Regulation - What is it Good For? The Industry

The Latest FCC Maps

As promised, the FCC released a new set of maps on May 30. These are supposed to be the maps that will be used to allocate the $42.5 billion in BEAD grant funding to states. Broadband analyst Mike Conlow quickly published a blog on Substack about the new mapping data that includes a summary of the new map in easy-to-understand tables. Mike’s summary shows that there are more than 114.5 million broadband passings in the country – locations that could be broadband subscribers). That’s an increase of over 1 million locations since the last version of the FCC maps.

More importantly, the new maps can be used to count the number of households that can buy broadband at various speeds. The $42.5 billion in BEAD grant funding will be allocated to states according to the number of unserved locations – places that can’t buy broadband at a speed of at least 25/3 Mbps. Locations are underserved if there is an ISP that offers broadband between 25/3 Mbps and 100/20 Mbps. According to Mike’s quick math, there are 8.67 million unserved locations and 3.55 million underserved locations. Mike subsequently corrected the number of unserved locations to 8.3 million.

Anybody who is intimately familiar with the FCC maps knows that there is a lot of fiction buried in the reporting. There is one huge flaw in the FCC mapping system that has carried over from the previous FCC mapping regime – ISPs self-report the speeds they can deliver. Per the FCC mapping rules, ISPs can claim broadband marketing speeds rather than some approximation of actual speeds. In every county where I’ve delved deep into the local situation, I’ve found multiple ISPs that are overclaiming broadband speeds.

ISPs vary widely in how they report broadband speeds to the FCC. I see some ISPs who meticulously categorize customers into a dozen or more speed tiers. It’s fairly obvious that these ISPs are trying to accurately show the speeds that are available. But there are also ISPs that claim the same speed over a large geographic area. In today’s world, I’m always instantly suspicious of any ISP that claims exactly 100/20 Mbps broadband since that conveniently classifies those locations as served. An ISP making that claim is telling the FCC that everybody in their service footprint already has adequate broadband and that there is no need to give grant money to anybody to compete with them.

But such a claim is ludicrous if the ISP is deploying a technology like DSL, cellular wireless, or fixed wireless where it is impossible that every customer over a wide geographic area to get the ISP’s top claimed speed. Such claims are easy to debunk when you look closely. For example, customers only a few miles from a DSLAM or a tower can’t get the fastest speeds. There are multiple reasons why a given customer’s speed might be slower. Such claims are even more quickly debunked when looking at detailed Ookla speed tests.

A second flaw in the FCC maps is the coverage areas claimed by ISPs. The FCC is counting on public broadband challenges or challenges by State Broadband Offices to somehow fix this problem – but that’s an unrealistic hope. Most people don’t know about the FCC maps and the challenge process – and even people who know about it are not motivated to file a challenge about an ISP that claims service at their home that’s not really available. This issue can apply to any technology, but it’s particularly a problem for WISPs and cellular broadband. It’s not easy for a knowledgeable engineer to accurately judge the coverage area of a wireless network from a given tower – I have to think it’s beyond the capability of the folks at a State Broadband Office to understand it enough to challenge coverage. But it doesn’t take any expertise to know that a WISP or a cellular company claiming ubiquitous 100/20 Mbps coverage across large areas is exaggerating both speed and coverage capabilities.

It’s going to be interesting to see how States react to these final counts. There have been rumors about states ready to sue the FCC and the NTIA if they feel these maps will cheat them out of funding. There has been legislation introduced in the Senate that would force the NTIA to wait longer for better maps before allocating most of the funding. It’s going to be surprising if nobody pops up to challenge the allocation of the $42.5 million dollars. A challenge could pluge the BEAD grants into huge uncertainty.

An even bigger issue is if the FCC maps will be used to determine the locations that are grant eligible – because that would be a travesty. That would mean that every ISP that claims a bogus 100/20 Mbps broadband coverage will be rewarded by keeping out competition from grant funding. Regardless of how the funding is allocated to States, Broadband Offices need to be the ones to determine which locations in their State don’t have good broadband.

5 replies on “The Latest FCC Maps”

I take issue with your statement of suspicion about any ISP showing 100/20 service plans. That is a natural number to pick when arriving at plan speeds. ISP operators are human just like the people the selected 100/20 as the “broadband” speed. Why are we not suspicious of that selection? What if 92/13 would actually suffice? Or 113/ 27? We had a 100/25 plan on our Wisp long before BEAD was a thing. That plan is available to anyone in the coverage that we reported to FCC at fair local market value. You know how we did that? By shrinking our coverage down to where signal levels are high enough we can deliver that speed. If everyone in that coverage area subscribed to the 100/25 could we support that kind of usage? No, neither could a cable or fiber ISP, they are oversubscribed also in their coverage. But guess what? In real life, at fair market value, having plans available from 25/10 to 100/25, we only have a very few people who select anything faster than 25 Mbps. Why? Because with latency at <50 millisecond across our whole network, the people choosing the 25/10 are totally satisfied. The few folks wanting faster can subscribe to our 50 or 100 Mbps plan, and everything works. Back to the coverage map. The map we use in house is entirely different they the one we reported to FCC. Why? Because of the statement of satisfaction I mentioned about our 25 Mbps plan. As far as I know there is nothing illegal or devious about hooking someone up outside the coverage we reported to FCC. We do it routinely. And if those people call for the 100 Mbps I'm going to tell them it's not available, or do like any smaller, local friendly, wisp would do and upgrade the sector in their direction to meet the requested speed. We have done that multiple times, ironically well within the 10 day limit given. Let's see a cable or fiber ISP response like that. So that's my 2 cents for the day. The high amount of wireless ISP's reporting 100/x is very likely because they are doing what we have done. Actually mapping coverage to where we can support the "broadband" speed that was arbitrarily selected by humans pulling a number out of a hat. If it was test driven metrics that arrived at the number it would not have been an even 100/20, that is for sure.

If every sub on a fiber ISP got on the net at the same time and did a sustained download and upload test for 1 hour would they all successfully maintain 100/20 for the whole hour? I highly doubt it, so they are over subscribed, just like we are over subscribed. The whole BEAD funding/FCC mapping system, as far as I understand, did not address oversubscription at all, yet it is a reality in every single ISP in existence. So playing totally by the rules, if I can deliver 100/25 (our fastest residential speed) to any one single client in our "FCC stated" coverage area, then I am 100% within the confines of the system that was forced upon us. Because over subscription is real and they left it completely off the discussion table. Real life is radically different than the mythical ideas floating around at the FCC offices. To date, with the new mapping system, we have zero challenges about our coverage, zero complaints about delivering what we advertise, and also zero churn other than people moving out of our service area. With over 75% of our customer base subscribed to our 25/10 service plan.

The problem is that a lot of ISPs are not as scrupulously honest as you are. I’m sure you don’t believe that T-Mobile and Verizon are this honest with customers. There are also plenty of WISPs and DSL ISPs who are claiming marketing speeds in the FCC mapping that are far in excess of what they are actually delivering.

The problem is with the less-than-honest ISPs. Such ISPs can keep away competition from BEAD funding by the simple act of claiming 100/20 Mbps speeds in the FCC maps while delivering something slower. People living in these areas are going to be left behind.

The problem is biggest for cellular wireless. These companies will admit that they can’t begin to serve everybody in an area – they have a natural upper limit on the folks they are willing to serve from a given tower – just like Starlink has done. In areas that are claimed to be served by fast cellular broadband, the majority of folks won’t be able to buy service from the only fast ISP.

My hope is that State Broadband offices look under the hood, on a case-by-case basis to find the real story. They ought to like folks like you, but should not be willing to give grants in areas where the ISP can’t deliver the claimed speeds to everybody.

Thank you for the compliment on honesty. Unfortunately like too many times now days it feels like all honesty does is ensures you will be annihilated. We use exclusively unlicensed spectrum, so we’re eligible for government funded overbuilding. Our only hope is that our area will be considered high cost and that will discourage a government funded build over. We have over a decade of hard labor building a solid network. No we can’t serve 500 Mbps, but our reviews are 100% positive. As we transition to 60 ghz ptmp we’ll be able to offer a lot higher speeds. I’m sure there are many wisps like us across America. It would be nice if there was some slight recognition for the fact that we have been providing solid service to people that the big ISP’s thumbed their nose at for decades.

I agree with Trendal here on multiple fronts. I also think that most ISPs are not good so I have a foot strongly on the naysayers site of the line. Most fiber or docsis ISPs gain markey dominance by perpetuating the wrong numbers on what makes internet fast and then stagnating for lack of competition. Why can good wISPs take customers from the cable companies? Because they are competing for it and the cable co isn’t.

We run into this scenario a lot. Someone moves from the city to the country and then they struggle to find the 300-600Mbps internet plan and ‘settle’ into a 25-100M plan from us. 6 months later they’ve realized that low latency and a company that cares about them is way more valuable and that they didn’t really have a use for more than the 25M or maybe 50M plan.

Back on topic here, the broadband maps. This map only shows one of the least important parts of a good broadband experience and the measurement methodology is completely broken. Where are the latency numbers? What happens under load? do they get those speed just in off hours or do they get adequate speeds during prime use hours? That maps is *almost* just a map of who took government funding and certainly isn’t anything to do with what the consumer will get in terms of complete service.

I think this map is easy to solve. Create a certification program for consumer routers that measures TCP latencies of actual data and peak throughput as measured at the customer’s WAN interface. Customers can still fire off a synthetic ‘speed test’ if they want but then their router that reports to the broadband map will see that and measure it and report on it.

Then don’t report or make any opinion on what people should have, just present them with good information from their neighbors so we have a foundation of good data. Consumers can see that, learn to read it, and make choises for their needs.

Consumers are driven to ‘faster’ and faster plans and more expensive plans when they really just need better latency and the ‘faster’ plan doesn’t get them anything. It’s deception.

I keep hoping that you would conduct a few experiments as to the impact of latency on web page loading, in particular. They are easy to do, and tremendously revealing on just about any PLT benchmark. The key factor, as pointed out long ago by mike belshe´s famous paper “more bandwidth does not matter much”, is cited in the broadband technical advisory report here:

Or of the various means of improving latency under load, published by the IETF, here:

WISPs that optimize for latency first, in aiming for good connectivity to IXPs, and eliminating it from as many hops of the network as possible, far, far out- perform one offering a gigabit with 10s of ms of latency. They outperform starlink 40ms baseline), they outperfom cable (10ms baseline), and dsl (20 ms baseline).

The simplest experiment is to rate limit a local connection to localhost to say, 10Mbits, and then progressively add delay, using perhaps, the hugo web page system and the netem utility.

If you will get in in your soul that 100/20 is not what is actually most needed for a better internet, perhaps you´ll help us build a better one. Rather than duke it out via your comment system, I wrote some additional material, here:

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