ICLE Response to FCC Re: Nineteenth Section 706 Report
We submit this letter and the white paper, “Dynamic Competition in Broadband Markets: A 2024 Update,” authored by Eric Fruits, Geoffrey A. Manne, Ben Sperry, & Kristian Stout, for the Commission’s Notice of Inquiry (NOI) regarding the Nineteenth Section 706 Report. The attached white paper addresses several issues raised in the NOI. In it, we find that that the broadband marketplace exhibits dynamic competition which has resulted in more households being connected to the internet, increased broadband speeds while prices have fallen, more households served by multiple providers, and new technologies like satellite and 5G expanding internet access, leading to greater intermodal competition among providers.
As the Commission conducts its inquiry “concerning the availability of advanced telecommunications capability to all Americans” and “determine[s] whether advanced telecommunications capability is being deployed to all Americans in a reasonable and timely fashion,”[1] the innovation and investment present in this dynamic marketplace should not—as in prior administrations—be obfuscated by creative (re-)definitions of what counts as “advanced telecommunications” or “deployment.”
The Commission is right to focus on deployment in a technologically neutral manner. The attached white paper has much data worth considering on how intermodal competition has served consumers well in the broadband marketplace.

Thank you for the opportunity to provide these comments.
[1] 47 U.S.C. § 1302(b).