NH Broadband Service Access

2021 NH Senate Bill 85 provides for matching grants to encourage broadband, but limits this to towns that do not have existing providers (even if such providers do not reach all locations or provide sufficient service.)

============

I support Senate Bill 85, but there is one critical wording/concept change I strongly encourage. This is to change “unserved areas” to “underserved addresses”, and encourage towns to define what sufficient upload and download service means in their local planning processes.

I’ve been researching and pursuing aspects of broadband residential computing for fifty years. This has moved from theory, to entertainment, to infrastructure. Towns need to determine how broadband will serve their planning, just as they evaluate roadways, transportation, electric, education, zoning and health care. Broadband provides tradeoffs in many of these areas that should be evaluated without state or FCC defined constraints.

The FCC currently defines “sufficient” as 25 Mbit down, 3Mbit up (25/3) with a single point of access in a census tract. This equates a block in Manchester with a hundred square miles in the North Country or miles of back roads in the White Mountains. The level of service needed in each of these areas, and viability of delivery methods will vary, and local political subdivisions need to make the decisions with respect to their needs and methods of provision. I am also supporting SB88 which brings critical clarity to determining what constitutes “service” in terms of location. While SB85 encourages gigabit broadband, it blocks this level of service by seriously constraining funding for competing, and in many areas, sufficient service. Incumbent suppliers with amortized facilities that have depended in the past on bundled entertainment and phone options have no incentive to invest in meeting the public need for universal affordable broadband at the same time their bundled services are being undermined by streaming services and cell phones. Even the FCC in its recent Rural Digital Opportunity funding set an effective minimum of 50/5 while encouraging 1000/500 (gigabit down.) We are likely to face a situation in the near future where our rural communities like Lempster, or Jaffery will have affordable gigabit broadband while our major cities remain trapped in the connectivity dark ages.

My professional society, IEEE (the world’s largest society for technical professionals) presented a webinar on broadband options with a focus on New Hampshire. This will not provide specific insight on the wording or funding issues before the General Court at this time, but will help members understand some of the options and future opportunities. This is available for viewing (2 hours) at: : https:/www.youtube.com/watch?v=Bnuesoqy158

Thank you for your attention and consideration.

======================

2021 Senate Bill 88 clarifies many key broadband factors. Most importantly, it calls for defining "service" in terms of what specific addresses are served within a community, not simply census tract access.

============

I strongly support SB88. In particular, it is essential to meet the objectives outlined in SB85 to “assure sufficient upload and download service” for all residents we need to assure political subdivisions have accurate information about the addresses being served, not just the areas being served.

I am a resident of Bedford, retired from thirty years In the computing industry with almost fifty exploring and enabling the pathways to residential broadband and personal computing. I currently present classes and chair committees as a volunteer that serve New Hampshire and beyond heavily dependent on broadband virtual and online community services. More on my background can be found at http://www.JimIsaak.com

When broadband was a luxury, having some vague concepts of access and service was a good start. Broadband is now an essential utility for education, employment, health care, civic engagement and of course the historical application of entertainment. Unfortunately, it is entertainment bundling that creates the market incentives to provide any services and as a result incumbent suppliers make the tradeoff between expanding their services or simply milking the cash-cows that their monopoly status and highly amortized investments provide. The migration of entertainment content to streaming creates additional disincentives for suppliers to release control of their monopoly status, or to engage in expensive expansion projects.

What has become clear, beyond the obvious transition of broadband to a public infrastructure necessity, is that the current FCC base line, used in RSA 38:38 to define broadband is not sufficient in many cases, and not available at many addresses. This definition fails in both ways. The FCC is currently reviewing its current “service areas” which are defined by a single point of access within a census tract. Such areas may be a block or two in a major city, hundreds of square miles in a rural area, or an access point many miles up mountain roads in the White Mountains. Also, the FCC currently depends on vendor claims of bandwidth, and even then considers 25 Mbit down, 3 Mbit up (25/3) as sufficient. It is relevant to note that the recent FCC Rural Digital Opportunity Fund essentially set a minimum of 50/5 and encouraged 1000/500 (Gigabit down) as evaluation criteria. Also, Comcast recently expanded their “Internet Essentials” low income service to 50/5 while limiting most customers with a monthly data cap.

It is essential that each town have the opportunity for local control of key “community characteristics” that we recognize already for school districts, road infrastructure and zoning. Some towns may find incumbent suppliers providing sufficient capacity to a sufficient set of addresses to meet their planning objectives. Others may set targets for broader access and higher service rates to balance between their planning objectives for industry, employees, education, transportation and other community defining characteristics. The current deference to the outdated FCC baseline for all New Hampshire towns is an inappropriate state constraint on local control. It also provides limited leverage or incentive for providers to actually partner with towns as opposed to stonewalling town objectives to maximize profits.

SB88 calls for more definitive mapping of service areas to specific address ranges, which is one essential step to allow towns to understand their current infrastructure status, and to articulate their objectives. It also provides incentives for current providers to be responsive in reporting their actual service areas and capabilities.

I would suggest replacing “unserved” with “underserved” in all related legislation, and specifically allow towns to define what sufficient service is as part of their planning and if needed funding proposals, with the FCC guidelines as a minimal, not a sufficient metric.

In early New England we had private toll roads and toll ferries. Over time it became obvious that most of these local monopolies interfered with commerce, and there existed a sufficient public good to warrant town/state ownership to meet the public needs. Today’s Internet providers and towns are at a similar junction. Except, the providers also control the delivery services over their toll roads, and provide competing services to other innovators who might bring better value to town residents. Finally, the town itself has need of open access to provide essential services such as education, access to jobs, and even access to this virtual committee meeting. While the long term best-practices for towns may not be clear, it is clear now that protecting monopolies that have very limited incentives to provide an essential public benefit is not the right road to follow at this time.

We have a cabin in the mountains where the local electric company is expanding fiber optic gigabit (1000/1000) service at a lower price than our current Bedford cable bill with 25/3. Partnerships in Lempster, Bristol and Jaffrey are targeting similar impact. We may face the irony that areas of New Hampshire able to meet the demands of 21^st century jobs are in the woods, while our cities remain in the broadband dark ages.