Berkman Report "an advocacy piece" argue NCTA and Verizon


The Berkman Report fails to accomplish its intended purpose. It is not an "independent expert review of existing literature and studies about broadband deployment and usage throughout the world." Rather, it represents new studies and new data sources that serve the specific policy and ideological goals of Professor Benkler. The Report should be accorded no special treatment simply because it was prepared at the Commission's request. Professor Benkler is an advocate with strongly-held beliefs and the Report is redolent with those biases. In particular, the research and analysis in the Report was structured in a manner that would lend support to Professor Benkler's established and strongly-held views favoring governmental access mandates over policies to promote investment in competitive broadband facilities. The Report simply ignores much of the academic literature that contradicts his policy preferences, giving it no value as an "independent expert review" of the literature. And when contrary evidence cannot be avoided, it is given short shrift or casually dismissed as anomalous. The Berkman Report, in short, is an advocacy piece, not the work of dispassionate scholarship that the Commission requested. NCTA commends the Commission, and in particular its Broadband Task Force, for the intellectual rigor with it appears to be approaching the many inquiries it has initiated to develop the National Broadband Plan. This Report is not consistent with that approach, it is not what the Commission ordered, and it should not be granted special significance exceeding that of any comment submitted to the Commission in this proceeding.

http://fjallfoss.fcc.gov/ecfs2/document/view;jsessionid=LBVHn87krG7M5dKGz1pB9yPQD9BMpW1NbcbhpQNGn8B3rTYqQwBc!543355665!-1624573522?id=7020348491

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