Earlier this month the National Rural Electric Cooperative Association (NRECA) made an ex parte filing with the FCC that warned that the current FCC maps do not reflect the reality on the ground of rural broadband. They warn that there are a lot of places that need broadband that will not be covered by BEAD. They warn that areas that don’t get funding now by BEAD will be left behind.

Anybody who reads this blog knows that I’ve been making this same argument for the last several years. As NRECA points out, the new FCC broadband maps are a big step up from the previous FCC mapping. The old maps reported broadband by Census block, and in doing so often showed an area as having good broadband when only a few places in the block had a faster technology.

NRECA points out that the fatal flaw in the new maps is that ISPs self-report broadband speeds and are free to report marketing speeds instead of something closer to what is actually delivered to customers. It was an interesting policy choice for the FCC to make since this doesn’t match what the FCC is doing elsewhere. For example, the FCC requires ISPs to report broadband speeds for each product on the new broadband labels. The rules for the labels suggest that ISPs should report speeds that have some basis derived from internal ISP speed testing. In my early examination of broadband labels, most ISPs are ignoring this requirement and claim the identical speed on the broadband labels that is reported on the FCC maps.

ISPs know the speeds they are delivering to customers. Most broadband networks have the ability to measure speeds from their core network to the customer location – a speed that doesn’t get influenced by the performance of WiFi inside of a customer premise.

I’ve seen numerous examples of speeds reported for the FCC maps that are far faster than speeds measured by speed tests. For example, I recently found a big telco reporting 100/20 Mbps for rural DSL, while Ookla speed tests show an average speed around 25 Mbps – and no speed test faster than 40 Mbps. I’ve seen the same thing for WISPs and FWA cellular broadband, where Ookla speed tests are far slower than what is being reported to the FCC. There are cable companies with no speed tests of upload speeds faster than 20 Mbps, which means their areas should be eligible for BEAD grant funding.

In its filing, NRECA suggested that the public should be allowed to take speed tests to report to the FCC. The FCC certainly has the ability to crowdsource speed tests since it does so for cellular broadband. Customers can take a cellular speed test using an FCC speed test app. I can’t think of any reason why the FCC couldn’t directly collect speed tests directly from customers using the same or a similar app. I’m also mystified why the FCC couldn’t partner with one of the big speed test sites like Ookla to gather the many millions of speed tests that are already being taken every day.

ISPs do not want customer speed tests to be part of the equation, and they have some valid arguments that the results of any given speed test can’t be trusted. Every ISP will tell you that a big part of the problem that customers have with broadband is the WiFi signal inside their home. They might have old or inadequately configured routers. They might be taking speed tests from a computer located far from the in-home router.

But interestingly, if you gather enough speed tests, a good picture of broadband performance emerges. I’ve always focused on the maximum speeds measured for a given ISP. If an ISP says it can deliver 100 Mbps or gigabit speed, then there should be some speed tests close to that speed. My experience is that looking at large numbers of speed tests will quickly identify ISPs who are reporting speeds far faster than what they are delivering.

To be fair to ISPs, speed tests can also show the opposite. I’ve seen ISPs that claim a speed on the FCC maps of 25 Mbps or 50 Mbps but are delivering much faster speeds.

The NRECA is absolutely right about the BEAD grants. There are a lot of rural areas that will be excluded from BEAD because of overstated broadband speeds. Broadband offices and the NTIA will say that there is a BEAD map challenge process to address this issue. But I could write a whole series of blogs describing the ridiculous steps that NTIA is requires to mount a successful map challenge for BEAD. Even if the map challenge process was reasonable, many local governments don’t have the resources or budget to mount a serious map challenge. This means that counties that were unable to mount a successful BEAD map challenge have a good chance of having locations improperly excluded from BEAD.

When the dust settles from BEAD grants, there are going to be a whole lot of rural neighborhoods that will not get a broadband solution – and they are going to be vocal about it.  My prediction is that this is going to end up being a few million such rural locations. As much as the industry wants to pretend that BEAD is going to solve the rural broadband issue, anybody who looks close at the FCC maps and the BEAD process knows this is not the case.