Comments to the National Telecommunications and Information Administration Regarding Project LEIA

Adoption is now the primary barrier to closing the digital divide.^[1] While deployment subsidies have been the bread and butter of broadband policy for decades, now that implementation of the National Telecommunications and Information Administration's (NTIA's) Broadband Equity Access and Deployment Program is underway, broadband policy must retool for a future that prioritizes adoption efforts to address the leading causes of Internet non-use rather than the dwindling problem of lack of deployment.^[2] Digital inclusion efforts that can address adoption gaps are necessarily more localized and not as susceptible to purely financial solutions; high-quality, localized data is essential to customizing effective policy solutions, but their complexity does not make them less valuable.^[3] Project LEIA is an excellent opportunity to move in the right direction, and we commend NTIA for this bold approach.

NTIA asks for potential applications of Project LEIA that would contribute to policy research and development, as well asways to improve these contributions in future iterations of LEIA. A central policy application of LEIA will be to enable identification of communities most in need of adoption support so policymakers and local communities can understand those needs, then tailor solutions to fit them. While this is a multifaceted question, one improvement to LEIA would be to present its findings in a comparable format to the FCC's Broadband Map and make the two interoperable. For example, an overlay of broadband adoption with broadband deployment with the same areas of analysis would allow policymakers to observe the extent to which deployment funding or pure adoption efforts should be a bigger priority.

NTIA should also examine broadband in the way that people use it, not based on outdated or arbitrary definitions. For example, focusing only on fixed broadband services offering at least 100 Mbps download and 20 Mbps upload speeds will skew the data since many Americans now use applications that never need such high throughput or use non-fixed broadband. Indeed, even bandwidth-intensive, real-time[1]services like video calls require far less than 10 Mbps upload.^[4] Those who successfully use a connection with only 10 Mbps upload speeds or use a low-earth-orbit satellite connection, for example, are not nonadopters, and digital inclusion policies that pretend otherwise will be ineffective and waste resources.

NTIA should also consider additional variables in future iterations of LEIA. The suggestion to apply "small area modeling to more detailed questions from the NTIA Internet Use Survey" is particularly important to that survey's questions about reasons for non-adoption. That modeling should be paired with more detailed questions on the Internet Use Survey itself to discover the reasons and meaning behind the large share of people who say they have "no need" or are "not interested" in subscribing to broadband.^[5] ITIF has proposed specific questions for use on the Internet Use Survey, and LEIA should also endeavor to gather similar data by all means available.^[6]

Another barrier to effective broadband usage is the quality of one's home network. Even if a household subscribes to broadband, its ability to realize the benefits of high-speed connectivity throughout the home will often depend on the quality of their Wi-Fi network. Consumers' sophistication with home networking options is likely to become a bigger bottleneck for connectivity as more and more devices compete for unlicensed spectrum. The quality of a home network is admittedly difficult to measure, but perhaps evaluating the age of network equipment sold in particular markets can give a directional indication of where home Wi-Fi is more or less sophisticated.

NTIA is right to make its adoption data more sophisticated. We look forward to working with NTIA to enable good data to form the basis of closing the digital divide.

Endnotes