Wireless RERC on the Record: Deployment of Advanced Telecommunications Capabilities

On October 5, 2017, the Wireless RERC submitted reply comments in response to the Federal Communications Commission’s Notice of Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion [GN Docket No. 17-199]. The Inquiry sought stakeholder input on a number of issues, not the least of which were considerations on how to evaluate and include (a) deployment and use of mobile services, (b) the demographic characteristics of unserved areas, and (c) deployment based on demographic characteristics, independent of geographical location. Reply comments supported and elaborated on initial comments submitted separately by the Colorado State Broadband Office (SBO), the Communications Workers of America (CWA), Public Knowledge, et al., National Electrical Manufacturers Association (NEMA), National Rural Electric Cooperative Association (NRECA), the Multicultural Media, Telecom and Internet Council (MMTC), and others. The Wireless RERC concurred with comments made in support of the need for both fixed and mobile advanced telecommunications services in a community to be considered reasonably and timely delivered. Regarding the hot-button topic, Public Knowledge, et al. poignantly stated that “Because consumers who can afford [emphasis added] both mobile and fixed connections typically purchase both, they should be seen as complementary, not substitute products, that the Commission measures separately…if two products were truly “interchangeable,” no one would buy both.^[1]”

Wireless RERC reply comments also addressed underserved populations and areas. Our knowledge of wireless technology access and the need for both mobile and fixed broadband to deliver robust services to people with disabilities led us to recommend that data be collected on availability and usage amongst people with disabilities. A successful broadband deployment and adoption strategy must take into account availability, affordability, and usability. Further compounding the issue, as it relates to rural areas, is that there is a higher prevalence of disability in rural America compared to urban areas.^[2]  Placing rural residents with disabilities in a double jeopardy with regard to access to broadband services and the benefits said access affords. That said, we agreed with recommendations to collect and report data on the demographic characteristics of unserved and underserved areas and specified that disability status be included as a variable.

Many more recommendations and comments were made regarding closing the digital divide, mobile edge content, accessibility, and affordability. To read the full document, select the following link: https://www.fcc.gov/ecfs/filing/1005674827669