The New America Foundation’s Open Technology Initiative (NAF) submits these
comments in response to the Public Notice seeking comment on the broadband measurement
methodology proposed by SamKnows Limited (SamKnows). NAF believes the SamKnows proposal will serve as an important component to the Commission’s broadband data collection efforts and provide policymakers key data for assessing the state of broadband and the Internet in the U.S.
We commend the Commission for moving forward on a systematic effort to collect
fundamental data on the actual performance of residential broadband networks. The data
gathered through this effort is likely to provide critical information to better understand the state
of broadband and the Internet in the U.S. and is integral to “data driven” policymaking. We
encourage the Commission to ensure the process remains as open and transparent as possible to
ensure the accuracy of the data collection process and the credibility of the results. Moreover, the
Commission should make the raw data publicly available, while protecting user privacy, to allow
for independent, diverse, and innovative analysis.