Who Should Report to the FCC Mapping?

I think there are a lot of ISPs that are not participating in the FCC data collection effort that the industry refers to as the broadband maps. In almost every county I’ve ever worked in, I run across a few ISPs that are not reporting broadband usage. There are several categories of ISPs in this category.

I often run across small regional WISPs and occasionally across fiber overbuilders that are not listed in the database. I know these ISPs are there because people claim them as their ISP when we do a broadband survey. These ISPs generally have a website that lists broadband rates and coverage areas – but for whatever reason, these ISPs do not participate in the FCC mapping database.

My guess in most cases is that these small ISPs don’t think they are required to report – they either don’t even know about the database, or they don’t fear any repercussions for not reporting. These are generally small single-owner or family businesses, and the owners might think that broadband isn’t regulated. Some of these ISPs have operated for years, and nobody has ever knocked on their doors about regulation, so they remain either blissfully unaware of their obligation to report or they don’t think it is important.

Another category that often doesn’t report is local governments that provide the fiber connectivity to their own buildings and sometimes to a few key businesses in town. These are not always small, and there are municipal networks in larger cities that are not included in the FCC database. Many cities don’t think they are ISPs even if they perform all of the ISP functions. They provide bandwidth to and from the Internet using facilities that they have built to connect to users. In some cases, there is an underlying ISP serving the city, but often there is not. Another similar category is school networks that buy wholesale bandwidth and do all of the ISP functions.

These local governments are doing themselves a disfavor by not reporting because their government buildings are not listed as being served by fiber. That could open up the door for some other ISP to ask for grant funding to serve the anchor institutions in the region that are already served.

Another interesting group of ISPs that often doesn’t report to the FCC is companies that buy wholesale loops from an open-access or leased loop environment. Generally, these loops are pure transport, and the ISP has to handle the functions of routing traffic to and from the Internet. These folks also often don’t think they are ISPs because they don’t own the fiber loop – but the entity that performs the ISP functions for a customer is the ISP and should be reporting to the FCC. These are often small companies that tackle being an ISP as a sideline business and I would guess they don’t think they are regulated.

The group that mystifies me the most are some of the big national ISPs. There are ISPs who have nationwide contracts to serve all branches of national chains like hotels, banks, etc. In a city of 20,000 or larger, there are often a half dozen such ISPs serving one or more businesses. But I regularly find that a few big ISPS are not reporting to the FCC. I’ve always wondered if some other big ISP includes these customers in its reporting, but when I look at the granular data, it often looks like many of the national chains served by fiber are not claimed by any ISP. The new FCC mapping is going to get a lot more granular and maybe we’ll finally be able to see if such connections are reported by somebody.

Adding together all of the ISPs that don’t report is likely only a minuscule sliver of the ISP market. However, these are often some of the most important connections in a city since they are the customers served with fiber. A small-city fiber network might be bringing multi-gigabit broadband to city buildings or a handful of businesses, and nobody knows about it.

I don’t know that the FCC has any hope of uncovering these small ISPs, and it’s not worth the investigative effort to identify them. But at least part of the blame for this lies at the FCC. The agency doesn’t have clear guidelines in plain English defining who is an ISP, with examples. But it might not help even if the FCC did, since it seems that many small ISPs barely know the FCC exists.