Today, TechFreedom and the International Center for Law and Economics filed comments with the Federal Communications Commission in response to a notice of inquiry regarding the promotion of broadband deployment that was included in the Commission’s latest Broadband Progress Report.

The comments urge the FCC “not merely to channel its unique resources towards broadband deployment, but to combine its own collective expertise with that outside the Commission, and to ensure that this work remains a priority for the FCC going forward. If the FCC should lose in court on its re-interpretation of Section 706, preemption of state laws under Section 706, Title II reclassification, etc., this diversification will ensure that the FCC does not wind up empty-handed. Simply put, it is the only way for the FCC to avoid putting all its eggs in one basket.”

The Commission is currently failing to adequately promote broadband deployment, but there are several steps it could take to remedy this problem. For a start, the FCC should evaluate what progress has been made under the Broadband Action Agenda within the National Broadband Plan, and then produce an updated version of the plan with clear steps and benchmarks for promoting broadband.

The FCC should also work to revitalize the Federal-State Advanced Services Joint Conference. The Conference, which was established to facilitate dialogue among federal and state governments on broadband deployment, has convened only once since 2009, and its members consist only of the five FCC commissioners and four public utility commission members from around the country. Because of the limitations on membership in the Conference, the Commission should also establish an advisory committee with members from the federal, state and local levels of government, as well as from the private sector, academia and other interested organizations.

Ultimately, the notice of inquiry regarding the promotion of broadband deployment is an encouraging start, but the FCC still has much to do in order to live up to its responsibility to promote deployment.