Google submits initial comments supporting a National Broadband Plan

Open, ubiquitous broadband connectivity holds the promise to catapult America to the next level of competitiveness, productivity, education, health, and security -- but how do we get there from here?

The American Recovery and Reinvestment Act (ARRA) of 2009 requires the Federal Communications Commission (FCC) to deliver to Congress a National Broadband Plan by February 2010. This represents a golden opportunity for policymakers and all Americans to take a hard look at the current state of broadband deployment and uptake, and begin laying the groundwork for a communications infrastructure truly capable of meeting the demands of the 21st century. Today Google submitted to the FCC our initial thoughts for how we might do just that.

As part of a comprehensive broadband policy framework, we believe that our government should adopt a bold yet achievable goal for making high-speed Internet capabilities available to each and every American. Our comments call for all American households to have access, by 2012, to at least 5 Mbps upload and download speeds over broadband. We believe that a 5 Mbps benchmark is an ambitious yet attainable first-step, and that even more challenging benchmarks with much higher capacity levels may well be necessary over the course of the next decade. If this benchmark is accomplished -- so that today's unserved or underserved consumers become tomorrow's broadband customers -- we will have truly become an always-on nation.

In addition to laying out a suggested public policy framework, our comments also describe four concrete proposals that we believe would help advance this vision:
  • Install broadband fiber as part of every federally-funded infrastructure project. By some estimates nearly 90 percent of the cost of deploying fiber is associated with construction costs like tearing up and repairing roads. The National Broadband Plan should require the installation of broadband fiber as part of all new federally-funded infrastructure projects. Laying fiber -- or even simply installing the conduit for later fiber deployment, as Rep. Anna Eshoo has suggested -- during the construction or repair of roads and other public works projects will dramatically reduce deployment costs. And it's just good common sense.
  • Deploy broadband fiber to every library, school, community health care center, and public housing facility in the United States. Low-income Americans are increasingly left out of the digital revolution. The National Broadband Plan should call for the deployment of high-speed fiber connections to every library, school, community health care center, and public housing facility in the country. This would create community hub centers nationwide, providing access to underserved populations and potentially acting as a springboard for more widespread broadband adoption in these communities.
  • Create incentives for providers to install multiple lines of fiber as new networks are rolled out. The Commission should offer incentives to providers wishing to build new network infrastructure to lay cable containing multiple fibers. These unused fibers could in turn be leased or sold to other network operators, increasing competition along with deployment.
  • Encourage greater wireless broadband and reduce barriers to deployment. Last November, the FCC paved the way for "white spaces" spectrum to be used to deliver better and faster wireless broadband connections to American consumers. The Commission should encourage use of unlicensed devices in "white spaces" spectrum by eliminating unnecessary requirements and easing interference standards in rural areas where no actual harmful interference would occur.
Our comments also note that using broadband as an optimal Internet platform will require both considerable focus and substantial resources, both private and public. In short, there is no "silver bullet" solution. Instead, some projects will depend on market forces and companies investing private capital to construct new infrastructure (like Verizon's FiOS platform), while others will require direct government involvement through subsidies or regulatory mandates. Still others will require a mix of public and private involvement.

In developing a National Broadband Plan, the FCC has the opportunity to embark on a fresh course to ensure our nation's digital infrastructure fully meets our 21st century opportunities and challenges.