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Christopher Mitchell: Brendan Carr is Wrong on the Treasury Department’s Broadband Rules

The Federal Communications Commission has no excuse for why the agency finished with the same bad data it started with.

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The author of this Expert Opinion is Chris Mitchell, director of the Community Broadband Networks Initiative at Institute for Local Self-Reliance

With all due respect to Federal Communications Commissioner Brendan Carrhis reaction to the Rescue Plan Act’s State and Local Fiscal Relief Fund (SLFRF) spending rules is way off base. As I wrote last week, the rules for broadband infrastructure spending are a good model for pushing down decision-making to the local level where people actually have the information to make informed decisions. (Doug Dawson recently also responded to Commissioner Carr’s statement, offering a response with some overlap of the points below.)

See Christopher Mitchell, Treasury Department Rescue Plan Act Rules Improve Broadband Funding, Broadband Breakfast, January 13, 2022

The Final Rule from the Treasury Department gives broad discretion to local and state governments that choose to spend some of the SLFRF (SLurF-uRF) funds on broadband infrastructure. The earlier draft of rules made it more complicated for networks built to address urban affordability challenges.

However, in coming out against the rules, FCC Commissioner Carr is giving voice to the anger of the big cable and telephone monopolies that cities can, after collecting evidence of need, make broadband investments even in areas where those companies may be selling services already. Commissioner Carr may also be frustrated that he has been reduced to chirping from the sidelines on this issue because the previous FCC, under his party’s leadership, so badly bungled broadband subsidies in the Rural Digital Opportunity Fund (RDOF) that Congress decide NTIA should administer these funds and have the state distribute them.

Nonetheless, the issues that Commissioner Carr raised are common talking points inside the Beltway and we feel that they need to be addressed.

Background Note

The failure of the FCC to assemble an accurate data collection is many years in the making. No single presidential administration can take the full blame for it, but each of them could have corrected it.

President Joe Biden’s FCC is not yet fully assembled because of delays in appointment and in Senate confirmation, but it would not be reasonable to lay blame on the current FCC for the failures discussed below. That said, it is not clear that we are on a course for having better maps and data that will resolve these problems anytime soon.

Commissioner Carr’s Criticism 

Commissioner Carr jumps immediately into the rural vs urban frame, suggesting that the Biden Administration could leave rural families behind by allowing local governments to invest in broadband in areas where an existing provider may already claim to offer service. Outlawing this practice – which he and others close to the largest cable and telephone companies call “overbuilding” – has been a major point for Republican FCC Commissioners.

  • Rather than directing those dollars to the rural and other communities without any Internet infrastructure today, the Administration gives the green light for recipients to spend those funds on overbuilding existing, high-speed networks in communities that already have multiple broadband providers. This would only deepen the digital divide in this country.

Pardon me? Logically, it is not clear what exactly Commissioner Carr is griping about here. Using Maryland as an example, if Baltimore is allowed to spend some of its funds to ensure unconnected families in public housing have high-quality Internet access, it is not clear that rural Garrett County in the western part of the state is harmed. Local governments do not receive different amounts of funds based on whether they spend it on broadband or other allowable expenses.

See Christopher Mitchell and other from the Institute for Local Self Reliance in the Broadband Breakfast Live Online for Wednesday, January 19, 2022 — The Community Broadband Network Approach to Infrastructure Funding

Broadband Breakfast on January 19, 2022 — The Community Broadband Network Approach to Infrastructure Funding

States could be the issue. Perhaps Commissioner Carr is concerned that Maryland will use some of its SLFRF money for broadband and it will spend too much in urban areas rather than rural regions. That would be an historical anomaly, even though there are far more people living in urban areas than in rural areas who are not on the Internet. And yet, nearly all state and federal dollars have gone to rural areas for infrastructure improvements, with very little being spent to help the low-income families left behind in urban areas. There is no history of states prioritizing urban investments over rural.

Bad Data, Srsly?

What I found really galling though was this bit:

  • It gets worse. The Treasury rules allow these billions of dollars to be spent based on bad data. It does this by authorizing recipients to determine whether an area lacks access to high-speed Internet service by relying on informal interviews and reports—however inaccurate those may be—rather than the broadband maps that the federal government has been funding and standing up

It is 2022. The FCC announced three weeks ago that it did not have a timeline for better maps.  Many of us have complained for more than 10 years about the misleading and inaccurate collection of claims that the FCC advances as its understanding of where broadband exists in the United States.

Commissioner Carr has been an FCC Commissioner for more than four years, nearly all of that time when his agency was run by a Republican. For part of that time, the Republicans controlled the Presidency, the House, and the Senate. They have no excuse for why his party’s FCC finished with the same bad data processes it started with. No one was defending the FCC data or maps during those years, but the FCC did not bother to begin collecting new data.

Now Commissioner Carr claims that “parts of this country” have broadband services at speeds near 100 Mbps down and 20 Mbps up. OK, Commissioner. Where? Do you have a secret list? No, these are talking points to obscure the fact that Commissioner Carr and his agency has utterly failed to track precisely what “parts of this country” actually has access to broadband.

Will I agree that most, perhaps 80 percent, of the country has access to 100 by 20 Mbps? Yes. But that doesn’t matter if no one can agree which homes are well-served. And it opens up a whole other set of questions that Carr neatly sidesteps, which is that contemporary broadband service goes beyond the academic question of whether an ISP provides that service most of the time at some price. If the price isn’t affordable, then there is a problem that needs to be addressed. Or as we like to say, if it’s not affordable, it’s not accessible. And, if the service is not very reliable, then there is a problem that must be addressed.

This is why the final rule is both necessary and good: because it allows communities the flexibility they need to address not just the gaps in infrastructure, but reliability and affordability as well. But of course Commissioner Carr should know that we do not have this information at the federal level, because I’m quite sure he opposes collecting pricing and other information. Despite the many instances in which providers have lied to the Commission in presenting the areas they offer service, Carr objects per se to local evidence gathered via interviews to understand where broadband actually is.

A Prediction: This Is Not A Problem

It is remarkable to see the amount of performative horror Commissioner Carr expresses at the prospect of a city like Baltimore using some of the Rescue Plan dollars to ensure its families in public housing are on the Internet, even if a cable provider could theoretically sell them Internet access for $75/month, or provide a subsidized service if they jump through all the right hoops. Compare that to the silence from the Commissioner when it became clear that the largest telephone companies took billions of dollars in broadband subsidies and might have forgotten to upgrade their services.

The SLFRF Treasury Rules give the appropriate amount of deference to local and state leaders to act in an utter void of information about what is available to each home. Commissioner Carr is deeply worried – because the largest cable and telephone companies are deeply worried – that some places will use these dollars to build networks that are unneeded or would create too much competition for the existing companies.

My prediction is that communities will not do this. Of course it’s not zero: a cardinal rule of dealing with large numbers of humans is that there are always outliers. But of the cities that allocate some of their SLFRF dollars to broadband infrastructure, they will overwhelmingly focus on areas where there are real affordability and reliability challenges from existing services. The reality is that very few of these investments will result in any material losses to existing ISPs, but the monopoly providers know that even modestly opening the door to locally built and operated infrastructure driven by community-driven solutions could open the floodgates to the competition they fear so much.

Commissioner Carr has spent years as one of a very small number of people that could correct the abject failure of the FCC to collect useful information about broadband deployments. The rest of us have had to move on and figure out how to work in the absence of data. The best option is to allow for local decision-making where they can collect evidence and act. And most importantly, they will have to take responsibility for their actions and lack of action in ways that FCC Commissioners often do not.

Editor’s Note: This piece was authored by Christopher Mitchell, director of the Institute for Local Self Reliance’s Community Broadband Network Initiative. His work focuses on helping communities ensure that the telecommunications networks upon which they depend are accountable to the community. He was honored as one of the 2012 Top 25 in Public Sector Technology by Government Technology, which honors the top “Doers, Drivers, and Dreamers” in the nation each year. This piece was originally published on MuniNetworks.org on January 20, 2022, and is reprinted with permission.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

Broadband Breakfast is a decade-old news organization based in Washington that is building a community of interest around broadband policy and internet technology, with a particular focus on better broadband infrastructure, the politics of privacy and the regulation of social media. Learn more about Broadband Breakfast.

Expert Opinion

Rahul Sen Sharma: The Metaverse is Not Web 3.0

The Metaverse is at the forefront of developments in seamless payments and richer information flows.

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The author of this Expert Opinion is Rahul Sen Sharma, managing partner at Indxx.

Web 3.0 is a concept for the next generation of internet architecture that envisions a decentralized ecosystem based on blockchain technology. It is an evolution of how users would control, own, and manage their online content, digital assets and identities.

Web 3.0 marks a departure from the centralized mega platforms and corporations that currently dominate the Web 2.0 ecosystem.

The Metaverse is at the forefront of the Web 3.0 internet revolution. It can be defined as a set of interconnected, experience driven 3D virtual worlds where users can socialize in real-time to form a persistent and thriving user-owned internet economy regardless of any physical or geographical constraints.

Both the technologies of Web 3.0 and Metaverse support each other perfectly. Even though the Metaverse is a virtual space whereas Web 3.0 favours a decentralized web, it could form the basis for connectivity in the Metaverse. While the development of the Metaverse is in nascent stages, the exponential growth of non-fungible tokens, P2E (Play to Earn) games and decentralised autonomous organisations have boosted the development of Web 3.0.

A future involving distributed and anonymous users

Web 3.0 envisions a future involving distributed anonymous users and machines interacting without the need for an intermediary, to form a composable human-centric and privacy preserving computing fabric.

These interactions would range from seamless payments and richer information flows, to trusted data transfers via a mechanism of peer-to-peer networks without the need for third parties.

The shift should lead to a wave of new business models that bypass the existing global co-operatives that we currently have, and replace them with decentralised, autonomous organisations and self-sovereign data marketplaces.

As mentioned, Web3 is built on blockchain technology and DAOs rather than the current model of centralized servers owned by large corporations. In the same way, the ideal structure of the Metaverse is also full decentralisation.

The technologies behind achieving decentralization would be distributed ledgers and blockchain technology which enables value-exchange between softwares, self-sovereign identities and the creation of a transparent and secure environment.

The blockchain is central to the Metaverse, and to Web 3.0

In an ideal form, both Web 3.0 and the Metaverse takes advantage of blockchain to give unrestricted, permissionless access to everyone with an internet connection.

Currently, development towards the Metaverse is being spearheaded by big tech corporations such as Meta, Microsoft, Nvidia, and more, all of which are major players in Web 2.0. The model of centralised Metaverse being built by them involves closed ecosystems that are only designed to extract value at the expense of their most valuable assets – users, content creators and customers.

This contrasts with the envisioned form of Metaverse and Web 3.0 with decentralization, interoperability and seamless interaction between different virtual worlds and the real world.

Still, the big tech corporations are investing resources into their Metaverse development and have their own vision and plans for what the Metaverse would be.

Meanwhile, decentralized Metaverses and Web3 initiatives are currently attracting record investment, pulling in around $30 billion in venture capital last year alone.

As we shift to what will likely be a more decentralized web, the creator economy is also evolving and likely to become a multibillion-dollar industry with immense potential for creators and publishers.

The creator economy in the Metaverse can supplement the vision of web 3.0 for developing a new financial world with decentralized solutions.

In Web 3.0, users can create content while owning, controlling, and monetizing them through the implementation of blockchain and cryptocurrencies. However, the model of this creator economy is likely to disrupt the business models of many current big-tech corporations.

Regardless, the Metaverse requires both big tech companies to build the technology and the creator economy to produce interesting content for driving engagement. Partnerships, reduced platform fees and creative commissions by big tech to creators within the metaverse can be a way to stimulate the already fast-growing creator economy.

Rahul Sen Sharma is a managing partner at Indxx and has been instrumental in leading the firm’s growth since 2011. He manages Indxx’s Sales, Client Engagement, Marketing and Branding teams while also helping to set the firm’s overall strategic objectives and vision. Prior to joining Indxx, Rahul was the Director of Investment Research for RR Advisory Group (now part of Mariner Wealth Advisors), a full service private wealth management firm based in New York that caters to high net worth individuals. This piece is exclusive to Broadband Breakfast.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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Digital Inclusion

W. Antoni Sinkfield: To Succeed in 21st Century, Communities Need to Get Connected Now

One of the primary responsibilities of being a faith leader is to listen to your community and understand its problems.

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The author of this Expert Opinion is Reverend W. Antoni Sinkfield, Associate Dean for Community Life at Wesley Theological Seminary.

One of the primary responsibilities of being a faith leader is to listen to your community, understand its problems, and provide support in challenging times. Particularly during the pandemic, it has been hard not to notice that my parishioners, and folks across the country, are divided into two groups: those with access to the internet, and those without.

In 2022, digital inclusion is still something we strive for in poor and rural areas throughout America. The lack of reliable internet access is an enormous disadvantage to so many people in all facets of their lives.

To fully participate in today’s society, all people, no matter who they are and no matter where they live, must have access to the internet. Think of the remote learning every child had to experience when schools were closed, and the challenges that families faced when they didn’t have access to a quality connection.

It’s a question of plain fairness.

Politicians have been talking for decades about bringing high-speed internet access to everyone, however many families continue to be left behind. More than 42 million people across the country lack affordable, reliable broadband connections, and as many as 120 million people who cannot get online are stuck with slow service that does not allow them to take advantage of everything the internet has to offer.

People of color are disproportionately affected by lack of broadband access

Lack of broadband disproportionately affects communities of color, as well: 35 percent of Americans of Latino descent and 29 percent of African-Americans do not have a broadband connection at home.

Every person in rural towns, urban neighborhoods, and tribal communities needs and deserves equal and full economic and educational opportunities. Studies show that students without home access to the internet are less likely to attend college and face a digital skills gap equivalent to three years’ worth of schooling. Small businesses, which are the cornerstone of rural and urban communities alike, need broadband to reach their customers and provide the service they expect.

Simply put, having access to the internet in every community is vital to its ability to succeed in the 21st century.

Fortunately, we have an opportunity to take major steps toward a solution. Last year, Congress passed President Biden’s Infrastructure Investment and Jobs Act, which provides $65 billion to expand broadband access and affordability. It is essential that we use this money to connect as many unserved and underserved communities as we can – and as quickly as we can.

Different places need different options to bridge the digital divide

As we bridge the digital divide, we must listen to those who have been left behind and make sure that we deploy solutions that fit their needs. Different places need different options – so it’s important that all voices are heard, and the technology that works best for the community is made readily available.

All people need access to broadband to learn, work, shop, pay bills, and get efficient healthcare.

When I talk to my parishioners, they speak about how much of their lives have transitioned online and are frustrated about not having reliable access. They do not care about the nuances of how we bring broadband to everyone. They just want to have it now – and understandably so.

This means that we must explore all solutions possible to provide high-speed broadband with the connection and support they need, when they need it, regardless of where they live.

Now is the time to meet those struggling where they are, stop dreaming about bridging the divide, and just get it done. Our government has a rare opportunity to fix an enormous problem, using money already approved for the purpose. Let’s make sure they do so in a manner that works for the communities they’re trying to help.

Rev. W. Antoni Sinkfield, Ph.D., serves as Associate Dean for Community Life at Wesley Theological Seminary, and is an ordained Itinerate Elder in the African Methodist Episcopal Church. This piece is exclusive to Broadband Breakfast.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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Broadband Mapping & Data

Bryan Darr: Federal Broadband Funding is Available for Local Governments

Ookla can help your community get the funding you need to provide access for all to the digital economy.

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The author of this Expert Opinion is Bryan Darr, vice president of Smart Communities at Ookla.

Local governments, the clock is ticking.

The Infrastructure Investment and Jobs Act set billions of dollars out on the infrastructure buffet table for local governments in the United States and there are more guests invited to the party than ever before.

This funding is almost certainly a once-in-a-lifetime opportunity to connect your community and provide access for all to the digital economy. The question is: will you be at the front or the back of the line?

Ookla can help you. This article is designed to give you the information you need to get started on the path toward getting the funding you need for your communities.

Look to your state for funding

Historically, broadband funding has had a very top-down approach.

The Federal Communications Commission has held almost all the power to determine where federal broadband infrastructure dollars have been spent. But for the first time, state governments will have an active role in guiding these decisions.

The Infrastructure Investment and Jobs Act directs $65 billion to improving broadband connectivity across the U.S., with $42.45 billion earmarked for building new infrastructure.

Once the initial FCC map has been released, each state that has declared their intent to participate through National Telecommunications and Information Administration will be provided a minimum $100 million to get the process started (U.S. territories will split an additional $100 million).

Much of the remaining $22 billion will target affordability, but more on that later.

The race for resources will be officially off and running.

Following this initial disbursement, there will be roughly $37 billion more to be awarded from the IIJA alone.

Many states are still sitting on billions of dollars from the American Rescue Plan Acts and broadband is an allowable expenditure for these remaining stimulus dollars.

Add to that the long running connectivity programs such as Connect America Fund, Rural Digital Opportunity Fund, Mobility Fund and the upcoming Rural 5G Fund, and all those programs combined approach $100 billion over the next decade.

Plan ahead to increase your competitiveness

Past programs have provided funding without setting proper expectations on results. More emphasis is now being placed on planning.

With a focus on estimated cost per service address, network design takes a front seat to ensure these resources are spent efficiently and state officials will be allowed to use up to five percent of this for mapping, designing, and cost estimation.

Most states are already planning, or already building, their own broadband availability maps. But if you have connectivity issues in your community, it’s time to make it known to those who will be responsible for directing funds and deciding which communities will see investment and which will not.

Ookla helped Loudoun County, Virginia secure $17 million

We have experience helping local governments navigate this challenging planning process.

When FCC Form 477 broadband availability data showed that nearly 100% of Loudoun residents have access to what the FCC defines as broadband (25 Megabits per second (Mbps) download, 3 Mbps upload), this was inconsistent with the connectivity experiences of county residents.

So the Loudoun Broadband Alliance chose to use Ookla Speedtest Intelligence® to create an accurate and reliable broadband access mapping methodology using real-world network performance data.

With this data, LBA identified a large number of unserved households in contrast to FCC data which showed them as served. Loudoun County was subsequently awarded over $17 million of funding to help eliminate the broadband gap.

Keep in mind that the maps will never be finished. They will change and evolve as the networks in your area grow.

Funded projects will need to be monitored for compliance and older networks will need to be watched for signs of deterioration. Everyone will need to keep an eye on progress, measure successes, and have the data to act early when projects go off track.

Acadiana, Louisiana used Speedtest data to win $30 million

With Speedtest data, the Acadiana Planning Commission was able to successfully challenge FCC maps on over 900 out of approximately 1,000 census blocks.

The APC applied for funding through the NTIA Broadband Infrastructure Program, which made $288 million in funding available to help close the digital divide in the U.S.. There were over 230 applicants, and only 13 grants were awarded.

Vice President Kamala Harris visited Acadiana in March to announce that the APC had been awarded a $30 million grant that will fund high-speed internet in 11 rural Acadiana communities.

Think big! Broadband funding is available for more than just infrastructure

Accessibility to broadband requires at least four components: infrastructure, affordability, equipment, and knowledge. The lack of any one of these means an individual does not have access to today’s digital economy.

Much of the focus has been on the lack of infrastructure in many rural communities, but infrastructure is the absolutely essential piece for anyone in any community to get connected.

The second component, affordability, often drives the last two requirements as people who cannot afford internet service often cannot afford the necessary equipment and, therefore, are less likely to have developed the knowledge to use it.

Tracking both of these two primary elements is key to understanding the digital divide.

You might qualify for funding in more than one of these four areas. For example, over $14 billion in a new Affordable Connectivity Program is included in the broadband portion of the IIJA.

Remaining funds include $2.75 billion for the Digital Equity Grant Program and the $2 billion Tribal Broadband Connectivity Program, as well as two more programs that will assist the USDA improve the internet in agricultural communities.

Agencies and local governments should work together

Cities should be coordinating with counties and other government entities within the same region — but someone needs to be in charge.

If your local government does not have an individual charged with coordinating all these efforts, there is bound to be duplication of efforts, wasted resources, stagnation of ideas, or all of the above.

Whether this person reports directly to the chief technology officer, chief information officer, mayor, or city manager, their purpose is to understand what all departments are doing in the space and coordinate discussions, grant opportunities, and overlapping initiatives to make sure that departments aren’t working at cross purposes.

Non-profits, community activists, and local corporations all have a stake in the success of these efforts.

Traffic problems won’t suddenly end at the municipal boundary. Improving traffic on one side of the line may create more problems on the other side. Working together with your neighbors is just as important as working with internal departments. The same can be said of both fixed and wireless broadband infrastructure.

Dig-once projects will score extra points in the competition to have projects selected.

Broadband is only part of the $1.2 billion infrastructure law. Roads, bridges, ports, and rail have billions of dedicated dollars as well.

Digging a new trench for a clean water system? Coordinate with the project to include conduit and fiber and your efficient use of taxpayer funds will likely be rewarded.

Consider funding for multiple technologies

As great as it might be to provide every service address in the country with a fiber connection, it may not make economic sense in some places.

But an important detail was clearly stated in the legislation that recognizes a technology neutral stance on solutions.

The rules are not yet complete on how the FCC and NTIA will award the IIJA funds and contend with challenges to their findings, but there are certainly far fewer restrictions on the ARPA funds that are already disbursed to the states. Many connectivity projects are already underway whether through infrastructure development, equipment distribution, or subsidies for affordable service.

Wireless services can get people connected much faster and there are several forms.

Traditional mobile operators are rolling out 5G and Fixed Wireless Access in some areas that can directly compete with traditional fixed services. Wireless internet service providers have launched coverage to homes and businesses that previously had satellite as their only option.

Some municipalities and school systems have launched private 4G LTE networks to connect underserved areas in their communities. And municipal Wi-Fi can still be an important part of an overall solution.

A portion of families may never find subscribing to a fixed network practical, but wireless services allow for easier movement and some don’t even require a residence. Understanding wireless network availability and performance across your jurisdiction is just as important as planning a fiber network.

And here’s a bonus — cellular and other transmission sites need fiber for any new 5G cell site. So if you know where your wireless networks need additional infrastructure, you can plan for places in the network to offer them accessible fiber connections.

If your state still has ARPA funds available, you still have an opportunity to make improvements and learn more about connectivity issues so you are better able to make your case for the IIJA funds as they begin to flow.

Ookla can provide you with the data you need to be competitive for federal funding

It has been said for years that broadband is the fourth utility.

Local governments have spent a lot of their resources managing the first three: water, gas, and electricity.

If any of those become unavailable, even for a brief period of time, their citizens will make their unhappiness known. Resiliency of these services will play a part in how elected officials are judged, whether the local government supplies these services or just manages an external provider.

If you serve in local government, you should anticipate the same expectations going forward for broadband in your community.

The internet has become vital to the way we live our lives, and access to it dictates much of our success both as residents and businesses. Recognizing connectivity as a critical service may have been a consequence of a pandemic, but that change in thinking is here to stay.

That’s why Ookla is here to help you learn more about the connectivity in your area.

We’ve already helped local governments secure tens of millions of dollars in federal funding in Loudoun County, Virginia and Acadiana, Louisiana. We are also working with state broadband offices as well as municipalities to help them gain visibility into network availability and performance.

If you want your community to take advantage of the billions pouring into improving connectivity, get in line before it’s too late.

Drawn from billions of Speedtest results, Ookla’s Broadband Performance Dataset provides governments, regulators, ISPs, and mobile operators with insights about the state of fixed networks and broadband accessibility. The Broadband Performance Dataset helps you identify unserved and underserved areas, prioritize investment opportunities to improve access to broadband, challenge funding decisions, and secure grants.

To learn more about the Broadband Performance Dataset, Speedtest Intelligence, and other solutions for your state and/or local governments, please contact us.

Bryan Darr is the Vice President of Smart Communities at Ookla. He coordinates Ookla’s outreach to local, state and federal governments and serves on CTIA’s Smart Cities Business & Technology Working Group. This piece was first published on Ookla’s web site, and is reprinted with permission.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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