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Regulation - What is it Good For? The Industry

Reporting the Broadband Floor

I want to start by giving a big thanks to Deb Socia for today’s blog. I wrote a recent blog about the upcoming public reporting process for the FCC maps. In that blog, I noted that ISPs are going to be able to continue to report marketing speeds in the new FCC mapping. An ISP that may be delivering 3 Mbps download will continue to be able to report broadband speeds of 25/3 Mbps as long as that is marketed to the public. This practice of allowing marketing speeds that are far faster than actual speeds has resulted in a massive overstatement of broadband availability. This is the number one reason why the FCC badly undercounts the number of homes that can’t get broadband. The FCC literally encourages ISPs to overstate the broadband product being delivered.

In my Twitter feed for this blog, Deb posted a brilliant suggestion, “ISPs need to identify the floor instead of the potential ceiling. Instead of ‘up to’ speeds, how about we say ‘at least’”.

This simple change would force some honesty into FCC reporting. This idea makes sense for many reasons. We have to stop pretending that every home receives the same broadband speed. The speed delivered to customers by many broadband technologies varies by distance. Telco DSL speeds get noticeably slower the further they are transmitted. The fixed wireless broadband delivered by WISPs loses speed with distance from the transmitting tower. The fixed cellular broadband that the big cellular companies are now pushing has the same characteristic – speeds drop quickly with the distance from the cellular tower.

It’s a real challenge for an ISPs using any of these technologies to pick a representative speed to advertise to customers – but customers want to know a speed number. DSL may be able to deliver 25/3 Mbps for a home that’s within a quarter-mile of a rural DSLAM. But a customer eight miles away might be lucky to see 1 Mbps. A WISP might be able to deliver 100 Mbps download speeds within the first mile from a tower, but the WISP might be willing to sell to a home that’s 10 miles away and deliver 3 Mbps for the same price. The same is true for the fixed cellular data plans recently being pushed by A&T, Verizon, and T-Mobile. Customers who live close to a cell tower might see 50 Mbps broadband, but customers further away are going to see a tiny fraction of that number.

The ISPs all know the limitations of their technology, but the FCC has never tried to acknowledge how technologies behave in real markets. The FCC mapping rules treat each of these technologies as if the speed is the same for every customer. Any mapping system that doesn’t recognize the distance issue is going to mostly be a huge fiction.

Deb suggests that ISPs must report the slowest speed they are likely to deliver. I want to be fair to ISPs and I suggest they report both the minimum “at least” speed and the maximum “up to” speed. Those two numbers will tell the right story to the public because together they provide the range of speeds being delivered in a given Census. With the FCC’s new portal for customer input, the public could weigh in on the “at least” speeds. If a customer is receiving speeds slower than the “at least” speeds, then, after investigation, the ISP would be required to lower that number in its reporting.

This dual reporting will also allow quality ISPs to distinguish themselves from ISPs that cut corners. If a WISP only sells service to customers within 5 or 6 miles of a transmitter, then the difference between its “at least” speeds and its “up to” speeds would be small. But if another WISP is willing to sell a crappy broadband product a dozen miles from the transmitter, there would be a big difference between its two numbers. If this is reported honestly, the public will be able to distinguish between these two WISPs.

This dual reporting of speeds would also highlight the great technologies – a fiber network is going to have a gigabit “at least” and “up to” speed. This dual reporting will end the argument that fixed wireless is a pure substitute for fiber – which it clearly is not. Let the two speeds tell the real story for every ISP in the place of marketing hype.

I’ve been trying for years to find a way to make the FCC broadband maps meaningful. I think this is it. I’ve never asked this before, but everybody should forward this blog to the FCC Commissioners and politicians. This is an idea that can bring some meaningful honesty into the FCC broadband maps.

2 replies on “Reporting the Broadband Floor”

“An ISP that may be delivering 3 Mbps download will continue to be able to report broadband speeds of 25/3 Mbps as long as that is marketed to the public.”

Isn’t the /3 in “25/3” the expected upload speed? If they are selling an expected 25 down, but only delivering 3 down, then that should be the floor.

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