There They Go Again

The FCC issued the 2020 Broadband Deployment Report on April 20. It’s a self-congratulatory document that says that the state of broadband in the country is improving rapidly and that the FCC is doing a great job. I had a hard time making it past the second paragraph of the report which summarized the state of broadband in the country. Consider the following:

The number of Americans lacking access to fixed terrestrial broadband service at 25/3 Mbps continues to decline, going down by more than 14% in 2018 and more than 30% between 2016 and 2018. 

The FCC has no factual basis for this statement because they don’t know the number of households in the US that don’t have access to 25/3 Mbps broadband. The numbers cited are based upon the Form 477 data collected from ISP that everybody in the country, including the FCC, has acknowledged is full of errors. The FCC has proposed moving to a new method of data collection that will produce maps based upon drawing polygons that they hope will fix the rural broadband reporting problem. 

I’ve been working all over the country with rural counties and I have yet to encounter a rural county where the Form 477 coverage of 25/3 broadband is not overstated. In county after county, we find places where the big telcos and/or WISPs exaggerate the broadband speeds that are available and the coverage area available for faster speeds of broadband. The reporting problem is getting worse rather than improving as witnessed by a recent filing by Frontier to the FCC that claims they have improved speeds in 16,000 rural Census blocks to 25/3 Mbps broadband since June 30, 2019. This claim is made by a company that just went into bankruptcy and which the whole rural industry knows is not spending a dime on rural infrastructure. There were similar claims made by the other big telcos in a proceeding that was to determine the areas available for FCC grant funding.

The number of Americans without access to 4G Long Term Evolution (LTE) mobile broadband with a median speed of 10/3 Mbps fell approximately 54% between 2017 and 2018. 

There has been a lot of rural cell sites upgraded from 3G to 4G as the big cellular carriers want to mothball 3G technology. However, any quantification of the improvement of cellular broadband coverage is suspect due to blatantly erroneous reporting by the big cellular carriers. In 2019 when the FCC went to award grant funding to upgrade rural cellular coverage the discovered that Verizon, T-Mobile, Sprint, and US Cellular had significantly overstated rural cellular coverage in an attempt to shuttle grant funds away from smaller cellular carriers. The FCC reacted by yanking that grant program and delaying it, in what is now called the 5G Fund. It’s hard to believe that the FCC would try to quantify the improvement in 4G coverage between 2017 and 2018 without acknowledging that this was the coverage that was badly overstated by the cellular carriers.  

AT&T, Sprint, T-Mobile, and Verizon are also rapidly expanding their 5G capability, with 5G networks in aggregate now covering the majority of the country’s population, especially in urban areas, and more live launches planned for 2020.

The FCC clearly buys the 5G hype from the cellular companies which are claiming widespread 5G coverage. The cellular companies have introduced new spectrum into their 4G LTE environment, and the cellular marketers have labeled this as 5G. Much of the first wave of new spectrum being used is in lower frequency bands such as 600 MHz for T-Mobile and 850 MHz for AT&T. These lower frequency bands don’t carry as much data as higher frequencies and won’t be delivering faster broadband. However, new spectrum bands improve the chances of grabbing a channel to get the data speeds that 4G was already supposed to be delivering.

5G will not arrive until the carriers begin implemented the new features described in the 5G specifications. For now, none of the important new 5G features have yet made it to the market. So, contrary to the FCC telling the public that 5G is nearly everywhere, the truth is that it is not yet anywhere in the country. I’ll be curious in a few years to see how the annual FCC reports on broadband describe the actual introduction of 5G features. It’s likely they’ll parrot whatever language the cellular marketers spin by then.

This opening pat on the back is followed by page after page of broadband statistics that are based upon the lousy Form 477 reporting from ISPs. There is almost no statistic in this report that is entirely trustworthy.

This report is unfortunate in many ways. The FCC feels compelled to exaggerate broadband coverage so that they can’t be forced to try to fix broadband gaps. The sad aspect of this report is that this is the statistics cited in this report are used to determines which parts of rural America are eligible for broadband grants – and this report is largely a fairy tale. It would have been nice if the summary of the report had acknowledged that the FCC knows that their data is faulty – something they have openly recognized in other dockets. Instead, the FCC chose to spin this fanciful tale of rapidly improving broadband that does little more than provide cover for the FCC to not have to fix rural broadband. 

Are You Covered by the RDOF Grant?

The FCC has published a detailed map of the upcoming RDOF grant program that is overlaid on Google Maps. This let’s everybody in rural America see if they might be getting covered by the $16 billion grants that will be awarded in October of this year. This is the largest broadband grant to ever be awarded and will serve only rural areas. You can zoom in on this map to see if your home or business will be covered by this giant grant program.

If it turns out your neighborhood is covered by this grant, here are a few things you should know:

  • The money is being awarded by reverse auction with different ISPs competing for the money. The ISP willing to take the least amount of federal grants will win the award for your area. There is one twist on the auction in that any ISP offering gigabit speeds wins the grant after a few rounds of bidding.
  • ISPs can use any technology that delivers at least 25/3 Mbps broadband to participate in the grant auction. The auction is weighted to try to give the money to faster technologies. However, the winner in your area could be proposing to use DSL, fixed wireless, satellite broadband, or fiber. The technology you will be served with is going to depend on the ISP that wins your area. You should be able to find out the technology that is coming to your neighborhood when the auction is finished sometime near the end of this year.
  • You might not see a solution quickly. Winners will have 6 years to complete construction, meaning that some homes in the winning areas won’t get broadband until 2026. Since people are being asked to work and school from home, that’s a really long time to wait.
  • If nobody wins the grant money in your area it would go back into the pot for a smaller $4 billion grant to be awarded in 2021.

What if you aren’t covered by these grants and don’t have good broadband? What are your chances of seeing a broadband solution?

It’s possible that your area would have been covered by the $1.5 billion reverse auction grants awarded last year. However, if your area was awarded one of these grants then hopefully you’ve already heard about it.

If you live really close to one of these RDOF areas, there is a chance that the winner of these grants might build to your home. However, that’s something that you aren’t likely to know for a long time, and the chances are not good that you’ll be covered.

There will be a second FCC auction in 2021 for $4 billion that will cover additional areas that are not on this map. $4 billion will cover a much smaller area than this map – but some folks will get a second chance. That auction is likely to have the same rules, meaning that you might not see a broadband solution until 2027. It’s likely that the FCC will issue a second map similar to this one for the areas covered by those grants.

There are other federal grant programs such as the ReConnect grants that are awarding smaller dollars. The ReConnect grant for this year is $300 million for the whole country and was boosted by $100 million in the COVID-19 stimulus package. There is no guarantee that this grant program will carry into the future – it’s been funded now for the last few years as part of the annual agriculture bill.

There are also state grant programs that might cover you. Most of the state grant programs are relatively small, but they are helping to spread broadband. However, there is a significant chance that a lot of state grant money will be used as matching funds for the RDOF grants.

If you have poor broadband options and you aren’t covered by this grant there is a good chance that you just got screwed. There are many millions of homes and business that don’t have good broadband that are not covered by this grant. That blame can be laid squarely on the FCC. The FCC is using information supplied by ISPs to define areas that are eligible for this grant. There are huge parts of rural America where the ISPs are falsely claiming to offer 25/3 speeds, and such areas are not included in this grant.

The FCC knows they are using faulty data and they decided to move forward with these grants anyway. The areas covered by the RDOF grants don’t have good broadband, but there is an even larger geographic area of the country that should be eligible for federal grants that have been shut out due to the FCC never insisting on good mapping data from ISPs.

If your neighborhood has poor broadband and isn’t covered by these grants, then you need to yell bloody murder to anybody and everybody. Complain to local, state and federal politicians. The fact is that if your neighborhood isn’t on these maps, or isn’t covered by a few other existing grant programs, then you are not likely to be getting broadband with federal grant assistance any time soon. You aren’t going to be alone and there are millions of other rural residents in this same situation – so join forces and shout until there is a solution.

The FCC is Redlining Rural America

The recent statistics of broadband usage in the US provide evidence that, unwittingly, the FCC is redlining rural America. OpenVault recently released its Broadband Industry Report for 4Q 2019 that tracks the way that the US consumes data. OpenVault has been collecting broadband usage for more than ten years, and the last two reports have been eye-opening.

The most important finding is that the average data consumed by households grow by 27% from 2018 to 2019 – in the fourth quarter of 2019 the average US home used 344 gigabytes of data, up from 275 gigabytes a year earlier.

The report also looks at power users – homes that consume a lot of broadband. They report that nearly 1% of homes now use 2 terabytes per month and 7.7% use over 1 terabyte per month. A terabyte is 1,000 gigabytes. The percentage of homes using over 1 terabyte almost doubled from 4% a year earlier. This statistic is important because it shows the number of homes that are hitting the 1 terabyte data caps of companies like Comcast, AT&T, Cox, and Mediacom is quickly growing.

Homes are starting to buy gigabit broadband when it’s available and affordable. 2.8% of homes in the country now subscribe to gigabit speeds, up 86% from the 1.5% of homes that bought gigabit in 2018.

54% of homes now purchase broadband plans with speeds of 100 Mbps or faster. Another 23.6% of homes are subscribing to broadband between 50-75 Mbps. This means that nearly 78% of homes are subscribing to data plans of greater than 50 Mbps. The average subscribed speed grew significantly in 2019, up from 103 Mbps to 128 Mbps.

What’s the point of all of these statistics? They show that broadband usage and speeds in urban America is growing by leaps and bounds while broadband in rural America sits still. Urban broadband speeds have increased so rapidly that the average home in the US in 2019 got speeds that were 25 Mbps faster than what they had in 2018. The average speed of broadband in 2019 was more than 100 Mbps faster than the FCC definition of broadband. I contend that FCC actions and inaction have now culminated in the redlining of rural broadband households. It may sound drastic to call the FCC inaction redlining, but I think the word fits the situation.

Redlining historically has been used to describe how big corporations discriminate against poor neighborhoods. Redlining is more often due to neglect than to conscious decisions – grocery stores don’t consider poor neighborhoods as places to build; cable companies and telcos make upgrades in neighborhoods where they have the most customers or the highest revenue per customer. The consequence of redlining is that some neighborhoods get left behind.

The FCC has taken a series of actions that is dooming large parts of rural America to poor broadband for decades to come. One of the most egregious actions by the FCC is refusing to consider a faster definition of broadband, although every statistic shows that urban America is leaping far ahead of rural America and the broadband gap is now growing rapidly each year.

The decision to stick with the outdated 25/3 definition of broadband then boxes the FCC into having to allow federal grant dollars go to build technologies that meet the 25/3 definition of broadband. Considering how fast broadband speeds and consumption are growing, this is an amazingly shortsighted decision when considering that that grant recipients for programs like RDOF have six years to construct the new networks. There will be ISPs still constructing 25/3 broadband networks using federal money in 2026.

Next, the FCC has made it clear that any rural area that gets any federal or state subsidy – even if it’s to support 25/3 Mbps, or to support satellite broadband is not going to be eligible for future federal assistance. Once the FCC sticks you with poor broadband, they’re done with you.

Finally, the FCC continues to hide behind ludicrously dreadful maps that show good broadband available for millions of homes that have no broadband option. The rules for the 477 data collection are lousy, but that’s only half the problem, and I can’t recall ever hearing any discussion at the FCC about penalizing ISPs that file fraudulent speeds. There should be huge financial penalties for a telco that claims 25/3 speeds when nobody gets speeds even close to that or for WISPs that claim 100 Mbps speeds and deliver 15 Mbps. These ISPs are stopping whole counties from being eligible for broadband grants.

All of these FCC actions and inaction have doomed huge swaths of rural America from even participating in federal grant programs to get better broadband. If that’s not redlining, I don’t know what else to call it.

How FCC Policies Hurt Communities

I was recently looking at one of the counties where the winner of the CAF II reverse auction was Viasat, a satellite broadband provider. There are many other rural counties with an identical outcome. As I thought about these counties, I came to realize that a series of FCC policies and decisions have hurt these counties in their search for better broadband. There is no single FCC action that hurt them, but a cascading series of individual decisions have made it harder for them to find a broadband solution.

The first FCC decision that created the current situation is when the current FCC declined to consider an increase in the definition of broadband from 25/3 Mbps. That definition was set in 2015 and there is ample record on file in FCC proceedings that 25/3 is already an obsolete definition of broadband.

The most recent evidence comes from OpenVault. The company just released its Broadband Industry Report for 4Q 2019 that shows the average subscribed speed in the US grew from 103 Mbps in 2018 to 128 Mbps in 2019. That result is largely being driven by the cable companies and the fiber providers that serve more than 2/3 of all of the broadband customers in the country. The FCC is stubbornly sticking to the 25/3 Mbps definition of broadband even as a large majority of households in the country are being given speeds greater than 100 Mbps.

The decision to stick to the outdated 25/3 Mbps then created a second problem for rural America when the outdated FCC speed definition is used to award federal grants. The FCC decided in the CAF II reverse auction grants that any technology that met the 25/3 Mbps speed was acceptable. The FCC boxed themselves in since they couldn’t set a higher speed threshold for grants without admitting that the 25/3 Mbps threshold is inadequate. That auction awarded funding for technologies that can’t deliver much more than 25 Mbps. What’s worse is that the winners don’t have to finish building new networks until 2025. When the FCC blessed the use of the 25/3 threshold in the reverse auction they also blessed that 25/3 Mbps broadband will still be adequate in 2025.

The next FCC decision that is hurting these specific counties is when the FCC decided to allow satellite broadband companies to bid for scarce federal broadband grant monies. The FCC probably thought they had no choice since the satellite providers can meet the 25/3 Mbps speed threshold. This was a dreadful decision. Satellite broadband is already available everywhere in the US, and a grant given to satellite broadband brings no new broadband option to a rural area and only pads the bottom line of the satellite companies – it doesn’t push rural broadband coverage forward by a millimeter.

Finally, the FCC recently rubbed salt in the wound by saying that areas that got a previous state or federal broadband grants won’t be eligible for the additional federal grants out of the upcoming $20.4 billion RDOF grant program. This means that a county where a broadband grant was given to satellite provider is ineligible for grant money to find a real broadband solution.

Such counties are possibly doomed to be stuck without a broadband solution due to this chain of decisions by the FCC. I’m sure that the FCC didn’t set out to hurt these rural counties – but their accumulated actions are doing just that. Each of the FCC decisions I described was made at different times, in reaction to different issues facing the FCC. Each new decision built on prior FCC decisions, but that culminated in counties with a real dilemma. Through no fault of their own, these counties are now saddled with satellite broadband and a prohibition against getting additional grant monies to fund an actual broadband solution.

A lot of this is due to the FCC not having a coherent rural broadband policy. Decisions are made ad hoc without enough deliberation to understand the consequences of decisions. At the heart of the problem is regulatory cowardice where the FCC is refusing to acknowledge that the country has moved far past the 25/3 Mbps broadband threshold. When 2/3 of the country can buy speeds in excess of 100 Mbps it’s inexcusable to award new grant monies for technologies that deliver speeds slower than that.

It’s obvious why the FCC won’t recognize a faster definition of broadband, say 100 Mbps. Such a decision would instantly classify millions of homes as not having adequate broadband. There is virtually no chance that current FCC will do the right thing – and so counties that fell through the regulatory cracks will have to find a broadband solution that doesn’t rely on the FCC.

The RDOF Grants – The Good and Bad News

The FCC recently approved a Notice of Proposed Rulemaking that proposes how they will administer the $16 billion in RDOF grants that are going to awarded later this year. As you might imagine, there is both good news and bad news coming from the grant program.

It’s good news that this grant program ought to go a long way towards finally killing off large chunks of big telco rural copper. Almost every area covered by these grants is poorly served today by inadequate rural DSL.

The related bad news is that this grant award points out the huge failure of the FCC’s original CAF II program where the big telcos were given $11 billion to upgrade DSL to at least 10/1 speeds. The FCC is still funding this final year of construction of CAF II upgrades. The new grant money will cover much of the same geographic areas as the original CAF II deployment, meaning the FCC will spend over $27 billion to bring broadband to these rural areas. Even after the RDOF grants are built, many of these areas won’t have adequate broadband. Had the FCC administered both grant programs smartly, most of these areas could be getting fiber.

Perhaps the best good news is that a lot of rural households will get faster broadband. Ironically, since the grants cover rural areas, there will be cases where the RDOF grant brings faster broadband to farms than will be available in the county seat, where no grant money is available.

There is bad news on broadband speeds since the new grant program is only requiring download speeds of 25/3 Mbps. This means the FCC is repeating the same huge mistake they made with CAF II by allowing federal money to spend on broadband that will be obsolete before it’s even built. This grant program will be paid out of ten years and require deployment over six years – anybody paying attention to broadband understands that by six years from now a 25/3 Mbps broadband connection will feel glacial. There is grant weighting to promote faster data speeds, but due to the vagaries of a reverse auction, there will be plenty of funding given to networks that will have speeds close to 25/3 Mbps in performance.

There is further bad news since the FCC is basing the grants upon faulty broadband maps. Funding will only be made available to areas that don’t show 25/3 Mbps capability on the FCC maps. Everybody in the industry, including individual FCC Commissioners, agrees that the current maps based upon 477 data provided by ISPs are dreadful. In the last few months, I’ve worked with half a dozen counties where the FCC maps falsely show large swaths of 25/3 broadband coverage that isn’t there. It’s definitely bad news that the grant money won’t be made available in those areas where the maps overstate broadband coverage – folks in such areas will pay the penalty for inadequate broadband maps.

There is a glimmer of good news with mapping since the FCC will require the big ISPs to report broadband mapping data using polygons later this year. Theoretically, polygons will solve some of the mapping errors around the edges of towns served by cable TV companies. But there will only be time for one trial run of the new maps before the grants, and the big telcos have every incentive to exaggerate speeds in this first round of polygon mapping if it will keep this big pot of money from overbuilding their copper. I don’t expect the big telco mapping to be any better with the polygons.

Another area of good news is that there will be a lot of good done with these grants. There will be rural electric cooperatives, rural telcos, and fiber overbuilders that will use these grants as a down-payment to build rural fiber. These grants are not nearly large enough to pay for the full cost of rural fiber deployment, but these companies will borrow the rest with the faith that they can create a sustainable broadband business using fiber.

The bad news is that there will be plenty of grant money that will be used unwisely. Any money given to the traditional satellite providers might as well just be burned. Anybody living in an area where a satellite provider wins the grant funding won’t be getting better broadband or a new option. There is nothing to stop the big telcos from joining the auction and promising to upgrade to 25/3 Mbps on DSL – something they’ll promise but won’t deliver. There are likely to be a few grant recipients who will use the money to slap together a barely adequate network that won’t be fast and won’t be sustainable – there is a lot of lure in $16 billion of free federal money.

It’s dismaying that there should be so many potential downsides. A grant of this magnitude could be a huge boost to rural broadband. Many areas will be helped and there will be big success stories – but there is likely to be a lot of bad news about grant money spend unwisely.

Testing the FCC Maps

USTelecom has been advocating the use of geocoding to make broadband maps more accurate. As part of that advocacy, the association tested their idea by looking at the FCC mapping in parts of Virginia and Missouri.

What they found was not surprising, but still shocking. They found in those two states that as many as 38% of households in rural census blocks were classified as being served, when in fact they were unserved. In FCC-speak, served is a home that has broadband available of 25/3 Mbps or faster. Unserved means homes having either no broadband available or that can buy broadband slower than 10/1 Mbps.

This distinction has huge significance for the industry. First, it’s been clear that the FCC has been overcounting the number of homes that have broadband. But far worse, the FCC has been awarding grants to provide faster broadband in unserved areas and all of the places that have been misclassified have not been eligible for grants. We’re about to enter the biggest grant program ever that will award $20.4 billion, but only to places that don’t have 25/3 Mbps speeds – meaning these misclassified homes will be left out again if the maps aren’t fixed soon.

The USTelecom effort is not even complete since several cable companies in the state did not participate in the trial – and this might mean that the percentage of homes that are misclassified is even larger. The misclassified homes are likely going to be those in census blocks that also contain at least some homes with fast broadband. Homes just past where the cable company networks start might be listed as being capable of buying a gigabit, and yet have no broadband option.

The existing FCC maps use data that is reported by ISPs using the Form 477 process. In that process, ISPs report speed availability by census block. There are two huge flaws with this reporting method. First, if even one customer in the census block can get fast broadband, then the whole census block is assumed to have fast broadband. Second, many ISPs have been reporting marketing speeds instead of actual speeds, and so there are whole census blocks counted as served when nobody can get real broadband.

The trial also uncovered other problems. The ISPs have not been accurate in counting homes by census block. Many ISPs have never accurately mapped their customers, and so the test found numerous examples of customers reported in the wrong census blocks. Additionally, the counts of buildings by census block are often far off, due in part to the confusing nature of rural addresses.

The bottom line is that the FCC has been collecting and reporting highly inaccurate data concerning rural broadband. We’ve known this for a long time because there have been numerous efforts to test the maps in smaller geographic areas that have highlighted these same mistakes. We also have evidence from Microsoft that shows that a huge number of homes are not connected to the Internet at speeds of at least 25/3 Mbps. That’s not just a rural issue, and for the Microsoft numbers to be true there must be a massive number of urban homes that are getting speeds slower than what is being reported to the FCC.

As dramatic as this finding is from USTelecom, it doesn’t tell the whole story. Unfortunately, no mapping strategy is going to be able to truthfully report the broadband speeds for DSL and fixed wireless. The speed of these products varies by home. Further, there is no way to know if a given home can utilize these technologies until somebody tries to connect them. Perhaps this isn’t important for DSL since there is almost no rural DSL capable of delivering 25/3 Mbps broadband. But any mapping of the coverage area of fixed wireless is going to be suspect since many homes are impeded from seeing a tranmitting antenna or else receive slower speeds than their neighbors due to impediments. The USTelecom effort is mostly fixing the boundary issues where homes are assumed to have broadband today but don’t. The 38% misreporting would be much higher if we could somehow magically know the real capabilities of DSL and fixed wireless.

The current FCC didn’t create this problem – it goes back several FCCs ago to the start of the 477 reporting system. However, I have to wonder if this FCC will change its mind about the status of rural broadband in the country even with better maps. The current FCC released broadband data for 2016 that included a huge error. A new ISP, Barrier Free had reported serving 25/3 broadband in census blocks covering 62 million people, when in June of that year the company didn’t yet have any customers. The FCC gleefully reported that the number of homes without broadband had dropped by 25%, mostly due to this reporting error. Even after correcting the error the FCC still declared that broadband in rural America was on the right trajectory and didn’t need any extraordinary effort from the FCC. I’m sure they will decide that rural broadband is fine, even if the number of unserved homes jumps significantly due to better mapping.

Setting the Definition of Broadband

One of the commenters on my blog asked a good question – can’t we set the definition of broadband by looking at the broadband applications used by the typical household? That sounds like a commonsense approach to the issue and is exactly what the FCC did when they set the definition of broadband to 25/3 Mbps in 2015. They looked at combinations of applications that a typical family of four might use in an evening, with the goal that a household ought to have enough broadband to comfortably do those functions at the same time. This might best be described as a technical approach to defining broadband – look at what households are really using and make sure that the definition of broadband is large enough to cover the expected usage for a typical household.

Taking this approach raises the bigger question – what should the policy be for setting the definition of broadband? I don’t know that I have any answers, but I ask the following questions:

  • The FCC largely conducted a thought experiment when setting the 25/3 definition of broadband – they didn’t try to measure the bandwidth used in the scenarios they considered. If the FCC had measured real homes doing those functions they likely would have found that bandwidth needs were different than they had estimated. Some functions use less bandwidth than they had supposed. But usage also would have been larger than they had calculated, because the FCC didn’t compensate for WiFi overheads and machine-to-machine traffic. As a household makes use of multiple simultaneous broadband functions, the WiFi networks we all use bog down when those applications collide with each other inside the home network. The busy-hour behavior of our home networks needs to be part of a mathematical approach to measuring broadband.
  • The FCC could have gotten a better answer had they hired somebody to measure evening broadband usage in a million homes. We know that broadband usage is like anything else and there are households that barely use broadband and others that use it intentsely. The idea of pinpointing the usage of a typical family is a quaint idea when what’s needed is to understand the curve of broadband usage – what’s the percentage of homes that are light, average, and heavy users. I’m sure that one of the big companies that track broadband usage could measure this somehow. But even after making such measurements we need a policy. Should the definition of broadband be set to satisfy the biggest broadband users, or something else like the medium speed used by households? Analytics can only go so far and at some point there has to be a policy. It’s not an easy policy to establish – if the definition of broadband is set anywhere below the fastest speeds used by households, then policy makers are telling some households that they use too much broadband.
  • If we are going to use measurements to determine the definition of broadband, then this also has to be an ongoing effort. If 25/3 was the right definition of broadband in 2015, how should that definition have changed when homes routinely started watching 4K video? I don’t think anybody can deny that households use more broadband each year, and homes use applications that are more data intensive. The household need for speed definitely increases over time, so any policy for setting a definition of broadband needs to recognize that the definition must grow over time.
  • One fact that is easy to forget is that the big cable companies now serve two-thirds of the broadband customers in the country, and any discussion we have about a definition of broadband is only considering how to handle the remaining one-third of broadband users. There is a good argument to be made that the cable companies already define the ‘market’ speed of broadband. The big cable companies all have minimum broadband speeds for new customers in urban markets today between 100 – 200 Mbps. The companies didn’t set these speeds in a vacuum. The cable companies have unilaterally increased speeds every 3-4 years in response to demands from their customers for faster speeds. I think there is a valid argument to be made that the market speeds used to serve two-thirds of the customers in the country should be the target broadband speed for everybody else. Any policymaker arguing that 25/3 Mbps should still be the definition of broadband is arguing that one-third of the country should settle for second-class broadband.
  • In a related argument I harken back to a policy discussion the FCC used to have when talking about broadband speeds. I can remember a decade or more ago when the FCC generally believed that rural broadband customers deserved to have access to the same speeds as urban customers. That policy was easy to support when cable networks and telco copper networks both delivered similar speeds. However, as cable broadband technology leaped ahead of copper and DSL, these discussion disappeared from the public discourse.
  • When looking at grant programs like the upcoming RDOF program, where the funded networks won’t be completed until 2027, any definition of broadband for the grants needs to look ahead to what the speeds might be like in 2027. Unfortunately, since we can’t agree on how to set the definition of broadband today, we have no context for talking about future speeds.

These are not easy questions. If the FCC was doing its job we would be having vigorous discussions on the topic. Sadly, I don’t foresee any real discussions at the FCC about the policy for setting the definition of broadband. The FCC has hunkered down and continues to support the 25/3 definition of broadband even when it’s clear that it’s grown obsolete. This FCC is unlikely to increase the definition of broadband, because in doing so they would be declaring that millions of homes have something less than broadband. It seems that our policy for setting the definition of broadband is to keep it where it is today because that’s politically expedient.

FCC – Please Don’t Fund 25/3 Broadband

The current FCC recognizes the disaster that was created when the original CAF II grant program subsidized the construction of broadband that supports speeds of only 10/1 Mbps. Several FCC commissioners have said that they don’t want to repeat that disaster. Had the CAF II grant monies been allowed for companies other than the big telcos, much of the money would have gone to fiber ISPs and we’d see a lot more areas covered with good broadband today (meaning fewer headaches for the FCC).

Today I ask the question: what speeds should the new $20.4 billion RDOF grant fund support? In the NPRM for the RDOF grant program, the FCC suggests that the minimum speed they will fund is 25/3 Mbps. It looks like the funding for these grants will start in 2021, and like the CAF II program, anybody taking the money will have six years to complete the broadband construction. I think the right way to think about the speeds for these grants is to look at likely broadband speeds at the end of the construction period in 2027, not at where the world is at two years before the RDOF is even started. If the FCC bases the program on broadband speeds today, they will be making the same error as on the original CAF II – they will use federal money to build broadband that is obsolete before it’s even constructed.

I start by referring to a recent blog where I challenge the idea that 25/3 should be the definition of broadband today. To quickly summarize that blog, we know that broadband demand has been growing constantly since the days of dial-up – and the growth in broadband demand applies to speeds as well as volume of monthly downloading. Both Cisco and Ookla have shown that broadband demand has been growing at a rate if about 21% annually for many years.

At a bare minimum, the definition of broadband today ought to be 50 Mbps download – and that definition is a minimum speed, not a goal that should be used for building tomorrow’s broadband. As I said earlier, in a world where demand continues to grow, today’s definition of broadband shouldn’t matter – what matters is the likely demand for broadband in 2027 when the RDOF networks are operational.

Trending the demand curve chart for download speeds forward presents a story that the FCC doesn’t want to hear. The need for speed is going to continue to increase. If the growth trend holds (and these trends have been steady since the days of dial-up), then the definition of broadband by 2027 ought to be 250 Mbps – meaning by then nobody should build a network that can’t meet that speed.

2019 2020 2021 2022 2023 2024 2025 2026 2027
54 65 78 95 115 139 168 204 246

The big cable companies already recognize what the FCC won’t acknowledge. The minimum speed offered to new customers on urban cable networks today is at least 100 Mbps, and most users can order a gigabit. The cable companies know that if they provide fast speeds they get a lot fewer complaints from customers. In my city of Asheville, NC, Charter unilaterally increased the speed of broadband in 2018 from 60/6 Mbps to 135/20 Mbps. Anybody who has watched the history of cable company broadband knows that they will increase speeds at least once before 2027 to stay ahead of the demand curve. It wouldn’t be surprising by 2027 if cable company minimum speeds are 300 – 500 Mbps. Do we really want to be funding 25/3 rural broadband when speeds in cities will be fifteen times faster?

Will the world behave exactly like this chart – not likely. But will homes in 2027 be happy with 25/3 Mbps broadband – most definitely not. Given a choice, homes don’t even want 25/3 Mbps broadband today. We are already seeing hordes of urban customers abandoning urban DSL that delivers speeds between 25 Mbps and 50 Mbps.

If the FCC funds 25/3 Mbps broadband in the RDOF grant they will be duplicating one of the dumbest FCC decisions ever made – when CAF II funded 10/1 Mbps broadband. The FCC will be funding networks that are massively obsolete before they are even built, and they will be spending scarce federal dollars to again not solve the rural digital divide. There will continue to be cries from rural America to bring real broadband that works and by 2027 we’ll probably be talking about CAF IV grants to try this all over again.

The Definition of Broadband

When the FCC set the definition of broadband at 25/3 Mbps in January of 2015, I thought it was a reasonable definition. At the time the FCC said that 25/3 Mbps was the minimum speed that defined broadband, and anything faster than 25/3 Mbps was considered to be broadband, and anything slower wasn’t broadband.

2015 was forever ago in terms of broadband usage and there have been speed increases across the industry since then. All of the big cable companies have unilaterally increased their base broadband speeds to between 100 Mbps and 200 Mbps. Numerous small telcos have upgraded their copper networks to fiber. Even the big telcos have increased speeds in rural America through CAF II upgrades that increased speeds to 10/1 Mbps – and the telcos all say they did much better in some places.

The easiest way to look at the right definition of broadband today is to begin with the 25/3 Mbps level set at the beginning of 2015. If that was a reasonable definition at the beginning of 2015, what’s a reasonable definition today? Both Cisco and Ookla track actual speeds achieved by households and both say that actual broadband speeds have been increasing nationally about 21% annually. Apply a 21% annual growth rate to the 25 Mbps download speeds set in 2015 would predict that the definition of broadband today should be 54 Mbps:

2015 2016 2017 2018 2019
25 30 37 44 54

We also have a lot of anecdotal evidence that households want faster speeds. Households have been regularly bailing on urban DSL and moving to faster cable company broadband. A lot of urban DSL can be delivered at speeds between 25 and 50 Mbps, and many homes are finding that to be inadequate. Unfortunately, the big telcos aren’t going to provide the detail needed to understand this phenomenon, but it’s clearly been happening on a big scale.

It’s a little sketchier to apply this same logic to upload speeds. There was a lot of disagreement about using the 3 Mbps download speed standard established in 2015. It seems to have been set to mollify the cable companies that wanted to assign most of their bandwidth to download. However, since 2015 most of the big cable companies have upgraded to DOCSIS 3.1 and they can now provide significantly faster uploads. My home broadband was upgraded by Charter in 2018 from 60/6 Mbps to 135/20 Mbps. It seems ridiculous to keep upload speed goals low, and if I was magically put onto the FCC, I wouldn’t support an upload speed goal of less than 20 Mbps.

You may recall that the FCC justified the 25/3 Mbps definition of broadband by looking at the various download functions that could be done by a family of four. The FCC examined numerous scenarios that considered uses like video streaming, surfing the web, and gaming. The FCC scenario was naive because they didn’t account for the fact that the vast majority of homes use WiFi. Most people don’t realize that WiFi networks generate a lot of overhead due to collisions of data streams – particularly when a household is trying to do multiple big bandwidth applications at the same time. When I made my judgment about the 25/3 Mbps definition back in 2015, I accounted for WiFi overheads and I still thought that 25/3 Mbps was a reasonable definition for the minimum speed of broadband.

Unfortunately, this FCC is never going to unilaterally increase the definition of broadband, because by doing so they would reclassify millions of homes as not having broadband. The FCC’s broadband maps are dreadful, but even with the bad data, it’s obvious that if the definition of broadband was 50/20 Mbps today that a huge number of homes would fall below that target.

The big problem with the failure to recognize the realities of household broadband demand is that the FCC is using the already-obsolete definition of 25/3 Mbps to make policy decisions. I have a follow-up blog to this one that will argue that using that speed as the definition of the upcoming $20.4 billion RDOF grants will be as big of a disaster as the prior FCC decision to hand out billions to upgrade to 10/1 Mbps DSL in the CAF II program.

The fact that household broadband demand grows over time is not news. We have been on roughly the same demand curve growth since the advent of dial-up. It’s massively frustrating to see politics interfere with what is a straight engineering issue. As homes use more broadband, particularly when they want to do multiple broadband tasks at the same time, their demand for faster broadband grows. I can understand that no administration wants to recognize that things are worse than they want them to be – so they don’t want to set the definition of broadband at the right speed. But it’s disappointing to see when the function of the FCC is supposed to be to make sure that America gets the broadband infrastructure it needs. If the agency was operated by technologists instead of political appointees we wouldn’t even be having this debate.

Summary Conclusions for Designing an FCC Broadband Grant

The earlier series of blogs looked at a number of ideas on how the FCC could create the most effective federal grant program for the upcoming $20.4 billion of announced grants. Following is a summary of the most important conclusions of those blogs:

Have a Clearly Defined Goal. If a federal grant’s program goal is something soft, like ‘improve rural broadband’ then the program is doomed to failure and will fund solutions that only incrementally improve broadband. The grant program should have a bold goal, such as bringing a permanent broadband solution to a significant number of households. For example, done well, this grant could bring fiber to 4 – 5 million homes rather than make incremental broadband improvements everywhere.

Match the Grant Process with the Grant Goals. Past federal grants have often had grant application rules that didn’t match the goals. Since the results of grants are governed by the application rules, those are all that matter. Stated goals for a grant are just rhetoric if those goals are not realized in the grant application requirements. As an example, if a grant goal is to favor the fastest broadband possible, then all grant application rules should be weighted towards that goal.

Match Speed Requirement with the Grant Construction Period. The discussion for the proposed $20.4 billion grant contemplates a minimum speed goal of 25/3 Mbps. That’s a DSL speed and is already becoming obsolete today. A goal of 25/3 Mbps will be badly outdated by the time any grant-funded networks are built. The FCC should not repeat their worst decision ever that gave out $11 billion for CAF II funding to build 10/1 Mbps networks – a speed that was obsolete even before the grants were awarded. The FCC should be requiring future-looking speeds.

Make the Grants Available to Everybody. FCC grant and loan programs often include a statement that they are available to every kind of entity. Yet the actual award process often discriminates against some kinds of applicants. For example, grants that include a loan component make it generally impossible for most municipal entities to accept the awards. Loan rules can also eliminate non-RUS borrowers. Grant rules that require recipients to become Eligible Telecommunications Carriers – a regulatory designation – discriminate against open access networks where the network owner and the ISP are separate entities. If not written carefully, grant rules can discriminate against broadband partnerships where the network owner is a different entity than the operating ISP.

Reverse Auction is not a Good Fit. Reverse auctions are a good technique to use when taking bids for some specific asset. Reverse auctions won’t work well when the awarded area is the whole US. Since reverse auctions favor those who will take the lowest amount of funding a reverse auction will, by definition, favor lower-cost technologies. A reverse auction will also favor parts of the country with lower costs and will discriminate against the high-cost places that need broadband help the most, like Appalachia. A reverse auction also favors upgrades over new construction and would favor upgrading DSL over building faster new technologies. From a political perspective, a reverse auction won’t spread the awards geographically and could favor one region, one technology or even only a few grant applicants. Once the auction is started the FCC would have zero input over who wins the funds – something that would not sit well with Congress.

Technology Matters. The grants should not be awarded to technologies that are temporary broadband band-aids. For example, if the grants are used to upgrade rural DSL or to provide fixed cellular broadband, then the areas receiving the grants will be back at the FCC in the future asking for something better. It’s hard to justify any reason for giving grants to satellite providers.

States Need to Step Up. The magnitude of the proposed federal grant program provides a huge opportunity for states. Those states that increase state grant funding should attract more federal grants to their state. State grants can also influence the federal awards by favoring faster speeds or faster technologies.

This blog is part of a series on Designing the Ideal Federal Broadband Grant Program.