Berkman Study Flawed, USTelecom argues

The Berkman Center for Internet and Society's draft study of broadband development and strategies in other countries is, unfortunately, seriously flawed. In concluding that unbundling policies play a critical role in broadband development, the Berkman Study contains numerous errors, omissions, and internal inconsistencies. As a result, it should not be relied upon by the FCC in formulating a National Broadband Plan. First, the Berkman Study incorrectly attributes successful broadband development in certain other countries to unbundling policies. Second, the Berkman Study employs a flawed methodology in finding a positive causality between unbundling and broadband development. Finally, the Berkman Study contains numerous internal inconsistencies and statements that contradict its own conclusions. These inconsistencies raise serious questions as to the Berkman Study's overall reliability.