FCC Modifies Broadband Mapping Parameters

Last week the FCC decided to change the method of collecting data to support its broadband maps. It’s widely understood that the current mapping system badly misstates broadband coverage. That’s a big problem since the FCC uses the faulty broadband mapping data to make decisions like determining eligibility for broadband grants.

The most important new change is that ISPs have to produce mapping ‘polygons’ to show where they have existing customers. The ISP polygons can cover areas without current customers only where an ISP “has a current broadband connection or it could provide such a connection within ten business days of a customer request and without an extraordinary commitment of resources or construction costs exceeding an ordinary service activation fee.”

The new polygons fix one of the big flaws in the current broadband map. The polygons are going to make a noticeable difference when showing coverage for a cable company or a fiber-to-the-home network. Those networks have hard boundaries – there is always a last home served at the edge of the service area after which nobody else is covered. Today’s mapping by census block doesn’t recognize the hard boundaries of these networks and often counts customers outside these networks as having access to fast data speeds. This is particularly a problem in rural areas where a large area outside a small town might be counted as having 100 Mbps or faster broadband when there is no broadband.

Unfortunately, I don’t see the new maps making a big difference for the rest of rural America unless the ISPs providing DSL and fixed wireless service get scrupulously honest with reporting.  I contend that it is difficult, and perhaps impossible to accurately map these technologies – particularly for disclosing the broadband speed available at a given customer location.

Consider DSL. There are several factors that affect the speed of a DSL product. The one everybody knows is that the amount of delivered bandwidth decreases with distance from the DSLAM (the DSL core modem). However, the quality of DSL performance also depends upon the gauge of the copper serving a customer (there are different sizes of copper in a network), the quality of that copper (copper deteriorates over time), issues with the drop wire (drop wires can suffer from a variety of issues separate from issues in the network), the age and type of DSL electronics (there is still plenty of DSL from the 1990s), and the telco technology used on a given copper route to boost or extend signals. There are also customers who can’t get DSL due to the simple issue that a telco has no spare pairs of copper with which to serve them.

It is not unusual for two customers who are side by side to have a drastically different DSL experience – one might have a decent speed and one might not be able to get any DSL service. There is no way for a telco to reflect these highly local conditions on a broadband map. I’m doubtful that the big telcos even track the speeds available to existing customers. The telcos can’t know anything about homes that don’t have their service today.

The same goes for fixed wireless. Broadband speeds also decrease with distance from the tower. Wireless broadband speeds can vary with temperature and humidity. There is a definite fall-off in speed during precipitation. Wireless broadband using unlicensed spectrum is subject to interference, which can mysteriously come and go. The biggest obstacle for many wireless customers is foliage and other obstacles between a customer and the wireless tower. Just like with DSL, wireless companies don’t have any idea what speed they can deliver to a customer who is not on their network. They usually only know what’s available after climbing on a roof to investigate a connection.

Another big issue the FCC didn’t address is reporting of actual speeds. Our examination of the FCC mapping data for both DSL and fixed wireless shows that many ISPs don’t try to report actual broadband speeds. Instead, we see marketing speeds or something other speed standard being reported. Even if these providers map the polygons correctly, we won’t have a good idea of rural broadband coverage unless the ISPs try hard to report actual speeds. We hear from customers all the time that are being sold a rural broadband product that is marketed to deliver speeds of 10 Mbps, 15 Mbps, or 25 Mbps but which delivers only a few Mbps. If the maps don’t reflect the actual speeds they will still be largely worthless.

One last issue is a head-scratcher. Many rural networks are oversubscribed, meaning there are more customers than can comfortably be accommodated at the busiest usage times on the networks. How do you report the broadband speed for a customer who can get 20 Mbps downloads at 4:00 AM but 3 Mbps in the evening?

I applaud the FCC for finally getting rid of the census blocks. But we can’t pretend that this fix is going to make much of a difference for most of rural America. The rural broadband gap is mostly due to the neglected copper networks of the largest telcos. I can’t imagine any way to ever accurately map DSL and fixed wireless technologies., which means the maps are still going to be terrible in the places we most care about. The FCC is still going to harming rural America if they use the new maps to make decisions for important things like awarding grant money. The only real fix is to throw the maps away for those purposes and do something more sensible. For example, grant money ought to always be available to somebody that wants to build fiber to replace big telco copper – we don’t need a map to know that is good policy.

FCC Looks to Kill Copper Unbundling

FCC Chairman Ajit Pai circulated a draft order that would start the process of killing the unbundling of copper facilities. This unbundling was originally ordered with the Telecommunications Act of 1996, and unleashed telephone and broadband competition in the US. This new law was implemented before the introduction of DSL and newly formed competitors (CLECs) were able to use telco copper to compete for voice and data service using T1s. The 1996 Act also required that the big telcos offer their most basic products for resale.

The FCC noted that their proposed order will “not grant forbearance from regulatory obligations governing broadband networks”, meaning they are not going to fully eliminate the requirement for copper unbundling. This is because the FCC doesn’t have the authority to fully eliminate unbundling since the obligation was required by Congress –  the FCC is mandated to obey that law until it’s either changed by Congress or until there is no more copper left to unbundle. Much of the industry has been calling for an updated telecommunications act for years, but in the current dysfunction politics of Washington DC that doesn’t look likely.

The big telcos have hated the unbundling requirement since the day it was passed. Eliminating this requirement has been near the top of their regulatory wish list since 1996. The big telcos hate of unbundling is somewhat irrational since in today’s environment unbundling likely makes them money. There are still CLECs selling DSL from unbundled copper and generating monies for the telcos that they’d likely not have otherwise. But the hatred for the original ruling has become ingrained in the big telco culture.

The FCC’s proposal is to have a three year transition from the currently mandated rates that are set at incremental costs to some market-based leased rate. I guess we’ll have to see during that transition if the telcos plan to price CLECs out of the market or if they will offer reasonable lease rates that will continue to offer connections.

This change has the possibility of causing harm to CLECs and consumers. There are still a number of CLECs selling DSL over unbundled copper elements. In many cases these CLECs operate the newest DSL electronics and can offer faster data speeds than the telco DSL. It’s not unusual for CLECs to have 50 Mbps residential DSL. For businesses they can now combine multiple pairs of copper and I’ve seen unbundled DSL products for businesses as fast as 500 Mbps.

There are still a lot of customer that are choosing to stay with DSL. Some of these customers don’t feel the need for faster data speeds. In other cases it’s due to the fact that DSL is generally priced to be cheaper than cable modem products. At CCG we do surveys and it’s not unusual to find anywhere from 25% to 45% of the customers still buying DSL in a market that has a cable competitor. While there are millions of customers annually making the transition to cable modem service, there are still big numbers of households still using DSL – it’s many years away from dying.

There is another quieter use of unbundled copper that still has competitors worried. Any competitor that offers voice service using their own switch is still required by law to interconnect to the local incumbent telcos. Most of that interconnection is done today using fiber transport, but there still is a significant impact from unbundled elements.

Surprisingly, the vast majority of the public switched telecommunications network (PSTN) still uses technology based upon T1s. There was a huge noise made 5 – 10 years ago about having a ‘digital transition’ where the interconnection network was going to migrate to 100% IP. But for the most part this transition never occurred. Competitors can still bring fiber to meet an incumbent telco network, but that fiber signal must still be muxed down to T1 channels using T1s and DS3. The pricing for those interconnections are part of the same rules the FCC wants to kill. CLECs everywhere are going to be worried about seeing huge price increases for the interconnection process.

The big telcos have always wanted interconnection to be done at tariffed special access rates. These are the rates that often had a T1 (1.5 Mbps connection) priced at $700 per month. The unbundled cost for an interconnection T1 is $100 or less in most places and competitors are going to worry about seeing a big price increase to tie their network to telco tandems.

It’s not surprising to see this FCC doing this. They have been checking off the regulatory wish list of the telcos and the cable companies since Chairman Pai took over leadership. This is one of those regulatory issues that the big telcos hate as a policy issue, but which has quietly been operationally working well now for decades. There’s no pressing reason for the FCC to make this change. Copper is naturally dying over time and the issue eventually dies with the copper. There are direct measurable benefits to consumers from unbundling, so the real losers are going to be customers who lose DSL connections they are happy with.

Broadband Subscriptions Continue to Grow

According to the Leichtman Research Group, the biggest ISPs added 945,000 broadband customers in the first quarter of 2019. If sustained that would be an annual growth rate of 4% for the year. That contrasts drastically with the largest cable providers that are now losing cable customers at a rate of 6% annually.

The table below shows the changes in broadband customers for the largest ISPs for the quarter.

4Q 2018 Added % Change
Comcast 27,597,000 375,000 1.4%
Charter 25,687,000 428,000 1.7%
AT&T 15,737,000 36,000 0.2%
Verizon 6,973,000 12,000 0.2%
Cox 5,100,000 40,000 0.8%
CenturyLink 4,806,000 (6,000) -0.1%
Altice 4,155,000 36,900 0.9%
Frontier 3,697,000 (38,000) -1.0%
Mediacom 1,288,000 24,000 1.9%
Windstream 1,032,400 11,400 1.1%
Consolidated 780,720 1,750 0.2%
WOW 765,900 6,300 0.8%
Cable ONE 678,385 15,311 2.3%
Cincinnati Bell 426,700 1,100 0.3%
98,724,105 943,761 1.0%

The two biggest cable companies, Charter and Comcast are growing furiously and added 85% of all of the net industry additions, with Charter growing at an annual growth rate of almost 7%. Mediacom and Cable ONE grew even faster for the quarter.

The cable companies continue to dominate the telcos. As a whole, the big cable companies added over 925,000 customers at an annual growth rate of 5.75%. By contrast, the big telcos collectively added 18,250 customers, an annual growth rate of only 0.2%. We know that telcos are continuing to lose DSL customers, so a slight gain as a group means they are finding new customers to replace lost DSL connections.

The overall net gains for the first quarter of 2018 was 815,000. The increases are larger this year due to smaller losses by the telcos rather than faster growth for the cable companies. Perhaps a few of the telcos are finally seeing some upside by the rural CAF II builds.

The surprising statistic is how much Comcast and Charter continue to grow. They are obviously winning the broadband battle in the major cities and continue to take customers away from telco DSL on copper.

There has to be something else behind this kind of growth. A few years ago, there were analysts that predicted that the broadband market was topping out. It seemed like everybody who wanted broadband had it and that there were not a lot of potential customers left in the market. In the last two years we’ve seen continued growth similar to this last quarter.

It’s always hard to identify trends when looking at a nationwide trend, but one of the few ways to explain this continued growth is that more households are deciding that they must have broadband. That might mean homes with occupants older than 65, since that demographic always trailed other demographics in broadband acceptance. It might mean more houses with low incomes are finding a way to buy broadband because they’ve decided it is a necessity. At least some of this growth is coming by the effort to extend broadband into rural America, although that effort is largely being done by ISPs that are not on the above list.

The Penn State Broadband Study

Penn State conducted an intensive study of broadband in rural Pennsylvania. The study was funded by the Center for Rural Pennsylvania, a legislative agency of the Pennsylvania General Assembly.  The results will surprise nobody who works with rural broadband and the study concluded that actual broadband speeds are significantly slower than the speeds reported by the ISPs to the FCC.

The study concluded that there was not one rural county in the state where more than 50% of residents actually achieve the 25/3 Mbps that the FCC has defined as broadband. The study came to these conclusions by conducting more than 11 million speed tests. Residents voluntarily provided an additional 15 million speed test results.

These results are similar to what’s been reported by Microsoft – they measure the actual speeds at which millions of customers download Microsoft software every month. Microsoft says such tests are the best measure of real broadband speeds and that roughly half of all broadband connection in the country are done at speeds slower than the definition of broadband.

Some of the Penn State results are dramatic. For example, in Westmoreland County the FCC maps show the whole county has access to 25/3 Mbps broadband and yet the average download speed for the county was only 12.3 Mbps. Allegheny County also shows 100% broadband coverage on the FCC maps and yet the average download speed in the County is only 20 Mbps.

The study further showed that the difference between actual and reported speeds have been widening since 2014. That’s likely to mean that the FCC maps are showing improvements that aren’t really happening in the rural networks.

I have to point out, in the FCC’s favor, that households don’t always buy faster broadband when it’s available – many households continue to purchase older, slower DSL to save money. However, this phenomenon can’t come close explaining the results in Westmoreland County, where the actual speeds are only 12 Mbps – half the FCC’s definition of broadband. A more likely explanation is that the maps for the County show broadband available in rural areas where actual DSL speeds are only a few Mbps.

CCG helps our clients conduct similar tests on a smaller scale and we’ve seen similar results all across the country. The FCC maps are often pure fantasy. We routinely find rural areas that supposedly have fast broadband where there is no broadband. We often study county seats that supposedly have fast data speeds and yet where actual speed tests show something far slower. The speeds on the FCC maps come from data that is self-reported by ISPs, and some of the ISPs clearly have reasons to overreport the available speeds.

What is really irksome is that the FCC knows all of this already. They know that ISP reported broadband speeds are overstated, and yet the FCC compiles the faulty data and makes policy decisions based upon garbage data. The FCC’s recently published their 2019 Broadband Deployment Report which concluded that broadband is being deployed in the US on a reasonable and timely basis. In my opinion, that conclusion borders on fraud since the FCC knows that much of the data used to reach that conclusion is wrong. The real broadband situation in rural America is much more like what is being reported by Penn State and Microsoft. Rural residents in places like Allegheny County, Pennsylvania should be incensed that the FCC is telling the world that their broadband is up to snuff.

The FCC is starting a multi-year process to ‘improve’ the broadband maps – but this will just push the problem a few years into the future. The fact is that it’s almost impossible to map real broadband speeds in rural America. How can you map broadband speeds when real networks in rural America are in lousy shape? How can you map broadband speeds when two neighbors can experience drastically different broadband speeds due to the nuances in their copper wires? The big telcos have neglected maintenance on copper networks for decades and it’s no surprise that broadband speeds vary widely even within a neighborhood.

The best solution is to throw the maps away. The fact is that every place served by copper ought to be considered as underserved, and locations more than a few miles from a DSLAM ought to be considered as unserved. We need to stop pretending that we can somehow make a realistic map of broadband speed availability – the proposed new mapping might be a little better, but it can never be accurate. Every ISP technician that works in the field will tell you how ridiculous it is to try to map rural broadband speeds.

We need to face facts and recognize that we’re going to have these same issues until rural America gets fiber. There are now enough places in rural America with fiber to show it can be done. The FCC’s ACAM program has shown that fiber can work if there are subsidies to help with the construction costs. We’ve understood this for more than a century since we built the rural electric grids. But we probably can’t fix the problem until we’re honest about the scope of poor broadband. I have big doubts that this FCC is ever going to acknowledge that the real state of broadband is the one highlighted by this study.

Technology and FCC Grants

This is the next in the series of blogs looking at the upcoming $20.4 billion FCC grant program. I ask the question of how the FCC should consider technology in the upcoming grant program.

Should Satellite Companies be Eligible? I think a more fundamental question is if the current generation of high-orbit satellites really deliver broadband. Over the last few years I’ve talked to hundreds of rural people about their broadband situation and I have never met anybody who liked satellite broadband – not one person. Most people I’ve talked to have tried it once and abandoned it as unworkable.

This goes back to the basic definition of broadband. The FCC defines broadband by download speeds of at least 25/3 Mbps. In their original order in 2015 the FCC discussed latency, but unfortunately never made latency part of the broadband definition. As a reminder, the standard definition of latency is that it’s a measure of the time it takes for a data packet to travel from its point of origin to the point of destination.

A few years ago, the FCC did a study of the various last mile technologies and measured the following ranges of performance of last-mile latency, measured in milliseconds: fiber (10-20 ms), coaxial cable (15-40 ms), and DSL (30-65 ms). Cellular latencies vary widely depending upon the exact generation of equipment at any given cell site, but 4G latency can be as high as 100 ms. In the same FCC test, satellite broadband was almost off the chart with latencies measured as high as 650 ms.

Latency makes a big difference in the perceived customer experience. Customers will rate a 25 Mbps connection on fiber as being much faster than a 25 Mbps connection on DSL due to the difference in latency. The question that should be asked for federal grants is if satellite broadband should be disqualified due to poor latency.

I was unhappy to see so much money given to the satellite providers in the recent CAF II reverse auction. Even ignoring the latency issue, I ask if the satellite companies deserve broadband subsidies. There is no place in rural America where folks don’t already know that satellite broadband is an option – most people have rejected the technology as an acceptable broadband connection. It was particularly troubling seeing satellite providers getting money in a reverse auction. Once a satellite is in orbit it’s costs are fixed and that means that the satellite providers will be happy to take any amount of federal subsidy – they can bid lower than any other grant applicant in a reverse auction. I have to question the wisdom of providing federal subsidies to companies that are already failing at marketing.

I don’t have enough information to know how to feel about the upcoming low-orbit satellites that are just now being tested and launched. Because of lower orbits they will have lower latency. However, the satellite companies still have a huge advantage in a reverse auction since they can bid lower than anybody else – a satellite company would be happy with only a few dollars per potential customer and has no bottom limit on the amount of grant they are willing to accept. If the new satellite companies can bid in the same manner as everybody else we could end up with the situation where these companies claim 100% of the new grant funds.

What About DSL? My nightmare scenario is that the FCC hands most or all of the $20.4 billion to the big telcos to upgrade rural DSL from 10/1 Mbps to 25/3 Mbps. This is certainly within the realm of possibility. Remember that the first CAF II program was originally going to be open to everybody but at the last minute was all given to the big telcos.

I find it troublesome that the big telcos have been quiet about the announced plans for this grant. The money will be spent in the big telco service areas and you’d think they be screaming about plans for federal money to overbuild them. Recall that the big telcos recently were able to derail the Re-Connect grants by inserting the rule that only 10% of the grant money could be used for customers who receive at least 10/1 Mbps broadband. This FCC clearly favors the big telcos over other ISPs and could easily hand all of this money to the big telcos and call it CAF III.

Even if they don’t do that, the question is if any federal grant money should be used to upgrade rural DSL. Rural copper is in dreadful condition due to the willful neglect of the big telcos who stopped doing maintenance on their networks decades ago. It’s frankly a wonder that the rural copper networks even function. It would be a travesty to reward the telcos by giving them billions of dollars to make upgrades that they should have routinely made by reinvesting customer revenues.

I think when the dust clears on CAF II we’re going to find out that the big telcos largely cheated with that money. We’re going to find that they only upgraded the low-hanging fruit and that many households in the coverage areas got no upgrades or minor upgrades that won’t achieve the 10/1 Mbps goals. I think we’ll also find that in many cases the telcos didn’t spend very much of the CAF II funds but just pocketed it as free revenue. I beg the FCC to not repeat the CAF II travesty – when the truth comes out about how the telcos used the funding, the CAF II program is going to grab headlines as a scandal. Please don’t provide any money to upgrade DSL.

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


Access to Low-Price Broadband

The consumer advocate BroadbandNow recently made an analysis of broadband prices across the US and came up with several conclusions:

  • Broadband prices are higher in rural America.
  • They conclude that 45% of households don’t have access to a ‘low-priced plan’ for a wired Internet connection.

They based their research by looking at the published prices of over 2,000 ISPs. As somebody who does that same kind of research in individual markets, I can say that there is often a big difference between published rates and actual rates. Smaller ISPs tend to charge the prices they advertise, so the prices that BroadbandNow found in rural America are likely the prices most customers really pay.

However, the big ISPs in urban areas routinely negotiate rates with customers and a significant percentage of urban broadband customers pay something less than the advertised rates. But the reality is messier even than that since a majority of customers still participate in a bundle of services. It’s usually almost impossible to know the price of any one service inside a bundle and the ISP only reveals the actual rate when a customer tries to break the bundle to drop one of the bundled services. For example, a customer may think they are paying $50 for broadband in a bundle but find out their real rate is $70 if they try to drop cable TV. These issues make it hard to make any sense out of urban broadband rates.

I can affirm that rural broadband rates are generally higher. A lot of rural areas are served by smaller telcos and these companies realize that they need to charge higher rates in order to survive. As the federal subsidies to rural telcos have been reduced over the years these smaller companies have had to charge realistic rates that match their higher costs of doing business in rural America.

I think rural customers understand this. It’s a lot more expensive for an ISP to provide broadband in a place where there are only a few customers per road-mile of network than in urban areas where there might be hundreds of customers per mile. A lot of other commodities cost more in rural America for this same reason.

What this report is not highlighting is that the lower-price broadband in urban areas is DSL. The big telcos have purposefully priced DSL below the cost of cable modem broadband as their best strategy to keep customers. When you find an urban customer that’s paying $40 or $50 for broadband it’s almost always going to be somebody using DSL.

This raises the question of how much longer urban customers will continue to have the DSL option. We’ve already seen Verizon abandon copper-based products in hundreds of urban exchanges in the last few years. Customers in those exchanges can theoretically now buy FiOS on fiber – and pay more for the fiber broadband. This means for large swaths of the northeast urban centers that the DSL option will soon be gone forever. There are persistent industry rumors that CenturyLink would like to get out of the copper business, although I’ve heard no ideas of how they might do it. It’s also just a matter of time before AT&T starts walking away from copper. Will there even be any urban copper a decade from now? Realistically, as DSL disappears with the removal of copper the lowest prices in the market will disappear as well.

There is another trend that impacts the idea of affordable broadband. We know that the big cable companies now understand that their primary way to keep their bottom line growing is to raise broadband rates. We’ve already seen big broadband rate increases in the last year, such as the $5 rate increase from Charter for bundled broadband.

The expectation on Wall Street is that the cable companies will regularly increase broadband rates going into the future. One analyst a year ago advised Comcast that basic broadband ought to cost $90. The cable companies are raising broadband rates in other quieter ways. Several big cable companies have told their boards that they are going to cut back on offering sales incentives for new customers and they want to slow down on negotiating rates with existing customers. It would be a huge rate increase for most customers if they are forced to pay the ‘list’ prices for broadband.

We also see carriers like Comcast starting to collect some significant revenues for customers going over the month data caps. As household broadband volumes continue to grow the percentage of people using their monthly cap should grow rapidly. We’ve also seen ISPs jack up the cost of WiFi or other modems as a backdoor way to get more broadband revenue.

As the cable companies find way to extract more revenue out of broadband customers and as the big telcos migrate out of DSL my bet is that by a decade from now there will be very few customers with ‘affordable’ broadband. Every trend is moving in the opposite direction.

Rural America Deserved Better

I’ve often contended that the large telcos have made their money back several times over in rural America and could have comfortably rolled those profits back into rural networks. If they had done so then by now most of rural America would have at least 25/3 Mbps DSL and an upgrade to rural fiber would be underway.

Since the big telcos haven’t modernized rural networks for decades we are now faced with making the leap from poorly maintained copper straight to fiber. Sadly, the big telcos could have copied what smaller telcos have done – continually build a little fiber each year deeper into the rural areas to reduce the length of the copper loops. I’ve watched small telco clients over the last twenty years that have upgraded rural DSL from 1 Mbps to 6 Mbps to 15 Mbps and then to 25 Mbps or faster.

Instead, the big telcos built DSL in county seats and some other small towns in their service areas. Where the small telcos might have upgraded electronics three or four times since the late 1990s, the big telcos have likely upgraded the DSL in towns once, and perhaps in some lucky towns twice. This is why it’s still easy to go to rural towns all over the US and find maximum DSL speeds of 6 Mbps or 12 Mbps. The DSL electronics in many of these towns are now over ten or fifteen years old. The big telcos also rarely extended DSL outside of the town hubs. Customers that lived within a few miles of town were given DSL of perhaps 1 Mbps or 2 Mbps and customers further out were offered DSL that is often barely faster than dial-up.

This was all a deliberate decision. Upper management of the big telcos decided before 2000 that they weren’t going to extend DSL into the rural areas surrounding towns and they’ve made zero effort to do so since then. The big telcos failed their rural customers when they walked away from upgrading the copper and regulators mostly let them get away with it. The telcos had collected telephone revenues from the rural areas for decades before 2000. The telcos were all still regulated in 2000 and were all still considered as the carrier of last resort for telephone service. I think the FCC and state regulators screwed up when they didn’t also make them the carrier of last resort for broadband.

Some states tried to force the telcos to provide rural broadband. Pennsylvania is a famous example of bad behavior by the big telcos. In 1993 Bell Atlantic promised state regulators that they would bring universal broadband to cover over two million rural homes in the state. The state rewarded the telco by allowing a major rate increase, supposedly to help pay for the upgrades. It’s now 26 years later and the company that renamed itself as Verizon never made any of the promised upgrades. The rural valleys of central and western Pennsylvania have some of the worse rural broadband in America due to this broken promise.

The sad thing is that states like Pennsylvania had to try to bribe the telco to do the right thing. As regulated telcos, the companies should have routinely spent annual capital to improve the rural networks, a little each year. They were collecting the revenues to make it happen. What I find shortsighted about this decision by the telcos is that, if they had upgraded to decent rural broadband they likely would enjoy 80%+ broadband penetration rates in rural areas – all with zero competition. The telcos passed on the opportunity to make a lot of money.

It’s a lot harder today to make a business case to leap from copper to fiber – mostly because little rural fiber has already been built in many counties. If the big telcos had built fiber deep into the last mile, then the upgrade to fiber could have been gradually introduced over time. Instead, the big telcos simply all decided that they were quietly going to walk away from rural America without making any announcement they were doing so. For years they have talked about their commitment to rural America. They are putting out press releases even today patting themselves on the back for the CAF II upgrades – which was funded by the FCC but which should all have been funded over past decades using the revenues collected from rural customers.

If the big telcos had done what they were supposed to have done as regulated carriers, then the CAF II subsidies could have been used to aid them in upgrading to fiber in the last mile. We know this could work because most small rural telcos are making upgrades to fiber from the ACAM funds, which is equivalent to the CAF II funds, but for smaller telcos.

I lay a lot of blame on the regulators. Everybody in the industry understood what the big telcos were doing (and not doing). Regulators could have been a lot tougher and threatened to yank the big telco franchises in rural America. In the perfect world, regulators would have handed the rural service areas of the big telcos to somebody else twenty years ago when it was clear the telcos had all but abandoned the properties.

Telco regulation helped to build the copper networks that reach to rural homes and regulation should have been used to expand broadband. The sad part of all of this is that, if the telcos had done the right thing, then millions of homes in rural America would have decent broadband today, provided by the telcos, and the telcos would be benefitting from the revenues from those customers. Rural America deserved better.

Please, Not Another Mapping Debacle

There are numerous parties making proposals to the FCC on how to fix the broken broadband mapping program. Today I want to look at the proposal made by USTelecom. On the surface the USTelecom proposal sounds reasonable. They want to geocode every home and business in the US to create a giant database and map of potential broadband customers. ISPs will then overlay speeds on the detailed maps, by address. USTelecom suggests that defining broadband by address will eliminate the problems of reporting broadband by Census block.

Their idea should work well for customers of fiber ISPs and cable companies. Customer addresses are either covered by those technologies or they’re not. But the proposed new maps won’t do much better than current maps for the other technologies used in rural America for a number of reasons:

  • Telcos that provide rural DSL aren’t going to tell the truth about the speeds being delivered. Does anybody honestly believe that after taking billions of dollars to improve rural DSL that Frontier and CenturyLink are going to admit on these maps that customers in areas covered by CAF II are getting less than 10 Mbps?
  • In the telcos favor, it’s not easy for them to define DSL speeds. We know that DSL speeds drop with distance from a DSLAM transmitting point, so the speed is different with each customer, even with ideal copper.
  • Rural copper is far from ideal, and DSL speeds vary widely by customer due to local conditions. The quality can vary between wires in the same sheathe due to damage or corrosion over time. The quality of the drop wires from the street to the house can drastically impact DSL speeds. Even the inside copper wiring at a home can have a big influence. We also know that in many networks that DSL bogs down in the evenings due to inadquate backhaul, so time of day impacts the speed.
  • What is never mentioned when talking about rural DSL is how many customers are simply told by a telco that DSL won’t work at their home because of one of these reasons. Telcos aren’t reporting these customers as unservable today and it’s unlikely that they’ll be properly reported in the future.
  • Rural fixed wireless has similar issues. The ideal wireless connection has an unimpeded line-of-sight, but many customers have less than an ideal situation. Even a little foliage can slow a connection. Further, every wireless coverage area has dead spots and many customers are blocked from receiving service. Like DSL, wireless speeds also weaken with distance – something a WISP is unlikely or unwilling to disclose by customer. Further, while WISPs can report on what they are delivering to current customers they have no way of knowing about other homes until they climb on the roof and test the line-of-sight.
  • It’s also going to be interesting to see if urban ISPs admit on maps to the redlining and other practices that have supposedly left millions of urban homes without broadband. Current maps ignore this issue.

USTelecom also wants to test-drive the idea of allowing individuals to provide feedback to the maps. Again, this sounds like a good idea. But in real life this is full of problems:

  • Homeowners often don’t know what speeds they are supposed to get, and ISPs often don’t list the speed on bills. The broadband map is supposed to measure the fastest speed available, and the feedback process will be a mess if customers purchasing slower products interject into the process.
  • There are also a lot of problems with home broadband caused by the customer. ISPs operating fiber networks say that customers claiming low speeds usually have a WiFi problem. Customers might be operating ancient WiFi routers or else are measuring speed after the signal has passed through inside multiple walls.

I still like the idea of feedback. My preference would be to allow local governments to be the conduit for feedback to the maps. We saw that work well recently when communities intervened to fix the maps as part of the Mobility Fund Phase II grants that were intended to expand rural 4G coverage.

My real fear is that the effort to rework the maps is nothing more than a delaying tactic. If we start on a new mapping effort now the FCC can throw their hands up for the next three years and take no action on rural broadband. They’ll have the excuse that they shouldn’t make decision based on faulty maps. Sadly, after the three years my bet is that new maps will be just as bad as the current ones – at least in rural America.

I’m not busting on USTelecom’s proposal as much as I’m busting on all proposals. We should not be using maps to decide the allocation of subsidies and grants. It would be so much easier to apply a technology test – we don’t need maps to know that fiber is always better than DSL. The FCC can’t go wrong with a goal of supplanting big telco copper.

Comcast the ISP

Occasionally I see a statistic that really surprises me. I just read a quote from Dave Watson, the President of Comcast Cable where he told investors that Comcast has an overall 47% broadband market penetration rate, meaning that 47% of the households in their footprint buy broadband from Comcast. I would have guessed that their market penetration rate was higher. He did say that they have markets where they exceed a 60% market share.

There are a few reasons why their overall market share isn’t higher. For one thing, the company overlaps a lot of the same big markets where Verizon competes with fiber-based FiOS. The company also competes with fiber overbuilders like US Internet in Minneapolis and Sonic in the Bay Area that are chipping away at broadband customers. The company is also competing against a few municipal fiber overbuilders like in Chattanooga where the city-based fiber ISP has won the lion’s share of the market. It’s clear that fiber is a formidable competitor for any cable company.

Comcast also faces significant competition in the MDU market where there are numerous companies vying to serve large apartment buildings and complexes. For example, a big percentage of AT&T’s fiber expansion goal to pass 12 potential customers has been achieved through building fiber to large MDUs all around the country. There are also a number of successful ISPs that compete nationwide in the large MDU market.

Comcast, like all of the big cable companies, was a latecomer in competing for the business market. Historically the cable companies didn’t build their network in business districts and the telcos and CLECs gained early control of this market. Comcast and other cable companies now compete vigorously in the business market, but this is the one market segment that is competitive almost everywhere.

It is clear that Comcast is winning the battle against DSL. Comcast added 1.35 million broadband customers in 2018, while the telcos collectively lost nearly half a million customers.

I believe that the secret to the recent Comcast success is from offering faster broadband speeds. The company has upgraded to DOCSIS 3.1 and now offers gigabit broadband speeds. More importantly, the company has unilaterally increased speeds across-the-board several times to give them a significant speed advantage over DSL. The most recent speed increase last year increased base product speeds to 200 Mbps. It’s now an easy marketing advantage for the company to contrast this with the top DSL speed of 50 Mbps. Comcast is betting that speed wins and looking at the trend of their customers versus the telcos they seem to be right.

Comcast is also benefitting from the fact that many homes now find themselves bumping against the speed limits on slower products. Many homes that use multiple devices simultaneously are starting to find that a broadband speed of even 50 Mbps isn’t adequate for the way they want to use broadband. We are finally reaching the point where even the best DSL is becoming obsolete for many families. This trend is certainly accelerating and we saw 3.5 million new cord-cutting households last year who now watch all video online.

Even knowing all of the above market trends I was still surprised by the 47% market share. My firm does broadband surveys and we’ve never seen a Comcast or Charter market share below 60% in the markets we’ve studied. Of course, our experience is biased by the fact that we are only studying markets where somebody is thinking about building fiber, and there are undoubtedly Comcast markets that are considerably higher or lower than the 47% average market share.

I expect the Comcast market share to keep climbing. I think they have now won the war with DSL and in those markets where they aren’t facing a fiber competitor they will continue to pick up customers who realize they need more speed. As the household demand for broadband continues to double every three years, the migration from DSL to cable broadband is likely to accelerate.

I think it’s likely that telcos with copper networks are starting to lose steam. As the telcos keep losing DSL customers one has to wonder how much money the telcos will spend on advertising to support a sinking market. Just like I’m always surprised when I find out that there are still a few million dial-up customers remaining across the country, I think we have reached the tipping point on DSL, and DSL will start to be considered as a dead and dying technology. It might take another decade for DSL to finally die, but that slow death is finally underway.

Where’s the CAF II Success?

If you’ve read this blog you know I’ve been a big critic of the FCC’s CAF II program that gave over $10 billion in federal subsidies to the biggest telcos to improve rural broadband. My complaint is that the program set the embarrassingly low goal of improving rural broadband to speeds of at least 10/1 Mbps. My complaint is that this money could have done a huge amount of good had it been put up to reverse auction as was done with the leftover customers from this program last year – many ISPs would have used this funding to help to build rural fiber. Instead, the telcos are using the money mostly to upgrade DSL.

While I think the program was ill-conceived and was a giveaway to the big telco lobbyists, I am at least glad that it is improving rural broadband. For a household with no broadband, a 10 Mbps product might provide basic access to broadband services for the first time. We are now into the fifth year of the six-year program, so we ought to be seeing the results of these upgrades. USTelecom just published a blog saying that deployments are ahead of schedule and that CAF II is a quiet success.

The telcos have told the FCC they are largely on track – by the end of 2018 they should have upgraded broadband for at least 60% of the required households. AT&T and Windstream report that they have made at least 60% of the needed upgrades everywhere. Frontier says they are on track in 27 of the 29 states needing upgrades. CenturyLink says they are on track in only 23 of 33 states that are getting CAF II upgrades. According to USTelecom, over 2.1 million households should now be seeing faster speeds.

It’s also worth noting that the CAF II program should improve broadband for many more households that are not covered directly by the program. For example, when upgrading DSL for a CAF II area that surrounds a town, those living in the town should also see better broadband. The secondary benefit of the CAF program is that rural towns should be seeing speeds increasing from 6 Mbps or slower to as fast as 25 Mbps. By now many more millions of households should be seeing faster broadband due to CAF II.

What I find puzzling is that I would expect to see an upward burst of broadband customers for the big telcos because of CAF II. But the numbers aren’t showing that. There were four telcos that accepted more than $1 billion from the program, as follows, and three of them lost broadband customers in 2018:

Funding Households Per Household 2018 Broadband Customers
CenturyLink $3.09 B 1,190,016 $2,593 (262,000)
AT&T $2.96 B 1,265,036 $2,342 (18,000)
Frontier $1.7 B 659,587 $2,578 (203,000)
Windstream $1.07 B 413,345 $2,595 8,400
Total CAF II $10.05 B 4,075,840 $2,467

Windstream is the only telco of the four that gained customers last year. Windstream’s footprint is probably the most rural of the four telcos. We know that every telco is losing the battle for customers in towns where cable companies are increasing speeds on coaxial networks. Windstream seems to be offsetting those losses, and I can conjecture it’s because they have been selling more rural broadband.

AT&T is in a category all by itself. It’s impossible to know how AT&T is faring with CAF II. They are largely implementing CAF II using their cellular network (with the goal of tearing down rural copper). The company has also been deploying fiber past millions of homes and business in urban areas. They are clearly losing the residential broadband battle in urban markets to companies like Comcast and Charter. However, I can tell you anecdotally that AT&T hasn’t given up on urban copper. They have knocked on my door in Asheville, NC at least three times in the last year trying to sell DSL. I have to assume that they are also marketing broadband improvements in rural areas.

CenturyLink and Frontier are clearly bleeding broadband customers and each lost over 200,000 customers just in the last year. I have to wonder how hard these companies are marketing improved rural broadband. Both companies work in urban and suburban markets but also in numerous county seats situated in rural counties. Like every telco they are losing DSL customers in these markets to the cable company competitors.

Just like I have anecdotal evidence that AT&T is still pushing copper I hear stories that say the opposite for CenturyLink and Frontier. I worked in a few rural counties last year where the CAF II upgrades were reported as complete. And yet the communities seemed unaware of the improvements. Local politicians who bear the brunt of complaints from households that want better broadband weren’t aware of any upgrades – which tells me their rural constituents weren’t aware of upgrades.

I honestly don’t know what this all means. I really expected to find more positive evidence of the impact of CAF II. From what I know of rural America, households ought to leap at the opportunity to buy 10/1 Mbps DSL if they’ve had no broadband in the past. Are the upgrades being done but not being followed up with a marketing and public awareness campaign? Are actual upgraded speed not meeting the 10/1 Mbps goal? Are the upgrades really being made as reported to the FCC? We’re perhaps a year and a half away from the completion of CAF II, so I guess we’ll find out soon enough.