national broadband map that will provide much needed public broadband 
availability and performance data. The Department, through its National 
Telecommunications and Information Administration (NTIA), has already 
launched the State Broadband Data and Development (SBDD) Grant Program 
to collect State-level broadband that assesses the availability and 
quality of nationwide broadband services, and that provides information
necessary for the development and maintenance of the national broadband 
map. 

Consistent with your observation of the need to ensure the consistency 
and accuracy of the data collected through the SBDD Grant Program, I am 
pleased to inform you that the Department has already begun to take 
proactive measures. In early September 2009, NTIA reduced the initial 
funding period SBDD grants from five years to two years to allow NTIA 
to assess lessons learned, determine best practices, and investigate 
opportunities for improved data collection methods prior to awarding 
funds subsequent years (see State Broadband Data and Development Grant 
Program, Notice of Funds Availability/Clarification of Period of 
Performance, 74 Fed. Reg. 46573,46574; Sept. 10,2009). 

NTIA will begin this process immediately following the awarding of SBDD 
grant funds. The Department's efforts in this regard will include 
qualitative and quantitative analyses of data collection verification 
methods, as well as an assessment of which methods are both cost-
efficient and accurate. The Department welcomes further discussions 
with the Government Accountability Office to discuss specific methods 
to examine the data received by grantees. The Department of Commerce 
remains committed to utilizing funds in a fiscally prudent manner 

as it develops a comprehensive and accurate national broadband map, 
which will serve as an important consumer, benchmarking, research, and 
policymaking tool. 

Sincerely, 

Signed by: 

Gary Locke: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Mark L. Goldstein, (202) 512-2834 or goldsteinm@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, David Sausville (Assistant 
Director), Eli Albagli, Derrick Collins, Amy Rosewarne, Andrew 
Stavisky, Hai Tran, Amy Ward-Meier, and Mindi Weisenbloom made key 
contributions to this report. 

[End of section] 

Footnotes: 

[1] The term "broadband" commonly refers to high-speed Internet access. 
Broadband enables consumers to receive information much faster than a 
dial-up connection and provides an "always on" connection to the 
Internet. Consumers can receive a broadband connection through a 
variety of technologies such as cable modem, digital subscriber line 
service, fiber, and satellite. These technologies are described in more 
detail later in the report. 

[2] "Penetration" is generally defined as the number or percentage of 
broadband subscribers per capita or per household. 

[3] Broadband Data Improvement Act, Pub. L. No. 110-385, tit. I, § 104, 
122 Stat. 4096, 4098 (2008). 

[4] For example, in low-density areas, the market does not support 
private broadband infrastructure investment. 

[5] See 47 U.S.C. § 1302. 

[6] In this report, we refer to the FCC Form 477 as the broadband 
reporting form and the resulting data as FCC's broadband data. 

[7] See 47 U.S.C. § 1301(3). 

[8] For a complete list of the stakeholders interviewed grouped by 
type, see appendix I. 

[9] The Department of Commerce's National Telecommunications and 
Information Administration is the President's principal 
telecommunications and information adviser and works with other 
executive branch agencies to develop the Administration's 
telecommunications policies. 

[10] In its notice of funding availability, NTIA refers to actual 
delivered speed as typical speed. See 74 Fed. Reg. 32545 (July 8, 2009) 
(Notice), 74 Fed. Reg. 40569 (August 12, 2009) (Notice clarification). 

[11] GAO, Performance Plans: Selected Approaches for Verification and 
Validation of Agency Performance Information, [hyperlink, 
http://www.gao.gov/products/GAO/GGC-99-139] (Washington D.C.: July 30, 
1999), and Tax Administration: IRS Needs to Further Refine Its Tax 
Filing Season Performance Measures, [hyperlink, 
http://www.gao.gov/products/GAO-03-143] (Washington, D.C.: Nov. 22, 
2002). 

[12] GAO, Performance Reporting: Few Agencies Reported on the 
Completeness and Reliability of Performance Data, [hyperlink, 
http://www.gao.gov/products/GAO-02-372] (Washington, D.C.: Apr. 26, 
2002). 

[13] Granular refers to the extent to which a system is broken down 
into small parts. Therefore, broadband comparisons at a community or 
local level are more granular than broadband comparisons of countries. 

[14] In digital telecommunication, the bit rate is the number of bits 
that passes a given point in a telecommunication network in a given 
amount of time, usually a second. Thus, a bit rate is usually measured 
in some multiple of bits per second--for example, kilobits, or 
thousands of bits per second. 

[15] Comment Sought on Defining "Broadband," Public Notice, DA 09-1842 
(2009); see also A National Broadband Plan for Our Future, Notice of 
Inquiry, 24 FCC Rcd 4342, 4346-48, at paras. 15-22 (2009); Inquiry 
Concerning the Deployment of Advanced Telecommunications Capability to 
All Americans in a Reasonable and Timely Fashion, and Possible Steps to 
Accelerate Such Deployment Pursuant to Section 706 of the 
Telecommunications Act of 1996, as Amended by the Broadband Data 
Improvement Act, Notice of Inquiry, FCC 09-65, at paras. 34-41 (rel. 
Aug. 7, 2009). 

[16] There also are low earth orbit satellite providers such as 
GlobalStar and Iridium that provide some level of broadband service. 
These satellite systems are in a nonstationary orbit and are between 
250 and 600 miles in orbit. 

[17] Radio spectrum is a natural resource used to provide an array of 
wireless communication services. FCC regulates commercial entities' use 
of spectrum. With unlicensed spectrum, a number of users without 
licenses share a portion of the spectrum, adhering to certain 
technological specifications. In contrast, with licensed spectrum, FCC 
licenses entities to use a specific portion of the spectrum. GAO, 
Telecommunications: Broadband Deployment Is Extensive throughout the 
United States, but It Is Difficult to Assess the Extent of Deployment 
Gaps in Rural Areas, GAO-06-426 (Washington, D.C.: May 5, 2006). 

[18] Pub. L. No. 104-104, § 706, 110 Stat. 56, 153 (1996). Section 
706(c) of the act describes advanced telecommunications capabilities as 
"high-speed, switched, broadband telecommunications capability that 
enables users to originate and receive high-quality voice, data, 
graphics, and video telecommunications using any technology." Section 
706 of the Telecommunications Act of 1996, Pub. L. No. 104-104, title 
VII, Sec. 706, 110 Stat. 56, 153 (1996) (1996 Act), as amended in 
relevant part by the Broadband Data Improvement Act, Pub. L. No. 110- 
385, 122 Stat. 4096 (2008) (BDIA), is now codified at 47 U.S.C. § 1301 
et. seq. Prior to the BDIA, section 706 was reproduced in the notes to 
Section 157 of the Communications Act of 1934, as amended (the Act). 47 
U.S.C. § 157 nt. (2008). 47 U.S.C. § 1302(d). 

[19] Under the Telecommunications Act, "telecommunications service" is 
defined as "the offering of telecommunications for a fee directly to 
the public, or to such classes of users as to be effectively available 
directly to the public, regardless of the facilities used." 47 U.S.C.§ 
153(46). "Telecommunications" is defined as "the transmission, between 
or among points specified by the user, of information of the user's 
choosing, without change in the form or content of the information as 
sent and received." 47 U.S.C. § 153(43). 

[20] Under the Telecommunications Act, "information service" is defined 
as the offering of a capability for generating, acquiring, storing, 
transforming, processing, retrieving, utilizing, or making available 
information via telecommunications, and includes electronic publishing, 
but does not include any use of any such capability for the management, 
control, or operation of a telecommunications system or the management 
of a telecommunications service. 47 U.S.C. § 153(20). 

[21] See e.g., Inquiry Concerning High-Speed Access to the Internet 
Over Cable and Other Facilities; Internet Over Cable Declaratory 
Ruling; Appropriate Regulatory Treatment for Broadband Access to the 
Internet Over Cable Facilities, Declaratory Ruling and Notice of 
Proposed Rulemaking, 17 FCC Rcd 4798 (2002) (Cable Modem Declaratory 
Ruling), aff'd Nat'l Cable & Telecomms. Ass'n v. Brand X Internet 
Servs., 545 U.S. 967 (2005); Appropriate Framework for Broadband Access 
to the Internet over Wireline Facilities; Universal Service Obligations 
of Broadband Providers; Review of Regulatory Requirements for Incumbent 
LEC Broadband Telecommunications Services; Computer III Further Remand 
Proceedings: Bell Operating Company Provision of Enhanced Services; 
1998 Biennial Regulatory Review--Review of Computer III and ONA 
Safeguards and Requirements; Conditional Petition of the Verizon 
Telephone Companies for Forbearance Under 47 U.S.C. § 160(c) with 
Regard to Broadband Services Provided via Fiber to the Premises; 
Petition of the Verizon Telephone Companies for Declaratory Ruling or, 
Alternatively, for Interim Waiver with Regard to Broadband Services 
Provided via Fiber to the Premises; Consumer Protection in the 
Broadband Era, Report and Order and Notice of Proposed Rulemaking, 20 
FCC Rcd 14853 (2005) (Wireline Broadband Internet Access Services 
Order), aff'd Time Warner Telecom, Inc. v. FCC, 507 F.3d 205 (3d Cir. 
2007); United Power Line Council's Petition for Declaratory Ruling 
Regarding the Classification of Broadband over Power Line Internet 
Access Service as an Information Service, Memorandum Opinion and Order, 
21 FCC Rcd 13281 (2006) (BPL-Enabled Internet Access Services Order); 
Appropriate Regulatory Treatment for Broadband Access to the Internet 
Over Wireless Networks, Declaratory Ruling, 22 FCC Rcd 5901 (2007). 

[22] See National Cable Telecomm. Ass'n. v. Brand X Internet Services, 
545 U.S. 967, 976 (2005) (FCC has jurisdiction to impose additional 
regulatory obligations under its Title I ancillary jurisdiction to 
regulate interstate and foreign communications). FCC has relied on its 
ancillary jurisdiction in adjudicatory proceedings, for example, in the 
proceeding in which it found Comcast's practices did not constitute 
reasonable network management. Formal Complaint of Free Press and 
Public Knowledge Against Comcast Corporation for Secretly Degrading 
Peer-to-Peer Applications; Broadband Industry Practices; Petition of 
Free Press et al. for Declaratory Ruling that Degrading an Internet 
Application Violates the FCC's Internet Policy Statement and Does Not 
Meet an Exception for "Reasonable Network Management," 23 FCC Rcd 13028 
(2008) (Comcast Order). Comcast filed a petition appealing this order 
on Sept. 4, 2008, with the U.S. Court of Appeals for the D.C. Circuit. 
Petition for Review, Comcast v. FCC, No. 08-1291 (D.C. Cir. Filed 
September 4, 2008). In 2005 the Commission adopted an Internet Policy 
Statement in which it committed "to preserve and promote the vibrant 
and open character of the Internet as the telecommunications 
marketplace enters the broadband age" by incorporating four consumer- 
based principles into its ongoing policy-making activities. Internet 
Policy Statement, 20 FCC Rcd 14986 (2005). 

[23] Federal courts have upheld FCC's authority to regulate broadband 
Internet service providers under the Communications Assistance for Law 
Enforcement Act. In addition, in 2005 the Commission determined that 
providers of interconnected voice over Internet protocol services and 
broadband Internet access services are subject to the Communications 
Assistance for Law Enforcement Act (CALEA). See Communications 
Assistance for Law Enforcement Act and Broadband Access and Services, 
First Report and Order and Further Notice of Proposed Rulemaking, 20 
FCC Rcd 14989, 14991-92, para. 8 (2005) (CALEA First Report and Order), 
aff'd sub nom. American Council on Educ. v. FCC, 451 F.3d 226 (D.C. 
Cir. 2006). 

[24] See 47 U.S.C. § 1302(b); see, e.g., Inquiry Concerning the 
Deployment of Advanced Telecommunications Capability to All Americans 
in a Reasonable and Timely Fashion, Fifth Report, 23 FCC Rcd 9615 
(2008) (Section 706 Fifth Report), pet. for recon. pending. 

[25] A facilities-based carrier is one that owns most of its 
facilities, such as switching equipment and transmission lines. A non-
facilities-based carrier is one that leases most of its switching and 
lines from others. 

[26] In the past, companies with fewer than 250 broadband connections 
were not required to submit information to FCC through Form 477. 

[27] [hyperlink, http://www.gao.gov/products/GAO-06-426]. 

[28] Development of Nationwide Broadband Data to Evaluate Reasonable 
and Timely Deployment of Advanced Services to All Americans, 
Improvement of Wireless Broadband Subscribership Data, and Development 
of Data on Interconnected Voice over Internet Protocol (VoIP) 
Subscribership, Report and Order, 23 FCC Rcd 9691 (2008); Order on 
Reconsideration, 23 FCC Rcd 9800 (2008). 

[29] 47 U.S.C. §§ 1302, 1303. 

[30] In recently issued comments, FTC stated that it shares 
jurisdiction over broadband Internet access and related content 
applications with FCC. A National Broadband Plan for Our Future, GN 
Docket No. 09-51, Comments of the FTC (submitted Sept. 4, 2009). 

[31] 15 U.S.C. § 41 et seq. FTC's authority to enforce the federal 
antitrust laws generally is shared with the Department of Justice's 
Antitrust Division. Federal Trade Commission Staff Report, Broadband 
Connectivity Competition Policy. Washington, D.C., 2007. 

[32] 15 U.S.C. § 45(a)(2). Specifically, section 45(a)(2) provides: 
"The Commission is hereby empowered and directed to prevent persons, 
partnerships, or corporations, except banks, savings and loan 
institutions described in section 18(f)(3) [15 USCS § 57a(f)(3)], 
Federal credit unions described in section 18(f)(4) [15 USCS § 
57a(f)(4)], common carriers subject to the Acts to regulate commerce, 
air carriers and foreign air carriers subject to the Federal Aviation 
Act of 1958 [49 USCS §§ 40101 et seq.], and persons, partnerships, or 
corporations insofar as they are subject to the Packers and Stockyards 
Act, 1921, as amended [7 USCS §§ 181 et seq.], except as provided in 
section 406(b) of said Act [7 USCS § 227(b)], from using unfair methods 
of competition in or affecting commerce and unfair or deceptive acts or 
practices in or affecting commerce." 

[33] Under telecommunications law, an entity is a common carrier only 
with respect to services that it provides on a common carrier basis. 
See 47 U.S.C. § 153(44) (provider of telecommunications services deemed 
a common carrier under the Communications Act "only to the extent that 
it is engaged in providing telecommunications services."). 

[34] For example, FTC challenged the proposed merger between America 
Online (AOL) and Time Warner, on the basis that the merger threatened 
to harm competition and injure consumers in several markets, including 
those for broadband Internet access and residential Internet transport 
services. The consent order resolving the agency challenge required the 
merged entity to open its cable system to competitor Internet service 
providers on a nondiscriminatory basis for all content. Am. Online, 
Inc. & Time Warner, Inc., FTC Dkt. No. C-3989 (April 17, 2001) (consent 
order), available at [hyperlink, 
http://www.ftc.gov/os/2001/04/aoltwdo.pdf]. 

[35] For example, See Am. Online & CompuServe Interactive Servs., Inc. 
FTC DKT No. C-4105 (Jan. 28, 2004) (consent order) available at 
[hyperlink, http://www.ftc.gov/os/caselist/00230000/0023000aol.shtm]. 

[36] In addition, according to NTIA officials, they periodically 
sponsor Internet use surveys conducted by the U.S. Census Bureau and 
publish the findings in reports. The next data collection is expected 
to occur in the fall of 2009. 

[37] GAO, Telecommunications: Broadband Deployment Plan Should Include 
Performance Goals and Measures to Guide Federal Investment, [hyperlink, 
http://www.gao.gov/products/GAO-09-494] (Washington, D.C.: May 12, 
2009). 

[38] California Broadband Task Force, The State of Connectivity, 
Building Innovation Through Broadband, Final Report of the California 
Broadband Task Force, January 2008. 

[39] The state partnered with speedtest.net to acquire 2006 California 
data, representing 350,000 broadband users that conducted 1,243,278 
test of their effective bandwidth. 

[40] In addition to collecting data through the broadband reporting 
form, the Commission tracks the deployment of mobile wireless broadband 
networks using network coverage data acquired through a contract with 
an independent consulting firm. The results of the Commission's 
analysis of mobile network deployment are included in its Annual CMRS 
Competition Reports. The Thirteenth CMRS Competition Report describes 
how the Commission analyzes mobile network coverage. See Implementation 
of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993; 
Annual Report and Analysis of Competitive Market Conditions with 
Respect to Commercial Mobile Services, Thirteenth Report, paras. 37-39, 
144-47 (WTB rel. Jan. 16, 2009) (Thirteenth CMRS Competition Report). 
Using this information, the commission develops an estimate of the 
percentage of the U.S. population covered by various broadband mobile 
network technologies. 

[41] [hyperlink, http://www.gao.gov/products/GAO-06-426]. 

[42] Specifically, FCC requires wired, terrestrial fixed wireless and 
satellite broadband service providers to report certain subscriber 
information by census tract. 

[43] John Horrigan, Home Broadband Adoption 2009, Pew Internet & 
American Life Project, (Washington, D.C.: June 2009). 

[44] Pew previously identified where people live by rural, urban, or 
suburban location, as it is easy to identify landline phones according 
to the Census Bureau's definitions of rural, urban, and suburban. The 
change to identifying where people live by rural and nonrural was made 
because blocks of cell phone numbers do not neatly map to Census Bureau 
definitions of urban, suburban, and rural. However, samples of cell 
phone numbers do include the Metropolitan Statistical Area (MSA) in 
which the cell phone was activated, which is a close proxy for where 
the user lives. 

[45] "ICT" is a general term that covers all methods that may be used 
to transmit, display, or use data for information processing or 
communication by electronic means. 

[46] In its 2008 report titled Broadband Growth and Policies in OECD 
Countries, OECD cautions that policy makers must examine a range of 
indicators that reflect the status of individual broadband markets in 
OECD countries. 

[47] The EU-27 indicates the 27 member states of the European Union: 
Austria, Belgium, Bulgaria, Cyprus, the Czech Republic, Denmark, 
Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, 
Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, 
Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the United 
Kingdom. 

[48] Inquiry Concerning the Deployment of Advanced Telecommunications 
Capability to All Americans in a Reasonable and Timely Fashion, and 
Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of 
the Telecommunications Act of 1996, Fifth Report, 23 FCC Rcd 9615 
(2008) (Section 706 Fifth Report), pet. for recon. pending. 

[49] The terms "resource-and efficiency-driven" and "innovation- 
driven" are borrowed from the World Economic Forum's classification. 
Innovation-driven economies are more highly developed than resource-and 
efficiency-drive economies. 

[50] The World Economic Forum is an independent international 
organization that seeks to improve the state of the world by engaging 
leaders in partnerships to influence global, regional, and industry 
agendas. 

[51] eLab has research facilities in Abu Dhabi, United Arab Emirates, 
and at INSEAD's two campuses located in France and Singapore. 

[52] Ofcom, The International Communications Market, 2008. 

[53] According to the attendees at the World Summit on the Information 
Society, organized by the United Nations, an information society has 
access to and takes advantage of the benefits of the digital revolution 
of ICT, such as in the form of e-commerce, e-government, education, 
sustainable development, and so forth. 

[54] The two organizations whose studies do not include composite 
indexes are OECD and Ofcom. Socioeconomic factors can affect broadband 
deployment and penetration. For example, it is easier and cheaper to 
deploy and upgrade broadband if most of a nation's residents live in 
highly dense urban areas, such as in South Korea. Conversely, if most 
of a nation's citizens live in single-family homes in the suburbs or 
rural areas, such as in the United States, the cost per household for 
deploying broadband is higher. 

[55] FCC has defined "intermodal competitors" as providers of services 
similar to those provided by incumbent local exchange carriers that 
rely exclusively on technological platforms other than wireline 
technologies. "Intermodal competitors include, for example, cable modem 
service providers, wireless broadband Internet access service 
providers, satellite broadband Internet access service providers, and 
other broadband Internet access service providers such as broadband 
over power line providers." See Appropriate Framework for Broadband 
Access to the Internet over Wireline Facilities, Report and Order and 
Notice of Proposed Rulemaking, 20 FCC Rcd 14853, 14856, para. 3, ftn 7 
(2005), aff'd sub nom. Time Warner Telecom, Inc. v. FCC, 507 F.3d 205 
(3d Cir. 2007). 

[56] Deployment of Nationwide Broadband Data to Evaluate Reasonable and 
Timely Deployment of Advanced Services to All Americans, Improvement of 
Wireless Broadband Subscribership Data, and Development of Data on 
Interconnected Voice over Internet Protocol (VoIP) Subscribership, 
Notice of Proposed Rulemaking, 22 FCC Rcd 7760, 7769-70 (2007); 
Development of Nationwide Broadband Data to Evaluate Reasonable and 
Timely Deployment of Advanced Services to All Americans, Improvement of 
Wireless Broadband Subscribership Data, and Development of Data on 
Interconnected Voice over Internet Protocol (VoIP) Subscribership, 
Report and Order and Further Notice of Proposed Rulemaking, 23 FCC Rcd 
9691, 9702 (2008); Inquiry Concerning the Deployment of Advanced 
Telecommunications Capability to All Americans in a Reasonable and 
Timely Fashion, and Possible Steps to Accelerate Such Deployment 
Pursuant to Section 706 of the Telecommunications Act of 1996, as 
Amended by the Broadband Data Improvement Act, Notice of Inquiry, 24 
FCC Rcd 10505 (2009); A National Broadband Plan for Our Future, Notice 
of Inquiry, 24 FCC Rcd 4342 (2009) (National Broadband Plan NOI). 

[57] According to FCC, it did not receive any formal complaints related 
to broadband speed during that time frame. 

[58] According to FTC, some consumers complained about the fair access 
policies of broadband access providers, particularly satellite, which 
unbeknownst to the consumers, would typically result in slower access 
speeds after a certain threshold of Internet activity was exceeded. In 
addition, some complained about their actual speeds after using online 
speed tests to compare what they were getting with what was promised in 
the advertisement. Other consumers complained more generally about 
performance issues, like slow speeds and lost connections, which failed 
to meet their expectations of service, and others mentioned their 
difficulty in attempting to cancel their slow service. Several 
consumers actually said their high-speed service was slower than what 
they previously experienced with dial-up. 

[59] Specifically, the Broadband Data Improvement Act requires the 
Commission to conduct and make public periodic surveys of consumers in 
urban, suburban, and rural areas in the large business, small business, 
and residential consumer markets to determine the types of technology 
used to provide the broadband service capability to which consumers 
subscribe; the amounts consumers pay per month for such capability; the 
actual data transmission speeds of such capability; the types of 
applications and services consumers most frequently use in conjunction 
with such capability; for consumers who have declined to subscribe to 
broadband service capability, the reasons given by such consumers for 
declining such capability; other sources of broadband service 
capability that consumers regularly use or on which they rely; and any 
other information the Commission deems appropriate for such purpose. 47 
U.S.C. § 1303(c). The Commission's Broadband Task Force is currently 
working to fulfill this requirement in coordination with the 
Commission's other broadband-related efforts. On March 31, 2009, the 
Commission issued a public notice that sought comments from 
stakeholders on how FCC should fulfill this requirement and currently 
has these comments under review. Comparison and Consumer Survey 
Requirements in the Broadband Data Improvement Act, Public Notice, 24 
FCC Rcd 3908 (2009) (BDIA Public Notice). 

[60] According to FCC, the registry will enable households to use the 
telephone, mail, e-mail, or the Internet to report apparent 
unavailability of broadband service for their location and information 
about existing service, such as the type and actual speed of Internet 
access service they use. FCC officials told us they are currently 
working to coordinate the development of the voluntary consumer 
registry for reporting broadband service information with efforts to 
fulfill its statutory broadband-related obligations. The Commission 
anticipates that it will implement the registry in conjunction with the 
other broadband-data-related efforts it is developing under the 
Broadband Data Improvement Act (BDIA) and the American Recovery and 
Reinvestment Act of 2009, Pub. L. No. 111-5, 123 Stat. 115 (2009) 
(Recovery Act). 

[61] Through its broadband reporting form, FCC collects from 
terrestrial mobile wireless broadband service providers the census 
tracts that best represent their broadband service footprint. 

[62] Michael J. Copps, Acting Chairman, FCC, Bringing Broadband to 
Rural America; Report on a Rural Broadband Strategy (May 22, 2009) 
(Rural Broadband Report), attached to Acting Chairman Copps Releases 
Report on Rural Broadband Strategy, Public Notice, DA 09-1211 (rel. May 
29, 2009). 

[63] 23 FCC Rcd 9691, 9702 (2008). 

[64] 22 FCC Rcd 7760, 7769-70 (2007); 23 FCC Rcd 9691, 9702 (2008); 
Inquiry Concerning the Deployment of Advanced Telecommunications 
Capability to All Americans in a Reasonable and Timely Fashion, and 
Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of 
the Telecommunications Act of 1996, as Amended by the Broadband Data 
Improvement Act, Notice of Inquiry, 24 FCC Rcd 10505 (2009); A National 
Broadband Plan for Our Future, Notice of Inquiry, 24 FCC Rcd 4342 
(2009) (National Broadband Plan NOI). 

[65] 47 U.S.C. § 1304. NTIA is carrying out this requirement for the 
Department of Commerce. The Broadband Data Improvement Act also directs 
the Secretary of Commerce, in consultation with FCC, to expand the 
American Community Survey (ACS) to elicit information for residential 
households, including those located on native lands, to determine 
whether persons at such households own or use a computer at that 
address, whether persons at that address subscribe to Internet service, 
and if so, whether such persons subscribe to dial-up or broadband 
Internet service at that address. 47 U.S.C. § 1303 (d). 

[66] Recovery Act, Section 6001(l). 

[67] See 74 Fed. Reg. 32545 (July 8, 2009) (Notice). 

[68] According to NTIA, all data provided in the first collection 
should be accurate as of June 30, 2009. 

[69] In response to concerns from broadband providers and related trade 
associations, NTIA issued a technical clarification to the notice of 
funds availability that revised the reporting requirements to census 
block rather than address-specific data and no longer required 
broadband providers to report average revenue per user or last-mile 
connection points. See 74 Fed. Reg. 40569 ( August 12, 2009) (Notice 
clarification). 

[70] The middle mile is the portion of the networks that leads from the 
first point of aggregation to the first point of interconnection. 

[71] 74 Fed. Reg. 46573 (Sept. 10, 2009)(NOFA clarification). 

[72] [hyperlink, http://www.gao.gov/products/GAO/GGC-99-139] and GAO, 
Tax Administration: IRS Needs to Further Refine Its Tax Filing Season 
Performance Measures, [hyperlink, 
http://www.gao.gov/products/GAO-03-143[ (Washington, D.C.: Nov. 22, 
2002). 

[73] 74 Fed. Reg. 32545, 32553, ftn. 27. 

[74] [hyperlink, http://www.gao.gov/products/GAO-02-372[. 

[75] According to OECD, reporting the number of broadband subscriptions 
in terms of households would be misleading because some connections 
reported by the countries are to businesses and normalizing subscribers 
as a percentage of total households would consistently overestimate 
broadband penetration. 

[76] George Ford, PhD; Thomas Koutsky; Esq.; and Lawrence Spiwak, Esq., 
The Broadband Performance Index: A Policy-Relevant Method of Comparing 
Broadband Adoption Among Countries (Policy Paper #29), Phoenix Center 
for Advanced Legal and Economic Public Policy Studies, July 2007, 8. 

[77] Federal Trade Commission Staff Report, Broadband Connectivity 
Competition Policy. Washington, D.C.: 2007. 

[78] Leonard Waverman and Kalyan Dasgupta, with assistance from 
Nicholas Brooks, Connectivity Scorecard 2009, 57. 

[79] Michela Nardo, Michaela Saisana, Andrea Saltelli, Stefano 
Tarantola, Anders Hoffman, and Enrico Giovannini, Handbook on 
Constructing Composite Indicators: Methodology and User Guide, OECD 
Statistics Working Paper, August 2005. 

[80] 12 FCC Rcd 9615 (2008). 

[81] 47 U.S.C. § 1303(b). 

[82] FCC seeks the cooperation of other foreign governments to compile 
the data in response to the international comparison requirement in the 
Broadband Data Improvement Act. Examples of the letter, such as this 
one sent to the government of Belgium on May 14, 2009, are available at 
[hyperlink, http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi] under GN 
Docket No. 09-47. 

[83] Comment Sought on International Comparison and Consumer Survey 
Requirements in the Broadband Data Improvement Act. Public Notice, 24 
FCC Rcd 3908 (2009) (BDIA Public Notice), available at [hyperlink, 
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-741A1.txt]. 

[84] Even though the literature review was limited to English-language 
documents, most reports focused on international comparisons are 
provided in English. 

[End of section] 

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