Tag Archives: broadband mapping

FCC Maps and Professional Engineers

When the FCC first adopted the new broadband data collection and mapping rules, the FCC had a requirement that ISPs must get FCC mapping data certified by a professional engineer or by a corporate officer that meets specific qualifications to make the certification. The genesis of this ruling was fairly clear – the FCC has taken a lot of flak about ISPs that have been submitting clearly inaccurate data about broadband coverage. To some degree, this was the FCC’s fault because the agency never reviewed what ISPs submitted, and there was no feedback or challenge mechanism for outsiders to complain about the maps – even though the FCC heard repeatedly about the poor quality of the maps. The FCC now wants an engineer to bless the coverage area for every ISP that submits broadband mapping data.

In July, the FCC temporarily backed off from that ruling since many ISPs are unable to find a professional engineer to bless its FCC reporting for the upcoming new mapping deadline in September. The FCC will allow ISPs to get coverage data certified by an experienced engineer for the first three FCC data collection cycles meaning that ISPs must comply with the original order by two years from now.

I think the FCC ruling is going to be harmful to small ISPs, and I’ll describe why below. But first, I want to highlight what ISPs must do for the current 477 mapping data due next month. ISPs still need to get somebody who is qualified to certify the broadband coverage area. Note that an engineer is not certifying the broadband speeds – the mapping issue that matters the most. ISPs have three choices of folks who can provide the certification:

  • They can get the coverage area certified by a professional engineer.
  • They can get the data certified by an engineer who meets the following qualifications: 1) a degree in electrical engineering, electronic technology, or similar technical degree along with seven years of experience in broadband network design and/or performance, or 2) somebody with specialized training relevant to broadband network engineering and ten years of experience in the field.
  • A corporate office of the ISP who has a degree in engineering and who also has direct knowledge of the network design. Note that this person must be a corporate officer and not just an employee of the ISP. ISPs cannot satisfy the future requirement by hiring a professional engineer unless that person also becomes a corporate officer. I’ll have to leave it up to lawyers to define what a corporate officer is, but I’m guessing a CTO is not a corporate officer.

The requirement to certify the biannual 477 data filings is going to be a burden for small ISPs for several reasons. First, as the FCC acknowledges in the recent ruling, there is a shortage of professional engineers in the broadband industry. I think this shortage is a lot more acute than the FCC understands. Big ISPs will have no problem meeting this requirement because these ISPs will meet the requirement with either a corporate officer with an engineering degree or by hiring a professional engineer.

The problem comes from the many small ISPs that don’t have a relationship with a professional engineer. Most small ISPs take great pride in that they’ve built the network themselves without paying for expensive external engineering or consulting help. Small ISPs must be frugal if they want to survive I’ve talked to several engineering companies in the industry, and they have zero interest in taking on new clients who only need them to certify FCC 477 filings. Engineering firms in the country are already working at full capacity due to the explosion of broadband grants and the general expansion of fiber networks. They view helping somebody with mapping to be busy paperwork rather than useful engineering. When the temporary FCC waiver is over, I don’t think little ISPs will find professional engineers willing to help them.

I also don’t think the FCC understands what it is requesting from a professional engineer. The FCC is asking the P.E. to certify that the ISP network reaches everywhere claimed in the 477 mapping data. Engineers are not going to be willing to sign a 477 certification without having done the research to fully understand the network. I can picture that easily costing $10,000 to $50,000, depending upon the complexity of the network. It’s clear in the mapping order that the FCC is counting on professional engineers to do that research – but I don’t think they understand how much this will cost a small ISP. Engineers are not going to certify a network without this research since they are putting their license on the line if they certify a network based solely on what an ISP tells them. As an aside, this requirement gets even more onerous if the P.E. must be certified in the same state as the ISP – some states have a major engineer shortage.

Second, I’m not sure that an engineer exists who can certify a WISP network with multiple radio sites. There are propagation models available that estimate the coverage of a given radio, and the FCC has suggested that those are an acceptable tool for understanding the reach of a given radio. But every engineer understands that propagation studies are largely fantasy after a short distance from a transmitter. There are local conditions like trees, buildings, and other impediments that can affect the reach of a radio that are not reflected in the propagation studies. WISPs usually don’t know if they can connect to a new customer until they visit the customer’s house and try to connect. How can an engineer certify the reach of a WISP network when a WISP doesn’t understand it?

I know that the FCC is trying to avoid the blame it has taken over the years for producing dreadful broadband maps. But in this case, the industry told the FCC why its requirements can’t work, and the agency ignored what they were told. Unfortunately, the FCC didn’t hear directly from the small ISPs – because it never does. These little companies don’t know what’s going on at the FCC and don’t make comments in dockets, even those that matter. For now, the FCC has booted this issue two years down the road – but I can promise that the same issues will exist then that exist now, and small ISPs will be unable to comply with this requirement, even if they want to.

New FCC Mapping Deadlines Announced

On March 4, the FCC released its long-awaited new instructions for how ISPs are to report broadband coverage, speeds, and customers to the FCC. The order also provides a timeline for reporting to the FCC in the new formats. The new reporting is still called the FCC 477 data filing, but the format has changed significantly.

These reporting rules are the culmination of several years of effort by the FCC to revamp the way the agency collects broadband data. The current broadband data is so erroneous today from some ISPs that it’s hard to take any statistics coming out of the FCC seriously. But today’s blog is not to bash the FCC’s past mapping performance but to let ISPs know what must be reported this summer. Following are the highlights of the new rules, which can be found here.

Who Must File? Any fixed or mobile entity that acts as the ISP for at least one customer on June 30, 2022 must file. It seems like in almost every county I work in, I find an ISP or two that is not reporting to the FCC. I’m wondering if the agency is going to make any effort to find the non-filers.

Interestingly, any federal agency along with state, local, and Tribal governments can also file broadband mapping and coverage data. I don’t think this data is automatically going into the new FCC map, but rather starts building what the FCC is calling a challenge process for those that don’t agree with what ISPs report.

Due Date. The new FCC reporting portal will be open on June 30. ISPs must complete filings by September 1. The FCC expects to be on the normal schedule with two filings due in 2023.

The FCC warned separately a few weeks ago that it may accelerate and shorten the September 1 date, so I advise ISPs to report early. If this is like any other large government reporting portal, there are bound to be glitches this first time – so don’t wait until the last minute.

The New Reporting Data.

The big change is that ISPs must submit shapefiles for polygons that define the service territory. Each polygon should include existing customers along with homes or businesses that can be connected within 10 business days of a request for service. If an ISP doesn’t want to provide shapefiles it can provide the detailed location of each customer. WISPS and cellular carriers must file propagation maps from each transmitter along with details of signal strength and heat map data. The 477 reporting now also requires traditional telephone and VoIP subscriber data. Cellular carriers must show broadband and voice coverage separately if it’s not the same service area.

This is the most material change in the new 477 data and will have the biggest impact if ISPs file correctly. For example, if done right, these maps will identify the last home served along every road leaving towns served by a cable company. This reporting is a lot more complicated for rural ISPs, and as I’ve written recently, I don’t know how rural WISPs can meet this requirement with any accuracy.

How to File. ISPs can either input data into the new FCC portal or submit data to the FCC using an API.

Double Reporting. An important thing to note is that ISPs are required for this filing to file in both the new and the old 477 system – you must file twice.

The FCC is banking heavily on this new data being more accurate than the past 477 data. I think in some ways it will, if ISPs like the cable companies draw accurate shapefiles. But I’m extremely skeptical that this is going to fix the problem of ISPs overstating broadband speeds – and that’s the issue the FCC has promised will be fixed to support the BEAD grants. I guess we’ll find out some time this winter after the FCC crunches the new data.

Note that anybody who analyzes FCC data for broadband coverage and speed is likely to have a steep learning curve to understand the new data.

Ideas for Better Broadband Mapping

The FCC is soliciting ideas on better ways to map broadband coverage. Everybody agrees that the current broadband maps are dreadful and misrepresent broadband availability. The current maps are created from data that the FCC collects from ISPs on the 477 form where each ISP lists broadband coverage by census block. One of the many problems with the current mapping process (I won’t list them all) is that census blocks can cover a large geographic area in rural America, and reporting at the census block level tends to blur together different circumstances where some folks have broadband and others have none.

There have been two interesting proposals so far. Several parties have suggested that the FCC gather broadband speed availability by address. That sounds like the ultimate database, but there are numerous reasons why this is not practical.

The other recommendation is a 3-stage process recommended by NCTA. First, data would be collected by polygon shapefiles. I’m not entirely sure what that means, but I assume it means using smaller geographic footprints than census blocks. Collecting the same data as today using a smaller footprint ought to be more accurate. Second, and the best idea I’ve heard suggested, is to allow people to challenge the data in the mapping database. I’ve been suggesting that for several years. Third, NCTA wants to focus on pinpointing unserved areas. I’m not sure what that means, but perhaps it means creating shapefiles to match the different availability of speeds.

These ideas might provide better broadband maps than we have today, but I’m guessing they will still have big problems. The biggest issue with trying to map broadband speeds is that many of the broadband technologies in use vary widely in actual performance in the field.

  • Consider DSL. We’ve always known that DSL performance decreases with distance from a DSL base station. However, DSL performance is not as simple as that. DSL also varies for other reasons like the size of the gauge of copper at a customer or the quality of the copper. Next door neighbors can have a significantly different DSL experience if they have different size wires in their copper drops, or if the wires at one of the homes have degraded over time. DSL also differs by technology. A telco might operate different DSL technologies out of the same central office and see different performance from ADSL versus VDSL. There really is no way for a telco to predict the DSL speed available at a home without installing it and testing the actual speed achieved.
  • Fixed wireless and fixed cellular broadband have similar issues. Just like DSL, the strength of a signal from a wireless transmitter decreases over distance. However, distance isn’t the only issue and things like foliage affect a wireless signal. Neighbors might have a very different fixed wireless experience if one has a maple tree and the other has a pine tree in the front yard. To really make it difficult to define the speed, the speeds on wireless systems are affected to some degree by precipitation, humidity and temperature. Anybody who’s ever lived with fixed wireless broadband understands this variability. WISPs these days also use multiple spectrum blocks, and so the speed delivered at any given time is a function of the particular mix of spectrum being used.

Regardless of the technology being used, one of the biggest issues affecting broadband speeds is the customer home. Customers (or ISPs) might be using outdated and obsolete WiFi routers or modems (like Charter did for many years in upstate New York). DSL speeds are just as affected by the condition of the inside copper wiring as the outdoor wiring. The edge broadband devices can also be an issue – when Google Fiber first offered gigabit fiber in Kansas City almost nobody owned a computer capable of handling that much speed.

Any way we try to define broadband speeds – even by individual home – is going to still be inaccurate. Trying to map broadband speeds is a perfect example of trying to fit a round peg in a square hole. It’s obvious that we can do a better job of this than we are doing today. I pity a fixed wireless ISP if they are somehow required to report broadband speeds by address, or even by a small polygon. They only know the speed at a given address after going to the roof of a home and measuring it.

The more fundamental issue here is that we want to use the maps for two different policy purposes. One goal is to be able to count the number of households that have broadband available. The improved mapping ideas will improve this counting function – within all of the limitations of the technologies I described above.

But mapping is a dreadful tool when we use it to start drawing lines on a map defining which households can get grant money to improve their broadband. At that point the mapping is no longer a theoretical exercise and a poorly drawn line will block homes from getting better broadband. None of the mapping ideas will really fix this problem and we need to stop using maps when awarding grants. It’s so much easier to decide that faster technology is better than slower technology. For example, grant money ought to be available for anybody that wants to replace DSL on copper with fiber. I don’t need a map to know that is a good idea. The grant process can use other ways to prioritize areas with low customer density without relying on crappy broadband maps.

We need to use maps only for what they are good for – to get an idea of what is available in a given area. Mapping is never going to be accurate enough to use to decide which customers can or cannot get better broadband.

How Bad is the Digital Divide?

The FCC says that approximately 25 million Americans living in rural areas don’t have access to an ISP product that would be considered as broadband – currently defined as 25/3 Mbps. That number comes out of the FCC’s mapping efforts using data supplied by ISPs.

Microsoft tells a different story. They say that as many as 163 million Americans do not use the Internet at speeds that the FCC considers as broadband. Microsoft might be in the best position of anybody in the industry to understand actual broadband performance because the company can see data speeds for every customer that updates Windows or Microsoft Office – that’s a huge percentage of all computer users in the country and covers every inch of the country.

Downloading a big software update is probably one of the best ways possible to measure actual broadband performance. Software updates tend to be large files, and the Microsoft servers will transmit the files at the fastest speed a customer can accept. Since the software updates are large files, Microsoft gets to see the real ISP performance – not just the performance for the first minute of a download. Many ISPs use a burst technology that downloads relatively fast for the first minute or so, but then slows for the rest of a download – a customer’s true broadband speed is the one that kicks in after the burst is finished. The burst technology has a side benefit to ISPs in that it inflates performance on standard speed tests – but Microsoft gets to see the real story.

I’ve ranted about the FCC’s broadband statistics many times. There are numerous reasons why the FCC data is bad in rural America. Foremost, the data is self-reported by the big ISPs who have no incentive to tell the FCC or the public how poorly they are doing. It’s also virtually impossible to accurately report DSL speeds that vary from customer to customer according to the condition of specific copper wires and according to distance from the DSL core router. We also know that much of the reporting to the FCC represents marketing speeds or ‘up-to’ speeds that don’t reflect what customers really receive. Even the manner of reporting to the FCC, by Census block, distorts the results because when a few customers in a block get fast speeds the FCC assumes that everyone does.

To be fair, the Microsoft statistics measure the speeds customers are actually achieving, while the FCC is trying to measure broadband availability. The Microsoft data includes any households that elect to buy slower broadband products to save money. However, there are not 140 million households that purposefully buy slow broadband (the difference between 163 million and 24 million). The Microsoft numbers tell us that the actual speeds in the country are far worse than described by the FCC – and for half of us slower than 25/3 Mbps. That is a sobering statistic and doesn’t just reflect that rural America is getting poor broadband, but also that many urban and suburban households also aren’t achieving 25/3 Mbps.

I’ve seen many real-life examples of what Microsoft is telling us. At CCG Consulting we do community surveys for broadband and we sometimes see whole communities where the achieved speeds for customers is lower than the speeds advertised by the ISPs. We often see a lot more households claim to have no broadband or poor broadband than would be expected using the FCC mapping data. We constantly see residents in urban areas complain that broadband with a relatively fast speed seems slow and sluggish.

Microsoft reported their findings to the FCC, but I expect the FCC to ignore their story. This is a drastic departure from the narrative that the FCC is telling Congress and the public. I wrote a blog just a few weeks ago describing how the FCC is claiming that big ISPs are delivering the speeds that they market. Deep inside the recent reports the FCC admitted that DSL often wasn’t up to snuff – but the Microsoft statistics mean that a lot of cable companies and other ISPs are also under-delivering.

In my mind the Microsoft numbers invalidate almost everything that we think we know about broadband in the country. We are setting national broadband policy and goals based upon false numbers – and not numbers that are a little off, but rather than are largely a fabrication. We have an FCC that is walking away from broadband regulation because they have painted a false narrative that most households in the country have good broadband. It would be a lot harder for politicians to allow broadband deregulation if the FCC admitted that over half of the homes in the country aren’t achieving the FCC definition of broadband.

The FCC has been tasked by Congress to find ways to improve broadband in areas that are unserved or underserved – with those categories being defined by the FCC maps. The Microsoft statistics tell us that there are huge numbers of underserved households, far higher than the FCC is recognizing. If the FCC was to acknowledge the Microsoft numbers, they’d have to declare a state of emergency for broadband. Sadly, the FCC has instead doomed millions of homes from getting better broadband by declaring these homes as already served with adequate broadband – something the Microsoft numbers say is not true.

The current FCC seems hellbent on washing their hands of broadband regulation, and the statistics they use to describe the industry provide the needed cover for them to do so. To be fair, this current FCC didn’t invent the false narrative – it’s been in place since the creation of the national broadband maps in 2009. I, and many others predicted back then that allowing the ISPs to self-report performance would put us right where we seem to be today – with statistics that aren’t telling the true story. Microsoft has now pierced the veil to see behind the curtain – but is there anybody in a position of authority willing to listen to the facts?