Our critique of the National Broadband Map, "Map to Nowhere," has caused quite a stir over at the Federal Communications Commission (FCC) and the National Telecommunications and Information Administration (NTIA). Yet the response from Steven Rosenberg, chief data officer with the FCC's Wireline Competition Bureau, offers PR spin and damage control rather than substantive ideas.
Mr. Rosenberg begins by saying that we "miss almost entirely the real story regarding broadband data and the FCC [and that] the National Broadband Map is the largest and most detailed map of broadband ever created." However, Mr. Rosenberg sidesteps our fundamental critique—if the map contains wrong data or excludes key information (for example, price), then it doesn't matter how large it is—a massive number of inaccurate details is no more helpful than a more modest heap of misinformation. While the map did get some things right, our critique is that the map is ineffective as a meaningful resource for U.S. residents.
Mr. Rosenberg states that we "omit any mention of the fact that the Commission sought public comment earlier this year ... including ... broadband prices, service quality, and adoption at a granular (census block) level"—a critique that parallels what Chairman Julius Genachowski's legal adviser, Zachary Katz, told us when we met with him in the chairman's office on May 21. In response to that meeting, we filed over 150 pages of data and information that we had previously filed with the FCC on this exact issue. In fact, we have been filing public comments to the NTIA and the FCC for years now and, as our filing from April 2009 makes clear, our critique (PDF) that the map must "provide the public with an easily-accessible, searchable, user-friendly database of information regarding the availability, price and speed of broadband services on a national scale" has been explicit from the very beginning. After years of working through official channels and participating in countless private meetings, only to see feedback from the public consistently ignored, we have become increasingly worried that Obama administration officials at the FCC and NTIA are creating a map that may become the epitome of regulatory puffery.
Misleading claims are increasingly being substituted for meaningful change to the map's methodology, as the FCC's official response exemplifies. Mr. Rosenberg's declares that "the map enables users to access information about broadband offers available locally—including price—by clicking through to providers' websites." Not only are the links the map provides no better than one would get from a quick Google search, Mr. Rosenberg fails to mention the warning this so-called "feature" carries every time you click on these links from the map: that the NTIA and FCC "are not responsible for the content of other websites, including their accuracy, completeness, or timeliness." In essence, the NTIA and FCC, rather than collect "accurate, complete, or timely" information, want the public to rely on information that they then feel compelled to publicly disavow, and then they call this a "feature." This is exactly the sort of half-measure we're raising public concern about. The fact that hundreds of millions of dollars were spent to bring us "features" like this should concern everyone.
NTIA and FCC officials are rightfully proud of the ability to download and use the data in the National Broadband Map, but because of the compromises NTIA has made, pricing information is not a part of the downloadable and mashable data sets. NTIA officials speaking on condition of anonymity in response to our article have told us that the decision to exclude pricing data from the map was made by NTIA Administrator Larry Strickling, possibly in response to pressure from Internet Service Providers seeking to keep this information from the public. Having worked with Mr. Strickling, we were stunned to hear this. A public commitment from Mr. Strickling addressing the question of how meaningful local-pricing data will be included in the map would go a long way to addressing this allegation. We're pleased that improvements to the map are forthcoming. As Mr. Rosenberg points out, "[T]he FCC has been working with a third party to collect what will likely be the largest and most robust data set on actual broadband performance in history—what speeds and how much latency do broadband consumers actually experience?"
This initiative, online at www.TestMyISP.com, is commendable, particularly since major Internet Service Providers have actively lobbied the FCC to prevent the public release of these and other broadband-mapping data, and we're glad to see the FCC highlighting this work as an exemplar. What Mr. Rosenberg fails to point out, however, is that five of the six core supporters of this project share many of our critiques of the National Broadband plan and one-half the supporting organizations are our own projects. For example, Measurement Lab (M-Lab) is a project we helped launch in 2009 and is an open, distributed server platform for researchers to deploy Internet measurement tools. The Test My ISP initiative uses M-Lab as its back-end infrastructure. In other words, Mr. Rosenberg is pointing at collaborations we set up as a solution to the problems we identified in the first place—which was one of the key points made in our original article.
The Test My ISP partnership is a great example of how the FCC should be moving forward. By collaborating with open data-collection platforms like M-Lab, the FCC can take a great tool for displaying data, the National Broadband Map, and add more meaningful information. As we mention in our article, we think these vital improvements will help ensure that the map is "an exemplar of government data transparency as well as an incredibly useful tool for U.S. residents and policymakers." Our article assesses the map today, highlighting both the poor quality and lack of important information that limits its utility. The National Broadband Map is a key opportunity for the leadership of the FCC and NTIA to demonstrate their gumption. The question is whether the Obama administration will make the long-called-for improvements to support the best interest of the general public or continue to bow to lobbying pressure from the Comcasts and AT&Ts of the world.