Speed Goals for FCC Grants

I literally grimaced when I first read about the 25/3 Mbps speed test that will likely be part of the new $20.4 billion grant program recently announced by the FCC. My first thought was that the 25/3 Mbps goal would provide an excuse for the FCC to give the grant money to the big telcos again. Those companies could then take another ten years to bring rural DSL up to the speeds they should have achieved on their own a decade ago. With the history of the FCC pandering to the big telcos I instantly feared this possibility.

But let’s assume that the upcoming grants will be available to all comers. Why would the FCC choose the 25/3 Mbps speed target? It’s a terrible goal for many reasons.

  • While this FCC will not admit it, 25/3 Mbps is already obsolete as the definition of adequate broadband. It’s been five years since 25/3 Mbps was adopted and households are using a lot more data than five years ago. It’s pretty easy to make the case that the definition of broadband today probably ought to be at least 50 Mbps download.
  • If the 25/3 Mbps speed is already outdated today, then it’s a lousy goal for a decade from now. This FCC should not repeat the same blunder as the last FCC did with the original CAF II program. They should set a forward-looking speed goal that reflects the likely speed requirements at the time the grant networks will be constructed. Any network engineer who tracks customer usage will tell you that the minimum speed requirement for eight years from now should be at least 100 Mbps.
  • The 25/3 Mbps just feels ‘puny’. I got the same letdown when I read that a new NASA goal is to put a man on the moon again. Considering the huge leaps we’ve made in technology since 1969, striving for a moon-landing again feels like a small national goal and a waste of our national resources – and so does setting a broadband speed goal of 25/3 Mbps.

One of the goals that Congress gave the FCC is to strive to bring rural broadband into parity with urban broadband. In setting a goal of 25/3 the FCC is ignoring the broadband trend in cities. The big cable companies have increased minimum download speeds for new customers to beteen 100 and 200 Mbps and have unilaterally increased speeds for existing customers. 25/3 Mbps is a DSL speed, and we see the biggest telcos finally starting to walk away from copper. Verizon has gotten out of the copper business in nearly 200 exchanges in the northeast. AT&T has been losing DSL customers and replacing them with fiber customers. It’s almost unthinkable that the FCC would establish a new forward-looking grant program and not expect broadband speeds any faster than DSL.

In my mind, the FCC betrayed rural communities when they adopted the 10/1 Mbps speed goal for CAF II. That told rural communities that they had to settle for second-rate broadband that was far slower than the rest of the country. From what I hear, most rural communities don’t even consider the CAF II upgrades as real broadband. Rural communities want fiber. They view anything slower than fiber as nothing more than a stepping-stone towards eventually getting fiber.

The FCC needs to listen to what rural America wants. If this giant new grant program will make rural communities wait for years to get 25/3 Mbps then rural America will largely ignore it. Communities will continue to plan for something better. Households might begrudgingly buy 25/3 broadband, but the people in rural America know that is not the same as broadband elsewhere and they will continue to clamor for the same broadband that they see in cities.

I hope the FCC understands this. Even if they allow technologies in these grants that can only deliver 25/3 Mbps, the FCC can still use the grant ranking process to favor faster broadband. If the grants grading process emphasizes speed, then the $20 billion could probably be used to bring fiber to 4 or 5 million rural homes. In my mind that would be the ideal use of these grants, because those homes would be brought to parity with the rest of the country. Those homes could be taken off of the FCC’s worry list and the universe of underserved homes would be significantly reduced. If the grants give money to anything less than fiber, the FCC will have to keep on dumping grant money into the same communities over and over until they finally finance fiber.

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

Setting the Right Goals for Grants

Most past federal broadband grant programs had very specific goals. For example, the USDA Community Connect grants that have been around for many years target grants to the poorest parts of the country – the awards are weighted towards communities with the highest levels of poverty. For any grant program to be effective the goals of the program need to be clearly defined, and then the award process needs to be aligned with those goals.

The FCC needs to define the goals of the upcoming $20.4 billion grant program. It the goals are poorly defined then the resulting grant awards are likely to be all over the board in terms of effectiveness. What are the ideal goals for a grant program of this magnitude?

The first goal to be decided is the scope of the coverage – will the goal be to bring somewhat better broadband to as many households as possible, or will it be to bring a long-term broadband solution to a smaller number of households? If the goal is to serve the most households possible, then the grants are going to favor lower-cost technologies and the grants will likely go to the wireless providers and satellite providers – as we saw happen in the recent CAF II reverse auction.

If the grants are aimed at a more permanent solution, then the grants will favor fiber. Perhaps the grants could also go towards anybody willing to extend a cable hybrid-fiber coaxial network into rural areas – but no other technology can be considered as a permanent solution.

There are huge consequences for choosing the first option of serving as many households as possible. These new grants are mostly going to be awarded in the geographic areas covered by the original CAF II program. That program awarded over $11 billion to the big telcos to beef up broadband to speeds of at least 10/1 Mbps. Now, before that program is even finished the FCC is talking about overbuilding those same areas with another $20 billion grant program. If this grant program is used to upgrade homes to fixed wireless, it doesn’t take a crystal ball to understand that in ten years from now we’ll be talking about overbuilding these areas again with fiber. It would be incredibly wasteful to use multiple rounds of grants to upgrade the same geographic areas several times.

The other big issue for these grants to deal with is defining which parts of the country are eligible for the grants. What should be the criteria to decide which homes can be upgraded?

If the test is going to be related to existing speeds, the FCC is going to have to deal with the existing broadband coverage maps that everybody in the industry knows to be badly flawed. The FCC is talking about tackling a new mapping effort – but it’s highly likely that the new maps will just swap old mapping errors for new mapping errors. The reality on the ground is that it’s virtually impossible to map the real speeds on copper or fixed wireless networks. In real life, two rural neighbors can have drastically different speeds due to something as simple as being on different copper pairs. It’s impossible to accurately map DSL or wireless broadband coverage.

To make matters even worse, the current Re-Connect grants are saddled with a rule that says that no more than 10% of grant-covered homes can have existing broadband of more than 10/1 Mbps. Layering that kind of rule on top of terrible maps creates an environment where an ISP is largely unable to define a believable grant footprint.

The FCC must figure out some way to rectify the mapping problem. One of the easiest ways is what I call the technology test – anybody that wants to overbuild copper with fiber should automatically be eligible without trying to figure out the current speeds on the copper. Perhaps the easiest rule could be that any place where there is telco copper and no cable company network should be grant-eligible for fiber overbuilders.

Assuming the grants won’t all go to fiber, then there has to be an alternate way for an ISP or a community to challenge poor maps. Perhaps the FCC needs to provide a realistic time frame to allow local governments to demonstrate the actual speeds in an area, much like what was done in the recent Mobility II grant process.

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

Designing the Ideal Federal Broadband Grant Program

In April, FCC Chairman Ajit Pai announced a new rural broadband initiative that will provide $20.4 billion of new funding. We don’t know many details yet, but here are a few things that will likely be involved in awarding the funding:

  • The FCC is leaning towards a reverse auction.
  • The program will likely require technologies that can deliver at least 25/3 Mbps broadband speeds.
  • The program will be funded within the existing Universal Service Fund, mostly by repositioning the original CAF II plan.
  • The grants might all be awarded at once, similar to A-CAM and CAF II awards, meaning that there might be only one chance to apply, with the awards to be paid out over a longer time period.

I’m writing a series of blogs that will examine the ideal way to design and administer a grant program of this size. We’ve seen both good and also disastously bad federal broadband programs before, and i’m hoping the FCC will take some time to make this grant program one of the effective ones. I’m sure the details of this new program are not yet set in stone, and folks in rural America need to make their voices heard now if they want some of this money to benefit their communities.

I’m going to look at the following topics, and perhaps more as I write this. At the end of this process I’ll post a whitepaper on my website that consolidates all of these discussions into one document.

A well-designed broadband grant program of this magnitude should consider the following:

What is the End Goal?

It’s important up-front for the FCC to determine how the grant moneys are to be used. The best grant programs have a specific goal, and then the application and award process is designed to best meet the goals. The goal can’t be something as simple as ‘promote rural broadband’, because a goal that simplistic is bound to create a hodgepodge of grant awards.

What Broadband Speeds Should be Supported?

This is an area where the FCC failed miserably in the past. They awarded over $11 billion in the CAF II program that was used to upgrade broadband speeds to speeds of only 10/1 Mbps. When the FCC set the 10/1 Mbps speed that didn’t even meet their own definition of broadband. How should the FCC determine eligible speeds this time to avoid a repeat of the CAF II debacle?

Who Should be Eligible?

FCC programs in the past have usually made the monies available to a wide range of recipients. However, the specific details of the grant programs have often made it hard for whole classes of entities like cities or counties to accept the awards. As an example, there are many entities electing to not participate in the current Re-Connect grant program because they can’t accept any part of the awards that include RUS loans.

Is a Reverse Auction the Right Mechanism?

The FCC and numerous politicians currently favor reverse auctions. Like any mechanism, there are situation where reverse grants are a great tool and others where they will distort the award process. Are reverse auctions a good tool for this grant program?

Other Issues

There are two drastically different ways to hand out these grants. One is to follow the CAF II mechanism and award all of the $20 billion in one huge auction and then pay it out over 6 or 8 years. The other would be to divide the award money into even tranches and have a new grant award for each of those years.

In the recent Re-Connect grants the FCC decided to blend grants and loans. I know the loan component stopped most of my clients from pursuing these grants. Should there be a loan component of the grants?

There are also technical issues to consider. I had clients who were outbid in the recent CAF II reverse auction by wireless companies that gained bidding preference by promising that their fixed wireless networks could achieve across-the-board 100 Mbps broadband. I still don’t know of a wireless technology that can do that over a large footprint. How should the FCC make sure that technologies deliver what’s promised?

What’s the Role of States in this Process?

What should states be doing to maximize the chance for federal grant money to be awarded to their state?

This blog is part of a series:

Setting the Right Goals for Grants

Speed Goals for FCC Grants

Clearing Mid-range Spectrum

The FCC is in the process of trying to free up mid-range spectrum for 5G. They just opened a Notice of Proposed Rulemaking looking at 2.5 GHz spectrum, located in the contiguous block between 2495 and 2690 MHz. Overall this is the largest contiguous block of mid-range spectrum. Over half of the spectrum sits idle today, particularly in rural America. The history of this spectrum demonstrates the complications involved in trying to reposition spectrum for broadband and cellular use.

The frequency was first assigned by the FCC in 1963 when it was made available to school systems to transmit educational TV between multiple schools. The spectrum band was called Instructional Television Fixed Service (ITFS). The band was divided into twenty channels and could transmit a TV signal up to about 35 miles. I grew up in a school system that used the technology and from elementary school onward we had a number of classes taught on the TV. Implementing the technology was expensive and much of the spectrum was never claimed.

In 1972 the FCC recognized the underuse of the spectrum and allowed commercial operators to use the bands of 2150 to 2162 MHz on an unlicensed basis for pay-TV transmissions to rooftop antennas. The spectrum could only carry a few TV channels and in the 1970s was used in many markets to transmit the early version of HBO and Nickelodeon. This spectrum band was known as Multipoint Distribution Service (MDS) and also was good for about 35 miles.

Reacting to pressure from cellular companies, the FCC reallocated eight additional channels of the spectrum for commercial use. Added to the MDS spectrum this became known as Multichannel Multipoint Distribution Service (MMDS). At the time this displaced a few school systems and anybody using the spectrum had to pay to move a school system to another workable channel. This spectrum was granted upon request to operators for specific markets.

In 1991 the FCC changed the rules for MMDS and allowed the channels to be used to transmit commercial TV signals. In 1995 any unused MMDS spectrum was sold under one of the first FCC auctions, which was the first to divide service areas into the geographic areas known as Basic Trading Areas (or BTAs) that are still used today. Before this auction, the spectrum was awarded in 35-mile circles called Geographic Service Areas (GSAs). The existing GSAs were left in place and the spectrum sold at auction had to work around existing GSAs.

The FCC started getting pressure from wireless companies to allow for the two-way transmission of data in the frequency (up to now it had been all one-way delivery to a customer site). In 2005 the FCC changed the rules and renamed the block of spectrum as Broadband Radio Service (BRS). This added significant value to licenses since the spectrum could now be repositioned for cellular usage.

At this point, Clearwire entered the picture and saw the value of the spectrum. They offered to buy or lease the spectrum from school systems at prices far lower than market value and were able to amass the right to use a huge amount of the spectrum nationwide. Clearwire never activated much of the spectrum and was in danger of losing the rights to use it. In 2013 Sprint purchased Clearwire, and Sprint is the only cellular company using the spectrum band today.

Today the spectrum band has all sorts of users. There are still school districts using the spectrum to transmit cable TV. There are still license holders who never stopped using the 35-mile GSA areas. There are still MMDS license holders who found a commercial use for the spectrum. And Sprint holds much of the spectrum not held by these other parties.

The FCC is wrestling in the NPRM with how to undo the history of the spectrum to make it more valuable to the industry. Education advocates are still hoping to play in the space since much of the spectrum sits idle in rural America (as is true with a lot of cellular and other mid-range spectrum). The other cellular carriers would like to see chunks of the spectrum sold at auction. Other existing license holders are fighting to extract the biggest value out of any change of control of the spectrum.

The challenge for repositioning this spectrum is complicated because the deployment of the spectrum differs widely today by market. The FCC is struggling to find an easy set of rules to put the genie back in the bottle and start over again. In terms of value for 5G, this spectrum sits in a sweet spot in terms of coverage characteristics. Using the spectrum for cellular data is probably the best use of the spectrum, but the FCC has to step carefully to do this in such a way as to not end up in court cases for years disputing any order. Reallocating spectrum is probably the most difficult thing the FCC does and it’s not hard to see why when you look at the history of this particular block of spectrum and realize that every block of spectrum has a similar messy past.

5G Claims for Rural America

There are a few hot-button topics that are the current favorite talking points at the FCC. T-Mobile and Sprint are pressing both the 5G and the rural broadband buttons with their merger request. The companies are claiming that if they are allowed to merge that they can cover 96% of America with a ‘deep, broad, and nationwide’ 5G network.

There are multiple technologies being referred to as 5G – wireless broadband loops and 5G cellular – and their claim doesn’t hold water for either application. In making the claim the companies want regulators to think that they are talking about wireless 5G loop like the technology that Verizon recently test-drove in Sacramento. That technology is delivering 300 Mbps broadband to those living close to the transmitters located on poles. The carriers are smart and know this is the kind of claim that will perk up the ears of regulators and politicians. A ubiquitous 300 Mbps rural broadband product would solve the rural digital divide.

T-Mobile and Sprint are not talking about 5G wireless loops. That technology requires two things to have any chance of success – sufficient neighborhood housing density and fiber backhaul. Rural areas with poor broadband generally lack fiber infrastructure built close to neighborhoods, so a 5G provider would have to build the needed fiber. I can’t imagine why anybody that builds fiber close to a neighborhood would then choose a squirrely wireless link that delivers less than a gigabit of speed instead of a direct fiber connection that can deliver 10 Gbps using today’s readily-available technology.

The other missing element in rural America is customer density. I read an article that says that each Verizon 5G wireless loop transmitter in Sacramento can see at least 20 potential customers. There are a number of industry analysts who think that even that is a hard business case to justify, so how can wireless loops ever work in rural American where a given transmitter will likely see only a few homes? I can foresee the 5G loop technology perhaps being used to deliver broadband to small rural subdivisions or small towns where the wireless link might be cheaper than stringing fiber. However, most of rural America is characterized by low density and homes that are far apart.

What T-Mobile and Sprint are really talking about is 5G rural cellular service. Sprint brings a unique asset to the merger – they are the only US cellular carrier using nationwide spectrum in the 850 MHz and the 2.5 GHz bands. T-Mobile is the only carrier currently using 600 MHz spectrum. The combined companies would have by far the biggest inventory of spectrum – giving them a big advantage in urban America.

But is there an advantage this spectrum can bring to rural broadband? The short answer is no. I say that because I don’t see 5G cellular being that important in rural America? There are several reasons why the T-Mobile and Sprint announcement makes little sense.

The biggest issue is that there is not going to be fully-functional 5G cell sites anywhere in the country for years. It’s likely to take most of the coming decade until we see cell sites that comply with all 13 of the major improvement goals listed in the 5G specifications. There will be a natural progression from 4G to 5G as the carriers implement upgrades over time – the same upgrade path we just saw with 4G, where the first fully-compliant 4G cell sites were finally implemented in late 2017.

The bigger question is if most rural cell sites need 5G. The new technology brings several major improvements to cellular. First will be the ability of one cell site to make up to 100,000 simultaneous connections to devices, up from several thousand connections today. This improvement will be mostly accomplished using frequency slicing. This allows a cell site to tailor the size of the broadband connection to each customer’s demand. For example, a connection to an IoT device might be set at a tiny fraction of a full cellular channel, thus freeing up the rest of that channel to serve other customers. Many rural cell sites won’t need this extra capacity. A rural cell site that serves a few hundred people at a time will continue to function well with 4G and won’t need the extra capacity.

5G also can be used to increase the speed of cellular broadband, with the goal in the standard to bring speeds to as fast as 100 Mbps. That is also unlikely to happen to any great degree in rural America. Speeds of 100 Mbps will be accomplished in urban areas by having multiple cell sites connect to a single cellphone. That will require densely packed small cell sites, which is something we are already starting to see in the busy parts of downtowns. It’s incredibly unlikely that the cellular companies are going to introduce small cell sites through rural America just to boost handset broadband speeds. Speeds are not likely to be much faster than 4G when a customer can see only a single tower.

The T-Mobile and Sprint claim is pure bosh. These companies are not going to be investing in fiber to bring 5G wireless loops to rural America. While a combined company will have more spectrum than the other carriers there is no immediate advantage for using 5G for rural cellular coverage . The T-Mobile and Sprint announcements are just pushing the 5G and the rural broadband hot-buttons because the topics resonate well with politicians who don’t understand the technology.

FCC Expands Wireless Attachment Rights

On April 12 the FCC issued a new Notice for Proposed Rulemaking in Docket 19-71 that will use 5G as the justification for another giveaway to the wireless carriers. Last year the FCC ordered that wireless carriers are free to put small cell sites and other wireless devices on utility poles, light poles or buildings that are in the public right-of-way. This new docket would expand some additional rights for buildings along the sides of rights-of-way. Comments will be due within 30 days of publication in the Federal Register with an additional 45 days for replay comments.

This docket requires an understanding of past orders to fully understand what is being proposed. The order would modify existing industry rules that apply to OTARDs (Over-the-Air Reception Devices). The original order on the topic was issued in 2000 and dealt with the right of consumers to connect a receiving antenna on their home to receive a wireless signal. At the time this mostly applied to satellite dishes for cable TV, but at the time there was also a budding wireless industry that was deploying WiFi mesh networks.

In the original order, the FCC said that residents, particularly renters, had the right to install receiving antenna under a twelve-inch dish size. Landlords could have some say in the placement of the dishes, but they could not deny a renter the right to receive the wireless service.

In that original order the FCC considered and rejected the idea that any OTARD installations gave the wireless carrier the right to also install a wireless repeater or other device that would re-originate the wireless signal and send it to another nearby location, such as a neighboring home. At the time such devices were relatively large and added to the bulk and appearance of a wireless receiver.

The new docket proposes to reverse part of that original order and provide rights to wireless carriers that were not included in the first order. Under the proposed rules the wireless carriers would be automatically allowed to place a repeater or other similar device anywhere they have been given permission to mount a receiver. Effectively, when a customer grants a wireless carrier the right to mount a receiver on their home, they will also be conveying ‘ownership rights’ to the carrier for that small portion of their building.

Unlike in 2000 when repeaters were bulky, the repeaters used for millimeter wave radios are tiny and can easily be incorporated in any receiving dish. Very few homeowners or apartment owners will know or care that an active receiving antenna is also being used to bounce a signal to a neighboring customer. However, the controversy will arise when a customer stops using a wireless service and wants to take down the antenna. According to this new docket, that little circle of real estate around the receiver would now belong to the wireless carrier instead of the home or apartment owner and the carrier could insist that it stays in place.

The wireless carriers want this right due to the physics of delivering 5G using millimeter wave spectrum. Both lab tests and reports from the early 5G deployments from Verizon show that local obstructions can easily block a millimeter wave signal coming from a pole-mounted transmitter. However, a home that can’t get a clear shot from the pole unit might instead be able to get a clear signal that is bounced from a neighbor’s home. This kind of mesh network is going to be an integral part of distributing 5G broadband from poles.

This is clearly another land grab by the wireless carriers. If a customer disconnects service, they are likely to want to take down an unused antenna. This docket would give the wireless carrier the right to claim access to the area that was occupied by the former receiver. It’s not hard to picture the numerous disagreements and fights this will result from this order.

However, it’s also easy to sympathize with the wireless carriers. If a customer that is near to a pole drops service, the ISP might lose several other customers that relied on a signal from the disconnecting home. I can easily envision the controversies that will happen in neighborhoods if customers lose service due to an action taken by one of their neighbors. It’s not even hard to envision a homeowner taking down an antenna just to spite a neighbor.

This is ultimately an issue of authority. Many cities are already suing the FCC over the last wireless ruling saying that the placement of electronics in the right-of-way is a matter of local jurisdiction, not federal. The FCC’s authority seems even sketchier when extended to any home or structure within a thousand feet of a wireless transmitter. Can a wireless carrier be allowed to carve out a small piece of real estate on a building in perpetuity simply because that building once subscribed to a wireless service? Should the homeowner expect compensation for use of that real estate (like has been ordered by pole owners). Would a homeowner be expected to power a repeater when they no longer recieve service?

The FCC is clearly in favor of giving the authority to wireless carriers to deploy as they see fit. I am fairly certain that these issues are going to be resolved ultimately in the courts.

Broadband Have-nots

In one of my recent blogs I talked about a few cities that had broadband penetration north of 90%, meaning that most households in those cities have broadband. I’ve run across three such cities this year. But there are also cities with a very different story. I saw a recent article about Syracuse, New York that claimed that 66% of the homes in the city have a landline broadband connection and only a little more than half of households have a connection that meets the FCC definition of broadband at 25/3 Mbps.

It’s easy to look at the national average broadband penetration rate of 84% and think that most people in cities across the country have broadband. This is particularly true when you adjust that national average to remove the millions of rural households that still have no landline broadband option, which adjusts the national average to over 90%.

We’ve always known that there is a correlation between income and broadband subscription rates – in fact, the basic definition of the urban digital divide is households that can’t afford broadband. We also know that in every larger city that the broadband penetration rates are not uniform but are lower in poorer neighborhoods.

I am concerned that the urban digital divide is going to get worse. Most industry analysts believe that we’ll see significant increases in broadband prices over the next decade. The big cable companies have little choice but to raise broadband rates if they want to maintain the steady bottom line revenue growth expected by Wall Street. This means that’s it’s likely over time that broadband penetration rates in cities are going to drop even lower.

Cities badly want to find a solution to the digital divide that is so heavily impacting low-income neighborhoods. They know there are huge negative impacts on households without broadband. There have been several recent studies showing that school students without home broadband lag behind students with broadband, and they never close the gap. Having whole neighborhoods that can’t afford broadband will be condemning whole generations of underperforming students, helping to perpetuate the cycle of poverty.

Syracuse is considering a solution that would bring some broadband to the neighborhoods that most need it. The city has a plan to buy 18,000 streetlights that would include outdoor WiFi hotspots. These WiFi units can produce decent broadband outdoors, but the strength of WiFi signals decrease significantly when passing through the exterior walls of buildings. While any broadband is better than nothing, outdoor WiFi units are not going to provide the same quality of broadband as a landline connection. Such efforts will likely be welcomed by residents without broadband, but this is still second-rate broadband compared to that given to households that can afford to buy broadband from the incumbent ISPs.

The dilemma for cities is that there is no easy solution to the digital divide. For Syracuse, the problem is mostly affordability and not access. Most of the homes without broadband probably have the option to buy from the incumbent providers. I say most because there are still poor neighborhoods present in almost every city that don’t have the same broadband infrastructure as the rest of the city. I’ve seen estimates that there are nearly as many residences in cities with no broadband option as are rural homes without broadband. It’s hard to know for sure because the areas without broadband are comprised of an apartment building here and a dead-end street there rather than big neighborhoods without broadband.

Cities often consider building their own broadband network as a solution to the digital divide. I undertake numerous broadband feasibility studies every year, and almost every city I’ve ever worked for has universal access to fiber as one of their primary goals. However, building fiber or any broadband infrastructure is expensive, and it’s usually hard to justify the cost of providing free or low-cost broadband to low-income homes. It’s challenging in a competitive environment to make enough profit from normal broadband customers to subsidize low-income homes.

We’ve been talking about the digital divide since the late 1990s when we saw the introduction of DSL and cable modems. In my mind, the problem is far worse today than it was then since broadband has grown to become a necessity of the same magnitude as having electric or water in a home. Unfortunately, I think the urban digital divide will be growing as broadband prices climb year after year.

Amazon Joins the Broadband Space Race

I wrote a blog just a few weeks ago talking about how OneWeb had fully leaped into the race to place broadband satellites by launching a few test satellites and also by raising a few more billion dollars to fund the venture.

It’s been rumored for several years that Amazon was also interested in the idea, but their plans have been under wraps. It just came to light that Amazon has taken the first public steps and had the FCC file paperwork with the International Telecommunications Union to make notice of Amazon’s intent to launch satellites.

Amazon filed with the FCC under the name of Kuiper Systems LLC. Space fans will recognize the corporate name as a reference to the Kuiper belt, which is the area of the solar system past Neptune that is believed to contain numerous comets, asteroids and other small objects made largely of ice.

Amazon has big plans and the ITU filing said the company wants to launch a constellation of 3,236 satellites in low earth orbit. That’s 784 satellites in orbit at 367 miles above the earth, 1,296 in orbit at 379 miles, and 1,156 in orbit at 391 miles. Added to the other companies that are talking about getting into the business that’s now more than 10,000 planned satellites.

We know that Jeff Bezos is serious about space. He owns a rocket business, Blue Origins, that is developing an orbital-class rocket called the New Glenn. That company already has some future contracts to make private launches for OneWeb and Telesat. Amazon also recently launched a cloud computing service knows as AWS Ground Station that is intended to provide communications data links between earth and object in outer space. We also found out recently that Bezos kept 100% control of Blue Origins as part of his divorce settlement.

None of the low-orbit satellite ventures have talked about broadband speeds, prices or customer penetration goals. The only one making any announcement was SpaceX who said that his Starlink satellites would be capable of making a gigabit connection to earth. But that’s a far cry from a realistic estimate of a broadband product and is the satellite version of the Sprint cellphone test that showed that millimeter wave spectrum could deliver gigabit speeds to a cellphone. It can be done but is incredibly hard and would involve synching big data pipes from multiple satellites to a single customer.

We got another clue recently when OneWeb asked the FCC for permission to eventually create 1 million links to earth-based receivers, meaning customers. That puts some perspective on the satellites and shows that they are not trying to bring broadband to every rural customer. But still, one million satellite connections would represent about 10% of the rural homes in the US that don’t have broadband today. If that’s their US goal it automatically tells me that prices will likely be high.

NASA and others in charge of space policy have also started talking recently about the potential dangers from so many objects in orbit. We don’t know the size of the Amazon satellites yet. But Elon Musk said his satellites would range in size from a refrigerator down to some that are not larger than a football. NASA is worried about collisions between manned space flights with satellites and space debris.

Amazon is still early in the process. They haven’t yet filed a formal proposal to the FCC discussing their technology and plans. They are several years behind OneWeb and Starlink in terms of getting a test satellite into orbit. But an Amazon space venture has the built-in advantage of being able to advertise a satellite broadband product on the Amazon website where the vast majority of Americans routinely shop. I can envision Amazon measuring the broadband speed of a customer connected to the Amazon website and popping up an offer to buy faster broadband.

It’s absolutely impossible to predict the impact these various satellite companies will have on US broadband. A lot of their impact is going to depend upon the speeds and prices they offer. A lot of rural America is starting to see some decent speeds offered by WISPs with newer radios. Every year some pockets of of rural America are getting fiber and gigabit speeds. Where might the satellites fall into that mix? We can’t forget that the need for broadband is still doubling every three years, and one has to consider the speeds that homes will want a decade from now – not the speeds households want today. We’re at least a few years from seeing any low-orbit broadband connections and many years away from seeing the swarm of over 10,000 satellites that are planned for broadband delivery.

$20.4 Billion in Broadband Funding?

Chairman Ajit Pai and the White House announced a new rural broadband initiative that will provide $20.4 billion over ten years to expand and upgrade rural broadband. There were only a few details in the announcement, and even some of them sound tentative. A few things are probably solid:

  • The money would be used to provide broadband in the price-cap service areas – these are the areas served by the giant telcos.
  • The FCC is leaning towards a reverse auction.
  • Will support projects that deliver at least 25/3 Mbps broadband.
  • Will be funded from the Universal Service Fund and will ‘repurpose’ existing funds.
  • The announcement alludes to awarding the money later this year, which would be incredibly aggressive.
  • This was announced in conjunction with the auction of millimeter wave spectrum – however this is not funded from the proceeds of that auction.

What might it mean to repurpose this from the Universal Service Fund?  The fund dispersed $8.7 billion in 2018. We know of two major upcoming changes to the USF disbursements. First. the new Mobility II fund to bring rural 4G service adds $453 million per year to the USF. Second. the original CAF II program that pays $1.544 billion annually  to the big telcos ends after 2020.

The FCC recently increased the cap on the USF to $11.4 billion. Everybody was scratching their head over that cap since it is so much higher than current spending. But now the number makes sense. If the FCC was to award $2.04 billion in 2020 for the new broadband spending, the fund would expand almost to that new cap. Then, in 2021 the fund would come back down to $9.6 billion after the end of CAF II. We also know that the Lifeline support subsidies have been shrinking every year and the FCC has been eyeing further cuts in that program. We might well end up with a fund by 2021 that isn’t much larger than the fund in 2018.

There are some obviously big things we don’t know. The biggest is the timing of the awards. Will this be a one-time auction for the whole $20.4 billion or a new $2 billion auction for each of the next ten years? This is a vital question. If there is an auction every year then every rural county will have a decent shot at the funding. That will give counties time to develop business plans and create any needed public private partnership to pursue the funding.

However, if the funding is awarded later this year in one big auction and then disbursed over ten years, then I predict that most of the money will go again to the big telcos – this would be a repeat of the original CAF II. That is my big fear. There was great excitement in rural America for the original CAF II program, but in the end that money was all given to the big telcos. The big telcos could easily promise to improve rural DSL to 25/3 Mbps given this kind of funding. They’d then have ten years to fulfill that promise. I find it worrisome that the announcement said that the funding could benefit around 4 million households – that’s exactly the number of households covered by the big telcos in CAF II.

What will be the study areas? The CAF II program awarded funding by county. Big study areas benefit the big telcos since anybody else chasing the money would have to agree to serve the same large areas. Big study areas means big projects which will make it hard for many ISPs to raise any needed matching finds for the grants – large study areas would make it impossible for many ISPs to bid.

My last concern is how the funds will be administered. For example, the current ReConnect funding is being administered by the RUS which is part of the Department of Agriculture. That funding is being awarded as part grants and part loans. As I’ve written many times, there are numerous entities that are unable to accept RUS loans. There are features of those loans that are difficult for government entities to accept. It’s also hard for a commercial ISP to accept RUS funding if they already carry debt from some other source. The $20.4 billion is going to be a lot less impressive if a big chunk of it is loans. It’s going to be disastrous if loans follow the RUS lending rules.

We obviously need to hear a lot more. This could be a huge shot in the arm to rural broadband if done properly – exactly the kind of boost that we need. It could instead be another huge giveaway to the big telcos – or it could be something in between. I know I tend to be cynical, but I can’t ignore that some of the largest federal broadband funding programs have been a bust. Let’s all hope my worries are unfounded.

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.