There are numerous parties making proposals to the FCC on how to fix the broken broadband mapping program. Today I want to look at the proposal made by USTelecom. On the surface the USTelecom proposal sounds reasonable. They want to geocode every home and business in the US to create a giant database and map of potential broadband customers. ISPs will then overlay speeds on the detailed maps, by address. USTelecom suggests that defining broadband by address will eliminate the problems of reporting broadband by Census block.

Their idea should work well for customers of fiber ISPs and cable companies. Customer addresses are either covered by those technologies or they’re not. But the proposed new maps won’t do much better than current maps for the other technologies used in rural America for a number of reasons:

• Telcos that provide rural DSL aren’t going to tell the truth about the speeds being delivered. Does anybody honestly believe that after taking billions of dollars to improve rural DSL that Frontier and CenturyLink are going to admit on these maps that customers in areas covered by CAF II are getting less than 10 Mbps?
• In the telcos favor, it’s not easy for them to define DSL speeds. We know that DSL speeds drop with distance from a DSLAM transmitting point, so the speed is different with each customer, even with ideal copper.
• Rural copper is far from ideal, and DSL speeds vary widely by customer due to local conditions. The quality can vary between wires in the same sheathe due to damage or corrosion over time. The quality of the drop wires from the street to the house can drastically impact DSL speeds. Even the inside copper wiring at a home can have a big influence. We also know that in many networks that DSL bogs down in the evenings due to inadquate backhaul, so time of day impacts the speed.
• What is never mentioned when talking about rural DSL is how many customers are simply told by a telco that DSL won’t work at their home because of one of these reasons. Telcos aren’t reporting these customers as unservable today and it’s unlikely that they’ll be properly reported in the future.
• Rural fixed wireless has similar issues. The ideal wireless connection has an unimpeded line-of-sight, but many customers have less than an ideal situation. Even a little foliage can slow a connection. Further, every wireless coverage area has dead spots and many customers are blocked from receiving service. Like DSL, wireless speeds also weaken with distance – something a WISP is unlikely or unwilling to disclose by customer. Further, while WISPs can report on what they are delivering to current customers they have no way of knowing about other homes until they climb on the roof and test the line-of-sight.
• It’s also going to be interesting to see if urban ISPs admit on maps to the redlining and other practices that have supposedly left millions of urban homes without broadband. Current maps ignore this issue.

USTelecom also wants to test-drive the idea of allowing individuals to provide feedback to the maps. Again, this sounds like a good idea. But in real life this is full of problems:

• Homeowners often don’t know what speeds they are supposed to get, and ISPs often don’t list the speed on bills. The broadband map is supposed to measure the fastest speed available, and the feedback process will be a mess if customers purchasing slower products interject into the process.
• There are also a lot of problems with home broadband caused by the customer. ISPs operating fiber networks say that customers claiming low speeds usually have a WiFi problem. Customers might be operating ancient WiFi routers or else are measuring speed after the signal has passed through inside multiple walls.

I still like the idea of feedback. My preference would be to allow local governments to be the conduit for feedback to the maps. We saw that work well recently when communities intervened to fix the maps as part of the Mobility Fund Phase II grants that were intended to expand rural 4G coverage.

My real fear is that the effort to rework the maps is nothing more than a delaying tactic. If we start on a new mapping effort now the FCC can throw their hands up for the next three years and take no action on rural broadband. They’ll have the excuse that they shouldn’t make decision based on faulty maps. Sadly, after the three years my bet is that new maps will be just as bad as the current ones – at least in rural America.

I’m not busting on USTelecom’s proposal as much as I’m busting on all proposals. We should not be using maps to decide the allocation of subsidies and grants. It would be so much easier to apply a technology test – we don’t need maps to know that fiber is always better than DSL. The FCC can’t go wrong with a goal of supplanting big telco copper.