The Benton Foundation, Columbia Telecommunications Corporation, Consumers Union, Native Public Media, and New America Foundation respectfully submit comments in response to the Commission’s Public Notice seeking comment on the measurement of mobile broadband network performance. The commenters believe that an open and transparent measurement process that ensures access to the underlying methodology of the utilized measurement tools and to the resulting raw data by the public, researchers and policymakers is essential to the success of this measurement effort and to promoting its extensibility for the future.

The comments provide an overview of several approaches to measuring mobile broadband including a systematic engineering approach and end-user or ‘crowdsourcing’ measurement tools. Commenters encourage the Commission not to focus on a single approach but to utilize a wide variety of tools and tests. The commenters further encourage the Commission to think broadly about measurement and data collection, both to empower consumers and policymakers with data-driven assessments of the capabilities of mobile broadband services and to provide viable sources of data on Internet traffic and network performance for the public and researchers.