Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554

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1 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC In the Matter of ) ) Inquiry Concerning the Deployment of Advanced ) GN Docket No Telecommunications Capability to All Americans ) In a Reasonable and Timely Fashion, and Possible ) Steps to Accelerate Such Deployment Pursuant to ) Section 706 of the Telecommunications Act of ) 1996, as Amended by the Broadband Data ) Improvement Act ) REPLY COMMENTS OF THE AGRICULTURAL BROADBAND COALITION 1 Background The newly re-branded Agricultural Broadband Coalition ( ABC ) respectfully submits these Reply Comments to the FCC s Twelfth Broadband Notice of Inquiry ( NOI ). 2 The NOI seeks public input that will enable the Commission to meet its obligations under Section 706 of the Telecommunications Act of 1996 to assess whether advanced telecommunications capability is being deployed to all Americans in a reasonable and timely fashion. 3 1 The Agricultural Broadband Coalition ( ABC ), formerly known as the Rural Broadband Working Group, is comprised of U.S. agricultural sector organizations including the American Farm Bureau Federation ( AFBF ), the American Soybean Association ( ASA ), the National Corn Growers Association ( NCGA ), the Association of Equipment Manufacturers ( AEM ), the Agricultural Retailers Association ( ARA ), Deere & Company ( John Deere ), Trimble Navigation Limited ( Trimble ), and AGCO Corporation ( AGCO ). 2 Inquiry Concerning the Deployment of Advanced Telecommunications Capability to All Americans In a Reasonable and Timely Fashion, and Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, as Amended by the Broadband Data Improvement Act, Twelfth Broadband Progress Notice of Inquiry, FCC , GN Docket No (rel. Aug. 4, 2016) U.S.C. 1302(b). 1

2 Today s farmers are highly incentivized to operate in the most efficient, economical, and environmentally friendly means possible. As the U.S. and world population continues to grow, 4 U.S. agricultural producers respond by producing more food, fuel, and fiber even as resources become more limited and regulatory requirements increase. Over the last fifteen years, many producers have turned to precision agriculture and technology-equipped machine solutions as a way to achieve substantial efficiency and productivity gains. Today s Farmer Needs Broadband Connectivity Farmers are compelled by long-term demand trends to achieve and sustain unprecedented high levels of productivity, by increasing yields and managing inputs with finite amounts of land and water. These trends are leading the transformation of U.S. production agriculture into a technology-driven sector increasingly dependent on access to broadband. In response to these market dynamics, those people and businesses working in and dependent on, the agricultural sector are intensely interested in expediting the deployment of mobile broadband services to farms and cropland. Wireless service is necessary for farmers and ranchers who use precision agricultural equipment. The wireless connection allows farmers and ranchers to make real-time data transfers that can minimize the amount of necessary seed, fertilizer and pesticides, reduce costs for fuel, labor, water, and identify best practices for fields in a given location. 4 World population is expected to climb from approximately 6 billion in 1999 to 9.6 billion by See International Data Base World Population: , United States Census Bureau at (last visited September 15, 2016). 2

3 Comments We agree with the Fiber to the Home Council America ( FTTH ) that consumers residing in rural areas want and need access to the same caliber of broadband services that is available in urban areas. 5 Other parties described the existing disparity in broadband services in rural areas. The Utilities Technology Council ( UTC ) points out in their comments, [t]hirtynine percent (about 24 million) of Americans living in rural areas lack access to advanced telecommunications capability, as compared to four percent of Americans living in urban areas -- making Americans living in a rural area ten times more likely to be denied access to 25 Mbps/3 Mbps broadband. 6 The Competitive Carriers Association ( CCA ) adds: advanced telecommunications capability is not being deployed to all Americans in a reasonable and timely fashion, and urges the Commission to adopt specific reforms to spur broadband deployment, particularly in currently underserved rural areas. Even where broadband deployment has brought advanced telecommunications capability to an area, the majority of Americans including more than 87 percent of Americans living in rural areas have, at most, only one choice of provider for fixed broadband service (including 39 percent with zero providers). 7 As producers, we share the view stated by John Deere in its comments that American farmers are no exception to the rule that those living in rural America need high-speed 5 FTFH Comments in GN Docket No (filed Sept. 6, 2016) at 4. The FTTH Council previously studied the economic benefits of broadband availability for communities and found that, of the communities studied, communities with widely available gigabit broadband enjoyed over $1 billion in additional GDP when gigabit broadband became widely available, relative to communities where gigabit broadband was not widely available. See Early Evidence Suggests Gigabit Broadband Drives GDP, prepared by the Analysis Group for the FTTH Council (Sept. 2014). A link to the study may be found at (last visited July 18, 2016). We note that in addition to its obligations under Section 706, the Commission has a mandate pursuant to Section 254 of the Communications Act that consumers residing in rural areas of the nation have access to telecommunications and information services that are reasonably comparable to those services provided in urban areas.) 47 U.S.C Broadband Progress Report, 31 FCC Rcd at 701, , 4, See id. 6. 3

4 broadband in order to compete in the digital economy. 8 In other words, in addition to agriculture, rural areas also drive vital economic (and now high-tech) activities. Access to much of this technology is wholly dependent on the presence of cell towers and other communications infrastructure in areas of the nation s cropland. Unfortunately, today s farm machines typically operate in rural areas with little or no cell coverage. This coverage shortfall was recently described in a letter to FCC Chairman Wheeler by U.S. Senators Roger Wicker (R-MS) and Joe Manchin (D-WVA) and a bipartisan group of 24 other Senators representing states with significant rural areas and in which agriculture is a major generator of economic activity. 9 Because farming today involves far more than create a plan in winter and execute the plan in the summer, in any successful modern farm operation, a network of agronomists, coops, equipment dealers, farm employees, supervisors, chemical and seed providers, landlords and operators are often in continuous contact during any given day of the year. Agricultural, weather, labor, and equipment information is changing by the hour which drives the need for farmers to employ technology that allows them to adjust and optimize operations rapidly. This activity occurs while work is executed in the field. High-speed data connections to and among these active field operations in real time is therefore necessary to optimize the operation and maximize their opportunities in real-time or near real-time. 8 Comments of Deer & Company in GN Docket No (filed Sept. 6, 2016) at 3 ( John Deere Comments ). 9 Letter to Chairman Tom Wheeler, FCC, from United States Senators Wicker, Manchin, et. al. (July 11, 2016) ( Senate Letter ). The Senate Letter states [s]ignificant work remains to ensure that broadband service are available in rural American and reasonably comparable to services enjoyed in urban areas.without the certainty that essential mobile broadband infrastructure will be deployed and maintained, investments in agricultural productivity will be delayed or bypassed altogether, and the potential efficiency and benefits to rural communities will be lost. 4

5 Therefore, we also fully support the cropland concept referenced by John Deere in its comments that in order to address the mobile coverage gap, we urge the Commission to consider a metric of broadband access in croplands (as defined by USDA major acres of cropland planted) and incorporate into the Commission s Form 477 broadband data collection process, mobile broadband coverage for agricultural operations. 10 The Senate Letter also supports the need to assess specifically cropland coverage: [c]roplands and ranch lands have lagged behind in adequate mobile coverage, even as demand for coverage has grown. To address this gap, we urge you to consider a metric of broadband access in croplands (and farm buildings), in addition to road miles, to identify these areas of greatest need. 11 Conclusion The continued expansion of rural broadband will serve the public interest and should be a top priority of the FCC, as expanded coverage will address important economic, educational, healthcare and other societal goals with respect to the nation s rural communities. We urge the Commission to integrate this priority throughout the Commission s policies including modification and reform to the various support programs, including the Mobility Fund, which can provide a mechanism for enabling affordable broadband access in rural communities where 10 See John Deere Comments at Senate Letter at 2. 5

6 people live, work and travel that is truly comparable to broadband services provided in urban and suburban areas. Respectfully submitted, Nick Tindall Senior Director, Government & Industry Relations Association of Equipment Manufacturers 1000 Vermont Avenue, N.W. Suite 450 Washington, DC Zippy Duvall President American Farm Bureau Federation 600 Maryland Avenue, S.W. Suite 1000W Washington, DC Richard Wilkins President American Soybean Association 600 Pennsylvania Avenue, S.E. Washington, DC Mark N. Lewellen Manager, Spectrum Policy Deere & Company th Street, N.W., 2nd Floor Washington, DC Chip Bowling President National Corn Growers Association 20 F Street, N.W. Suite 600 Washington, DC Dated: September 21,