• by Wendy Davis  @wendyndavis, September 22, 2017

Mobile broadband service is complementary to wireline service, not a substitute for it, advocacy groups say in a new filing with the Federal Communications Commission.

"Like chocolate and peanut butter, fixed and mobile broadband are products that many people enjoy together," Public Knowledge, the Benton Foundation, National Consumer Law Center, National Hispanic Media Coalition and other groups write in a new FCC filing.

"The evidence shows that people can afford to typically purchase both products," the groups add. "It is not possible for a customer to 'switch' to a product she already has, and if two products were truly 'interchangeable,' no one would buy both."

The groups' comments come in response to an FCC notice soliciting public opinion for its upcoming Congressionally mandated report about the state of broadband deployment. In its notice, the FCC said it it may, for the first time, set benchmarks for mobile broadband service. The agency proposed defining mobile broadband as service at speeds of at least 10 Mbps downstream and 1 Mbps upstream. The agency also proposed retaining the standards for wireline broadband at the current speeds of at least 25 Mbps downstream and 3 Mbps upstream.

Among other questions, the FCC sought comments on whether it should evaluate fixed and mobile broadband "as separate and distinct ways to achieve advanced telecommunications capability."

The advocacy groups argue that any decision by the FCC to consider mobile broadband at 10 Mbps/1Mbps as a substitute for wireline service would render the annual report "less granular and less useful to the point of being actively deceptive."

"Congress intended the report to provide granular information on the nature of broadband deployment to all Americans, and ensure that all Americans have access to comparable broadband services," the groups write. "Rather than providing the detail and granularity Congress demanded by passing the BDIA, the Commission’s proposal would so obscure relevant information as to constitute an affirmative hindrance to the formulation of good policy."

In separate comments, New America Foundation's Open Technology Institute is urging the FCC to increase its benchmark for wireline networks to 50 Mbps downstream and 20 Mbps upstream. The group writes that emerging technologies like augmented reality and virtual reality will require significant bandwidth, and that the growing Internet of Things will also likely lead to increased broadband usage.

"People use their connections for many reasons, and often multitask," the group writes. "It is easy to see how multiple people with multiple devices engaging in multiple online activities on the same residential connections can quickly lead to buffering, slow load times, and frustration even with a 25/3 connection."