The FCC’s Strategic Plan

In one of those quiet things that the FCC does behind the scenes, the FCC has created a strategic plan for the four years from October 2018 to October 2022. This strategic plan represents their official goals that they report to Congress. This plan also supposedly is how they judge their performance internally. The Strategic Plan has four primary goals:

Strategic Goal 1: Closing the Digital Divide. Develop a regulatory environment to encourage the private sector to build, maintain, and upgrade next- generation networks so that the benefits of advanced communications services are available to all Americans. Where the business case for infrastructure investment doesn’t exist, employ effective and efficient means to facilitate deployment and access to affordable broadband in all areas of the country.

 Strategic Goal 2: Promoting Innovation. Foster a competitive, dynamic, and innovative market for communications services through policies that promote the introduction of new technologies and services. Ensure that the FCC’s actions and regulations reflect the realities of the current marketplace, promote entrepreneurship, expand economic opportunity, and remove barriers to entry and investment.

 Strategic Goal 3: Protecting Consumers & Public Safety. Develop policies that promote the public interest by providing consumers with freedom from unwanted and intrusive communications, improving the quality of communications services available to those with disabilities, and protecting public safety.

 Strategic Goal 4: Reforming the FCC’s Processes. Modernize and streamline the FCC’s operations and programs to increase transparency, improve decision-making, build consensus, reduce regulatory burdens, and simplify the public’s interactions with the agency.

Within each goal there are more specific targeted objectives. For example, the goal for Closing the Digital Divide includes more specific goals like: adopt pro-competitive rules that will expand facility-based competition; ensure that broadband is built everywhere; use reverse auctions to efficiently award USF grants; remove regulatory barriers to next generation technology; develop industry best practices; foster participation in the market by non-traditional participants; free up spectrum to help eliminate the digital divide; continue to free up spectrum in the 600 MHz band; and, conduct timely spectrum licensing.

The period covered by these goals is already barely underway, and yet it’s already interesting to see how the FCC is performing against some of these goals. For example, the first Digital Divide goal is to provide a regulatory environment to promote broadband. This FCC has already tried to walk completely away from regulating broadband, and I have to suppose that they believe the best way to meet this goal is to have no regulations. However, it’s sophistry to claim that lack of regulation is the same thing as a ‘regulatory environment’.

I can think of a number of regulations that would help to foster competition. For example, regulations that curtail monopoly abuses by big ISPs help smaller carriers. Allowing small ISPs to continue to use unbundled copper loops fosters competition (something the FCC wants to end). Making Lifeline funds available to all ISPs fosters competition. Allowing rural carriers to use idle spectrum would foster competition. Many of the actions taken or being considered by this FCC seem to favor large ISPs rather than foster competition. I’m guessing that the giveaways to the big ISPs are covered in the ‘promoting innovation’ goal.

You can make similar observations about many of their goals. For instance, this FCC seems to be antagonistic towards municipal broadband, which makes it hard to meet their goal of fostering participation by non-traditional participants.

I have no doubt that the FCC will claim that they are meeting every goal in the Strategic Plan. The goals are high-level and they are likely to be able to self-grade themselves as successfully meeting each goal. I coach clients on setting goals and I tell them they can’t have soft goals like “bring broadband to more customers in the coming year’. For a goal to have any meaning it has to be far more specific, such as “add 2,000 new broadband customers in the next calendar year”. The FCC’s goals are so nebulous that they can almost do the opposite of the goals and still claim to meet many of them.

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