Broadband mapping: be ready to augment & verify carrier data

12 Speaking at the recent Virginia Summit on Broadband Access, NTIA administrator Larry Strickling expressed confidence that broadband service providers will not only provide the detailed supply data requested by his agency, but also that carriers would waive the confidentially provisions that keep this data from being associated with specific companies.That sounds like a pretty “audacious” hope to me, though I certainly hope Mr. Strickling is correct.  But, just in case he isn’t, we at SNG suggest that states be ready to put together as much broadband data as they can without relying solely on carrier cooperation.

States and their broadband mapping contractors should, of course, work closely and in good faith with carriers to negotiate agreements and develop systems so carriers can provide the data elements set forth in the NOFA on terms that adhere to the document’s confidentiality provisions and that carriers find acceptable.

But we don’t think it’s wise for states to rely solely on carrier cooperation in the design and execution of their broadband mapping programs. As the NOFA makes clear ( see pg. 45), NTIA is asking for more detailed data than has ever been provided for a broadband mapping project.  The extent to which carriers will provide this data remains at best an open question.

In fact, as reported by the Dow Jones Newswire, several industry trade associations recently drafted a letter to Strickling expressing serious concerns about the scope, confidentiality and national security implications of the data sought by NTIA.

It may turn out that some carriers—especially the shrinking number of large carriers that serve most of the nation–will perceive the public interest goals of NTIA’s ambitious broadband mapping effort as too much at odds with their own self interests.  After all, these companies are managed to maximize shareholder value, with the public interest a secondary consideration, if at all.

In  a post at GigaOM, Stacey Higginbotham desccirbes the conflict between public and carrier interests:

“Carriers don’t want to share the data because then we’d know exactly how uncompetitive the market for broadband is in most areas of the country — and armed with that knowledge, the government may have to figure out what to do about it.”

This suggests a strategy in which state mapping programs include a strong multi-source data collection process that not only satisfies NTIA’s requirement for verification of carrier supplied data, but also can “fill-in” data if carries are either unwilling or unable to provide it.

We call this an “augment and verify” strategy.

According to a recent article at, Strickling may be thinking along similar lines:

If carriers refuse to comply with the imperatives for providing broadband data, Strickling specifically said, “There are other ways to collect this: there are survey techniques, and other ways to collect this information short of the carrier.” “We have appropriated $350 million” to this task, and “we are expecting the states to be creative, to be collaborative, to work together, and to find some new ways to collect the data, whether or not it is supplied by the carrier.” Strickling concluded: “Once that is made clear to them, at the most senior levels, then this thing will work itself out.”

As Strickling seems to be suggesting, the best way to get carrier cooperation may very well be for each state to gather as much broadband data as it can without relying on carriers, while continuing to invite their cooperation in a shared national effort to serve the public interest.  And, to maximize their chances of success, states should collaborate amongst themselves, sharing success strategies and lessons learned.

Based on past experience, it seems likely that, if we just hope “this thing will work itself out,” it won’t.  This is suggested not only by the recent draft letter prepared by industry associations, but also by the decades of success carriers have had in stonewalling (and/or suing) regulators to get their way.

But if we heed Strickling’s invitation to be creative and collaborative and “work together…to find…new ways to collect the data,” state and federal mapping efforts may yield the kind of public interest benefits targeted by NTIA and the Obama Administration.

As Art Brodsky noted on his blog at Public Knowledge:

“At the end of the day, somebody is going to be in control of the mapping. It will either be the public, and the public interest, as represented by NTIA, or the industry.”

What we’d add to Art’s comment is that, during the next two weeks, states will be making crucial decisions that reveal the extent to which they are committed to invest public funds in service of the public interest. Our suggestion to states as they evaluate the mapping options available to them: work respectfully with carriers to obtain data on mutually acceptable terms, but also have plans in place to augment and verify carrier-provided data.  If you don’t, you may end up with no leverage in dealing with carriers and no way to satisfy NTIA funding requirements for your mapping project.  If you do, you’ll be able to deal with carriers respectfully, but from a position of strength.  And you’ll have credibility with NTIA even if you fall a bit short of the agency’s ambitious data requirements.

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