ZeroDivide Comments on National Broadband Plan

ZeroDivide provides financial support, capacity building and technical assistance to nonprofit organizations that benefit low-income, minority, immigrant, non-English speaking, LGBT, aged and disability communities.

Our key comments and recommendations to the Federal Communications Commission regarding the development of a National Broadband Plan are:

Community Engagement

• The Commission should conduct significant outreach to unserved and underserved communities in developing the National Broadband Plan.
• Supporting community institutions is critical in providing broadband access, creating broadband demand, and creating economic, educational and civic engagement opportunities through broadband.

The Market and Affordability

• The issue of price and marketplace competition should be a key consideration in the Commission’s plan. Unserved and underserved communities should be a priority in the national plan.
• Market failure has occurred in certain communities because the product is not affordable and/or applications and content are not relevant to the community.
• Affordability is a determinant of access for low-income and other underserved communities.
• The goals of Affordability and Maximum Utilization are linked, however, affordability is not the only issue which drives adoption(and maximum utilization) in underserved communities.

Demand and Adoption in Unserved and Underserved Communities

• The Commission should consider programs which provide broadband subsidies for low income communities and create low-cost community based broadband services.
• Broadband adoption and demand strategies must be included in a National Broadband Plan to assure maximum utilization.
• Technology adoption programs in unserved and underserved communities work best when tied to other community outcomes such as civic participation, community development, health care delivery, education, worker training, entrepreneurial activity, job creation, and economic growth.

Broadband Mapping and Data

• The Commission should develop a system for collecting data on availability of broadband as well as the broadband adoption
• The broadband mapping effort should include the mapping and tracking of broadband adoption, in addition to broadband availability. 

Accessibility for Individuals with Disabilities

• The Broadband Plan must promote the concept of universal design in broadband networks and application in order to assure that individuals with disabilities can fully access and benefit from broadband.
• These recommendations are based upon our lessons learned over the past decade and focus largely on broadband adoption, demand, training, education and job creation in unserved and underserved communities.

ZeroDivide is a 501(c)(3) public foundation that has invested more than $45 million over the past 10 years in innovative programs that encourage sustainable adoption of broadband services in unserved and underserved communities.

Download entire document (PDF) of ZeroDivide's Comments to the FCC

Link to Press Release on ZeroDivide and Broad Spectrum of Organizations Endorse FCC's Broadband Adoption Recommendations