Federal Communications Commission	FCC 20-94


STATEMENT OF
COMMISSIONER JESSICA ROSENWORCEL,
APPROVING IN PART, DISSENTING IN PART

Re: 	Establishing the Digital Opportunity Data Collection, WC Docket No. 19-195; Modernizing the FCC Form 477 Data Program, WC Docket No. 11-10.

In 1993 the novelist William Gibson is reported to have said “the future is here, it’s just not very evenly distributed.”  Recall at that time accessing the internet meant the hiss and ding of a dial-up modem, mobile phones were the size of a brick, and real bragging rights came with every visit to the world wide web.  But in many ways Gibson’s commentary is the most honest thing you can say about broadband today.  The future of broadband is here, but it’s not evenly distributed.  There are communities in this country with blazing fast gigabit speeds and areas where buffering means suffering and still others where there is no service to be found at all.  
The sad truth is that the Federal Communications Commission does not know with precision where these areas are.  We don’t know where broadband is and is not across this country.  We don’t know with accuracy what areas have wired service.  We don’t know with accuracy what areas have wireless service.  
If you think that’s crazy, you’re right.  We’re in this mess because for the last several years we have failed to put in place the kind of updated broadband collection that would yield accurate and honest data about where service is located.  The agency tried a year ago with its Digital Opportunity Data Collection but then nothing happened.  In fact, during the last three years we have made almost no changes to our data gathering process, despite pleas from consumers who are angry that our existing maps say they have service when they know all too well they do not, despite pleas from state and local officials that we have our facts wrong, and despite identical pleas from federal officials—including one cabinet secretary—who dismissed FCC maps as “fake news.”  
But no more.  That’s because Congress finally told us to clean up our act in the Broadband DATA Act.  So that is what we do here.  We implement this new law—and we mostly get it right.  We require carriers to produce granular data about where they are able to provide both wired and wireless services.  Then we commit to checking and validating this information, in part through the use of crowdsourcing.  This is smart because we are using the wisdom of the crowd.  There are people across the country who want to help and are willing to participate.  As we go forward, we need to make it simple for them as well as our state, local, and Tribal partners to do so.  To this end, our rulemaking asks important questions about how the challenge process will work and how we can offer technical assistance to those in need.  I am pleased it also asks about an idea I offered long ago—a pilot program to take advantage of existing services like postal trucks that crisscross rural communities every day and could help us perfect our new maps.  All in all, this is a big undertaking and we need to get working because statutory deadlines loom.  
But there is one thing we surely get wrong.  We are going to gather all of this precise data about where broadband is and is not, but we are not going to use any of it this fall when we distribute $16 billion in funding for improved broadband service across the country.  In fact, the way this works is that less than one week before the election the FCC will distribute 80 percent of these broadband funds for the next decade.  If you think that sounds irresponsible, you’re right.  Because when a major trade association studied the accuracy of our existing data and maps, it found an error rate of nearly two in five.  None of us would ever invest our own funds this way.  We shouldn’t be so cavalier with public dollars—especially when they are being spent to solve the digital divide and make sure the future is more evenly distributed.  
So we have this backwards.  We are giving out funding before rolling up our sleeves and doing the hard work to fix our maps.  In the end, that is my primary concern with our efforts today.  For too long we have accepted the fact that our data is wrong and ignored the fact that it limits our ability to target policy solutions effectively.  I appreciate that we make changes today.  But I regret that it took an act of Congress to force us to do so.  For these reasons, I approve in part and dissent in part.
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