[ NNSquad ] Broadband Mapping Fiasco

[Matt Larsen - Lists <lists@manageisp.com>]

I was on a conference call with the State of Nebraska broadband mapping 
contractors and the Public Service Commission this morning and came away 
with a bad feeling.

Based on the Form477 data, and the PSC's broadband provider registration 
information, there are 283 broadband providers in the state of 
Nebraska.  But they only have complete information for about 25, and 
signed NDAs from only 160.   I offered to them that they would have 
better luck getting data if they weren't asking for so much 
information.    The data template that they ask for includes:

1)  All subscriber addresses, and the type of broadband deployed at that 
location
2)  GPS coordinates for all of our tower locations, the types of 
antennas provided and the frequencies in use at that location
3)  Key "anchor institutions" that are receiving service from our system

I have had a couple of phone calls and several emails back and forth 
with the mapping subcontractors, and they (and the PSC) are still 
adamant about the data collection requirements.   I thought that we had 
negotiated to the point that they would accept a shape file of the 
coverage and a summary of the number of subscribers per census block, 
but the phone call this morning confirmed that incomplete data 
submissions (ones that do not include the tower verification information 
and subscriber information in the format that they requested) will not 
be included in the summary data, or the state broadband availability map 
that will be released to the public.

The contractors and the attorney for the PSC gave the indication that 
the NTIA is mandating this level of data collection, and that their NDA 
should be enough protection to ensure the safety of our proprietary 
information.   My position, and the position of the majority of WISP 
operators that I have visited with, is that I am not going to turn over 
the information that they are asking for.   Full disclosure of all my 
tower sites and the addresses of my customers is an onerous request and 
fundamentally unnecessary to determine where broadband coverage exists 
within the state.   I would prefer to run the risk of being overbuilt by 
a government funded program in the future than to turn over information 
to entities (NTIA in particular) that could be legally obligated to turn 
over that information through a FOIA request.

I don't know whether it is too late to push back at the NTIA to reduce 
the data that they are requesting.   I can sympathise to a certain 
degree with the PSC and the contractors, as they are just trying to 
collect the data that NTIA has mandated them to collect.  But they are 
simply asking for too much information.   In the end, it will be another 
inaccurate representation of broadband coverage and that information 
will be used to develop policy and programs that will make the 
competitive environment for WISPs and other independent ISPs even more 
difficult to succeed in.   That sucks.

Matt Larsen
vistabeam.com

 [ I am sympathetic to such competitive concerns when they do not
   directly impinge on the broader issues of the public interest.  At
   the very least I would urge that reasonable protection from misuse
   or abuse of the assimilated data should be a requirement for its
   collection.

   However, it's difficult to see how a reasonable understanding of
   existing broadband deployment can be made without knowing pretty
   precisely where existing services are installed -- street to
   street and even house to house differences can be important.
   
   And let's face it, various other entities are likely already going
   to have this detailed information from payment processing if
   nothing else, and their frequent "repurposing" of such consumer
   data is well known.  There are probably mailing list brokers ready
   to provide such info on demand -- I see incredibly detailed
   promotions from such guys all the time.

   Unwillingness to provide tower locations is even less supportable.
   These are using either licensed or public unlicensed
   spectrum, and are presumably out there in the real world for
   anyone to see if they know what they're looking for.

   This is all pretty basic stuff necessary to understanding what's
   going on with the provision of what has become critical infrastructure
   crucial to people's lives, and sooner or later it's going to be
   required reporting much like the requirements in other critical
   access and transportation areas.

   -- Lauren Weinstein
      NNSquad Moderator ]