HF Benchmark Statement v2

Statement of Harold Feld, Legal Director, Public Knowledge Before the Federal Communications Commission National Broadband Plan Workshop: Benchmarking September 2, 2009 Thank you for inviting me to speak today on the subject of necessary benchmarks for the National Broadband Plan. Rather than focus on specific benchmarks (although I intend to address some of these as well), I would like to focus primarily on the nature of 1the benchmarks required by ARRA for the National Broadband Plan and how the FCC can successfully monitor achievement against the benchmarks. Briefly: 1. ARRA requires an incredibly rich and complex set of benchmarks that include not merely traditional quantitative metrics such as deployment, but also qualitative metrics that ensure that all Americans receive the projected benefits from ubiquitous, affordable broadband access. In other words, the FCC should envision this not as a limited exercise in prodding the broadband marketplace, but an exercise in understanding and transforming the “broadband ecology” — by which I mean a recognition that broadband exists in a complex, interrelated system going well beyond producers and consumers, where these separate elements of the system all have different needs and responses, and where benchmarks must reflect this interrelation and complexity. 2. The FCC must examine whether to set benchmarks dynamically and with reference to each other, as well as absolutely. For example, the FCC ...