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Re: Upcoming conference on "Broadband Census for America"
From: David Farber <dave () farber net>
Date: Sat, 9 Aug 2008 10:20:28 -0400

Begin forwarded message:

From: Brett Glass <brett () lariat net>
Date: August 8, 2008 11:17:06 PM EDT
To: "Drew Clark (Broadband Census)" <drew () broadbandcensus com>, dave () farber net
Subject: Re: [IP] Re: Upcoming conference on "Broadband Census for America"

At 11:25 AM 8/8/2008, Drew Clark (Broadband Census) wrote:

With respect to the issue data confidentiality, it's important to separate out several issues here:

(1) The names of carriers and the locations in which they offer services, by ZIP code.

(2) The number of subscribers that carriers have in a particular ZIP code.

The Form 477 of the Federal Communications Commission requires that carriers submit both types of information to the FCC.

I agree that category (2) may well be confidential information. I do not believe that category (1) can be considered confidential.

As a wireless ISP, I believe that the exact extent of my coverage is, and should be, proprietary information. Competitors -- especially large ones -- are capable of targeting consumers literally house by house, and certainly block by block.

The web site that I run, http://BroadbandCensus.com, is an attempt to combine information about broadband from various sources. In addition to "crowdsourcing" data from internet users, we are combining public information from the FCC's Form 477,

The FCC should not provide disaggregated information from Form 477, as this would allow the sort of anticompetitive practices I've mentioned. If you are in favor of widespread broadband deployment, competition, and choice, you should not attempt
to give large competitors tools with which to attack us.

It is important to note that Form 477 data released by the FCC does _not_ include the names of the carriers.

No, but this can be inferred easily.

Who would benefit more from public disclosure about the locations, technology types, promised speeds and prices: small carriers or big carriers? I don't know.

Brett clearly feels that small carriers would suffer. I know of others who disagree with him.

I would wager that they are large carriers.

With regard to the conference on September 26, 2008, that is being sponsored by BroadbandCensus.com, Carnegie Mellon University, the University of Texas at Austin's Robert S. Strauss Center, and the Virginia Tech eCorridors Program, we plan to make the list of our panel speakers available within the coming weeks. Although space on the conference agenda is tight, the program committee is open to including others.

The current agenda contains no one who is actually in the business of providing Internet service. This is a terrific deficiency. If you do not involve ISPs, discussion is pointless because there is no one there who is actually rolling out broadband. I would encourage you to add multiple ISPs -- not just one and not
just large ones -- to your agenda.

The goal of the conference, as stated on http://broadbandcensus.com/blog/?p=331 , is to "invite government officials, academic researchers and other key stakeholders to a half-day conference on collecting and sharing public data about high-speed internet access."

Are ISPs not "key stakeholders?"

With regard to issue of the Freedom of Information Act that Brett raises:

It is correct that an organization for which I previously worked -- the Center for Public Integrity -- filed a lawsuit seeking the disclosure of the Form 477 database. As the suit proceeding, the Center dropped its request for data in category (2), and instead sought the data in category (1).

The revelation of such data has no bearing on public integrity. Those bringing the lawsuit should also contemplate what would happen if such data was publicly available. I, for one, would expect to find myself in the crosshairs of marketing campaigns by Qwest, Bresnan Communications, third party DSL providers, and
companies attempting national wireless rollouts (e.g. Clearwire).

Perhaps if you pushed as hard to outlaw anticompetitive tactics as you are to obtain data which could (at the moment aid them), there would come a time when
we did not have to play our cards so close to our vest.

--Brett Glass

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