Federal Communications Commission	"FCC  XX-XXX"


STATEMENT OF
COMMISSIONER MICHAEL O’RIELLY

Re: 	Inquiry Concerning Deployment of Advanced Telecommunications Capability to All 
	Americans in a Reasonable and Timely Fashion, GN Docket No. 18-238, 2019 
Broadband Deployment Report.

This report fulfills our task mandated by Congress and I am pleased to support it.  To be clear:  according to our data collection, which has been rightfully criticized, approximately nine million Americans still lack access to even 10/1 Mbps service, and our finding here does not deny that point.  However, our statutory mandate is not only to determine whether all Americans currently have access to advanced telecommunications capabilities, but also whether progress in deploying such services is proceeding at a reasonable and timely pace, and an affirmative response to the latter inquiry is completely consistent with the facts on the ground.  I remain steadfast in my commitment to bringing access to those Americans currently without any broadband option at all and look forward to further actions by this Commission on this front, including, above all, the implementation of the Remote Areas Fund (RAF) auction in some form or fashion.  At the same time, there is no doubt that rapid and robust progress in deployment, particularly in the wireless space, is evident according to the albeit imperfect data we have.
Notwithstanding my overall support, I remain dismayed by the report’s reliance on purported “insufficient evidence” as a basis for maintaining—for yet another year in a row—an outdated siloed approach to evaluating fixed and mobile broadband, rather than examining both markets as one.  Data shows that fixed and mobile service are undoubtedly substitutable for many Americans and that fixed and mobile providers are in fierce competition with one another for customers.  According to a 2018 Pew Research study cited in this very record, one in five American adults have opted to subscribe exclusively to mobile service—a 7-point increase since 2015. Aaron Smith, Declining Majority of Online Adults Say the Internet Has Been Good for Society, Pew Research Center (April 30, 2018), http://www.pewinternet.org/2018/04/30/declining-majority-of-online-adults-say-the-internet-has-been-good-for-society/.
  Beyond the existence of cross-platform competition, fixed providers are increasingly entering the wireless market, and integrating their wired and wireless technologies with each other.  Given this new horizon of technological convergence, a siloed approach to fixed and mobile service makes even less sense.
Moreover, the report focuses shortsightedly on the limitations of mobile service, whereas, one could just as easily point to the limitations of fixed service in meeting the functionalities that customers value.  For example, why do we focus on the shortcomings of mobile service with respect to bandwidth capacity—which is especially absurd given consumers’ increasing reliance on mobile services for bandwidth-intensive applications like video-streaming—but ignore the shortcomings of fixed service with respect to flexibility and mobility?  Whether mobile and fixed serve interchangeable functions for every American for every potential use is immaterial for purposes of this report, and we should be evaluating both services from a technology neutral standpoint.  
Therefore, while I vote to approve, I express hope that by next year’s report, the Commission will have the requisite data to finally recognize marketplace and technological reality with respect to mobile broadband and evaluate the state of deployment in a more comprehensive manner.



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