Averting a Mapping Disaster?

Alan Davidson, the head of the National Telecommunications and Information Administration, recently announced that the agency is canceling plans to use the first iteration of the new FCC maps that the FCC says will be available by early November. Davidson says that he feels obligated to let the FCC’s challenge process play out before using the mapping data. I’m sure this wasn’t an easy decision, but it says that it’s better to hold out for a more accurate map rather than settling for the first iterations of the new FCC maps.

This decision will clearly add more time and delay to the $42.5 billion BEAD grant program. But the decision to wait recognizes that using incorrect maps would almost inevitably mean lawsuits that could delay the grant program even longer.

The timing of the new maps became unfortunate when Congress mandated that the FCC maps must be used to allocate over $38 billion in grant funding to states. The FCC has been stating all summer that it hopes that the new maps will be relatively accurate and will fix many of the obvious problems in the current broadband maps. If it wasn’t for the pressure of the BEAD grant program, the FCC would have had several cycles of the new maps to smooth out kinks and errors in the reporting before they had to bless the new maps as solid. The NTIA decision to delay relieves the pressure to have the first set of maps be error-free – which nobody believes will happen. I have a hard time recalling any cutover of a major government software system that was right the first time, and the FCC’s assurances all summer have felt more like bravado than anything else.

Over the last few weeks, I’ve been talking to the engineers and other folks who are helping ISPs with the new maps. I didn’t talk to anybody who thinks the new maps will be solid or accurate. Engineers are, by definition, somewhat cautious folks, but I expected to find at least a few folks who thought the new maps would be okay.

I’ve been saying for six months that the likelihood of the new maps being accurate is low, and I was thinking about not writing anything more about mapping until we see what the new maps produce. However, I was prompted to write about mapping again when I saw a headline in FierceTelecom that quoted Jonathan Chambers of Conexon saying that the new maps will be a train wreck. Conexon is working with electric cooperatives all across the country to build broadband networks, which gives the company an interesting perspective on rural issues.

Jonathan Chambers cites two reasons for pessimism. One is the reason I already mentioned, which is that it’s irrational to use the outputs of a new federal mapping system to allocate billions of dollars between states. He says that there are simpler alternatives that would take all of the pressure off the new mapping system. He’s right, but unfortunately, Congress specifically required In the IIJA legislation that the FCC maps be used. It would take an act of Congress to change that ruling.

Chambers is also pessimistic about the challenge process that is being allowed for the new maps. He expects the challenges to be major and ongoing. It seems unlikely that the FCC is prepared to investigate the huge number of protests that could come from every corner of the country claiming that the new maps got the facts wrong.

My discussions with engineers raised other questions not mentioned by Chambers. Some engineers told me that the underlying mapping fabric has a lot of mistakes. This is where CostQuest, the firm that created the new mapping system, laid out the location nationwide of every possible broadband customer. This was a nearly impossible task in the short time the company had to create the maps. I’ve been working for years with local governments that use GIS data to define potential broadband locations, and it’s always a challenge to identify only those buildings where somebody might buy broadband and exclude buildings used for some other purpose.

My biggest concern is that ISPs are still allowed to report marketing speeds instead of actual speeds, and I fear that ISPs will be motivated to overstate broadband speeds in the new maps (like many have done in the old ones). Any areas designated by the maps to already have broadband available at 100/20 Mbps will be declared ineligible for the BEAD grants, and any ISP that wants to protect against being overbuilt has a high motivation to claim that speed – and it seems likely that many of them will do so. I don’t know if this is true, but my interpretation of the FCC map challenge is that the FCC won’t entertain challenges based on speed, but only on the coverage area. If that is true there will be a huge uproar from states and communities that get disadvantaged from deceptive reporting by ISPs.

I’ve also heard from ISPs in the last week that were unable to navigate the new mapping system by the deadline. These are relatively small ISPs, but many of them have built fiber and it’s not good to have them excluded from the maps. I’ve heard from multiple sources that the new mapping system is not easy to use. I’ve heard from ISPs who didn’t have an engineer who was able to certify the maps and just gave up.

I guess we’ll find out in a few months how the first draft of the maps turns out. The FCC says it will release the results by early November. I expect there are a whole lot of folks who are poised to compare the new maps to their local knowledge of actual broadband usage – and then the challenges will begin.

Who Should Report to the FCC Mapping?

I think there are a lot of ISPs that are not participating in the FCC data collection effort that the industry refers to as the broadband maps. In almost every county I’ve ever worked in, I run across a few ISPs that are not reporting broadband usage. There are several categories of ISPs in this category.

I often run across small regional WISPs and occasionally across fiber overbuilders that are not listed in the database. I know these ISPs are there because people claim them as their ISP when we do a broadband survey. These ISPs generally have a website that lists broadband rates and coverage areas – but for whatever reason, these ISPs do not participate in the FCC mapping database.

My guess in most cases is that these small ISPs don’t think they are required to report – they either don’t even know about the database, or they don’t fear any repercussions for not reporting. These are generally small single-owner or family businesses, and the owners might think that broadband isn’t regulated. Some of these ISPs have operated for years, and nobody has ever knocked on their doors about regulation, so they remain either blissfully unaware of their obligation to report or they don’t think it is important.

Another category that often doesn’t report is local governments that provide the fiber connectivity to their own buildings and sometimes to a few key businesses in town. These are not always small, and there are municipal networks in larger cities that are not included in the FCC database. Many cities don’t think they are ISPs even if they perform all of the ISP functions. They provide bandwidth to and from the Internet using facilities that they have built to connect to users. In some cases, there is an underlying ISP serving the city, but often there is not. Another similar category is school networks that buy wholesale bandwidth and do all of the ISP functions.

These local governments are doing themselves a disfavor by not reporting because their government buildings are not listed as being served by fiber. That could open up the door for some other ISP to ask for grant funding to serve the anchor institutions in the region that are already served.

Another interesting group of ISPs that often doesn’t report to the FCC is companies that buy wholesale loops from an open-access or leased loop environment. Generally, these loops are pure transport, and the ISP has to handle the functions of routing traffic to and from the Internet. These folks also often don’t think they are ISPs because they don’t own the fiber loop – but the entity that performs the ISP functions for a customer is the ISP and should be reporting to the FCC. These are often small companies that tackle being an ISP as a sideline business and I would guess they don’t think they are regulated.

The group that mystifies me the most are some of the big national ISPs. There are ISPs who have nationwide contracts to serve all branches of national chains like hotels, banks, etc. In a city of 20,000 or larger, there are often a half dozen such ISPs serving one or more businesses. But I regularly find that a few big ISPS are not reporting to the FCC. I’ve always wondered if some other big ISP includes these customers in its reporting, but when I look at the granular data, it often looks like many of the national chains served by fiber are not claimed by any ISP. The new FCC mapping is going to get a lot more granular and maybe we’ll finally be able to see if such connections are reported by somebody.

Adding together all of the ISPs that don’t report is likely only a minuscule sliver of the ISP market. However, these are often some of the most important connections in a city since they are the customers served with fiber. A small-city fiber network might be bringing multi-gigabit broadband to city buildings or a handful of businesses, and nobody knows about it.

I don’t know that the FCC has any hope of uncovering these small ISPs, and it’s not worth the investigative effort to identify them. But at least part of the blame for this lies at the FCC. The agency doesn’t have clear guidelines in plain English defining who is an ISP, with examples. But it might not help even if the FCC did, since it seems that many small ISPs barely know the FCC exists.

Challenging the FCC Broadband Maps

I’ve written many times about the absurdity of using the FCC mapping data for identifying areas with or without broadband. I’ve lately been looking at the FCC mapping data in West Virginia and New Mexico – two of the states with the worst broadband coverage in the country – and the FCC maps are atrocious. I see counties where the claimed broadband coverage in the FCC maps is wrong for more than half of the geographic area.

Unfortunately, the FCC is about to award $20.4 billion in RDOF grants later this year based solely on these dreadful maps. Luckily, there are other grant programs that allow grant applicants to challenge the FCC data. This includes the USDA ReConnect grants and many of the state grant programs.

One of the few ways to challenge the FCC maps is with speed tests. Anybody undertaking such a challenge needs to be aware that the incumbent telcos might challenge your speed test results, and unfortunately, some of their criticisms will be right. This means that anybody challenging the FCC maps has to take some steps to maximize the effectiveness of speed tests. Here are a few aspects of administering speed tests that should be considered.

  • A speed test needs to distinguish between cellular and landline connections. Rural folks with no broadband connection or those using cellular for home broadband are going to take the test with their cellphone. While such results are interesting, cellular speed tests can’t be mixed into a challenge of landline broadband coverage.
  • Everybody needs to use the identical speed test because each speed test measures speed using a different algorithm. Never use a speed test from the incumbents – it might be baked to show too good results.
  • A challenge can be most effective if it can get feedback from folks with no broadband available at their home. You need to somehow solicit and include results from folks that can’t take the speed tests.
  • You also should be aware a speed test sometimes doesn’t work for somebody with really slow broadband or high latency. We recently sat on the phone with somebody using satellite broadband and they couldn’t get the speed test to complete, even after many attempts.
  • The biggest challenge is in mapping the results. If you map the results so precisely that the results can be overlaid on individual homes on Google Earth, then you have provided an incumbent ISP the chance to challenge the test results. They can likely identify homes where they aren’t the ISP, or homes that have broadband that meets the FCC speed thresholds, meaning that slow speed test results might be due to poor WiFi or some other reason. Ultra-precise mapping might also violate the privacy of the people taking the speed test, This is an issue that many state speed test programs have wrestled with – some of them take such care to mask the precise location of the data that their final product can’t be used to challenge the FCC maps. For example, if speed test results are summarized by Census blocks then the results incorporate the same kinds of problems that are included in the FCC maps. Probably the best approach is to embed the final results in a pdf that is of low enough resolution to not identify individual homes.

There is one other way to map broadband coverage. An experienced field technician or engineer can drive around an area and can identify every broadband asset in the field. They can precisely identify where the cable TV networks end, down to the house. They can identify field DSLAMs that generate DSL signals out of rural cabinets – and they can often precisely identify the flavor of DSL and know the maximum speed capability of a given unit. They can identify the location and height of wireless transmitters and can map out the likely coverage areas. This kind of effort is most effective at identifying where there is no broadband, A good technician can make a decent map of the likely maximum broadband speeds available in a given area – something that is rarely achieved on most rural networks. This kind of challenge could be expensive and time-consuming, and I’ve never seen a challenge done this way. But I know engineers and technicians capable of making highly accurate maps.

Communities can tackle speed tests – they can get households to take the same speed test, such as the speed test from Ookla, and then match and map the results using GIS data. This can be a lot of work. Mapping can also be provided by many telecom engineering companies. One of the lowest-costs solutions is a speed test by Neo Partners that administers the speed test and overlays the speed test results automatically on Google maps.

Even if you aren’t challenging a grant, communities ought to consider speed tests to better understand the broadband in their community. As an example, I worked for a city where the speed tests showed that one neighborhood had far slower speeds than the rest of the city – something the city hadn’t known before the speed test. We’ve done speed tests that showed that the incumbent was delivering more than the advertised speed – again, something worth knowing.

Another Story of Lagging Broadband

We don’t really need any more proof that the FCC broadband data is massively out of touch with reality. However, it seems like I see another example of this almost weekly. The latest news comes from Georgia where the Atlanta Journal-Constitution published an article that compared actual broadband speeds measured by speed tests to the FCC data. The newspaper analyzed speed tests from June through December 2017 and compared those results to the FCC databases of supposed broadband speeds for the same time period. Like everywhere else that has done this same comparison, the newspaper found the FCC data speeds to be overstated – in this case, way overstated.

The newspaper relied on speed tests provided by Measurement Labs, an Internet research group that includes Google, the Code for Science & Society, New America’s Open Technology Institute, and Princeton University’s PlanetLab. These speed tests showed an average Internet speeds of only 6.3 Mbps for areas where the FCC data reported speeds of 25 Mbps are available.

Anybody that understands the FCC mapping methodology knows that you have to make such a comparison carefully. The FCC maps are supposed to show available speeds and not actual speeds, so to some degree the newspaper is comparing apples and oranges. For instance, when multiple speeds are available, some people still elect to buy slower speeds to save money. I would expect the average speed in an area where 25 Mbps is the fastest broadband to be something lower than that.

However, the ultralow average speed test results of 6.3 Mbps points out a big problem in rural Georgia – homes electing to buy lower speeds can’t possibly account for that much of a difference. One thing we now know that is an area shown by the FCC to have 25 Mbps broadband speeds is probably served by DSL and perhaps by fixed wireless. The vast majority of cable companies now have speeds much faster than 25 Mbps and areas shown on the maps that are served by cable companies will show available speeds of at least 100 Mbps, and in many cases now show 1 Gbps.

The only way to explain the speed test results is that the FCC maps are wrong and the speeds in these areas are not really at the 25 Mbps level. That highlights one of the big fallacies in the FCC database, which is populated by the ISPs. The telcos are reporting speeds of ‘up to 25 Mbps’ and that’s likely what they are also marketing to customers in these areas. But in reality, much of the DSL is not capable of speeds close to that level.

The newspaper also gathered some anecdotal evidence. One of the areas that showed a big difference between FCC potential speed and actual speed is the town of Social Circle, located about 45 miles east of Atlanta. The newspaper contacted residents there who report that Internet speeds are glacial and nowhere near to the 25 Mbps as reported on the FCC maps. Several residents told the newspaper that the speeds are too slow to work from home – one of the major reasons that homes need faster broadband.

Unfortunately, there are real-life ramifications from the erroneous FCC maps. There have been several grant programs that could have provided assistance for an ISP to bring faster broadband to places like Social Circle – but those grants have been limited to places that have speeds less than 25 Mbps – the FCC definition of broadband. Areas where the maps are wrong are doubly condemned – they are stuck with slow speeds but also locked out of grant programs that can help to upgrade the broadband. The only beneficiary of the bad maps are the telcos who continue to sell inadequate DSL in towns like Social Circle where people have no alternative.

The State of Georgia has undertaken an effort to produce their own broadband maps in an attempt to accurately identify the rural broadband situation. The University of Georgia analyzed the FCC data which shows there was 638,000 homes and businesses that couldn’t get Internet with speeds of at least 25 Mbps. The state mapping effort is going to tell a different story, and if the actual slow speeds indicated by the speed tests are still true today then there are going to by many more homes that actually don’t have broadband.

It seems like every examination of the FCC mapping data shows the same thing – widespread claimed broadband coverage that’s not really there. Every time the FCC tells the public that we’re making progress with rural broadband, they are basing their conclusions on maps they know are badly flawed. It’s likely that there are many millions of more homes that don’t have broadband than claimed by the FCC – something they don’t want to acknowledge.