GAO 

United States Government Accountability Office

Report to Congressional Committees

October 2009 TELECOMMUNICATIONS 

Current Broadband 

Measures Have 

Limitations, and New 

Measures Are 

Promising but Need 

Improvement 

GAO-10-49 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

October 2009

TELECOMMUNICATIONS

Current Broadband Measures Have Limitations, and 

New Measures Are Promising but Need Improvement 

Highlights of GAO-10-49, a report to 

congressional committees 

The Broadband Data Improvement 

Act, enacted in 2008, established a 

variety of initiatives intended to 

improve the quality of state and 

federal data on broadband (i.e., 

high-speed Internet) services and 

promote the deployment (the 

building of infrastructure over 

which broadband services can be 

provided) of affordable broadband 

services to all parts of the nation. 

The act required GAO to conduct a 

study to consider and evaluate 

additional broadband metrics or 

standards. This mandated report 

addresses (1) the measures 

generally available to consumers, 

industry, government and others, 

and (2) the limitations, if any, of 

the measures and how they could 

be supplemented or improved. To 

identify and evaluate the measures, 

GAO conducted a review of 

literature and related laws and 

interviewed and reviewed related 

documentation from stakeholder 

groups. 

What GAO Recommends

To increase the data quality and 

subsequent results from the State 

Broadband Data and Development 

Grant Program, GAO recommends 

that the Secretary of Commerce 

examine the results of data 

collection and determine whether 

to develop specific guidance for 

grantees to improve the 

consistency and accuracy of the 

data collected under the program. 

The Department of Commerce 

generally agreed with GAO’s 

recommendation and stated it had 

begun taking actions to address the 

recommendation. 

Multiple measures are generally available to consumers, industry, and 

government to assess broadband performance. Consumers can generally 

access measures of availability, price, advertised speed, and actual delivered 

speed from providers and third parties to compare services. Industry and 

government also have access to some measures that enable comparisons 

across segments of the United States to inform policy and guide investment. 

For example, the Federal Communications Commission’s (FCC) data from its 

semiannual reporting requirement for providers are the primary source for 

comparing the availability of and subscribers to broadband. Through a 

literature review and interviews with stakeholders, GAO focused on 10 

measures that can be used to make international comparisons of broadband 

service to inform policy. Eight were composite indexes that are generally used 

to account for factors such as demographic and economic differences among 

countries, which, according to stakeholders, can affect broadband 

deployment and penetration (the number or percentage of subscribers per 

capita or per household). 

Through available documentation and discussions with stakeholders, GAO 

found that current measures have limitations, views were mixed on potential 

alternatives, and ongoing efforts need improvement: 

• According to some stakeholders, the lack of comprehensive measures 

from the government to compare price, actual delivered speeds, and 

service reliability data from providers is a limitation for consumers. FCC 

has open proceedings on requiring providers to report such information, 

but there was no consensus among stakeholders on the need for 

additional reporting requirements and measures. 

• Stakeholders told GAO that FCC’s semiannual data collection from 

providers does not include information on availability, price, or actual 

delivered speeds, which limits the ability to make comparisons across the 

country and inform policy or investment decisions. Stakeholders generally 

agreed that the Department of Commerce’s effort to develop a national 

broadband inventory map through its State Broadband Data and 

Development Grant Program would address some gaps and provide 

detailed data on availability, subscribership, and actual delivered speeds, 

but the department did not provide guidance to grantees on calculating 

actual delivered speeds or specific standards to verify the data collected. 

This could result in inconsistent data and limit the effectiveness of the 

effort. GAO has previously reported that consistency and data verification 

are important for reducing the risk of producing inaccurate data. 

• Finally, the measures used for international broadband comparisons have 

limitations for a variety of reasons, including socioeconomic differences 

that make the comparisons difficult. Despite the concerns, stakeholders 

found the measures useful to help inform policy. Stakeholders generally 

supported FCC’s efforts to develop international comparisons because the 

comparisons will be at a local level within each country, and could 

provide more relevant information.

View GAO-10-49 or key components.

For more information, contact Mark Goldstein 

at (202) 512-2834 or goldsteinm@gao.gov. 
Page i GAO-10-49 Telecommunications 

Contents 

Letter 1

Results in Brief 3 

Background 7 

Multiple Measures Are Available for Consumers, Industry, 

Government, and Others to Assess Broadband Performance 16 

Stakeholders Reported Limitations with Current Broadband 

Performance Measures, but Views Are Mixed on Potential 

Alternatives and Ongoing Efforts Need Improvement 25 

Conclusions 43 

Recommendation for Executive Action 44 

Agency Comments 44 

Appendix I Scope and Methodology 45 

Appendix II Comments from the Department of Commerce 48 

Appendix III GAO Contact and Staff Acknowledgments 49 

Tables 

Table 1: U.S. Ranking in International Broadband Performance 

Comparisons 24 

Table 2: Broadband Performance Measures Proposed by 

Stakeholders 28 

Table 3: Stakeholder Arguments for and against Proposed 

Measures 29 

Table 4: Stakeholders Interviewed 46 
Abbreviations 

3G third generation 

ADSL asymmetric digital subscriber line 

BAI Broadband Adoption Index 

BPI Broadband Performance Index 

BQS Broadband Quality Score 

CRS Congressional Research Service 

DSL digital subscriber line 

EIU Economist Intelligence Unit 

FCC Federal Communications Commission 

FTC Federal Trade Commission 

GDP gross domestic product 

ICT information and communications technology 

IDI ICT Development Index 

IEEE organization previously known as the Institute of Electrical 

 and Electronics Engineers, Inc. 

ITIF Information Technology and Innovation Foundation 

ITU International Telecommunications Union 

Kbps kilobits per second 

Mbps million bits per second 

MIT Massachusetts Institute of Technology 

NRI Networked Readiness Index 

NTIA National Telecommunications and Information 

 Administration 

OECD Organisation for Economic Co-operation and Development 

OPASTCO Organization for the Promotion and Advancement of Small 

 Telecommunications Companies 

OSTP Office of Science and Technology Policy 

TPI Technology Policy Institute 

Wi-Fi wireless fidelity 

WiMax Worldwide Interoperability for Microwave Access 

WISPA Wireless Internet Service Provider Association 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately. 

Page ii GAO-10-49 Telecommunications 
Page 1 GAO-10-49 Telecommunications 

 

United States Government Accountability Office

Washington, DC 20548 

 

October 9, 2009 

The Honorable John D. Rockefeller, IV 

Chairman 

The Honorable Kay Bailey Hutchison 

Ranking Minority Member 

Committee on Commerce, Science, and Transportation 

United States Senate 

The Honorable Henry A. Waxman 

Chairman 

The Honorable Joe Barton 

Ranking Minority Member 

Committee on Energy and Commerce 

House of Representatives 

Universal access to the Internet via broadband technologies—commonly 

referred to as broadband Internet access—is commonly viewed as a vital 

public infrastructure and a key driver of economic growth. For example, 

broadband technology makes it possible for patients to receive medical 

attention from specialists hundreds of miles away, students to access 

information not available from their local libraries, school systems to use 

one teacher to teach students in multiple schools, and small businesses to 

advertise and market their products and services to attract customers.1

The Broadband Data Improvement Act, enacted in 2008, established a 

variety of initiatives intended to improve the quality of state and federal 

data on the availability and quality of broadband services, and promote the 

deployment of affordable broadband services to all parts of the nation. 

The act required GAO to conduct a study to consider and evaluate 

broadband metrics or standards that may be used by industry and the 

federal government to provide consumers with better information about 

the cost and capability of their broadband connection, and compare the 

deployment (the building of infrastructure over which broadband services 

1

The term “broadband” commonly refers to high-speed Internet access. Broadband enables 

consumers to receive information much faster than a dial-up connection and provides an 

“always on” connection to the Internet. Consumers can receive a broadband connection 

through a variety of technologies such as cable modem, digital subscriber line service, 

fiber, and satellite. These technologies are described in more detail later in the report. 
 

can be provided) and penetration2 of broadband across the United States 

and among other countries.3

Various policy makers believe that disparities in broadband access across 

the United States, including rural areas, could have adverse consequences 

for unserved or underserved populations.4

 In the Telecommunications Act 

of 1996, the Federal Communications Commission (FCC) and state 

regulatory commissions were directed to encourage the deployment of 

advanced telecommunications capability, including broadband, to all 

Americans.5

 As a result, FCC collects broadband deployment data from 

the private sector semiannually using the FCC Form 477, a standardiz

industry census.

ed 

 

6

 The Broadband Data Improvement Act cited a need for 

improved broadband data to help the government better understand the 

extent of broadband deployment, develop and maintain appropriate 

broadband policies, and direct limited financial resources.7

 In addition, 

some broadband advocates have argued that broadband is an important 

international indicator of economic strength; thus the United States seeks 

additional measures of the nation’s progress compared with that of other 

countries. To respond to the requirement in the Broadband Data 

Improvement Act that GAO evaluate additional broadband metrics or 

standards, this report addresses the following questions: 

(1) What measures are generally available to consumers, industry, 

government, and other stakeholders to assess broadband performance? 

(2) What, if any, are the limitations of these measures, and how can the 

measures be supplemented or improved? 

2

“Penetration” is generally defined as the number or percentage of broadband subscribers 

per capita or per household. 

3

Broadband Data Improvement Act, Pub. L. No. 110-385, tit. I, § 104, 122 Stat. 4096, 4098 

(2008). 

4

For example, in low-density areas, the market does not support private broadband 

infrastructure investment. 

5

See 47 U.S.C. § 1302. 

6

In this report, we refer to the FCC Form 477 as the broadband reporting form and the 

resulting data as FCC’s broadband data. 

7

See 47 U.S.C. § 1301(3). 

Page 2 GAO-10-49 Telecommunications 
 

To identify the broadband performance measures available, we conducted 

a review of the literature and related laws and interviewed representatives 

and reviewed related documentation from the following stakeholder 

groups: academicians and think tanks, broadband providers, consumer 

advocacy groups, federal and state agencies and public/private 

partnerships, international organizations, and trade and industry groups. 

To evaluate the limitations, if any, of the measures, and how the measures 

could be supplemented or improved, we interviewed and reviewed related 

documentation from the stakeholders previously mentioned to obtain their 

opinions and analysis on the strengths and limitations of the measures and 

any potential options suggested. We identified potential stakeholders 

based on their expertise with broadband measures as evidenced by our 

literature review, previous GAO work, recommendations from our internal 

telecommunication experts, and suggestions by stakeholders we 

interviewed to develop knowledge of issues related to broadband 

performance measures.8

 We also asked the stakeholders to discuss the 

validity and reliability of the measures and any potential improvements. 

We conducted this performance audit from February 2009 through 

October 2009 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. See appendix I for more 

information about our scope and methodology. 

Multiple measures to assess broadband performance are generally 

available to consumers, industry, and government, although these 

measures have limitations that we discuss later. Consumers can generally 

access performance measures of availability, price, advertised speed, and 

actual delivered speed from broadband providers and third parties to 

compare services and assist in their decision-making process. Some states 

have also completed broadband mapping efforts that provide consumers 

with information on broadband performance, including availability and 

advertised speed. Industry, government, and other stakeholders also have 

access to some broadband measures that enable comparisons across 

various segments of the United States to inform policy positions and guide 

Results in Brief 

 

8

For a complete list of the stakeholders interviewed grouped by type, see appendix I. 

Page 3 GAO-10-49 Telecommunications 
 

broadband investment. For example, stakeholders told us that FCC’s data 

from its semiannual reporting requirement for broadband providers are 

the primary source for comparing the availability and number of 

broadband subscribers across the country. Furthermore, industry, 

government, and other stakeholders can use a number of broadband 

performance measures to compare the quality and availability of 

broadband in selected countries. We focused on 10 such performance 

measures, 8 of which were “composite indexes,” i.e., a combination of 

measures that are generally used to try to account for demographic, 

economic, and geographic differences among countries that can make 

international comparisons difficult. 

Despite the availability of various measures of broadband performance, 

many stakeholders told us that these measures have limitations, but views 

are mixed on potential alternatives and we found that ongoing efforts need 

improvement. More specifically: 

• According to some stakeholders, the lack of comprehensive measures 

from the federal government for consumers to compare price, actual 

delivered speed, and service reliability data from competing broadband 

providers was a limitation. These stakeholders believed that improved 

measures on price and actual delivered speed data from providers would 

help consumers make more informed decisions about broadband services. 

FCC has open proceedings to potentially require broadband providers to 

report measures on price and actual delivered speeds, but it currently does 

not collect such measures. While some stakeholders suggested additional 

measures, such as price per megabit per second, opinions were mixed on 

these alternatives, with consumer advocacy groups, academicians, and 

representatives from think tanks generally in favor of and broadband 

providers and related trade and industry groups generally against them. 

• Stakeholders told us that while industry and government use FCC’s 

semiannual data collection from broadband providers to measure 

deployment and penetration, the form does not require broadband 

providers to report on price or actual delivered speeds, which limits the 

ability to make comparisons of broadband service across various 

segments of the country to inform policy positions or investment 

decisions. Furthermore, the data from FCC and the Pew Internet & 

American Life Project, which reports on home broadband adoption, do not 

provide enough detail to track subscribership in tribal lands or rural areas. 

The National Telecommunications and Information Administration 

Page 4 GAO-10-49 Telecommunications 
 

(NTIA)9 has implemented the State Broadband Data and Development 

Grant Program, in an effort to develop a national broadband inventory 

map, which would provide detailed data on broadband availability, type of 

technology, and advertised and actual delivered speed by census block.10

As of September 9, 2009, NTIA had received applications representing all 

50 states, 5 territories, and the District of Columbia. NTIA is currently 

reviewing the applications and plans to announce funding decisions 

beginning in early fall 2009, with the first data collection due by March 1, 

2010. Although stakeholders agree the effort will provide more detailed 

data, NTIA did not provide standardized guidance to broadband providers 

on calculating actual delivered speeds. We have previously reported that 

consistency, or the extent to which data are collected using the same 

procedures, is a key dimension of data quality and a key attribute of a 

successful performance measure.11 NTIA officials told us they chose not to 

provide this guidance because each provider may have a different method 

for measuring speed, and they did not want to prescribe a standard 

method, given the multiple technologies used. However, this could result 

in inconsistent measurements across providers, limiting the effectiveness 

of the mapping effort in making comparisons across the country. In 

addition, while NTIA required grant applicants to provide a description of 

the methods the applicant intends to employ to verify data accuracy and 

provided an example in its guidance, it did not contain specific standards 

on how to do so. We have previously reported that both verification and 

validation of performance data are important for reducing the risk of 

producing inaccurate data; this additional information helps to place the 

credibility of an agency’s reported performance data in context for 

decision makers.12 While it is too early to determine the effect, if any, of 

the limited guidance, the lack of specific standards for data verification 

could result in inconsistent data across states, limiting the effectiveness of 

 

9

The Department of Commerce’s National Telecommunications and Information 

Administration is the President’s principal telecommunications and information adviser 

and works with other executive branch agencies to develop the Administration’s 

telecommunications policies. 

10In its notice of funding availability, NTIA refers to actual delivered speed as typical speed. 

See 74 Fed. Reg. 32545 (July 8, 2009) (Notice), 74 Fed. Reg. 40569 (August 12, 2009) (Notice 

clarification). 

11GAO, Performance Plans: Selected Approaches for Verification and Validation of 

Agency Performance Information, GAO/GGC-99-139 (Washington D.C.: July 30, 1999), and 

Tax Administration: IRS Needs to Further Refine Its Tax Filing Season Performance 

Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002). 

12GAO, Performance Reporting: Few Agencies Reported on the Completeness and 

Reliability of Performance Data, GAO-02-372 (Washington, D.C.: Apr. 26, 2002). 

Page 5 GAO-10-49 Telecommunications 
 

the data in making comparisons across the country. To increase the data 

quality and subsequent results from the State Broadband Data and 

Development Grant Program, including a national broadband inventory 

map, we recommend that the Secretary of Commerce examine the first 

round of data collection and determine whether to develop specific 

guidance for grantees to improve the consistency and accuracy of the data 

collected under the program. 

• Although industry, government, and other stakeholders can choose from 

many measures to compare broadband performance, there are a variety of 

limitations, including socioeconomic differences among countries, which 

make international comparisons difficult. For example, the Organisation 

for Economic Co-operation and Development (OECD) reports broadband 

subscribers per 100 inhabitants rather than as a percentage of households. 

According to multiple stakeholders, household size alone explains most of 

the differences in this measure, since countries with larger households are 

likely to have lower per capita residential connections. In addition, 

according to Federal Trade Commission (FTC) staff and other 

stakeholders, because the socioeconomic status of individual countries 

and the historical nature of their telecom markets can vary widely, simple 

comparisons across countries may not be meaningful. Stakeholders also 

reported that the lack of reliable and uniform data can limit international 

comparisons. Despite the concerns raised about the limitations of the 

measures used for international comparisons, several stakeholders found 

the comparisons useful because they can help inform policy decisions. 

Stakeholders generally supported FCC’s efforts to develop an additional 

international comparison of communities in other countries with 

comparable communities within the United States, because the 

comparison is to be at a more granular level, which could provide more 

relevant analysis.13

We provided a draft of this report to the Department of Commerce and 

FCC for their review and comment. The Department of Commerce 

provided written comments, which are reprinted in appendix II. In its 

written comments, the Department of Commerce generally agreed with 

our recommendation and stated that it had already begun taking actions to 

address the recommendation. More specifically, the Department of 

Commerce stated that immediately following the awarding of grant funds, 

it will investigate opportunities for improved data collection methods 

 

13Granular refers to the extent to which a system is broken down into small parts. 

Therefore, broadband comparisons at a community or local level are more granular than 

broadband comparisons of countries. 

Page 6 GAO-10-49 Telecommunications 
 

including qualitative and quantitative analyses of data collection and 

verification methods, as well as an assessment of which methods are costefficient and accurate. FCC responded that it did not have any comments 

on the draft report. 

The Internet is a vast network of interconnected networks that is used by 

governments, businesses, research institutions, and individuals around the 

world to communicate, engage in commerce, perform research, educate, 

and entertain. The Internet became widely accessible to U.S. households 

by the mid-1990s. Early on, the primary means to access the Internet was a 

dial-up connection, in which a standard telephone line is used to make an 

Internet connection. A dial-up connection offers data transmission speeds 

of up to 56 kilobits, or 1,000 bits per second (Kbps).14 Broadband access to 

the Internet became available by the late 1990s. Broadband differs from a 

dial-up connection in certain important ways. First, broadband 

connections offer a higher-speed Internet connection than dial-up. For 

example, some broadband connections offer speeds exceeding 1 million 

bits per second (Mbps) both upstream (data transferred from the 

consumer to the Internet service provider) and downstream (data 

transferred from the Internet service provider to the consumer). These 

higher speeds enable consumers to receive information much faster and 

thus enable certain applications to be used and content to be accessed 

that might not be possible with a dial-up connection. The higher 

transmission speeds that broadband offers cost more than dial-up, and 

some broadband users pay a premium to obtain very-high-speed service. 

Second, broadband provides an “always on” connection to the Internet, so 

users do not need to establish a connection to the Internet service 

provider each time they want to go online. Although broadband often is 

referred to as a singular service, it is available in a wide variety of data 

speeds—ranging from 768 Kbps to greater than 100 Mbps. FCC’s current 

categories for collecting data on the number of broadband subscribers by 

advertised download and upload speeds range from greater than 200 Kbps 

but less than 768 Kbps to equal to or greater than 100 Mbps. On August 20, 

Background 

 

14In digital telecommunication, the bit rate is the number of bits that passes a given point in 

a telecommunication network in a given amount of time, usually a second. Thus, a bit rate 

is usually measured in some multiple of bits per second—for example, kilobits, or 

thousands of bits per second. 

Page 7 GAO-10-49 Telecommunications 
 

2009, as part of the proceeding to develop a National Broadband Plan, FCC 

posted a public request for comment on defining “broadband.”15

Consumers can receive a broadband connection to the Internet through a 

variety of technologies that offer varying speeds of service, including, but 

not limited to, the following: 

• Cable modem. Cable television companies first began providing 

broadband service in the late 1990s over their cable networks. When 

provided by a cable company, broadband service is referred to as cable 

modem service. Cable modem service is primarily available in residential 

areas. Cable modem service enables cable operators to deliver broadband 

service by using the same coaxial cables that deliver pictures and sound to 

television sets. Most cable modems are external devices that have two 

connections, one to the cable wall outlet and the other to a computer or 

router. Although the speed of service varies with many factors, download 

speeds of up to 6 Mbps are typical. Cable providers are developing even 

higher-speed services. 

• DSL. Local telephone companies provide digital subscriber line (DSL) 

service, another form of broadband service, over their telephone networks 

on capacity unused by traditional voice service. To provide DSL service, 

telephone companies must install equipment in their facilities and install 

or provide DSL modems and other equipment at customers’ premises and 

remove devices on phone lines that may cause interference. Most 

residential customers receive older, asymmetric DSL (ADSL) service with 

download speeds of 1.5 Mbps to 3 Mbps. ADSL technology can achieve 

speeds of up to 8 Mbps over short distances. Newer DSL technologies can 

support services with much higher download speeds. 

• Fiber. This technology, also known as fiber optic, converts electrical 

signals carrying data to light and sends the light through transparent glass 

fibers smaller than the diameter of a human hair. Fiber optic systems can 

transmit data at speeds far exceeding current DSL or cable modem speeds, 

typically by tens of gigabits per second. Fiber optic technology may be 

 

15Comment Sought on Defining “Broadband,” Public Notice, DA 09-1842 (2009); see also A 

National Broadband Plan for Our Future, Notice of Inquiry, 24 FCC Rcd 4342, 4346-48, at 

paras. 15-22 (2009); Inquiry Concerning the Deployment of Advanced 

Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, 

and Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the 

Telecommunications Act of 1996, as Amended by the Broadband Data Improvement Act, 

Notice of Inquiry, FCC 09-65, at paras. 34-41 (rel. Aug. 7, 2009). 

Page 8 GAO-10-49 Telecommunications 
 

provided in several ways, including fiber to a customer’s home or business 

or to a location somewhere between the provider’s facilities and the 

customer. In the latter case, the last part of the connection to the 

customer’s premises may be provided over cable, copper loop, or radio 

technology. Such hybrid arrangements may be less costly than providing 

fiber all the way to the customer’s premises, but they generally cannot 

achieve the high transmission speed of a full fiber-to-the-premises 

connection. 

• Satellite. Three providers currently offer broadband service via satellite in 

the United States. These providers use geostationary satellites that orbit in 

a fixed position above the equator and wirelessly transmit and receive data 

directly to and from subscribers.16 Satellite companies provide 

transmission from the Internet to the user’s computer and from the user’s 

computer to the Internet, eliminating the need for a telephone or cable 

connection. Typically a consumer can expect to receive (download) at a 

speed of about 1 Mbps and send (upload) at a speed of about 200 Kbps. 

Transmission of data via satellite causes a slight lag in transmission, 

typically one-quarter to three-fourths of a second, thus rendering this 

service less suitable for certain Internet applications, such as 

videoconferencing. While satellite broadcast service may be available 

throughout the country, it generally costs more than most other 

broadband modes and its use requires a clear line of sight between the 

customer’s antenna and the southern sky. Both the equipment necessary 

for service and recurring monthly fees are generally higher for satellite 

broadband service, compared with most other broadband transmission 

modes. 

• Wireless. Land-based, or terrestrial, wireless broadband connects a home 

or business to the Internet using a radio link. Some wireless services are 

provided over unlicensed radio spectrum and others over spectrum that 

has been licensed to particular companies.17 In licensed bands, some 

companies are offering fixed wireless broadband throughout cities. Also, 

 

16There also are low earth orbit satellite providers such as GlobalStar and Iridium that 

provide some level of broadband service. These satellite systems are in a nonstationary 

orbit and are between 250 and 600 miles in orbit. 

17Radio spectrum is a natural resource used to provide an array of wireless communication 

services. FCC regulates commercial entities’ use of spectrum. With unlicensed spectrum, a 

number of users without licenses share a portion of the spectrum, adhering to certain 

technological specifications. In contrast, with licensed spectrum, FCC licenses entities to 

use a specific portion of the spectrum. GAO, Telecommunications: Broadband 

Deployment Is Extensive throughout the United States, but It Is Difficult to Assess the 

Extent of Deployment Gaps in Rural Areas, GAO-06-426 (Washington, D.C.: May 5, 2006). 

Page 9 GAO-10-49 Telecommunications 
 

mobile telephone carriers—such as the large companies that provide 

traditional cell phone service—have begun offering broadband mobile 

wireless Internet service over licensed spectrum—a service that allows 

subscribers to access the Internet with their mobile phones or laptops in 

areas throughout cities where their provider supports the service. A 

variety of broadband access technologies and services also are provided 

on unlicensed spectrum—that is, spectrum that is not specifically under 

license for a particular provider’s network. For example, wireless Internet 

service providers may offer broadband access in particular areas by 

establishing a network of subscriber stations, each with its own antenna 

that relays signals throughout a neighborhood and has a common interface 

to the Internet. Subscribers place necessary reception equipment outside 

their homes that transmits and receives signals from the nearest antenna. 

Also, wireless fidelity (Wi-Fi) networks—which provide broadband service 

in so-called hot spots, or areas within a radius of up to 300 feet—can be 

found in cafes, hotels, airports, and offices. Such netowrks generally use a 

short-range technology that provides speeds up to 54 Mbps. Some 

technologies, such as Worldwide Interoperability for Microwave Access 

(known as WiMAX), can operate on either licensed or unlicensed bands, 

and can provide broadband service up to approximately 30 miles. 

FCC has primary responsibility for regulating broadband. Section 706 of 

the Telecommunications Act of 1996 directs FCC to encourage the 

deployment of advanced telecommunications capability, which includes 

broadband, to all Americans.18 Under this authority, FCC has to date 

established a minimal regulatory environment for broadband 

Internet access services. In the past, FCC has stated that less 

regulation has encouraged providers to invest in broadband 

infrastructure. The Communications Act, as amended, allows FCC to 

 

18Pub. L. No. 104-104, § 706, 110 Stat. 56, 153 (1996). Section 706(c) of the act describes 

advanced telecommunications capabilities as “high-speed, switched, broadband 

telecommunications capability that enables users to originate and receive high-quality voice, 

data, graphics, and video telecommunications using any technology.” Section 706 of the 

Telecommunications Act of 1996, Pub. L. No. 104-104, title VII, Sec. 706, 110 Stat. 56, 153 

(1996) (1996 Act), as amended in relevant part by the Broadband Data Improvement Act, Pub. 

L. No. 110-385, 122 Stat. 4096 (2008) (BDIA), is now codified at 47 U.S.C. § 1301 et. seq. Prior 

to the BDIA, section 706 was reproduced in the notes to Section 157 of the 

Communications Act of 1934, as amended (the Act). 47 U.S.C. § 157 nt. (2008). 47 U.S.C. 

§ 1302(d). 

Page 10 GAO-10-49 Telecommunications 
 

classify services as telecommunications services19 or information 

services,20 the latter being subject to fewer regulatory restrictions. FCC, 

through a number of proceedings, classified broadband Internet access 

(regardless of the platform) as an information service.21 FCC does not 

have explicit statutory authority to regulate the provision of information 

services; however, FCC has the authority to impose regulations under 

what is termed its ancillary jurisdiction to regulate services that are 

 

19Under the Telecommunications Act, “telecommunications service” is defined as “the 

offering of telecommunications for a fee directly to the public, or to such classes of users 

as to be effectively available directly to the public, regardless of the facilities used.” 47 

U.S.C.§ 153(46). “Telecommunications” is defined as “the transmission, between or among 

points specified by the user, of information of the user’s choosing, without change in the 

form or content of the information as sent and received.” 47 U.S.C. § 153(43). 

20Under the Telecommunications Act, “information service” is defined as the offering of a 

capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, 

or making available information via telecommunications, and includes electronic 

publishing, but does not include any use of any such capability for the management, 

control, or operation of a telecommunications system or the management of a 

telecommunications service. 47 U.S.C. § 153(20). 

21See e.g., Inquiry Concerning High-Speed Access to the Internet Over Cable and Other 

Facilities; Internet Over Cable Declaratory Ruling; Appropriate Regulatory Treatment 

for Broadband Access to the Internet Over Cable Facilities, Declaratory Ruling and Notice 

of Proposed Rulemaking, 17 FCC Rcd 4798 (2002) (Cable Modem Declaratory Ruling), 

aff’d Nat’l Cable & Telecomms. Ass’n v. Brand X Internet Servs., 545 U.S. 967 (2005); 

Appropriate Framework for Broadband Access to the Internet over Wireline Facilities; 

Universal Service Obligations of Broadband Providers; Review of Regulatory 

Requirements for Incumbent LEC Broadband Telecommunications Services; Computer 

III Further Remand Proceedings: Bell Operating Company Provision of Enhanced 

Services; 1998 Biennial Regulatory Review—Review of Computer III and ONA 

Safeguards and Requirements; Conditional Petition of the Verizon Telephone Companies 

for Forbearance Under (c) with Regard to Broadband Services Provided 

via Fiber to the Premises; Petition of the Verizon Telephone Companies for Declaratory 

Ruling or, Alternatively, for Interim Waiver with Regard to Broadband Services 

Provided via Fiber to the Premises; Consumer Protection in the 

47 U.S.C. § 160

Broadband Era, Report 

and Order and Notice of Proposed Rulemaking, 20 FCC Rcd 14853 (2005) (Wireline 

Broadband Internet Access Services Order), aff’d Time Warner Telecom, Inc. v. FCC, 507 

F.3d 205 (3d Cir. 2007); United Power Line Council’s Petition for Declaratory Ruling 

Regarding the Classification of Broadband over Power Line Internet Access Service as 

an Information Service, Memorandum Opinion and Order, 21 FCC Rcd 13281 (2006) (BPLEnabled Internet Access Services Order); Appropriate Regulatory Treatment for 

Broadband Access to the Internet Over Wireless Networks, Declaratory Ruling, 22 FCC Rcd 

5901 (2007). 

Page 11 GAO-10-49 Telecommunications 
 

reasonably related to its existing statutory authority.22 FCC also has the 

authority to adopt broadband regulations to ensure that broadband 

providers are capable of providing authorized surveillance to law 

enforcement agencies.23

As part of its responsibilities, FCC has periodically issued a report to 

Congress on the status of advanced telecommunications capability in the 

United States, including the quality of broadband data.24 To assist in the 

preparation of this report, in 2000, FCC implemented the previously 

described broadband reporting form, a semiannual reporting requirement 

for facilities-based broadband Internet service providers.25 In November 

2004, FCC modified its rules on filing this information, and the revised 

rules went into effect for the companies’ second filing in 2005. Specifically, 

 

22See National Cable Telecomm. Ass’n. v. Brand X Internet Services, 545 U.S. 967, 976 

(2005) (FCC has jurisdiction to impose additional regulatory obligations under its Title I 

ancillary jurisdiction to regulate interstate and foreign communications). FCC has relied on 

its ancillary jurisdiction in adjudicatory proceedings, for example, in the proceeding in 

which it found Comcast’s practices did not constitute reasonable network management. 

Formal Complaint of Free Press and Public Knowledge Against Comcast Corporation for 

Secretly Degrading Peer-to-Peer Applications; Broadband Industry Practices; Petition of 

Free Press et al. for Declaratory Ruling that Degrading an Internet Application Violates 

the FCC’s Internet Policy Statement and Does Not Meet an Exception for “Reasonable 

Network Management,” 23 FCC Rcd 13028 (2008) (Comcast Order). Comcast filed a 

petition appealing this order on Sept. 4, 2008, with the U.S. Court of Appeals for the D.C. 

Circuit. Petition for Review, Comcast v. FCC, No. 08-1291 (D.C. Cir. Filed September 4, 

2008). In 2005 the Commission adopted an Internet Policy Statement in which it 

committed “to preserve and promote the vibrant and open character of the Internet as the 

telecommunications marketplace enters the broadband age” by incorporating four 

consumer-based principles into its ongoing policy-making activities. Internet Policy 

Statement, 20 FCC Rcd 14986 (2005). 

23Federal courts have upheld FCC’s authority to regulate broadband Internet service 

providers under the Communications Assistance for Law Enforcement Act. In addition, in 

2005 the Commission determined that providers of interconnected voice over Internet 

protocol services and broadband Internet access services are subject to the 

Communications Assistance for Law Enforcement Act (CALEA). See Communications 

Assistance for Law Enforcement Act and Broadband Access and Services, First Report 

and Order and Further Notice of Proposed Rulemaking, 20 FCC Rcd 14989, 14991-92, para. 

8 (2005) (CALEA First Report and Order), aff’d sub nom. American Council on Educ. v. 

FCC, 451 F.3d 226 (D.C. Cir. 2006).

24See 47 U.S.C. § 1302(b); see, e.g., Inquiry Concerning the Deployment of Advanced 

Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, 

Fifth Report, 23 FCC Rcd 9615 (2008) (Section 706 Fifth Report), pet. for recon. pending.

25A facilities-based carrier is one that owns most of its facilities, such as switching 

equipment and transmission lines. A non-facilities-based carrier is one that leases most of 

its switching and lines from others. 

Page 12 GAO-10-49 Telecommunications 
 

FCC removed existing reporting thresholds,26 and all companies were 

required to report their total state subscribership by technology. In 2006, 

we reported that the approach FCC then used to collect data on 

broadband deployment, which counted broadband service providers with 

subscribers at the ZIP code level, resulted in inadequate information about 

broadband deployment.27 Subsequent to our recommendation, in March 

2008, FCC acted to increase the precision and quality of its broadband data 

by revising its methodology and requiring that broadband providers report 

the number of broadband connections in service by census tract.28

In addition to FCC’s data collection effort using its broadband reporting 

form, the Broadband Data Improvement Act calls for additional actions to 

improve the quality of data available on broadband deployment.29 Among 

other things, the act directs FCC to 

(1) periodically survey consumers to collect information on the types 

of technologies used by consumers to access the Internet, the 

applications or devices used in conjunction with broadband 

service, and the actual connection speeds of users; 

(2) collect information on reasons why consumers have not 

subscribed to broadband services; 

(3) determine certain demographic data for geographical areas not 

served by any provider of advanced telecommunications capability 

(i.e., areas where broadband has not yet been deployed); and 

(4) provide information on the extent of broadband service capability, 

including the speed and price of broadband service in a total of 75 

communities in at least 25 countries. 

 

26In the past, companies with fewer than 250 broadband connections were not required to 

submit information to FCC through Form 477. 

27GAO-06-426. 

28Development of Nationwide Broadband Data to Evaluate Reasonable and Timely 

Deployment of Advanced Services to All Americans, Improvement of Wireless Broadband 

Subscribership Data, and Development of Data on Interconnected Voice over Internet 

Protocol (VoIP) Subscribership, Report and Order, 23 FCC Rcd 9691 (2008); Order on 

Reconsideration, 23 FCC Rcd 9800 (2008). 

2947 U.S.C. §§ 1302, 1303. 

Page 13 GAO-10-49 Telecommunications 
 

FTC also has regulatory jurisdiction over broadband services with respect 

to competition and consumer protection issues.30 FTC’s jurisdiction over 

broadband services comes chiefly from its statutory mandate to prevent 

“unfair methods of competition” and “unfair or deceptive acts or practices 

in or affecting commerce” under FTC’s enabling legislation, the FTC Act.31

Although this authority is very broad, certain limited market sectors are 

expressly excluded from FTC’s enforcement authority. In particular, FTC’s 

enforcement authority does not reach “common carriers subject to the 

Communications Act of 1934, as amended.32 However, since most 

broadband Internet services are not provided on a common carrier basis, 

they are generally part of the larger economy subject to FTC’s general 

competition and consumer protection authority with regard to methods, 

acts, or practices in or affecting commerce.33 FTC has, where appropriate, 

investigated and brought enforcement actions in matters involving access 

to content via broadband and other Internet access services.34

Additionally, FTC has brought a variety of cases against Internet service 

 

30In recently issued comments, FTC stated that it shares jurisdiction over broadband 

Internet access and related content applications with FCC. A National Broadband Plan for 

Our Future, GN Docket No. 09-51, Comments of the FTC (submitted Sept. 4, 2009). 

3115 U.S.C. § 41 et seq. FTC’s authority to enforce the federal antitrust laws generally is 

shared with the Department of Justice’s Antitrust Division. Federal Trade Commission 

Staff Report, Broadband Connectivity Competition Policy. Washington, D.C., 2007. 

3215 U.S.C. § 45(a)(2). Specifically, section 45(a)(2) provides: “The Commission is hereby 

empowered and directed to prevent persons, partnerships, or corporations, except banks, 

savings and loan institutions described in section 18(f)(3) [15 USCS § 57a(f)(3)], Federal 

credit unions described in section 18(f)(4) [15 USCS § 57a(f)(4)], common carriers subject 

to the Acts to regulate commerce, air carriers and foreign air carriers subject to the Federal 

Aviation Act of 1958 [49 USCS §§ 40101 et seq.], and persons, partnerships, or corporations 

insofar as they are subject to the Packers and Stockyards Act, 1921, as amended [7 USCS 

§§ 181 et seq.], except as provided in section 406(b) of said Act [7 USCS § 227(b)], from 

using unfair methods of competition in or affecting commerce and unfair or deceptive acts 

or practices in or affecting commerce.” 

33Under telecommunications law, an entity is a common carrier only with respect to 

services that it provides on a common carrier basis. See 47 U.S.C. § 153(44) (provider of 

telecommunications services deemed a common carrier under the Communications Act 

“only to the extent that it is engaged in providing telecommunications services.”). 

34For example, FTC challenged the proposed merger between America Online (AOL) and 

Time Warner, on the basis that the merger threatened to harm competition and injure 

consumers in several markets, including those for broadband Internet access and 

residential Internet transport services. The consent order resolving the agency challenge 

required the merged entity to open its cable system to competitor Internet service 

providers on a nondiscriminatory basis for all content. Am. Online, Inc. & Time Warner, 

Inc., FTC Dkt. No. C-3989 (April 17, 2001) (consent order), available at 

http://www.ftc.gov/os/2001/04/aoltwdo.pdf.

Page 14 GAO-10-49 Telecommunications 
 

providers that have engaged in allegedly deceptive marketing and billing 

practices.35

Two other federal agencies have responsibility for telecommunications 

policies. The Office of Science and Technology Policy (OSTP) within the 

Executive Office of the President has a broad mandate to advise the 

President and the federal government on the effects of science and 

technology on domestic and international affairs and has led interagency 

efforts to develop science and technology policies and budgets. NTIA is 

the President’s principal telecommunications and information adviser and 

works with other executive branch agencies to develop the 

Administration’s telecommunications policies.36

 

35For example, See Am. Online & CompuServe Interactive Servs., Inc. FTC DKT No. C-4105 

(Jan. 28, 2004) (consent order) available at 

http://www.ftc.gov/os/caselist/00230000/0023000aol.shtm. 

36In addition, according to NTIA officials, they periodically sponsor Internet use surveys 

conducted by the U.S. Census Bureau and publish the findings in reports. The next data 

collection is expected to occur in the fall of 2009. 

Page 15 GAO-10-49 Telecommunications 
 

Multiple Measures 

Are Available for 

Consumers, Industry, 

Government, and 

Others to Assess 

Broadband 

Performance 

Consumers Can Generally 

Access Measures of 

Availability, Price, 

Advertised Speed, and 

Actual Delivered Speed 

from Broadband Providers 

and Third Parties 

Although there are limitations that we discuss later, consumers interested 

in broadband service can generally contact providers or search provider 

Web sites to determine the availability of service, advertised price, and 

advertised speed of broadband service in their area. For example, 

consumers can go to att.com or timewarnercable.com and enter their 

street address to learn about the availability of broadband service at their 

address, including price and advertised speeds. Each Web site also 

provides a phone number that consumers can use to reach a customer 

service representative to obtain information on availability, price, and 

advertised speeds of service. Consumers can then make their own 

comparisons of these prices and advertised speeds. In addition, third 

parties provide consumer Web sites, such as dslreports.com, that assemble 

this information for consumers to review. 

However, actual delivered speeds depend on multiple factors, such as the 

equipment of the consumer, the applications in use, and Internet traffic, 

and may not always match advertised speeds or the theoretical maximum 

speeds stated by the provider. Consequently, there are tools available to 

consumers to measure actual delivered speed. Consumers with broadband 

service have access to their actual delivered speeds through speed tests 

from broadband provider Web sites and third parties. Speed tests generally 

measure the “last mile” speed (download and upload) of the consumer’s 

connection. Some third-party Web sites also provide information on actual 

delivered speeds of service and allow consumers to compare speeds. For 

example, speedtest.net allows individuals to compare their speed with that 

of other consumers by provider or in a set geographic region. 

Some states have also completed broadband mapping efforts that provide 

consumers with information on broadband performance, including 

availability and advertised speed. We previously reported that 12 states 

had mapped broadband deployment, and 2 of these states, California and 

Page 16 GAO-10-49 Telecommunications 
 

Massachusetts, had mapped both the speed and availability of broadband 

in their state and placed the information on their state’s Web site.37 In its 

2008 report,38 California also provided information on average delivered 

upload and download speeds aggregated throughout the state and 

advertised residential speeds by price.39

Industry and Government 

Have Some Broadband 

Performance Measures to 

Make Comparisons across 

Various Segments of the 

United States 

The stakeholders we interviewed told us that FCC’s broadband data, 

collected through its broadband reporting form, constitute the primary 

data source generally used to measure performance and make 

comparisons across various segments of the United States, although there 

are limitations, which we discuss later. The Commission has tracked 

broadband subscribership and deployment since 2000 through its 

broadband reporting form.40 In 2006, we reported that the approach FCC 

then used to collect data on broadband deployment, which counted 

broadband service providers with subscribers at the ZIP code level, 

resulted in inadequate information about broadband deployment.41 To 

improve this information, in 2008, the Commission revised the semiannual 

reporting requirements of the broadband reporting form. The Commission 

now requires most broadband providers to file subscribership information 

by census tract, including the number of subscribers by technology, speed 

 

37GAO, Telecommunications: Broadband Deployment Plan Should Include Performance 

Goals and Measures to Guide Federal Investment, GAO-09-494 (Washington, D.C.: May 12, 

2009). 

38California Broadband Task Force, The State of Connectivity, Building Innovation 

Through Broadband, Final Report of the California Broadband Task Force, January 2008. 

39The state partnered with speedtest.net to acquire 2006 California data, representing 

350,000 broadband users that conducted 1,243,278 test of their effective bandwidth. 

40In addition to collecting data through the broadband reporting form, the Commission 

tracks the deployment of mobile wireless broadband networks using network coverage 

data acquired through a contract with an independent consulting firm. The results of the 

Commission’s analysis of mobile network deployment are included in its Annual CMRS 

Competition Reports. The Thirteenth CMRS Competition Report describes how the 

Commission analyzes mobile network coverage. See Implementation of Section 6002(b) of 

the Omnibus Budget Reconciliation Act of 1993; Annual Report and Analysis of 

Competitive Market Conditions with Respect to Commercial Mobile Services, Thirteenth 

Report, paras. 37-39, 144-47 (WTB rel. Jan. 16, 2009) (Thirteenth CMRS Competition 

Report). Using this information, the commission develops an estimate of the percentage of 

the U.S. population covered by various broadband mobile network technologies. 

41GAO-06-426. 

Page 17 GAO-10-49 Telecommunications 
 

tier, and business/residential connection.42 In addition, mobile wireless 

service providers are now required to report the number of connections in 

(1) individual states, (2) the census tracts that best represent their 

broadband service footprint, and (3) in a separate category, the number of 

subscribers whose device and subscription permit them access to the 

lawful Internet content of their choice. These changes are expected to 

result in data that are more detailed than what was previously collected. 

The first round of data filings under the new requirements was due on 

March 16, 2009. As of September 2009, FCC staff was still in the process of 

analyzing the information. 

Stakeholders also identified the Pew Internet & American Life Project’s 

reports on home broadband adoption as a source for measuring adoption 

and making comparisons across the United States. The results in the 

reports are based on data from approximately 2,300 telephone interviews 

(on both landline and cellular telephones) conducted by Princeton Survey 

Research International over the course of a month. The 2009 report 

included the following information that can be used to compare rural and 

nonrural areas:43 broadband adoption, broadband connection type, and, 

when applicable, reason for not having broadband access or Internet 

access.44

 

42Specifically, FCC requires wired, terrestrial fixed wireless and satellite broadband service 

providers to report certain subscriber information by census tract. 

43John Horrigan, Home Broadband Adoption 2009, Pew Internet & American Life Project, 

(Washington, D.C.: June 2009). 

44Pew previously identified where people live by rural, urban, or suburban location, as it is 

easy to identify landline phones according to the Census Bureau’s definitions of rural, 

urban, and suburban. The change to identifying where people live by rural and nonrural 

was made because blocks of cell phone numbers do not neatly map to Census Bureau 

definitions of urban, suburban, and rural. However, samples of cell phone numbers do 

include the Metropolitan Statistical Area (MSA) in which the cell phone was activated, 

which is a close proxy for where the user lives. 

Page 18 GAO-10-49 Telecommunications 
 

Through our literature review and interviews with stakeholders, we 

focused on 10 performance measures often used by industry, government, 

and other stakeholders to make international comparisons of broadband 

service, as summarized below (limitations of these measures are discussed 

later). These measures fall into two general categories: (1) broadbandspecific measures and (2) more general measures that cover a wide array 

of information and communications technology (ICT).45

Industry, Government, and 

Other Stakeholders Have 

Many Performance 

Measures Available for 

Making International 

Comparisons 

The broadband-specific rankings measure a nation’s broadband 

performance by focusing on the availability, penetration (or adoption), and 

quality of broadband in each country, and include those listed below (see 

table 1 for the U.S. ranking for each.) 

• Broadband Adoption Index. The Phoenix Center for Advanced Legal and 

Economic Public Policy Studies recently developed the Broadband 

Adoption Index (BAI), which proposes to compare the actual value that a 

society derives from broadband usage with that country’s target level for 

adopting various broadband technologies based on maximizing societal 

well-being. These targets vary by technology, demographic group, and 

country. The index does not include an overall ranking of countries based 

on broadband performance, because each country has its own unique set 

of adoption targets. 

• Broadband Quality Score. The Oxford Saïd Business School in Oxford, 

United Kingdom (UK), in conjunction with the University of Oviedo in 

Oviedo, Spain, and Cisco Systems, Inc., created the Broadband Quality 

Score (BQS) in September 2008 to highlight each representative nation’s 

ability to benefit from next-generation Web applications and services. 

According to the study, to establish broadband leadership, countries must 

focus on broadband availability, penetration, and quality. 

• Broadband Subscribers per 100 Inhabitants. OECD produces many 

broadband-related measures annually on its online broadband Web site. 

According to FCC and many of the stakeholders we interviewed, one of 

the most widely reported figures on broadband performance is OECD’s 

count of broadband subscribers per 100 inhabitants by technology. OECD 

also collects comparative data from its 30 member countries on multiple 

broadband measures such as penetration, usage, coverage, prices, services 

and speeds, and choice and competition. However, unlike other 

 

45“ICT” is a general term that covers all methods that may be used to transmit, display, or 

use data for information processing or communication by electronic means. 

Page 19 GAO-10-49 Telecommunications 
 

stakeholders, OECD does not aggregate its data into a composite indicator 

of national broadband performance.46

• Broadband Performance Index. The European Commission recently 

implemented the Broadband Performance Index (BPI), which measures 

and benchmarks the overall broadband performance of European Union 

member states based on a range of factors, which could include speeds, 

rural coverage, affordability, innovation, and other socioeconomic 

dimensions. In particular, the BPI ranks the EU-27 countries plus Norway 

in terms of supply and demand factors that affect the penetration and use 

of broadband.47

• ITIF broadband rankings. For its broadband rankings, the Information 

Technology and Innovation Foundation (ITIF) measures three primary 

broadband indicators, household penetration (rather than subscriber), 

average speed, and price, to rank the broadband performance of OECD 

nations. ITIF notes the importance of non-policy factors on a nation’s 

broadband performance, including demographic, economic, and 

broadband supply variables. 

In contrast to broadband-specific rankings, the other performance 

measures we identified were based on each country’s development and 

use of ICT. These rankings are more general, focusing on the larger picture 

of how ICT usage, infrastructure, and skills can affect a country’s 

economic growth. According to an official at the Technology and Policy 

Institute (TPI), broadband is but one component in the makeup of a 

country’s ICT landscape, as ICT encompasses Internet usage along with 

other forms of telecommunications. According to FCC, these various 

measures demonstrate the value of understanding the broader context 

 

46In its 2008 report titled Broadband Growth and Policies in OECD Countries, OECD 

cautions that policy makers must examine a range of indicators that reflect the status of 

individual broadband markets in OECD countries. 

47The EU-27 indicates the 27 member states of the European Union: Austria, Belgium, 

Bulgaria, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Germany, 

Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, 

Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the United Kingdom. 

Page 20 GAO-10-49 Telecommunications 
 

when making comparisons regarding broadband deployment and 

adoption.48 Examples of ICT-specific rankings include the following: 

• Connectivity Scorecard. The Dean at the Haskayne School of Business at 

the University of Calgary in Calgary, Canada, worked in collaboration with 

Nokia Siemens Networks and LECG (a global services and consulting 

firm) to release the first version of the Connectivity Scorecard in 2008. The 

scorecard measures the impact of ICT on economic growth in three key 

areas of society—the consumer sector, the business sector, and the 

government sector. The report presents separate sets of rankings for 

“innovation-driven economies” and “resource- and efficiency-driven 

economies” while specifically focusing on each country’s ICT 

infrastructure and usage.49

• E-readiness Ranking. The Economist Intelligence Unit (EIU) is the 

business information arm of The Economist Group, publisher of The 

Economist magazine. The EIU produces an annual E-readiness Ranking, 

which measures the quality of a country’s ICT infrastructure as well as the 

ability of its consumers, businesses, and government to use ICT to their 

benefit. The EIU makes this assessment by specifically measuring a 

country’s connectivity and technology infrastructure, business 

environment, social and cultural environment, legal environment, 

government policy and vision, and consumer and business adoption. 

Overall, more than 100 separate qualitative and quantitative criteria are 

considered. 

• Networked Readiness Index: The World Economic Forum,50 in 

cooperation with INSEAD international business school’s eLab research 

center51 and Cisco Systems, Inc., produced the Networked Readiness 

 

48Inquiry Concerning the Deployment of Advanced Telecommunications Capability to All 

Americans in a Reasonable and Timely Fashion, and Possible Steps to Accelerate Such 

Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, Fifth 

Report, 23 FCC Rcd 9615 (2008) (Section 706 Fifth Report), pet. for recon. pending. 

49The terms “resource- and efficiency-driven” and “innovation-driven” are borrowed from 

the World Economic Forum’s classification. Innovation-driven economies are more highly 

developed than resource- and efficiency-drive economies. 

50The World Economic Forum is an independent international organization that seeks to 

improve the state of the world by engaging leaders in partnerships to influence global, 

regional, and industry agendas. 

51eLab has research facilities in Abu Dhabi, United Arab Emirates, and at INSEAD’s two 

campuses located in France and Singapore. 

Page 21 GAO-10-49 Telecommunications 
 

Index (NRI). The NRI is used to assess the extent to which different 

economies benefit from the latest ICT advances based on their ICT 

environment, readiness, and usage while taking into account the key roles 

played by individuals, businesses, and governments. The NRI covers 134 

economies worldwide and accounts for nearly 70 factors. 

• International Communications Market. In its 2008 report, Ofcom, the 

regulator for the UK communications industry, described developments in 

international communications markets, including information on 

broadband availability and usage.52 In the report, Ofcom aimed to provide 

statistically driven international comparative data for the UK 

communications sector by examining trend data from 2002 to 2007 on how 

various countries’ industries, consumers, and regulatory landscapes affect 

their communication markets. 

• ICT Development Index. The International Telecommunication Union 

(ITU), a United Nations agency, developed the ICT Development Index 

(IDI), which measures the development of ICT, the level of advancement 

of ICT, and the development potential of ICT in more than 150 countries 

worldwide, comparing their progress between 2002 and 2007. The purpose 

of the index is to track the global digital divide and to measure each 

country’s progress toward becoming an “information society.”53 The 

primary index measures ICT infrastructure/access, use, and skills, while a 

separate index was created to capture the price of ICT relative to a 

country’s income. 

Eight of the 10 performance measures listed above are “composite 

indexes,” i.e., combinations of measures that are generally used to try to 

account for and normalize a variety of factors such as demographic, 

economic, and geographic differences among countries, which according 

to many of the stakeholders we spoke with can affect broadband 

deployment and penetration.54 Several of the stakeholders identified 

 

52Ofcom, The International Communications Market, 2008. 

53According to the attendees at the World Summit on the Information Society, organized by 

the United Nations, an information society has access to and takes advantage of the 

benefits of the digital revolution of ICT, such as in the form of e-commerce, e-government, 

education, sustainable development, and so forth. 

54The two organizations whose studies do not include composite indexes are OECD and 

Ofcom. Socioeconomic factors can affect broadband deployment and penetration. For 

example, it is easier and cheaper to deploy and upgrade broadband if most of a nation’s 

residents live in highly dense urban areas, such as in South Korea. Conversely, if most of a 

nation’s citizens live in single-family homes in the suburbs or rural areas, such as in the 

United States, the cost per household for deploying broadband is higher. 

Page 22 GAO-10-49 Telecommunications 
 

advantages to using composite indexes in making international 

comparisons. Officials from the European Commission reported that 

composite indexes are a useful tool to summarize the multidimensional 

issues, such as the socioeconomic differences among countries, which 

cannot be captured by a single indicator. According to ITU, compared with 

single indicators, composite indexes allow grouping several key 

performance indicators into one figure that captures a variety of 

information and provides a more comprehensive picture. While the 

various indexes differ on which demographic, economic, and geographic 

factors play a greater role in the supply and demand of broadband, 

income, age, education, population density, gross domestic product (GDP) 

per capita, and intermodal competition are generally considered 

important.55 According to ITIF, nonpolicy factors, such as demographic, 

economic, and broadband supply variables explain about three-quarters of 

the differences among nations’ broadband performance in international 

rankings. The determination of which factors to include or exclude in a 

composite index can greatly affect a nation’s ranking in a report, as 

demonstrated by the fact that the United States’ broadband and ICT 

rankings vary greatly by study, as shown in table 1. 

 

55FCC has defined “intermodal competitors” as providers of services similar to those 

provided by incumbent local exchange carriers that rely exclusively on technological 

platforms other than wireline technologies. “Intermodal competitors include, for example, 

cable modem service providers, wireless broadband Internet access service providers, 

satellite broadband Internet access service providers, and other broadband Internet access 

service providers such as broadband over power line providers.” See Appropriate 

Framework for Broadband Access to the Internet over Wireline Facilities, Report and 

Order and Notice of Proposed Rulemaking, 20 FCC Rcd 14853, 14856, para. 3, ftn 7 (2005), 

aff’d sub nom. Time Warner Telecom, Inc. v. FCC, 507 F.3d 205 (3d Cir. 2007). 

Page 23 GAO-10-49 Telecommunications 
 

Table 1: U.S. Ranking in International Broadband Performance Comparisons 

Composite index or performance measure U.S. ranking Top-ranked country 

Broadband-specific measures 

BAI; Phoenix Center (2009) No ranking provided because each country 

has its own unique set of adoption targets. 

No ranking provided because each 

country has its own unique set of 

adoption targets. 

BQS; Oxford Saïd Business School, 

University de Oviedo, and Cisco (2008) 

16th out of 42 Japan 

Broadband subscribers per 100 inhabitants 

by technology; OECD (2008) 

15th out of 30 Denmark 

BPI; European Commission (2008) United States not included in ranking Sweden 

2008 ITIF Broadband Rankings; ITIF, Robert 

Atkinson 

15th out of 30 South Korea 

ICT measures 

Connectivity Scorecard 2009; LECG, Nokia 

Siemens Networks, and Leonard Waverman 

1st out of 50 (for innovation-driven 

economies) 

United States 1st for innovation-driven 

economies 

Malaysia 1st for efficiency- and resourcedriven economies 

E-readiness rankings 2009; Economist 

Intelligence Unit 

5th out of 70 Denmark 

NRI; World Economic Forum and INSEAD 

(2009) 

3rd out of 134 Denmark 

International Communications Market 2008; 

Ofcom 

Many rankings listed; United States 2nd in 

residential and small and medium-sized 

enterprise broadband connections per 100 

households 

Many rankings listed: Canada 1st in 

residential and small and medium-sized 

enterprise broadband connections per 

100 households 

IDI; ITU (2009) 17th out of 154 Sweden 

Source: GAO analysis. Dates provided represent the published date of the report. 

Page 24 GAO-10-49 Telecommunications 
 

Stakeholders 

Reported Limitations 

with Current 

Broadband 

Performance 

Measures, but Views 

Are Mixed on 

Potential Alternatives 

and Ongoing Efforts 

Need Improvement 

Price, Actual Delivered 

Speed, and Service 

Reliability Measures for 

Consumers Have 

Limitations, but There 

Are Differing Views on 

Alternatives 

Even though consumers have access to measures, stakeholders told us 

that measures of price, actual delivered speed, and service reliability have 

limitations that may affect their usefulness for consumers: 

• Price. Stakeholders told us the available pricing measures for consumers 

are limited. For example, officials from the Consumer Federation of 

America and Pew Internet & American Life Project told us the lack of a 

comprehensive and consistent measure from the government for 

consumers to compare prices from providers was a limitation. They added 

that improved measures for prices would help consumers make more 

informed decisions about broadband services. Although FCC has open 

proceedings on requiring providers to include measures of price in the 

broadband reporting form, it currently does not collect this information.56

 

56Deployment of Nationwide Broadband Data to Evaluate Reasonable and Timely 

Deployment of Advanced Services to All Americans, Improvement of Wireless Broadband 

Subscribership Data, and Development of Data on Interconnected Voice over Internet 

Protocol (VoIP) Subscribership, Notice of Proposed Rulemaking, 22 FCC Rcd 7760, 7769-

70 (2007); Development of Nationwide Broadband Data to Evaluate Reasonable and 

Timely Deployment of Advanced Services to All Americans, Improvement of Wireless 

Broadband Subscribership Data, and Development of Data on Interconnected Voice over 

Internet Protocol (VoIP) Subscribership, Report and Order and Further Notice of 

Proposed Rulemaking, 23 FCC Rcd 9691, 9702 (2008); Inquiry Concerning the Deployment 

of Advanced Telecommunications Capability to All Americans in a Reasonable and 

Timely Fashion, and Possible Steps to Accelerate Such Deployment Pursuant to Section 

706 of the Telecommunications Act of 1996, as Amended by the Broadband Data 

Improvement Act, Notice of Inquiry, 24 FCC Rcd 10505 (2009); A National Broadband 

Plan for Our Future, Notice of Inquiry, 24 FCC Rcd 4342 (2009) (National Broadband Plan 

NOI). 

Page 25 GAO-10-49 Telecommunications 
 

• Actual delivered speed. Stakeholders also identified limitations regarding 

the speed tests for consumers to measure actual delivered speeds. A 

representative from Akamai, a company that handles approximately 15 to 

20 percent of all Internet traffic worldwide through its global server 

network, said one problem with speed tests is that the result can be 

significantly affected by the location of the server that is used to test the 

speed; the farther away the server, the less accurate the result. Many other 

factors can also affect a user’s speed of service, such as congestion on the 

network, time of day, and other applications that the user may have open 

on the computer when testing. NTIA officials told us that the speed tests 

are not able to determine the Internet traffic congestion points, if any, 

along the chain of networks. An official from the Pew Internet & American 

Life Project told us the results of the speed tests are not verified by other 

parties. He also explained that some third-party Web sites that attempt to 

compare actual delivered speeds have limited numbers of respondents and 

do not have an independent party verify the results, a fact that decreases 

the utility of the information for making comparisons. Finally, an official 

from the Information Technology and Innovation Foundation said the lack 

of comprehensive data for consumers to compare actual delivered speeds 

from providers was a limitation for consumers in comparing service 

options and policy makers in monitoring broadband. Actual delivered 

speed can be an important measure for consumers because it can 

determine whether or not a connection can be used to originate and 

receive high-quality voice, data, graphics, and video. FCC has open 

proceedings on requiring providers to report actual delivered speeds on 

the broadband reporting form, but it currently does not collect this 

information. 

While broadband connection speeds that customers experience are 

generally not identical to the advertised speeds or theoretical maximums 

offered by the broadband provider, there is some evidence that consumers 

are not focused on this issue. Despite access to the tools to measure actual 

speed, one study found that few people actually know the speed of their 

broadband connections. In its report titled “Home Broadband Adoption 

2006,” the Pew Internet & American Life Project reported that 81 percent 

of broadband users did not know their home connection speed. In 

addition, the federal government has received relatively few complaints 

regarding broadband speed. From February 1, 2008, through May 12, 2009, 

FCC reported receiving about 624,000 informal complaints, of which only 

Page 26 GAO-10-49 Telecommunications 
 

157 were related to broadband speed.57 Further, FTC reported receiving 

approximately 147 complaints that could be related to broadband speeds 

from January 2005 through June 19, 2009.58 According to some 

stakeholders, such as the Information Technology and Innovation 

Foundation, consumers appear more concerned with their end user 

experience, such as the ability to complete transactions or use their 

applications. 

• Service reliability. Some stakeholders we contacted, including 

BroadbandCensus.com, IEEE (previously known as the Institute of 

Electrical and Electronics Engineers), the Internet Engineering Task 

Force, Akamai, an economist from the Massachusetts Institute of 

Technology (MIT), NTIA, and Wireless Internet Service Provider 

Association (WISPA) are concerned that there is no measure for 

consumers that addresses service reliability. A service reliability measure 

would provide information to consumers on factors such as transmission 

quality, which affects perceived speed and could be useful to consumers in 

comparing the reliability of broadband services. According to an official 

from Akamai, service quality is the most difficult performance measure to 

define, measure, and relay to a consumer. 

While consumers have measures of price, advertised speed, and actual 

delivered speed to make decisions regarding broadband service, some 

stakeholders suggested improved measures of price and actual delivered 

speeds for consumers, as shown in table 2. 

 

57According to FCC, it did not receive any formal complaints related to broadband speed 

during that time frame. 

58According to FTC, some consumers complained about the fair access policies of 

broadband access providers, particularly satellite, which unbeknownst to the consumers, 

would typically result in slower access speeds after a certain threshold of Internet activity 

was exceeded. In addition, some complained about their actual speeds after using online 

speed tests to compare what they were getting with what was promised in the 

advertisement. Other consumers complained more generally about performance issues, 

like slow speeds and lost connections, which failed to meet their expectations of service, 

and others mentioned their difficulty in attempting to cancel their slow service. Several 

consumers actually said their high-speed service was slower than what they previously 

experienced with dial-up. 

Page 27 GAO-10-49 Telecommunications 
 

Table 2: Broadband Performance Measures Proposed by Stakeholders 

Proposed broadband measure Description 

Price 

Price per megabit per second The price of a broadband offering by megabit per second. 

Average revenue per user A measure generally used by telecommunications companies that states how much 

money the company makes from the average user. This is the revenue from the services 

provided divided by the number of users buying those services. 

Actual delivered speed 

Average actual delivered speed of last-mile 

connections 

The data transfer throughput rate from the end user point (home) to the first aggregation 

point in the networks used by facilities-based broadband providers. 

Contention ratio This is the ratio of the potential maximum demand to the actual bandwidth available. The 

higher the contention ratio, the greater the number of users that may be trying to use the 

actual bandwidth at any one time and, therefore, the lower the effective bandwidth or 

speed offered, especially at peak times. 

Service reliability 

Latency This is the delay incurred in the processing of network data, which can decrease the 

effective bandwidth. A low-latency network connection is one that generally experiences 

small delay times, while a high-latency connection generally suffers from long delays. 

High latency can affect the ability to use certain applications, such as online gaming.a

Source: GAO analysis. 

a

Businesses use the term “quality of service” to refer to measuring and maintaining consistent 

performance on a network by managing both bandwidth and latency in a coordinated fashion. 

As shown in table 3, stakeholders identified arguments for and against the 

proposed measures. 

Page 28 GAO-10-49 Telecommunications 
 

Table 3: Stakeholder Arguments for and against Proposed Measures 

Potential measure Stakeholder arguments for the measure Stakeholder arguments against the measure 

Price 

Price per megabit per 

second 

• Provides a reliable indicator of the value 

of the broadband services purchased by 

the consumer. 

• Provides improved information to make 

comparisons of available services. 

• The measure is not sufficiently reliable, as a wide 

variety of factors affect price, including speed of 

service, term of contract, bundling with other 

services, and promotions, which can make it difficult 

to develop meaningful comparisons. 

• Collecting pricing data would impose significant and 

unnecessary burdens on providers. 

• Price does not necessarily reflect the quality of the 

service. 

Average revenue per user • Provides a method for addressing 

temporary price discounts and bundled 

service. 

• Broadband providers already collect this 

information. 

• The measure is not relevant for consumers, because 

it is not linked to the price and speed of the 

consumer’s service. 

Speed 

Average actual delivered 

speed of last-mile 

connections 

• This portion of the network is where the 

provider has the most control. 

• Providers are likely to have this 

information to help them manage their 

networks. 

• Actual delivered speed is a function of many factors, 

including wiring, computer equipment of the user, 

software and applications being run by the consumer, 

general Internet congestion, responsiveness of 

servers, and other technology-specific factors, that 

limit the reliability of the comparisons. 

• The existence of the various sites that measure 

actual delivered speeds suggests that this is an area 

in which market forces are disseminating the relevant 

information. 

• Collecting these data would impose a significant and 

unnecessary burden on providers. 

Contention ratio • Contention ratios are a useful proxy for 

actual delivered speeds, because the 

higher the contention ratio, the greater the 

number of users that may be trying to use 

the actual bandwidth at any one time and, 

therefore, the lower the effective 

bandwidth or speed offered, especially at 

peak times. 

• Broadband providers are likely to already 

have this information to help them 

manage their networks. 

• A high contention ratio does not necessarily mean 

low speeds or a low contention ratio high speeds 

because the ratio does not account for the 

applications being used by the consumers, such as 

e-mail or downloading movies. 

• Measuring contention ratios would cost an enormous 

amount of time and money, and the information is 

likely to be proprietary and confidential. 

• Most consumers do not have a frame of reference for 

understanding contention ratios, and an extensive 

consumer education program would be required. 

Service reliability 

Latency • Would provide information on the quality 

of the access line. 

• Providers may consider this information to be 

proprietary. 

• Consumers may not be familiar with this measure. 

Source: GAO analysis. 

Page 29 GAO-10-49 Telecommunications 
 

It should be noted that while federal and state agencies and public/private 

partnerships, academicians and think tanks, consumer advocacy groups, 

and trade and industry groups identified arguments for and against the 

proposed measures, broadband providers generally only provided 

arguments against the proposed measures. Thus, while stakeholders 

identified multiple alternatives, they differed on the need for FCC to 

develop additional reporting requirements to measure price, average 

actual delivered speed, and service reliability as follows: 

• Consumer advocacy groups and academicians and representatives from 

think tanks generally believed there was a need for improved information 

on price and actual delivered speeds to make comparisons and good 

decisions about service. These stakeholders preferred that FCC require 

broadband providers to report price per megabit per second and the 

averaged actual delivered speed of last-mile connections (from the home 

to the first provider node or aggregation point) to provide more consistent 

measures for consumers to make comparisons. These stakeholders 

generally believed that calculating price per megabit should be done using 

the published, stand-alone nonpromotional, noncontractual price. Some 

suggested providing an average price by speed tier, while others suggested 

providing the lowest and highest prices by speed tier. Finally, some 

consumer advocacy groups and academicians and representatives from 

think tanks also favored a measure on service reliability to provide 

consumers with information on the quality of their connections. 

• In contrast, broadband providers and trade and industry groups generally 

did not perceive a need for additional broadband measures because, in 

their opinion, price and speed information is readily available from 

providers and third-party sources. According to these stakeholders, 

additional reporting requirements would be an intrusion into a market that 

is working, as evidenced by falling prices for increased speeds. They 

added that additional reporting requirements would be an impediment to 

investment in infrastructure, as more resources would need to be devoted 

to data collection. These stakeholders also reported that price per megabit 

and the average actual delivered speed are difficult to measure (as 

previously shown in table 3), and that FCC is not likely to report the 

information in a timely fashion. For example, in the past, it has taken FCC 

close to a year to report the data from the broadband reporting form once 

it has been submitted by broadband providers. 

• While officials at federal and state agencies and public-private 

partnerships generally said more information is good, there were mixed 

opinions on the need for FCC to require additional broadband measures. 

None of the federal agencies we interviewed provided an opinion; an 

Page 30 GAO-10-49 Telecommunications 
 

official with the California Public Utilities Commission was uncertain if 

additional requirements were needed because similar information is 

already available to the public; and of the two interviewed, one 

public/private partnership was for additional broadband measures and one 

was against. 

Finally, all stakeholder groups generally noted that FCC’s efforts to 

develop periodic surveys, per the Broadband Data Improvement Act,59 and 

a voluntary registry60 for consumers to report information about their 

broadband service, could be used to collect and disseminate price and 

speed information for consumer use. However, stakeholders also 

cautioned that periodic consumer surveys and a voluntary registry may 

not provide reliable information because consumers are not informed 

enough about the price and speed of their broadband service to report 

accurate information, and they believe that this should be taken into 

consideration when reviewing the results. Additionally, consumers may 

not take the time to enter their information in a registry, as current 

voluntary registries for broadband data sponsored by third parties are 

sparsely populated. 

 

59Specifically, the Broadband Data Improvement Act requires the Commission to conduct 

and make public periodic surveys of consumers in urban, suburban, and rural areas in the 

large business, small business, and residential consumer markets to determine the types of 

technology used to provide the broadband service capability to which consumers 

subscribe; the amounts consumers pay per month for such capability; the actual data 

transmission speeds of such capability; the types of applications and services consumers 

most frequently use in conjunction with such capability; for consumers who have declined 

to subscribe to broadband service capability, the reasons given by such consumers for 

declining such capability; other sources of broadband service capability that consumers 

regularly use or on which they rely; and any other information the Commission deems 

appropriate for such purpose. 47 U.S.C. § 1303(c). The Commission’s Broadband Task 

Force is currently working to fulfill this requirement in coordination with the Commission’s 

other broadband-related efforts. On March 31, 2009, the Commission issued a public notice 

that sought comments from stakeholders on how FCC should fulfill this requirement and 

currently has these comments under review. Comparison and Consumer Survey 

Requirements in the Broadband Data Improvement Act, Public Notice, 24 FCC Rcd 3908 

(2009) (BDIA Public Notice). 

60According to FCC, the registry will enable households to use the telephone, mail, e-mail, 

or the Internet to report apparent unavailability of broadband service for their location and 

information about existing service, such as the type and actual speed of Internet access 

service they use. FCC officials told us they are currently working to coordinate the 

development of the voluntary consumer registry for reporting broadband service 

information with efforts to fulfill its statutory broadband-related obligations. The 

Commission anticipates that it will implement the registry in conjunction with the other 

broadband-data-related efforts it is developing under the Broadband Data Improvement Act 

(BDIA) and the American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5, 123 

Stat. 115 (2009) (Recovery Act). 

Page 31 GAO-10-49 Telecommunications 
 

Despite FCC’s efforts to improve the data collected through its broadband 

reporting form, comparisons of broadband service across various 

segments of the country still have the following limitations that diminish 

their usefulness in informing policy and investment decisions: 

• While FCC requires most broadband providers to report broadband 

subscribership on the broadband reporting form, it does not have a 

reporting requirement for these providers to report broadband 

availability.61 Additionally, although the majority of those we interviewed 

cited the change from reporting by ZIP codes to census tract as an 

improvement, some said the data still do not provide enough granularity to 

track subscribership in tribal lands or rural areas. In fact, according to 

FCC’s report Bringing Broadband to Rural America: Report on a Rural 

Broadband Strategy, there are no accurate data on broadband deployment 

in rural America, including where broadband facilities are deployed, 

prices, speeds, and the number of subscribers.62

Current Data Sources for 

Industry and Government 

to Compare Broadband 

across Various Segments 

of the United States 

Have Limitations, and 

Stakeholders Generally 

Support Ongoing Efforts 

for Improvement 

• FCC also does not require broadband providers to report price 

information for broadband services on its broadband reporting form, so it 

is difficult to measure how price varies across various segments of the 

country. The Commission has open proceedings concerning whether and 

how the Commission could collect price information for broadband 

services. For example, the Commission sought comment on requiring 

providers to report, for each state or each census tract in which they offer 

service, the monthly price the provider charges for stand-alone broadband 

service in each of the speed tiers used for the broadband reporting form, 

potential alternatives, and whether and in what form the Commission 

should use the reported service price information.63

• Similarly, FCC does not require broadband providers to include 

information on actual broadband connection speeds experienced by 

consumers, although the data from the revised broadband reporting form 

will provide information on the number of connections by advertised 

 

61Through its broadband reporting form, FCC collects from terrestrial mobile wireless 

broadband service providers the census tracts that best represent their broadband service 

footprint. 

62Michael J. Copps, Acting Chairman, FCC, Bringing Broadband to Rural America; Report 

on a Rural Broadband Strategy (May 22, 2009) (RURAL BROADBAND REPORT), attached 

to Acting Chairman Copps Releases Report on Rural Broadband Strategy, Public Notice, 

DA 09-1211 (rel. May 29, 2009). 

6323 FCC Rcd 9691, 9702 (2008). 

Page 32 GAO-10-49 Telecommunications 
 

speed. As previously mentioned, actual delivered speed can determine the 

applications that can be run by consumers and could be useful in 

comparing broadband service across various segments of the country. The 

Commission also has open proceedings concerning how the Commission 

might require broadband service providers to report actual broadband 

connection speeds, and any alternative means, in addition to or other than 

requiring such service provider reporting.64

• Some stakeholders noted that FCC may overestimate the number of 

wireless broadband users. FCC’s reporting requirement for mobile 

wireless broadband service providers collects data on the number of 

terrestrial mobile wireless subscribers whose subscription and device 

allow them to access the Internet content of their choice, not the number 

of consumers actually using broadband on the device. According to a Vice 

President and Senior Fellow at the Technology Policy Institute, it is 

unlikely that all persons whose subscription and device allow them to 

access the Internet actually use the service. As a result, counts of the 

number of terrestrial mobile wireless subscribers whose subscription and 

device allow them to access the Internet content of their choice may 

overestimate the number of wireless broadband users. However, other 

stakeholders, such as an official with the Rural Utilities Services, thought 

the reporting standard would produce accurate results, as they thought 

most consumers that paid for the service would use it. Stakeholders we 

spoke with generally characterized mobile wireless as a complement to 

and not a substitute for fixed wireline service. They added that this may 

change as the technology improves over time. Stakeholders also generally 

agreed that the mobile wireless counts should be kept separate from fixed 

wireline counts when determining deployment and availability. 

• Stakeholders also identified limitations with the Pew Internet & American 

Life Project data. While the survey collects information on cost, speed, 

availability, and usage, the data are limited because the sample size lacks 

the granularity needed for making comparisons at the state or regional 

level. 

 

6422 FCC Rcd 7760, 7769-70 (2007); 23 FCC Rcd 9691, 9702 (2008); Inquiry Concerning the 

Deployment of Advanced Telecommunications Capability to All Americans in a 

Reasonable and Timely Fashion, and Possible Steps to Accelerate Such Deployment 

Pursuant to Section 706 of the Telecommunications Act of 1996, as Amended by the 

Broadband Data Improvement Act, Notice of Inquiry, 24 FCC Rcd 10505 (2009); A National 

Broadband Plan for Our Future, Notice of Inquiry, 24 FCC Rcd 4342 (2009) (National 

Broadband Plan NOI). 

Page 33 GAO-10-49 Telecommunications 
 

Despite the concerns about FCC’s data collected through the broadband 

reporting form, several stakeholders said they found the data useful. 

According to one academic expert, FCC’s broadband data are the best 

publicly available data on the geographic dispersion of broadband services 

across the United States. In addition, an official with a consumer advocacy 

organization said FCC’s changes to the broadband data collection struck 

the right balance between the need for detailed subscribership data and 

the burden to providers of gathering such information by choosing the 

census tract as the geographic unit for data collection. 

To address the limitations in broadband data, recently enacted legislation 

requires the Secretary of Commerce to obtain more complete data on 

broadband availability. The Broadband Data Improvement Act requires the 

Secretary of Commerce to establish a grant program for multiple 

purposes, including collection of state-level broadband data.65 The 

American Recovery and Reinvestment Act of 2009 requires NTIA to 

establish a comprehensive nationwide inventory map of existing 

broadband service capability and availability in the United States that 

depicts the geographic extent to which broadband service is deployed and 

available from a commercial provider or public provider throughout each 

state.66 By February 17, 2011, NTIA must make the national inventory map 

available online to the public in a form that is interactive and searchable. 

The Recovery Act provides up to $350 million, pursuant to the Broadband 

Data Improvement Act, for developing and maintaining the national 

broadband inventory map. 

NTIA has used the grant-making authority provided under the Broadband 

Data Improvement Act to establish the State Broadband Data and 

Development Grant Program. Through this program, NTIA has solicited 

grant applications from states for projects designed to collect data, 

develop state maps, conduct state planning efforts, and deliver data to 

 

6547 U.S.C. § 1304. NTIA is carrying out this requirement for the Department of Commerce. 

The Broadband Data Improvement Act also directs the Secretary of Commerce, in 

consultation with FCC, to expand the American Community Survey (ACS) to elicit 

information for residential households, including those located on native lands, to 

determine whether persons at such households own or use a computer at that address, 

whether persons at that address subscribe to Internet service, and if so, whether such 

persons subscribe to dial-up or broadband Internet service at that address. 47 U.S.C. § 1303 

(d). 

66Recovery Act, Section 6001(l). 

Page 34 GAO-10-49 Telecommunications 
 

NTIA for the purposes of developing the national broadband map.67 As of 

September 9, 2009, NTIA had received applications representing all 50 

states, 5 territories, and the District of Columbia. NTIA is currently 

reviewing the applications and plans to announce funding decisions 

beginning in early fall 2009. Applicants must demonstrate that they have 

the ability to provide a substantially complete set of all broadband 

mapping data on or before February 1, 2010, and to complete such data 

collection by March 1, 2010.68 NTIA officials told us they are working 

closely with FCC regarding the development of the map. As part of its 

efforts, NTIA is requiring awardees under the State Broadband Data and 

Development Grant Program to provide, among other things, the following 

information:69

• for each facilities-based provider of broadband service, a list of all census 

blocks of 2 square miles or smaller in which broadband service is available 

in the provider’s service area; 

• for census blocks of greater than 2 square miles, for each facilities-based 

provider of broadband service, a list of all street segments in the census 

block in which broadband service is available in such provider’s service 

area; 

• for wireless providers, geographical information system compatible 

polygonal shape files depicting areas in which broadband service is 

available; 

• technology type of service provided by census block, street segment, or 

shape file area, as applicable; 

• maximum advertised speed available across each service area or local 

franchise area, by metropolitan or rural statistical area; 

• actual delivered speed that can be consistently achieved during expected 

periods of heavy network usage by census block, or street segment, as 

applicable; and 

• middle-mile connection points.70

 

67See 74 Fed. Reg. 32545 (July 8, 2009) (Notice). 

68 According to NTIA, all data provided in the first collection should be accurate as of June 

30, 2009. 

69In response to concerns from broadband providers and related trade associations, NTIA 

issued a technical clarification to the notice of funds availability that revised the reporting 

requirements to census block rather than address-specific data and no longer required 

broadband providers to report average revenue per user or last-mile connection points. See 

74 Fed. Reg. 40569 ( August 12, 2009) (Notice clarification). 

70The middle mile is the portion of the networks that leads from the first point of 

aggregation to the first point of interconnection. 

Page 35 GAO-10-49 Telecommunications 
 

Though the program does not require it, awardees may satisfy program 

requirements by providing address-level data. Awardees may also provide 

last-mile connection points, if available. Identification of a provider’s name 

and its availability/speed at a particular address is considered confidential. 

However, identification of a service provider’s specific service area, or 

“footprint,” at the census block or street segment level is not considered 

confidential and will be displayed on the national broadband map. The 

initial period of performance for awards under the program was 5 years 

from the date of the award. However, on September 10, 2009, NTIA 

announced that it will fund the mapping and data collection efforts for 2 

years from the date of the award and will assess lessons learned, 

determine best practices, and investigate opportunities for improved data 

collection prior to obligating funding for subsequent years.71

In the notice of funds availability for the State Broadband Data and 

Development Grant Program, NTIA noted that it reserved the right to 

request that FCC exercise its authority to compel any service provider 

subject to its jurisdiction to provide data. NTIA also explained that, to the 

extent possible, the service areas of individual providers will be 

aggregated with those of other providers of the same technology type. 

According to NTIA officials, this determination was based on its review of 

the comments, an examination of mapping methodologies employed at the 

state level, and consultation with FCC. 

Stakeholders generally agreed that the national broadband inventory map 

would help supplement gaps in FCC’s broadband data by providing 

detailed data on availability and subscribership across the country. For 

example, a Pew Internet & American Life Project official told us that 

broadband mapping has the most potential for providing the granular and 

accurate information required to make comparisons across the country. 

Several stakeholders also explained that in order for the national 

broadband map to be effective, NTIA needs to develop data collection 

standards to help ensure that the data collected by each state are 

comparable across states. Some stakeholders also stressed the need for 

collecting information regarding demand side data (desire for service or 

usage). 

Despite the consensus among stakeholders regarding the potential 

benefits of broadband mapping, there are some concerns about the effort. 

 

7174 Fed. Reg. 46573 (Sept. 10, 2009)(NOFA clarification). 

Page 36 GAO-10-49 Telecommunications 
 

We found NTIA did not provide guidance on how to calculate actual 

delivered speed that can be consistently achieved during expected periods 

of heavy network usage at the address. For example there is no guidance 

on the number of speed measurements that must be taken or a definition 

of heavy network usage. We have previously reported that consistency—

the extent to which data are collected using the same procedures—is a key 

dimension of data quality and a key attribute of a successful performance 

measure.72 NTIA officials told us they chose not to provide this guidance 

because each provider may have a different method for measuring speed, 

and they did not want to prescribe a standard method, given the multiple 

technologies used. However, this could result in inconsistent 

measurements across grantees, limiting the effectiveness of the mapping 

effort in making comparisons across the country. 

While NTIA required applicants to provide a description of the methods 

the applicant intends to employ to verify data accuracy, it did not set out 

specific standards on how to do so. NTIA’s notice of funds availability did 

provide the following example: “A project should propose to collect 

availability data by address . . . and should cross-check that data for 

accuracy by using at least one other metric.”73 We have previously 

reported that both verification and validation of performance data are 

important for reducing the risk of producing inaccurate data; this 

additional information helps to place the credibility of an agency’s 

reported performance data in context for decision makers.74 NTIA offic

told us they chose not to specify how grantees should verify data because

they did not want to be too prescriptive, as allowing states to develop thei

own data verification processes may yield best practices that can be used 

going forward. While it is too early to determine the effect, if any, of the 

limited guidance, the lack of specific standards for data verification could 

result in inconsistent data across states, limiting the effectiveness o

data in making comparisons acros

ials 

r 

f the 

s the country. 

 

The broadband providers we spoke with were generally concerned about 

the cost and burden of complying with any additional reporting 

requirements. For example, officials from Time Warner told us that some 

72GAO/GGC-99-139 and GAO, Tax Administration: IRS Needs to Further Refine Its Tax 

Filing Season Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002). 

7374 Fed. Reg. 32545, 32553, ftn. 27. 

74GAO-02-372. 

Page 37 GAO-10-49 Telecommunications 
 

providers do not store data in an address-by-address format and would 

have to revise their existing data collection procedures, taking time and 

resources away from network upgrades. According to FCC, broadband 

providers already average 337 staff hours to complete the reporting 

requirements for the broadband reporting form. Other stakeholders, such 

as Connected Nation, Consumers Union, and the Organization for the 

Promotion and Advancement of Small Telecommunications Companies 

(OPASTCO), also acknowledged that additional reporting requirements 

can be particularly burdensome to small broadband providers in rural 

areas that do not have the staff and resources of larger broadband 

providers. In addition, the NTIA requirement to provide data on 

availability may overlap with FCC’s requirement for broadband providers 

to report subscribership information through the broadband reporting 

form, because subscribership is a subset of availability. Service must be 

available for a consumer to be a subscriber. To ease the potential burden 

on broadband providers, NTIA has timed its future data collection efforts 

to coincide with FCC’s broadband data collection. 

Finally, some stakeholders, including the Pew Internet & American Life 

Project, Consumer Federation of America, and Consumers Union, were 

concerned that some data underlying the state maps would not be publicly 

available for review. They explained that public-private partnerships often 

agree to nondisclosure agreements with broadband providers to facilitate 

data collection by easing provider concerns regarding what the providers 

consider to be the proprietary nature of the data. However, according to 

these stakeholders, this reduces the transparency of the maps and 

prevents other interested parties from analyzing the information. 

Again, stakeholders generally noted that FCC’s efforts to develop periodic 

surveys (per the Broadband Data Improvement Act) and a voluntary 

registry could be used to collect and disseminate price and speed 

information to make comparisons of broadband service across the 

country. But they cautioned that information gleaned from these efforts is 

limited and therefore should be a supplement to other data collection 

efforts, because, as previously mentioned, consumers may not be well 

informed about the price and speed of their Internet service. 

Page 38 GAO-10-49 Telecommunications 
 

As previously discussed, stakeholders reported that socioeconomic 

differences among countries can limit the efficacy of international 

comparisons. For example, OECD and ITU report broadband subscribers 

per 100 inhabitants rather than as a percentage of households.75 According 

to a senior official at the Technology Policy Institute, household size alone 

explains most of the differences in the broadband rankings of countries, 

since countries with larger households are likely to have lower per capita 

residential connections. As the Phoenix Center demonstrated, even if 

every home and business in every OECD country were wired with a 

broadband connection, the United States’ per capita rank would fall from 

15th to 20th because the United States has a larger average household size 

than countries, such as Sweden and Iceland, that rank above it.76

According to FTC staff, because the socioeconomic status of individual 

countries and the historical nature of their Internet access markets can 

vary widely, simple comparisons of individual indicators such as 

broadband deployment and adoption rates across countries may not be 

meaningful.77

International Broadband 

Comparisons Have 

Limitations for a Variety of 

Reasons, but Stakeholders 

Generally Support FCC’s 

Efforts to Develop 

Additional International 

Comparisons 

In contrast to OECD’s use of subscriber data, the composite indexes we 

previously described attempt to take into account the socioeconomic 

differences and other variables among countries when comparing 

broadband performance. However, according to stakeholders, even 

composite indexes provide limited analysis because of their complex 

nature and the number of variables they seek to measure. For example, 

one of the authors of the Connectivity Scorecard noted that composite 

indexes are “ultimately based on subjective decisions about which 

indicators to include or exclude and how to weight these indicators.”78 The 

more factors or variables considered in a composite index, the more data 

must be collected, normalized, and weighted for comparative purposes. A 

 

75According to OECD, reporting the number of broadband subscriptions in terms of 

households would be misleading because some connections reported by the countries are 

to businesses and normalizing subscribers as a percentage of total households would 

consistently overestimate broadband penetration. 

76George Ford, PhD; Thomas Koutsky; Esq.; and Lawrence Spiwak, Esq., The Broadband 

Performance Index: A Policy-Relevant Method of Comparing Broadband Adoption 

Among Countries (Policy Paper #29), Phoenix Center for Advanced Legal and Economic 

Public Policy Studies, July 2007, 8. 

77Federal Trade Commission Staff Report, Broadband Connectivity Competition Policy. 

Washington, D.C.: 2007. 

78Leonard Waverman and Kalyan Dasgupta, with assistance from Nicholas Brooks, 

Connectivity Scorecard 2009, 57. 

Page 39 GAO-10-49 Telecommunications 
 

spokesperson for the EIU’s E-readiness ranking stated that more variables 

increase the room for error. Multiple variables also make it difficult to 

determine a causal relationship for policy-making purposes between the 

variable and its measured impact on the result, according to officials with 

the European Commission. For example, the EIU included nearly 100 

quantitative and qualitative variables in its E-readiness Ranking Report in 

an attempt to measure the impact of a country’s social, political, 

economic, and technological developments on its ICT usage and 

infrastructure. A representative of the EIU told us that there are 

limitations to this approach, and that some of the unit’s data must be 

estimated because of the sheer number of variables the EIU attempts to 

consider for the 70 countries in the E-readiness Ranking Report. 

Stakeholders also reported that the necessary data to improve 

international comparisons of broadband deployment and penetration are 

not available. OECD and others have noted that while supply-side data 

from broadband providers are both readily available and easily 

quantifiable, demand-side data from consumers for measuring broadband 

penetration are limited. Some stakeholders, such as officials with ITU, TPI, 

and ITIF, have noted the importance of collecting demand-side data 

through household surveys to more accurately reflect how consumers use 

their personal broadband service for economic or social gain. 

Governments are also increasingly recognizing the importance of 

collecting better demand-side data. For example, EU member countries 

are now required to collect household survey data on ICT usage. 

In addition, stakeholders reported a lack of uniformity and reliability with 

the data used to make international broadband comparisons, whether by 

composite index or single indicator. For example, although most of the 

countries that participate in international broadband ranking systems 

recognize broadband to be Internet service above 256 Kbps, there is no 

internationally agreed upon definition for broadband, which affects the 

comparability of the data collected. OECD and ITU have recommended 

uniform reporting standards among their member countries, but the 

standards are neither enforceable nor applicable to countries outside their 

membership. In addition, some of the organizations that develop 

international comparisons rely on participating countries to provide the 

needed data rather than independently gather the data directly from 

providers or in the form of household surveys, a fact that leads some to 

question its reliability. The officials we interviewed from the organizations 

that develop international comparisons told us they have limited ability to 

corroborate the data received from participating governments, outside of 

questioning and confirming a figure when a number appears out of line 

Page 40 GAO-10-49 Telecommunications 
 

with trend data. Estimates are also made when the data are simply lacking 

for a particular country. 

Currently, discussions are also taking place on how to collect and 

differentiate among wireline, wireless, and mobile wireless broadband 

counts. According to OECD, wireless Internet connections at broadband 

speeds are increasingly available and particularly important in 

underserved areas around the world. Similarly Internet access via mobile 

cellular networks has grown rapidly with the increasing availability of 

third-generation (3G) networks and enabled devices that allow users to 

access the Internet over mobile cellular networks using a laptop, cell 

phone, or alternative mobile device. A representative from the Economist 

Intelligence Unit stated that mobile wireless Internet access is particularly 

important for individuals in developing countries, such as in Africa, where 

mobile access may be their primary Internet source. However, 

stakeholders noted that it is important to differentiate between 3G 

subscribers whose plan may allow them to access the Internet on their 

mobile device and those who actually take advantage of the service; 

current data usually do not differentiate and are therefore potentially 

misleading. OECD is in discussions with member countries to develop a 

common methodology to improve the collection of mobile wireless data. 

Despite the concerns raised about the limitations of the measures used for 

international comparisons, several stakeholders found the comparisons 

useful. As previously mentioned, OECD’s count of broadband subscribers 

per 100 inhabitants by technology is one of the most reported figures. 

Representatives from the Consumer Federation of America, Free Press, 

and the Pew Internet & American Life Project said the OECD broadband 

comparisons provide valuable information to policy makers. In its 

guidance on developing composite indicators, OECD noted that composite 

indexes used by other organizations in making international broadband 

comparisons are recognized as a useful tool in policy analysis and public 

communication.79 The indexes serve the important purpose of raising 

awareness among policy makers and the public of areas that deserve 

particular attention in future policy decisions. 

 

79Michela Nardo, Michaela Saisana, Andrea Saltelli, Stefano Tarantola, Anders Hoffman, 

and Enrico Giovannini, Handbook on Constructing Composite Indicators: Methodology 

and User Guide, OECD Statistics Working Paper, August 2005. 

Page 41 GAO-10-49 Telecommunications 
 

FCC has noted that a more fully developed picture of broadband markets 

would provide more accurate and useful international comparisons.80 The 

recent Broadband Data Improvement Act mandated that FCC include in 

future 706 reports information that compares the extent of broadband 

service capability in a total of 75 communities in at least 25 countries 

abroad for each of the data benchmarks for broadband service under 

FCC’s current speed tiers.81 The Commission was directed to choose 

international communities for the comparison that will offer a population 

size, density, topography, and demographic profile that are comparable to 

those of various communities within the United States. In May 2009, FCC 

officials informed us that they had already assembled a cross-bureau team 

of economists and attorneys to perform this international comparison. 

FCC staff is currently in the process of identifying and reaching out to a 

number of countries believed to have the relevant broadband data 

necessary to make such comparisons. According to the officials, they have 

sent letters to 37 countries to request data.82 They are working under the 

assumption that the mandate will require them to communicate the results 

of their comparisons in the next Section 706 report, which is to be 

released in February of 2010. In addition, on March 31, 2009, FCC posted a 

public request for comment on the international comparisons component 

of the act.83 The majority of stakeholders we spoke with generally support 

FCC’s efforts to develop an additional international comparison on 

broadband performance. Although the term “community” was not defined 

in the act and had yet to be defined by FCC, this level of analysis could be 

more granular and therefore more comparable than what is generally 

provided in current international comparison reports. Representatives 

from organizations such as Connected Nation and Free Press support data 

that are collected and analyzed at a more granular local level rather than at 

 

8012 FCC Rcd 9615 (2008). 

8147 U.S.C. § 1303(b). 

82FCC seeks the cooperation of other foreign governments to compile the data in response 

to the international comparison requirement in the Broadband Data Improvement Act. 

Examples of the letter, such as this one sent to the government of Belgium on May 14, 2009, 

are available at http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi under GN Docket No. 09-

47. 

83Comment Sought on International Comparison and Consumer Survey Requirements in 

the Broadband Data Improvement Act. Public Notice, 24 FCC Rcd 3908 (2009) (BDIA 

Public Notice), available at http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-

741A1.txt. 

Page 42 GAO-10-49 Telecommunications 
 

a national level, because they believe that such data make the comparisons 

more relevant. 

A wide range of measures to assess broadband performance is generally 

available to consumers, industry, and government. However, many 

stakeholders told us that the measures used by consumers and those used 

to make comparisons across the United States and among other countries 

have limitations. Reaching a compromise among broadband providers, 

consumer advocates, and others on improved broadband measures in the 

United States has proven to be difficult because they do not agree on 

alternatives for improvement. Nevertheless, all stakeholders are generally 

supportive of NTIA’s State Broadband Data and Development Grant 

Program and its effort to create a national broadband inventory map, 

which could help fill some current gaps in data. NTIA has made progress 

in (1) implementing its State Broadband Data and Development Grant 

Program and (2) requiring grantees to collect data that have important 

implications for consumers, policy makers, and industry in measuring 

broadband performance. NTIA will begin receiving data by March 2010 as 

part of its new grant initiative to collect state-level broadband data and 

establish a national broadband inventory map. However, NTIA lacks 

specific guidance for grantees on calculating actual delivered speeds. 

Without such guidance, it will be difficult to ensure the consistency, and 

therefore the quality, of the data, limiting the effectiveness of the mapping 

effort in making comparisons across the country. In addition, while NTIA 

provided potential grantees with an example of how to verify data 

accuracy, it did not provide specific standards to verify data accuracy. 

Consequently, NTIA will need to determine whether the data provided in 

the initial submission are accurate, and if additional guidance is needed. 

Developing procedures to help ensure consistent and accurate data is 

critical, as NTIA begins to distribute funds to grantees and they begin their 

data collection. More importantly, this effort has the potential to provide 

consumers, policy makers, and industry with accurate and reliable 

information such as broadband availability, type, and advertised and 

actual delivered speed by census block, information that could be used by 

each in their decision-making process and help guide broadband 

investment in unserved or underserved populations. 

Conclusions 

Page 43 GAO-10-49 Telecommunications 
 

To increase the data quality and subsequent results from the State 

Broadband Data and Development Grant Program, including a searchable 

nationwide inventory map of existing broadband service capability and 

availability in the United States, we recommend the Secretary of 

Commerce examine the first round of data collection and determine 

whether to develop specific guidance for grantees to improve the 

consistency and accuracy of the data collected under the program. 

Recommendation for 

Executive Action 

We provided a draft of this report to the Department of Commerce and 

FCC for their review and comment. The Department of Commerce 

provided written comments, which are reprinted in appendix II. In its 

written comments, the Department of Commerce generally agreed with 

our recommendation and stated that it had already begun taking actions to 

address the recommendation. More specifically, the Department of 

Commerce stated that immediately following the awarding of grant funds, 

it will investigate opportunities for improved data collection methods 

including qualitative and quantitative analyses of data collection and 

verification methods, as well as an assessment of which methods are costefficient and accurate. FCC responded that it did not have any comments 

on the draft report. 

Agency Comments 

We are sending copies of this report to the Secretary of Commerce and the 

Chairman of the Federal Communications Commission. In addition, the 

report will be available at no charge on the GAO Web site at 

http://www.gao.gov. 

If you or your staff have any questions about his report, please contact me 

at (202) 512-2834 or goldsteinm@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Contact information and major contributors to this report 

Mark L. Goldstein 

are listed on appendix III. 

Director, Physical Infrastructure Issues 

Page 44 GAO-10-49 Telecommunications 
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To gather information related to both objectives, we reviewed related 

documentation and laws, including the Broadband Data Improvement Act, 

enacted in 2008; the legislative history of the act; the American Recovery 

and Reinvestment Act of 2009 and its legislative history; various Federal 

Communications Commission (FCC) proceedings; and reports from the 

Congressional Research Service (CRS). We also conducted a literature 

review to identify broadband performance measures, including 

international broadband comparisons.1

To identify the broadband performance measures available to consumers, 

industry, government, and other stakeholders, we interviewed officials and 

representatives from several stakeholder groups. On the basis of the 

requirements of the mandate, the literature review, the judgment of our 

staff with expertise in broadband and telecommunications issues, and 

suggestions from the initial interviews held, we determined to include the 

following stakeholder groups in our analysis to ensure a variety of 

perspectives and views on broadband performance measures: 

academicians and think tanks, broadband providers, consumer advocacy 

groups, federal and state agencies and public/private partnerships, 

international organizations, and trade and industry groups. We used the 

same process to identify potential stakeholders for interviews. Table 4 

contains a detailed list of the stakeholders included in our study: 

 

1

Even though the literature review was limited to English-language documents, most 

reports focused on international comparisons are provided in English. 

Page 45 GAO-10-49 Telecommunications 
Appendix I: Scope and Methodology 

Table 4: Stakeholders Interviewed 

Stakeholder category Name 

Academicians and think tanks Johannes Bauer, Co-Director, Quello Center for Telecommunications Management and 

Law, Michigan State University 

Information Technology and Innovation Foundation 

Dr. Bill Lehr, Massachusetts Institute of Technology 

Pew Internet & American Life Project 

Phoenix Center for Advanced Legal and Economic Public Policy Studies 

Technology Policy Institute 

Dr. Leonard Waverman, Dean, Haskayne School of Business at the University of Calgary 

Broadband providers AT&T 

Comcast 

Qwest 

Time Warner 

Verizon 

Wild Blue Satellite 

Consumer advocacy groups BroadbandCensus.com 

Consumer Federation of America 

Consumers Union 

Free Press 

Federal and state agencies and 

public/private partnerships 

California Public Utilities Commission 

Census Bureau 

Connected Nation 

e-NC Authority 

Federal Communications Commission 

Federal Trade Commission 

National Telecommunications and Information Administration 

United States Department of Agriculture, Rural Utilities Services 

International organizations Economist Intelligence Unit 

European Commission 

International Telecommunication Union 

Organisation for Economic Co-operation and Development 

Trade and industry groups Akamai 

IEEE (previously known as the Institute of Electrical and Electronics Engineers) 

The Internet Engineering Task Force 

National Association of Regulatory Utility Commissioners 

National Cable and Telecommunications Association 

National Rural Telecommunications Cooperative 

National Telecommunications Cooperative Association 

Organization for the Promotion and Advancement of Small Telecommunications Companies 

Satellite Industry Association 

U.S. Telecommunications Association 

The Wireless Association (CTIA) 

Wireless Internet Service Provider Association 

Source: GAO. 

Page 46 GAO-10-49 Telecommunications 
Appendix I: Scope and Methodology 

To evaluate the limitations, if any, of the measures, and how the measures 

could be supplemented or improved, we interviewed and reviewed related 

documentation from the stakeholders previously mentioned to obtain their 

opinions and analysis on the strengths and limitations of the measures and 

any potential options identified. We also asked the stakeholders to discuss 

the validity and reliability of the measures and any potential 

improvements. 

Although representatives from the think tanks and academicians we 

interviewed identified limitations with the data that are used to make 

international comparisons, stakeholders generally use the same sources, 

thought the data were adequate, and support current efforts being made to 

improve the quality of the data. 

We conducted this performance audit from February 2009 through 

October 2009 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Page 47 GAO-10-49 Telecommunications 
Appendix II: Comments from the Department Appendix II: Comments from the Department of Commerce 

of Commerce 

Page 48 GAO-10-49 Telecommunications 
Appendix III: GAO Contact and Staff Appendix III: GAO Contact and Staff Acknowledgments 

Acknowledgments 

Mark L. Goldstein, (202) 512-2834 or goldsteinm@gao.gov

In addition to the contact named above, David Sausville (Assistant 

Director), Eli Albagli, Derrick Collins, Amy Rosewarne, Andrew Stavisky, 

Hai Tran, Amy Ward-Meier, and Mindi Weisenbloom made key 

contributions to this report. 

Page 49 GAO-10-49 Telecommunications 

GAO Contact 

Staff 

Acknowledgments 

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