Garland McCoy: State Broadband Officials Must Be Prepared to Defend Deployment

Will you be prepared to defend your BEAD deployment at a future state or federal hearing?

Garland McCoy: State Broadband Officials Must Be Prepared to Defend Deployment
The author of this Expert Opinion is Garland T. McCoy. His bio is below.

The continuing lack of transparency, standards, and protocols in the Internet Service Provider “retail” broadband network marketplace (i.e., “last mile” networks) will once again result in an unchanged playing field when it comes to issues like waste, fraud, and abuse. Operating in the dark has its rewards.

It is instructive to note that ISPs operate in a transparent, standards and protocol based “wholesale” marketplace (Middle Mile, IXP/Peering) and that openness brings assurance to those who rely on them.   

With $42 billion of taxpayer dollars on the line, and millions of citizens still lacking broadband, now is the time to finally harmonize on a standards-based measurement protocol to provide for “apples to apples” validation of broadband quality of service, using defensible methodology to deliver much-needed transparency and stand up to the brightest public klieg lights and the inevitable aspersions from ISPs. 

Shifting the responsibility to states

NTIA’s BEAD program staff wisely shifted responsibility to the states, or more precisely to state broadband officials, to design and implement oversight and accountability programs for their BEAD-funded contracts. They did this knowing that the marketplace conditions mentioned above are still very much in place, despite the intent of the widely supported, bipartisan Broadband DATA Act signed into law in 2020.

Many state broadband officials have already been briefed by their technical advisors on how the lack of transparency, standards and regulations allow ISPs to “game” broadband testing. And these same officials and technical advisors also know that no big accounting firm audits will actually lead to accurately measured network performance improvements that are tied to BEAD contracts. Not one.

There is also the issue of plausible deniability. Since 2009, more than $90 billion of taxpayer dollars have already been spent in the U.S. to close the broadband gap, yet that gap is still breathtakingly large.

Therefore, it’s hard to say with a straight face that the types of excessive waste, fraud and abuse – often associated with markets that are not transparent, operate without governing standards and are lightly regulated – are not to blame in this case.

With this in mind, many state officials have concluded that unless they are able to produce their own independent validation, they will always be at a disadvantage, on defense, and in the dark.

PAgCASA transparently collecting broadband data

For the past five years, my colleagues at Precision Ag Connectivity & Accuracy Stakeholder Alliance (PAgCASA) and I have been collaborating with a wide range of telecommunications engineering experts from the private and public sectors, as well as from leading academic institutions.

Our goal has been to find an automated, standards based “tool” that would deliver true network transparency and “apples to apples” validation measurement data to state officials and citizens, using methodology that impartial academics and regulators can agree represents a best practice. 

Our efforts culminated late last year with a conversation I had with an old friend who happens to be the Executive Director of Packet Clearing House. PCH is the highly respected intergovernmental treaty organization responsible for providing operational support and security to critical Internet infrastructure around the globe, including the Internet exchange points where ISPs source the bandwidth that they sell to customers.

PAgCASA and PCH have now joined forces to advance a “transparency and measurement tool” based on principles discussed at the OECD Workshop “Internet performance measurement: Where do we stand and the road ahead,” held in Paris on April 22. 

This automated transparency and measurement tool includes “probes” measuring from customers’ locations to “targets” in the internet exchange points where the customer gets their bandwidth. It will be ready first quarter of 2025, in time for benchmarking BEAD-supported ISP networks and “middle mile.”

Our tool will also be in advance of contract expenditures for those state officials interested in a defensible BEAD oversight and accountability program for their state. 

To learn more about our tool, how it complies with FCC and Body of European Regulators for Electronic Communications best practices in network testing, how it will be able to provide both transparency and valuable measurement data on network performance over time, and to find out more about the work of the OECD in this area, visit PAgCASA’s  website.

And, if you think your state BEAD oversight and accountability program would benefit from our tool please contact me directly.

Garland T. McCoy, Co-Founder and Executive Director of Precision Ag Connectivity and Accuracy Stakeholder Alliance, is a long-time non-profit veteran in the fields of technology and telecommunication policy having served as Founder and CEO of the Technology Education Institute. Garland was recently an adjunct professor at Syracuse University’s iSchool, teaching information policy and decision making. This piece is exclusive to Broadband Breakfast.

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