Bringing Back Payphones

My last blog for the year includes a nostalgic look back at my days as a telephony guy – many of my older readers will get it. The Washington Post recently had an article about Mike Dank, who is working to bring free payphones to Philadelphia.

I can remember growing up when payphones were ubiquitous. The peak of the market was 1995, when there were 2.6 million payphones in the country. There was an outdoor payphone at every gas station and around many retail stores. There were payphones inside businesses like hotels, malls, and any other place where a lot of people gathered. And there were big banks of payphones at airports. Anybody who did business travel in the days before cellphones can remember rushing off airplanes to try to find an open payphone.

I rode along once with folks in the payphone department at Southwestern Bell who told me about the elaborate process for collecting coins from phones and for making sure that the coin boxes weren’t getting robbed or embezzled. It required an elaborate effort in large cities to continually empty and count the coins from payphones.

In the days before the deregulation of the big telephone companies, most payphones were provided by the big Bell Telephone Companies. After divestiture into the regional Bell companies, the payphones all got relabeled as AT&T. When traveling, I’d run into payphones from smaller telcos, such as the banks of telephones in the Pittsburg airport that were provided by the North Pittsburgh Telephone Company, which happened to be the monopoly provider at the airport site.

Eventually, the FCC broke up the payphone monopoly, and the payphone business went a bit crazy. There were banks of phones in airports from companies you had never heard of with signs luring travelers to use their phones instead of the telco phones. Hotels were besieged by salespeople trying to get their phones into the lobby. Everybody walked around with a few calling cards in their wallet. But eventually, the ubiquitous presence of cell phones killed the payphone business. One by one, the old telephone booths and wall payphones were torn down and junked.

Payphones aren’t entirely gone, and this Google Map site supposedly shows the remaining payphones. If this site is right, there are still 307 working payphones in the country. Here in North Carolina, the only remaining payphone shown is at the Greensboro airport.

Mike Dank is a 31-year-old guy who became intrigued by payphones. He picked up a payphone for $20 at a flea market a few years ago that has been sitting in his basement. He heard about a group in Portland that had installed ten payphones that provide free calling to the public. This provides a public service to folks who can’t afford a phone or who need to use one in an emergency. In case you don’t remember, you could always call the operator for free from a telco payphone.

He rewired the phone so that it could work fusing WiFi, and he talked a Philadelphia books store, Iffy Books, into installing the phone. The phone uses online software to place a phone call to anywhere in the country (and many places around the world). The bookstore reports that the free phone has been popular and is in steady use.

Dank says that he’d love to rehab more old phones if he can find them. He estimates that it costs around $300 to refit a phone to be able to connect to broadband, so this is a labor of love – but one that I think most old telephone guys will appreciate. Do any of you old telco guys still have old payphones in the basement?

More Assistance for Rural America

The Biden Administration launched an initiative earlier this year that has some interesting benefits for rural communities. The new initiative is called the Rural Partners Network, and has the goal of helping rural areas maximize the benefits available from the federal government.

The new program is putting federal employees directly in rural communities and making them available to help rural communities navigate the confusing federal bureaucracy.

As an example, one of the primary roles of the RPN is to help local communities find and apply for grants. I know this would be extremely useful just in the area of broadband. I’ve counted dozens of distinct ways that communities can get grant funding to help with broadband. By now, most of them have heard of the giant $42.5 billion BEAD grants, but there are many other grants available. For example, there are dozen of grants related to broadband that can go to rural schools and libraries. There are grants for strengthening the electric grid that might allow rural electric companies to extend middle-mile fiber where it’s highly needed. There are grants for rural healthcare facilities. And there are grants for digital inclusion which be used to buy computers and teach people how to use them. These same grants could be used to establish more formal technical training courses.

This blog clearly focuses on broadband issues, but there is a dizzying array of grants for other purposes as well. There are grants to help people kick-start an interesting new business idea. There are grants that help local non-profits meet their goals. There are grants to pay for online education and training. There are grants to help people to get their finances organized in order to qualify for buying a house. But the list of federal grants is so huge that it’s almost impossible for somebody to wade through the possibilities.

The new program will be part of the Department of Agriculture. But the program promises to help rural people and communities work with the Departments of Commerce, Education, Interior, Treasury, the Small Business Administration, and dozens of other agencies.

The RPN has already deployed people in Alaska, Arizona, Georgia, Kentucky, Mississippi, Nevada, New Mexico, North Carolina, Puerto Rico, West Virginia, and Wisconsin. The goal is to get these folks deployed everywhere, assuming the funding is approved by Congress.

I work in rural America a lot, and in my experience, many counties are not able to navigate the huge number of grant opportunities or complete grant requests even if they know about them. This puts small communities at a huge disadvantage compared to larger cities that have a department of full-time grant writers on board. This program will help make sure that federal funding ends up where it’s needed the most.

Should ISPs Consider Open-Access?

There are suddenly a lot of open-access networks springing up around the country. Traditionally, open-access networks have been built by local governments such as the PUDs in Washington, the small cities in Utah that are part of Utopia, or cities in states like Colorado. Today, there are also open-access networks being built by commercial network owners.

I’ve been asked by several ISPs if they should consider operating on an open access network. Like with any decision of this magnitude, there are no easy right or wrong answer, but instead a lot of pluses and minuses to consider. Following are a few of the most important factors to consider about operating on an open-access network.

Capital Expenditures. One of the primary reasons to think about using somebody else’s network is the savings from not having to fund and built a new network. For small ISPs without a lot of borrowing capacity, an open-access network might be one of the easiest ways to get more customers.

But there is a flip-side to not spending money on capital. If the ISP plans on eventually selling the business, there is a lot more long-term value created by owning a network than by riding somebody else’s. There might be far more corporate value created by building a small fiber network with a few thousand customers than by serving 10,000 customers on an open-access network. If you pursue open-access, it has to strictly be about the cash flow generated today rather than about the value created in the future.

Economy-of-scale. Another reason to consider operating on somebody else’s network is that anything that makes your ISP larger adds to economy-of-scale. There is a big benefit to spreading the costs of overheads like OSS/BSS systems and corporate staff costs over as many customers as possible. Any costs you can shuffle off to an open-access expansion should make your other markets more profitable.

But economy-of-scale savings can diluted if you decide to tackle a open-access network that is far away from your existing operations. It’s never as cost-efficient to open and operate in a new distant market compared to one that is next door.

Trust. One of the scary parts of being on an open access network is being captive to the processes and prices charged by the network owner. An ISP is taking a leap of faith that the network owner will always perform as promised.

If the network owner decides to increase wholesale rates, there is no option but to go along. While a rate increase would also apply to the other ISPs on the open-access network, it’s possible for rates to get too high compared to other competitors like the cable company.

It can also be a problem having to rely on somebody else’s processes. For example, in most open-access networks, the network owner builds new fiber drops and installs customer electronics. It can be devastating for a marketing plan if the network owner can’t deliver customer installations on time, or decides it has a limited budget to add more customers. An ISP is also a captive of all other processes of the network owner like trouble reporting and resolution, timely network upgrades, network monitoring, and the ordering process. Even if the processes are good today, the network owner can change the way they do anything. This is possibly the biggest reservation for an ISP that is used to working on its own network.

No Technology Advantage. It’s an odd situation for an ISP to be operating on a fiber network and yet have no technology advantages over many of your competitors. Every ISP on the open-access network has the identical capabilities as you. This means that an ISP on an open-access network must distinguish themselves through either price or customer service. Open-access can turn into a race to the bottom if one of the ISPs on the network decides to deeply slash prices.

This blog wasn’t meant to scare ISPs away from working on an open-access network. There are ISPs that are thriving in this environment. But it’s not for everybody, particularly for ISPs that want to control the customer experience from beginning to end.

FCC Cellular Broadband Mapping

I mostly write about broadband, but one of the most common complaints I hear from rural folks is the lack of good cellular coverage. Poor cellular coverage doesn’t seem to have gotten the same press as poor broadband, but not having access to cell phones might be more of a daily challenge than the lack of broadband.

For the first time, the new FCC maps now show us the claimed coverage everywhere for each cellular carrier. This coverage is shown on the same maps used for broadband.

People are going to find the claimed cellular coverage to be confusing since the FCC is showing coverage using massively out-of-date cellular speeds. The FCC maps only ask a cellular carrier to show if it meets the FCC definition of cellular broadband, which is embarrassingly low. A cellular carrier only needs to achieve a speed of 5 Mbps download and 1 Mbps upload to be considered covered for 4G. The FCC has two claimed speed tiers for 5G at 7/1 Mbps and 35/3 Mbps.

The FCC speed thresholds for cellular are massively out of touch with modern technology. According to Ookla’s nationwide speeds test, the national average cellular speeds at the end of the third quarter of 2022 was 148 Mbps download and 16 Mbps upload. The national median speed (meaning half of people are either faster or slower) was 75 Mbps download and 9 Mbps upload. The FCC is sticking with its obsolete definition of cellular broadband speeds for the same reasons it has stuck with using 25/3 as the official definition of broadband – the primary reason likely being the lack of a fifth FCC Commissioner.

That makes the FCC cellular maps largely useless for people in cities. What does it mean if a cellular carrier claims a 5G connection of 7/1 Mbps – that’s probably not even one bar of coverage. My house shows coverage from AT&T, T-Mobile, Verizon, TDS (US Cellular), and Project Genesis, the new Dish Network offering. AT&T claims only 4G coverage at my house and doesn’t claim a speed capability, even though I just tested at over 150 Mbps download as I was writing this blog. The other four carriers claim 5G coverage and speeds of at least 7/1 Mbps, while T-Mobile and Project Genesis claim speeds of at least 35/3 Mbps. The FCC reporting doesn’t give me any idea if I can trust any of these carriers at my house.

That’s because cellular coverage areas are incredibly hard to map. This is something that everybody in America is already an expert on. No matter where you live, you see the bars of available data vary at your house hour-by-hour and day-by-day. Cellular networks are broadcast networks that blast signals to anybody in range of a cell tower. Cellular radio signals can be disturbed by heat, humidity, air pollution, and temperature. And the strength of the signal varies depending on the number of users on the network at a given time.

It’s convenient to picture cellular coverage areas as a circle around a tower, with the signal being broadcast outward everywhere – but that is only true to the flattest and most open places in the county. Cellular signals are blocked or deflected by impediments in the environment, like hills and buildings. While cellular signals travel decently through foliage, leaves still add distortion and cut the distance and strength of a signal. A more apt way to picture a cellular coverage area is as an amoeba with different length arms reaching in many directions.

Because of the physics of cellular delivery, the claimed coverage by cellular companies has been badly overstated. For years, cellular companies have published maps that claim they have the best nationwide coverage – but those maps are badly distorted when looking at real places. Every cell phone user understands dead spots. My house is a good example. I live downtown in a city, and cellular coverage is generally good. But I live partway up a hill, and at my house, there is zero Verizon coverage, although folks at the other end of the block can get Verizon. I use AT&T and run into AT&T dead spots as I drive around.

Rural cellular coverage in the past is often the most exaggerated. Anybody who has driven through rural America knows that a lot of the claimed coverage is bosh. The FCC is hoping to rein in the exaggerated coverage claims of cellular carriers. You can challenge the cellular coverage at your home in the same way that you can challenge landline broadband coverage. The challenge is built directly into the FCC broadband map. When you type in an address, you’ll see a place on the top right to toggle between fixed and mobile broadband. Unfortunately, the method of challenging cellular coverage is cumbersome, and I’ll cover it in another blog.

There is also a process for bulk challenges of cellular broadband by local governments. This means gathering a lot of cellular speed tests around a community, done in a way that meets the FCC rules. I’ve already seen several counties that have started the bulk speed testing to challenge the maps.

Progress Against Robocalling

I mostly write about broadband these days, but we can’t forget that telephony is still a significant part of the industry. While the national penetration rate of residential landline telephones has dropped to about 20%, most businesses continue to have telephones, and practically everybody has a cellphone.

The bane of telephony continues to be robocalling and other nuisance calls that pester anybody with a telephone. There are bad actors that impersonate government or commercial entities with the goal of scamming the elderly and other vulnerable individuals. Scammers pretend to be the Social Security Administration, banks, utilities, the local sheriff, or tech companies in an attempt to solicit credit card numbers or other valuable data from people. In a more development robocalls are used to launch denial of service attacks against hospitals and public service entities to block the ability to send or receive legitimate phone calls.

There is a systematic industry effort to squash robocalling. The Industry Traceback Group includes a collaboration of over 400 wireline, wireless, VoIP, and cable companies that are tackling the robocalling issue. This group works with law enforcement to trace, identify, and stop the sources of illegal robocalling. The group’s goal is to block or shut down illegal robocalling.

The effort is having an impact and routinely has been able to black robocall operations. Earlier this year, the FCC issued a record $225 million in fines against two Texas companies, Rising Eagle and JSquared Telecom. These companies had been making billions of illegal spoofed calls (where they used a false call-from number) to sell fraudulent health insurance. The callers claimed to represent major insurance companies like Aetna, Blue Cross Blue Shield, Cigna, and UnitedHealth Group.

There was a Supreme Court decision earlier in 2022 which threatened to weaken the effort to slow and stop robocalling. The case, Facebook v. Duguid, focused on the definition of an automatic telephone dialing system, which is commonly called an autodialer, as defined in the Telephone Consumer Protection Act (TCPA) from 1991. The Act defined an autodialer as equipment that can store telephone numbers to be used by a random or sequential number generator. The Supreme Court ruled in favor of Facebook and found that definition to be narrow and to only apply to a specific type of calling equipment.

This ruling hasn’t slowed down the Industry Tracking Group since most robocalls still violate the 1991 legislation. Calls made for the purposes of scams still violate the law. It is still illegal to call cell phones with a prerecorded or artificial voice without the permission of the user. Telemarketing calls often also violate state laws when spoofing with false caller ID is used with the intent to defraud or cause harm to call recipients.

The large FCC fine and the attempt to shut down robocalling operations have, unfortunately, driven the robocalling industry overseas, and a large percentage of robocalls now originate from overseas.

The industry is fighting against robocalling in several ways. First, many carriers have provided call-blocking tools to subscribers to block calls from unwanted numbers. The industry has implemented and continues to refine the STIR/SHAKEN process that makes it harder for robocallers to spoof telephone numbers. Probably most importantly, the industry is working with law enforcement to shut down illegal robocalling operations.

One of the most interesting features of the effort is the labeling of calls. I use AT&T for cell service, and my caller ID labels routinely identifies calls as either a telemarketing call or as potential spam. While it’s annoying to continue to get these calls, it’s comforting to be able to ignore them.

Can Frontier Reinvent Itself?

Diana Goovaerts recently wrote an article that quotes Frontier’s Consumer EVP John Harrobin as saying that Frontier expects to become the ‘un-cable” option in the market. He says that Frontier is doing this by simplifying its product lines to eliminate behavior that customers hate.

One of the biggest changes is to get rid of special pricing, where a customer signs with an ISP due to a low-price special, only to see the rates jump up at the end of the special period. This is the one characteristic of big ISPs that customers dislike the most. For years I’ve been advising smaller ISPs to avoid the practice and to offer a fair price all of the time.

I have ISP clients who sometimes panic when they see big ISPs offering special prices as they enter a new market. The specials work to some degree, and the big ISPs lure some customers with the special prices. But small ISPs have learned that after a year or two, when the special pricing ends, they have a good chance to win most of these customers. Small ISPs have learned that when they treat customers fairly that those customers don’t bite on new pricing offers. In the long run, the best way to reduce churn is to treat customers fairly and with transparency.

The interview didn’t mention it, but if Frontier is going to be an un-cable ISP, it also will have to eliminate hidden fees. These are the fees that are not included in advertising but appear on the first customer bill, usually as an unpleasant surprise. The biggest hidden fees are for cable TV service where ISPs hide programming and sports fees and settop box fees – and where a first bill can be $30 higher than the advertised price. But big ISPs do the same thing and don’t mention expensive modem fees in advertising – and customers are instantly unhappy when they get a first bill where the actual price is $10 or $15 higher than the price they expected.

Frontier has announced plans to build fiber to pass 10 million homes and businesses. The company was getting creamed by competition as long as it primarily offered DSL. In 2018, Frontier lost over 200,000 broadband customers. In 2019 the losses grew to 235,000, and in 2020 the company lost 400,000 broadband customers. But by 2021, Frontier started turning the ship around and only lost 35,000 customers for the year as fiber additions started to outnumber DSL losses.

Frontier has a long way to go to have its customer base come to trust it. The company was guilty of all of the same sins as other big rural telcos. It cut back on maintenance to the point where customers might be out for a week or two before they heard from a technician. In many cases, the company would disconnect a customer that had a problem rather than fix it. The company accepted federal CAF II funding, but many customers saw little or no improvements. Frontier has a long way to go to regain the trust of customers that it largely abandoned for many years.

Building fiber is a huge start to regaining customer trust since delivering broadband that actually works is essential to have customers want to stay with any ISP. But Frontier is still going to have to demonstrate to customers that it cares about them when there is a problem. Most small ISPs try to clear customer problems within a day of a trouble report and will work extra hours to do so. If Frontier really wants to be the un-cable company it will mean adding maintenance staff. Folks have become so reliant on broadband that they are annoyed if they lose service for an hour – they won’t forgive an ISP that puts them out of service for a day or longer.

Frontier has also been embroiled in a few overbilling controversies in recent years, and being the un-cable ISP means taking the attitude that the customer is right, even if that costs the company a few bucks.

It’s going to be interesting to see if Frontier’s practices live up to the public relations hype. There is one sign that perhaps the company has started to turn the ship. In the 2022 American Customer Satisfaction Index, the consumer rating of Frontier jumped from 57 to 61 in one year. In 2020, the only ISP with a worse customer rating was Suddenlink. Within a year, the company bypassed the rating for MediaCom and CenturyLink. A 60 rating still means that Frontier (and most other ISPs) is still the most disliked companies among 45 different major business sectors. But if Frontier can sustain being an un-cable ISP, then over time, customers will begin to trust the company again.

Access to the FCC Broadband Maps

I suspect that there are already a lot of communities and other folks who are in violation of the license agreement to view and use the new FCC mapping fabric and associated data. CostQuest, the firm that created the mapping fabric, has provided communities and others with a basic license to view and utilize the mapping data strictly for the purpose of the Broadband Data Collection (BDC) process – for reviewing and challenging the FCC maps.

Anybody that wants to use the mapping data for any other purpose must sign a different agreement and pay to utilize the data. The basic CostQuest agreement clarifies that the mapping data can’t be used for any other purposes and gives examples of uses that are prohibited under the basic use contract. Communities or others with the basic license can’t use the mapping data to:

  • Prepare for the BEAD program, grant proposals, or other funding initiatives.
  • Broadband Mapping.
  • Opportunity Analysis.
  • Network Planning or Design.
  • Marketing purposes, such as sending mailers to addresses or identifying new customers to target marketing efforts.

I have to think that communities have already violated some of these prohibitions. It’s natural when getting the new data to want to map it so that elected officials and other stakeholders can see what has been reported to the FCC. I have a hard time thinking that ISPs won’t use the data when determining areas that are eligible for grants.

I am completely flabbergasted by this whole process. The FCC paid CostQuest $44 million to create the maps. One would think that would mean the resulting maps and data belongs to the FCC, and that CostQuest is just a vendor hired to create the maps and mapping fabric. But it appears that having created the maps is creating a permanent revenue stream for CostQuest, and the company is acting as if it is the owner of the federal mapping data. The NTIA has been negotiating to pay an additional $49.9 million to CostQuest to be able to use the mapping data during the BEAD grant process.

You have to let that sink in. One federal agency is paying a license fee that is higher than the cost of creating the maps in order to use the data that is gathered by the FCC. I have to imagine that CostQuest plans to extract fees from ISPs and communities to use the data for any purpose other than the BDC mapping challenge.

This raises a lot of questions, starting with the big question of why the FCC would allow a vendor to extract big fees to utilize a software system and data mandated and paid for by the FCC. Perhaps the bigger question is why broadband mapping data isn’t publicly available to everybody.

The funny thing is that you don’t need a license to use the data – just a license to use it easily. I looked at my own neighborhood, and I can see the ISPs that claim to be able serve each home, and in doing so I can see the border of any ISP’s claimed service area. For example, I can see in my neighborhood the several block area where AT&T has built fiber.

A small town could easily gather and map everything about its community by gathering the data for each home from the national map provided by the FCC. The licensing makes things easier by allowing the use of the underlying databases needed to analyze the data in mass instead of one home at a time.

It’s easy to see why there was such a big battle to win the mapping RFP, because this created a huge new permanent revenue stream for CostQuest to provide access to use the FCC data. I wrote a blog earlier this year talking about creating policies to make sure that communities have access to government data. I don’t know if there is anything more vital to communities with poor broadband than understanding the broadband map of who has and doesn’t have access to broadband.

I hope that the FCC will come to its senses and reclaim its own data, or at least mandate that it should be easily available to everybody. If not, this is something Congress ought to address. We’re spending billions to bring better broadband while absurdly making it hard for communities to use the public data that documents broadband coverage.

Maybe some smart programmer will solve this for everybody by capturing the data one house at a time from the FCC map and make the data available to everybody for free.

Hidden Unserved Locations

There is a mountain of complaints to be made about the new FCC maps. In some parts of the country there are a lot of missing rural locations, including entire subdivisions. Various ISPs have continued to exaggerate both coverage areas and broadband speeds. But even with all of the flaws there is a lot of interesting information in the new maps.

I live in Asheville, North Carolina. In the previous version of the FCC mapping the whole city and a lot of the surrounding areas were shown as having broadband available from Charter. There is also parts of the city that have fiber provided from AT&T. As you might imagine, the old maps didn’t tell the real story. The FCC mapping protocol showed an entire Census block covered by a given ISP that has even one customer in the Census block. It’s mostly this mapping rule that showed everybody here able to buy broadband from Charter.

The new maps are far more granular. If you search the map throughout the city you can find homes, businesses, and whole streets where Charter doesn’t claim to offer broadband. The AT&T coverage on the new maps shows how AT&T typically builds small fiber networks that cover only a few blocks in a given area.

Close analysis of the map shows what folks in the broadband world have always known, but were unable to prove, that the big cable companies and telcos don’t cover everybody. It is these unserved folks in the middle of cities that I call the hidden unserved locations. Such locations cannot buy the same broadband as nearby neighbors.

These little pockets came about for a variety of reasons. Some are costly to serve and the cable company decided not to reach them when the initial network was built. The cable company might not have been unable to obtain the needed rights-of-way for some reason. A house might be sitting inside of a park or other land that makes it complicated to pursue an easement. ISPs also don’t always automatically build to reach newly constructed homes, which can be a real shock to the new tenants.

In many of these cases where the cost to connect a drop is high, and an ISP often refuses to connect the location unless the customer pays for the cost of the connection. Everybody in the industry has heard the horror stories where an ISP quotes a cost of thousands, or even tens of thousands of dollars to make a connection, even inside of a city. Many homes and businesses in this situation cannot afford the big connection fee.

It’s not always the ISPs fault that the broadband isn’t available. It’s not unusual for the owners of privately-owned road not to give permission to an ISP or others to dig up the streets. There are apartment buildings where the owner decided not to allow a given ISP into the building. There are homes where the owner doesn’t want a connection and refuses to provide an easement.

In looking around Asheville I found a surprising number of such locations. I found individual homes or pockets of homes that are not claimed as served by Charter. But the real surprises came when looking at the outer portions of the city. There are parts of neighborhoods that have been bypassed for some reason, even though homes further outside of the city have service. It also looks like neighborhoods with large lots and long driveways have been selectively bypassed.

This version of the FCC maps likely still has a lot of reporting errors. Some of the homes shown as not being served might have a connection available, while some homes shown as having broadband might not be able to get it. Over time it’s hopeful that a lot of these local issues will be resolved as people use the FCC map challenge to fix the maps. But I think a lot of these situations are real. It’s not worth the effort yet with this first iteration of the maps to dig too deeply. But cities are going to be able at some point to make an inventory of locations that don’t have good broadband. At that point cities will be able to work to close the gap of the hidden unserved locations.

New Member of the CCG Team

I’m happy to announce that Chris Rozycki has joined the CCG team.

Chris’s last position was as the Broadband Projects Administrator for the State of South Carolina. In that positioned Chris created, authored, and implemented a complete broadband grant program and plan that included creating the draft plan, dramatically improving State broadband mapping, creating a grant application process and forms, and a grant scoring methodology. He then worked to implement the grant program that included reviewing and scoring grant applications, refereeing challenges, conducting onsite reviews and approvals, and establishing a broadband demonstration project in an unserved rural black community. The grant program brought faster broadband, mostly fiber, to nearly 25,000 homes and businesses.

Before that, Chris has a long history in telecom policy, planning, and strategy, and worked for ISPs of all sizes. He has extensive experience in testifying with state PUCs and PSCs covering topics like inter-company compensation, industry performance standards, pricing and ratemaking, and interconnection agreement issues

If you think Chris’s talents might be on interest, you can contact him at Or reach him through CCG.


The Individual FCC Map Challenge

Hopefully, the word is getting out that individuals can challenge the FCC mapping. We’ve known for years that the FCC mapping is full of errors. ISPs often claim coverage and broadband speeds that are not actually available.

The new FCC map includes the ability to challenge the information that ISPs claim about the coverage at your home or business. The challenge process is built directly into the FCC Broadband map. Anybody can zero in on the map and see the broadband options that ISPs say are available at your location. There are a number of issues you can challenge for a given ISP:

  • The ISP denied a request for service via phone, the company’s website, or another method.
  • The ISP does not offer the technology reported on the FCC broadband map.
  • The ISP is unable or failed to schedule an installation date within 10 business days of your service request.
  • The ISP scheduled an installation but failed to perform the install at the scheduled date and time.
  • The ISP wants a fee greater than the advertised fee for an installation.
  • The ISP does not offer a product with the speed reported on the map. This challenge doesn’t say the ISP doesn’t deliver the speed, just that they didn’t offer the speed listed on the map.
  • No wireless or satellite signal is available at your location.
  • The ISP must construct new network to reach your location. Report if the ISP wants you to pay for construction.

If you challenge any of these items for a given ISP, the FCC will forward on your challenge to the ISP. If that ISP doesn’t respond or dispute the challenge, it must change its reporting for that location on the FCC map. For example, if it doesn’t offer service at your location, it must take you off its FCC map. If the ISP doesn’t offer the speed claimed to the FCC, it would have to lower the claimed speed it offers.

If the ISP disputes your claim, it must provide evidence to you and to the FCC that broadband is available at your location. After a dispute, the ISP has 60 days to reach an agreement with you about its claim. If you and the ISP can’t come to an agreement, the FCC says that it will then resolve the dispute within 90 days. That’s a real puzzler because the FCC doesn’t have the staff to process large volumes of such claims – they are banking on the ISP and the consumer reaching an agreement or the ISP backing down on the claim made on the maps.

The FCC hopes that over time that millions of such challenges will clean up the FCC mapping. The FCC believes that nobody knows more than you about what is available at your home. Rural folks, in particular, have dealt with ISPs that advertise but can’t actually deliver broadband to their home.

The challenge is somewhat weak in that making a challenge will rarely find you a broadband solution. But it’s possible that an ISP will agree to connect you after you make a challenge. The real benefit of the challenge process is to the whole community in that the FCC map gets cleaned up so that we can finally see and count the folks who can’t buy broadband. When it’s proven that your area doesn’t have broadband, the area becomes available for broadband grants.

Unfortunately, the challenge does not include the one thing that folks most want to challenge. You can’t file a formal challenge against an ISP that delivers speed that are far slower than what they sold to you. For example, you can’t file a formal challenge if an ISP sells you ‘up to’ 100 Mbps but delivers 3 Mbps. The FCC will accept this information, but they will treat it as a consumer complaint and not a mapping challenge. Unlike the challenge process, an ISP does not have to respond to a complaint. In fact, by deregulating broadband, the FCC under Ajit Pai weakened the complaint process to the point that it is toothless.

Note that you must provide your name and contact information to make a challenge because the FCC or an ISP might want to contact you. This means you can only challenge for your own location and not your neighbors. The real benefit of the challenge process will come if enough people in neighborhoods make the complaint to get the area maps corrected.