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Regulation - What is it Good For?

Testing the FCC Maps

USTelecom has been advocating the use of geocoding to make broadband maps more accurate. As part of that advocacy, the association tested their idea by looking at the FCC mapping in parts of Virginia and Missouri.

What they found was not surprising, but still shocking. They found in those two states that as many as 38% of households in rural census blocks were classified as being served, when in fact they were unserved. In FCC-speak, served is a home that has broadband available of 25/3 Mbps or faster. Unserved means homes having either no broadband available or that can buy broadband slower than 10/1 Mbps.

This distinction has huge significance for the industry. First, it’s been clear that the FCC has been overcounting the number of homes that have broadband. But far worse, the FCC has been awarding grants to provide faster broadband in unserved areas and all of the places that have been misclassified have not been eligible for grants. We’re about to enter the biggest grant program ever that will award $20.4 billion, but only to places that don’t have 25/3 Mbps speeds – meaning these misclassified homes will be left out again if the maps aren’t fixed soon.

The USTelecom effort is not even complete since several cable companies in the state did not participate in the trial – and this might mean that the percentage of homes that are misclassified is even larger. The misclassified homes are likely going to be those in census blocks that also contain at least some homes with fast broadband. Homes just past where the cable company networks start might be listed as being capable of buying a gigabit, and yet have no broadband option.

The existing FCC maps use data that is reported by ISPs using the Form 477 process. In that process, ISPs report speed availability by census block. There are two huge flaws with this reporting method. First, if even one customer in the census block can get fast broadband, then the whole census block is assumed to have fast broadband. Second, many ISPs have been reporting marketing speeds instead of actual speeds, and so there are whole census blocks counted as served when nobody can get real broadband.

The trial also uncovered other problems. The ISPs have not been accurate in counting homes by census block. Many ISPs have never accurately mapped their customers, and so the test found numerous examples of customers reported in the wrong census blocks. Additionally, the counts of buildings by census block are often far off, due in part to the confusing nature of rural addresses.

The bottom line is that the FCC has been collecting and reporting highly inaccurate data concerning rural broadband. We’ve known this for a long time because there have been numerous efforts to test the maps in smaller geographic areas that have highlighted these same mistakes. We also have evidence from Microsoft that shows that a huge number of homes are not connected to the Internet at speeds of at least 25/3 Mbps. That’s not just a rural issue, and for the Microsoft numbers to be true there must be a massive number of urban homes that are getting speeds slower than what is being reported to the FCC.

As dramatic as this finding is from USTelecom, it doesn’t tell the whole story. Unfortunately, no mapping strategy is going to be able to truthfully report the broadband speeds for DSL and fixed wireless. The speed of these products varies by home. Further, there is no way to know if a given home can utilize these technologies until somebody tries to connect them. Perhaps this isn’t important for DSL since there is almost no rural DSL capable of delivering 25/3 Mbps broadband. But any mapping of the coverage area of fixed wireless is going to be suspect since many homes are impeded from seeing a tranmitting antenna or else receive slower speeds than their neighbors due to impediments. The USTelecom effort is mostly fixing the boundary issues where homes are assumed to have broadband today but don’t. The 38% misreporting would be much higher if we could somehow magically know the real capabilities of DSL and fixed wireless.

The current FCC didn’t create this problem – it goes back several FCCs ago to the start of the 477 reporting system. However, I have to wonder if this FCC will change its mind about the status of rural broadband in the country even with better maps. The current FCC released broadband data for 2016 that included a huge error. A new ISP, Barrier Free had reported serving 25/3 broadband in census blocks covering 62 million people, when in June of that year the company didn’t yet have any customers. The FCC gleefully reported that the number of homes without broadband had dropped by 25%, mostly due to this reporting error. Even after correcting the error the FCC still declared that broadband in rural America was on the right trajectory and didn’t need any extraordinary effort from the FCC. I’m sure they will decide that rural broadband is fine, even if the number of unserved homes jumps significantly due to better mapping.

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