There is an old vaudeville era joke about diners advertising “blue plate specials” with eye-catching low prices. The trick was that a “blue plate special with food” cost a whole lot more. 

We don’t see blue plate specials advertised these days, but this particular sleight of hand endures, strangely enough in how the Federal Communications Commission wants to define the digital divide. 

Section 706 of the Telecommunications Act of 1996 requires the FCC to determine each year whether broadband is "being deployed to all Americans in a reasonable and timely fashion.” Last year, the FCC’s assessment was holistic – including broadband affordability, adoption, availability, and equitable access - the plate with the food. Unfortunately, the current FCC is backing away from that approach and wants Americans to be satisfied with an empty blue plate. The proposed approach reduces the measure to simply building, or planning to build, the infrastructure alone. We think that's a big mistake.

The FCC’s mission, articulated by Section 1 of the Communications Act of 1934 and reaffirmed by the Telecommunications Act of 1996, is, 

The FCC’s proposed approach to find that broadband deployment can be measured without assessing whether it is available to everyone and what they must pay for it defies both common sense and the core mission of the FCC. 

The FCC’s proposal also ignores Congress. In the Infrastructure Investment and Jobs Act, Congress characterized Section 706 as defining “the statutorily mandated goals of universal service for advanced telecommunications capability.” Section 706 does not treat “availability” and “deployment” as a single concept; the best reading of the law is to give meaning to both terms by the inclusion of multiple factors in assessing deployment. The goal of providing “all the people of the United States” directly addresses universal availability, and the goal of ensuring “adequate facilities at reasonable charges” emphasizes the need to consider accessibility and affordability. 

Without even reaching the interpretation of Section 706, the FCC unquestionably has the power and a clear need to collect and assess information about the practical cost, accessibility, and equitable access of broadband offerings throughout the country.  

The FCC should not, and cannot, blind itself to how these factors affect its overall mission. It is bad policy as well as bad law.

Why This Matters: Broadband Adoption Rates are Slowing

There was some good news during the COVID pandemic: broadband adoption rates went up—mainly from the help of the federal Emergency Broadband Benefit Program and Affordable Connectivity Program. But since 2023, broadband adoption gaps have narrowed at a slower rate. Benton Institute for Broadband & Society research found several trends:

• Low-income Americans continue to lag significantly when it comes to adoption of high-speed wireline service at home, but this group has also been the source of the strongest growth in home wireline subscriptions since 2017.
  
  • 56% of households whose annual incomes are below $25,000 had wireline broadband at home in 2023 compared with nearly 90% for households whose incomes are $150,000 or more.
• Older adults (those age 65 and older) have seen significant advances in connectivity, particularly in subscriptions to cellular data plans. Yet older adults still trail younger age cohorts, especially those age 75 and older.
  
  • 61% of those age 65 and over have home broadband compared with 82% in the age 31 to 50 category in 2023.
• Rural Americans are well short of metro- and urban-area residents in home wireline broadband adoption.
  
  • In 2023, 68% of rural Americans had home broadband subscriptions compared with 80% of those in non-rural areas.

Although public funding of broadband infrastructure in places with a weak business case for investment is important, the demand side is also part of the solution to reach universal connectivity. Analysis of rural/non-rural adoption gaps by income category illustrates this. Low-income rural Americans subscribe to home wireline broadband at a lower rate than upper-income rural households—and the gaps (proportionately) roughly mirror those in non-rural America. In other words, the 80 percent versus 68 percent adoption gap for non-rural and rural households is attributable partly to infrastructure availability but also to reasons other than infrastructure. Low-income rural households are much less likely to have broadband at home than upper-income rural households. Some 81 percent of rural households with annual incomes above $150,000 subscribe to wireline broadband compared with 55 percent of those with annual incomes below $25,000.

By the Benton Institute’s estimation, if rural broadband adoption rates (by income category) were to match those for non-rural households, a little more than one-quarter (28%) of the broadband adoption issue would be solved. The remainder of the adoption problem has to do with non-deployment factors—such as affordability of service, lack of computing devices in the household, and the need for digital skills training to promote meaningful and secure use.

Affordability of service, in particular, is a pervasive problem for low-income households when it comes to having and maintaining broadband connectivity. Benton’s 2024 survey of internet-connected low-income households found that 53 percent of households with annual incomes under $50,000 said it was very or somewhat difficult to pay for service. And 43 percent were “subscription vulnerable,” meaning they have lost service because of difficulty paying broadband bills, find it very difficult to afford service, or live at or near the poverty line.

The FCC Should Also Set Ambitious Broadband Speed Goals

The FCC is proposing to abolish, without replacement, the long-term goal of 1000/500 Mbps established in the Commission’s 2024 Broadband Deployment Report. Benton urges the FCC to maintain the long-term goal for three key reasons:

1. Consumer demand for high-speed service is growing,
2. Market offerings demonstrate that 100/20 Mbps is far from what we might consider advanced telecommunications capability, and
3. The long-term goal can help spur innovation.

First, consumer demand for high-speed service is growing. OpenVault’s Q2 2025 Broadband Insights Report identifies that the average U.S. broadband household had a downstream speed of 568.3 Mbps and upstream speed of 35.4 Mbps, both well exceeding the current broadband benchmark of 100/20 Mbps. Broadband subscribers are using more data than ever, as they use multiple devices for bandwidth-intensive applications simultaneously. Verizon reported that its subscribers had an average of 18 connected devices per household in late 2024, for example. Subscribers are increasingly opting for plans with faster speeds to ensure the performance of simultaneous connected activities. In line with this demand, fiber providers report a 45.2% take rate. Households that are accustomed to using the internet for remote work, telehealth, schoolwork, and entertainment, all with smart devices running in the background, would already find 100/20 Mbps broadband service to be insufficient based on their current internet usage. Emerging consumer applications, such as generative AI and the increasing diffusion of technologies like remote health monitoring, indicate that households may require even more bandwidth in the future. To quote the FCC’s assessment of 25/3 Mbps service just 10 years ago, consumers would not consider 100/20 Mbps “neither futuristic nor attractive only to a narrow set of heavy broadband users or early adopters.”

Second, market offerings indicate that 100/20 Mbps is far from what we might consider advanced telecommunications capability. The FCC’s National Broadband Map data show that 98 million, or 59.56% of residential units in the United States, already have access to 1000/100 Mbps service. At 250/25 Mbps, that number grows to 150.5 million residential units (91.45%). In short, providers already offer service at speeds greater than 100/20 Mbps to a vast majority of American households. At least 10 internet service providers already offer multi-gigabit speed plans that exceed the 1000/500 Mbps long-term goal. Consumers are adopting higher-speed plans due to their increasing bandwidth needs. The long-term goal should align with the market's realities, which already offer 1000/500 Mbps to many U.S. consumer households. 

Third, the notion of abolishing a goal in relation to the technology currently available is entirely antithetical to the pursuit of advanced telecommunications capability for all Americans. By establishing a long-term goal, the FCC effectively signals to the telecommunications sector that innovation will continue. If some technologies cannot consistently meet the goal standard, there is no reason to continue supporting, incentivizing, or motivating their use. Technologies that can no longer meet a benchmark or standard should no longer be considered advanced. To abolish the goal for the reasons stated in the Notice of Inquiry is analogous to declaring the transportation capability of the horse and buggy equal to that of the automobile, because it would constitute discrimination against horse and buggy technology to require it to attain a speed equal to that of the automobile. The telecommunications sector will take the signal of the long-term goal as an opportunity to conduct research and development, leading to new innovations and new market offerings. A vast body of research about the adoption and diffusion of innovations charts how new advances enter widespread use and how technologies with advantageous performance attain popular use, while those with inferior performance are gradually abandoned. It would be laughable to declare the use of technologies that may soon face obsolescence as advanced under the guise of being “technologically neutral,” thereby discouraging innovation in the telecommunications sector.

Finally, a long-term goal can only remain advanced if it changes in relation to demand, market offerings, and innovation. What qualifies as advanced can and should change over time. The Commission should continuously adjust benchmarks, based on the broadband speeds that consumers access, to ensure that consumers in all regions and all people of the nation—including low-income consumers and those in rural, insular, and high cost areas—have access to telecommunications and information services, including advanced telecommunications and information services, that are reasonably comparable to those services provided in urban areas and that are available at rates that are reasonably comparable to rates charged for similar services in urban areas. 

Furthermore, Benton recommends that the FCC adopt a methodology to ensure that the long-term goal changes over time to truly reflect advanced telecommunications capability, as consumer behavior, market offerings, and technologies are dynamic. Our comments reflect a prior statement from the FCC about the purpose of a speed benchmark: “to establish a practical benchmark that is not merely aspirational, but supports a contemporary and forward-looking vision of the high-quality services referenced in the statute.” Benton strongly urges the FCC to retain the long-term goal of 1000/500 Mbps as it is wholly appropriate as a contemporary and forward-looking threshold. 

Conclusion

The Benton Institute for Broadband & Society is a non-profit organization dedicated to ensuring that all people in the U.S. have access to competitive, High-Performance Broadband regardless of where they live or who they are. We believe communication policy - rooted in the values of access, equity, and diversity - has the power to deliver new opportunities and strengthen communities.

© Benton Institute for Broadband & Society 2025. Redistribution of this email publication - both internally and externally - is encouraged if it includes this copyright statement.

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Kevin Taglang
Executive Editor, Communications-related Headlines
Benton Institute
for Broadband & Society
1041 Ridge Rd, Unit 214
Wilmette, IL 60091
847-220-4531
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