Broadband consumer advocates have launched a "Mobile Only Challenge" to show US regulators that cellular data should not be considered an adequate replacement for home Internet service.

The awareness campaign comes as the Federal Communications Commission is considering a change to the standard it uses to judge whether broadband is being deployed to all Americans in a reasonable and timely fashion. While FCC Chairman Ajit Pai hasn't released his final plan yet, the FCC may soon declare that America's broadband deployment problem is solved as long as everyone has access to either fast home Internet or cellular Internet service with download speeds of at least 10Mbps. That would be a change from current FCC policy, which says that everyone should have access to both mobile data and fast home Internet services such as fiber or cable.

"The FCC wants to lower broadband standards," organizers of the Mobile Only Challenge say on the campaign's website. "Pledge to spend one day in January 2018 accessing the Internet only on your mobile device to tell them that's not OK."

The Mobile Only Challenge was organized by Public Knowledge, Next Century Cities, New America's Open Technology Institute, the Institute for Local Self-Reliance, the National Hispanic Media Coalition (NHMC), and other groups. Participants are encouraged to share their experiences using the #MobileOnly hashtag.

Some tasks “near-to-impossible on the phone”

"Already made several adjustments today for work for the #MobileOnly challenge," NHMC General Counsel Carmen Scurato tweeted yesterday. "Keep thinking about how all this would be 100 times easier & faster with access to a desktop and high-speed Internet."

"Wouldn't it be great if the whole FCC took the #MobileOnly Challenge?" she also suggested. "Legal research and word processing tasks are near-to-impossible on the phone."

Wouldn’t it be great if the whole @FCC took the #MobileOnly Challenge? Legal research and word processing tasks are near-to-impossible on the phone. — Carmen Scurato (@CarmenScurato) January 10, 2018

Mobile data generally has stricter data caps than home Internet services, some Mobile Only Challenge participants noted.

"I've been doing the #MobileOnly challenge for three hours and I've already used over 1GB of data," noted Public Knowledge Fellow Daiquiri Ryan. "If I were on a 2GB data capped plan, I would have used OVER HALF of my data today just to answer emails and tweet (which is a necessity for my job)."

Joe Miller, a tech policy podcaster, said he inadvertently took the Mobile Only Challenge when Cox failed to hook up his new Internet service.

"I was FORCED to participate in the #MobileOnly challenge when Cox was a no-show for 3 days after I moved over the weekend," Miller tweeted. "Sure, I was able to CONSUME content. But PRODUCING anything was impossible. By no stretch of the imagination was I 'adequately served.'"

.@fcc @AjitPaiFCC I was FORCED to participate in the #mobileonly challenge when Cox was a no-show for 3 days after I moved over the weekend. Sure, I was able to CONSUME content. But PRODUCING anything was impossible. By no stretch of the imagination was I "adequately served". — Joe Miller (@joemillerjd) January 9, 2018

Mobile and home Internet are both important

The main point of the Mobile Only Challenge is not to say that mobile Internet is unimportant, but rather to demonstrate that home Internet connections and cellular plans are complementary rather than substitutes for one another.

"The FCC's decision would classify more rural and low-income Americans across the country as 'served' by lowering the country's broadband standards while doing nothing to improve service, expand broadband access to all, or close the digital divide," the Mobile Only Challenge website says. "Asking Americans to rely on mobile subscriptions alone to access the Internet ignores the real limitations, speeds, and caps that come with mobile service."

People doing the Mobile Only Challenge seem to have generally just used their phones instead of tethering the mobile Internet connection to a laptop or other device. But using a phone as a mobile hotspot would pose some of the same problems. Even "unlimited" mobile data plans generally cap the amount of high-speed data that can be used for tethering each month to 10GB or 15GB, for example. By contrast, home Internet plans that have data caps often allow 1TB of usage each month.

Annual broadband inquiry

Section 706 of the Telecommunications Act requires the FCC to determine whether broadband (or more formally, "advanced telecommunications capability") is being deployed to all Americans in a reasonable and timely fashion. If the FCC finds that broadband isn't being deployed quickly enough to everyone, it is required by law to "take immediate action to accelerate deployment of such capability by removing barriers to infrastructure investment and by promoting competition in the telecommunications market."

An Obama-era FCC policy still in place today says that all Americans should have access to home Internet service with speeds of at least 25Mbps downstream and 3Mbps upstream and access to mobile broadband. Under Chairman Pai, the FCC's latest broadband inquiry suggested that Americans might only need one or the other but hasn't yet made a final determination.

"We seek comment on focusing this Section 706 Inquiry on whether some form of advanced telecommunications capability, be it fixed or mobile, is being deployed to all Americans in a reasonable and timely fashion," the FCC said in its Notice of Inquiry. "Would such an inquiry best follow the statutory instruction to evaluate the deployment of advanced telecommunications capability 'without regard to any transmission media or technology?'"

The notice also suggested that 10Mbps download speeds and 1Mbps uploads is sufficient for mobile networks, effectively lowering the FCC's broadband speed standard.

The FCC could vote on a final plan at its February 22 meeting. Pai would release his plan three weeks before the vote.

Whatever Pai proposes is likely to pass 3-2, with Republican commissioners voting in favor and Democrats against. Democratic Commissioner Jessica Rosenworcel called the proposal "crazy" in September.

"Lowering standards doesn't solve our broadband problems," she said at the time.

Ordinary Internet users have also pushed back on Pai's proposal by filing comments on the FCC docket.

Comcast says current standard is “arbitrary”

Comcast urged the FCC to declare that broadband deployment is proceeding fast enough. The current 25Mbps/3Mbps standard is "an arbitrary cutoff," Comcast said.

"[A]ny factually based analysis of the marketplace demonstrates that Americans already have access to a growing number of offerings over varied transmission media, including fixed wireless, satellite, and mobile wireless, which are increasingly capable of very fast speeds," Comcast also wrote.

Organizers of the Mobile Only Challenge obviously don't agree.

"Americans know they cannot rely on their mobile service alone for all their online needs," the Mobile Only Challenge website says. "People need fast, robust Internet connections for everyday tasks like applying for jobs, doing homework, or streaming videos."

If the FCC lowers the nation's broadband standards, "the FCC would have no obligation to ensure broadband providers are building out faster Internet connections, disproportionately disadvantaging rural and low-income Americans who are hardest for broadband providers to reach," the website says.