This week, the CPUC filed comments with the FCC regarding Section 706 of the 1996 Telecommunications Act (GN Docket No. 15-191, Inquiry Concerning the Deployment of Advanced Telecommunications Capability).
The comments examine some of the phenomena we have observed over the past seven rounds of statewide mobile testing and suggest that the FCC defer its decision on including mobile broadband in its definition of advanced telecommunications capability until the FCC confirms that it has reliable mobile data, and that it has mobile performance benchmarks that include critical performance metrics such as latency and packet loss.
The comments are publicly available from the FCC's web site and can be downloaded here.
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