Tag Archives: RWA

Concerns with the 5G Fund

The previous blog summarized the basics of the order for the new 5G Fund for Rural America that will provide $9 billion to improve rural cellular coverage. This blog looks at some concerns I identify with the order.

Are the Maps Accurate? The Rural Wireless Association (RWA), which represents smaller cellular companies, recently sent a letter to the FCC that claimed the FCC cellular maps are still highly inaccurate.It’s easy to check claimed cellular usage around you. Once you’ve loaded your address in the FCC map, look at the Mobile Broadband tab at the upper right. You will see the claimed cellular at your address or at any homes around you by clicking on locations.

I live in Western North Carolina, and rural cellular coverage around me is terrible – like is true for much of rural America. When I look at the rural cellular coverage around me on the FCC map it’s hard to find unserved areas. When I dig into the details of the map, I find a huge hodgepodge in rural areas where one carrier claims to serve each rural location – one cluster of homes might be deemed served due to T-Mobile, a nearby cluster deemed to be served by Dish, and another neighborhood claimed by AT&T. This mix of 35/3 Mbps 5G coverage in very rural areas seems unlikely.

An interesting complaint from RWA is that the FCC cellular reporting only looks at cellular coverage at homes. RWA argues that in rural areas, this is measuring the wrong thing – home cellular coverage is important, but cellular coverage should be measured along the roads where people drive every day. The current map shows no coverage data for areas between homes.

No Specific Public Map Challenge. The FCC is not pausing to give citizens and local governments a chance to challenge the cellular map. In fact, the FCC might only issue the final map of areas eligible for the funding 30 days before the auction begins.

This is a big oversight. If the RWA is right about poor maps, then the public should be given a chance to make sure that areas without adequate cellular coverage are included in the 5G Fund. It seems like the FCC thinks the public and local governments have had enough time to challenge the maps since the FCC started the BDC mapping process a few years ago.

The methodology need to challenge the maps is not easy. Speed tests to challenge can only be taken using the FCC speed test app. There must be a lot of tests in a given geographic area for tests to be considered. Speed tests must be taken either from a stationary place outside (like pulling over along the side of a road) or inside a home. Only the outdoor tests matter for the 5G Fund. To be done right, speed tests must be done using phones from all of the major carriers, meaning AT&T, T-Mobile, Verizon, Dish, and any local smaller carrier that offers decent coverage.

It’s basically impossible to challenge a carrier that has overstated coverage areas – you can’t conduct a speed test for a carrier that isn’t there. I note in rural North Carolina that there are a lot of places claimed as covered by Dish – but I’m highly dubious that there are many, if any, Dish subscribers in these areas who could take an FCC speed test to verify this. This is true for any carrier that is not really present – nobody is going to have a phone subscribed to a non-working service.

It’s unlikely that many county governments have undertaken a formal effort to organize the needed speed tests. And even if they did, that challenge has to have happened in the last year to be relevant. I work around the country, and in most of the rural counties I’ve worked in recent years, I’ve heard that cellular coverage is even worse than broadband coverage – and that’s saying something.

I don’t want to sound too critical of this plan because poor rural cellular coverage is a huge issue. This has been needed for a long time. But after having taken four years to get to this announcement, wouldn’t it make sense to take six more months to allow local governments to prove that cellular coverage is poor or that the FCC maps are inaccurate? The FCC does not want to repeat the dreadful problem it had with RDOF based on faulty maps. If the FCC rushes this through without the chance for a map challenge, it will feel like the agency is rushing to grab headlines. Doing this right is vital because communities that get missed by this upgrade are likely going to be stuck with poor cellular coverage for a decade or more.

More FCC Mapping Woes

The FCC has another new billion dollar grant program, this one aimed to improve rural cellular coverage. Labeled as the Mobility Fund II the program will conduct a reverse auction sometime next year to give $4.53 billion to cellular carriers to extend wireless coverage to the most remote parts of the country. For taking the funding a cellular carrier must bring 4G LTE coverage to the funded areas and achieve cellular download speeds of at least 10 Mbps. Funding will be distributed over 10 years with build out requirements sooner than that.

Just like with the CAF II program, the areas eligible for funding are based upon the FCC’s broadband maps using data collected by the existing cellular carriers. As you might expect, the maps show that the parts of the country with the worst coverage – those eligible for funding – are mostly in the mountains and deserts of the west and in Appalachia.

The release of the Mobility Fund II maps instantly set off an uproar as citizens everywhere complained about lack of cellular coverage and politicians from all over the country asked the FCC why there wasn’t more funding coming to their states. The FCC received letters from senators in Mississippi, Missouri, Maine and a number of other states complaining that their states have areas with poor or non-existent cellular coverage that were not covered be the new fund.

If you’ve traveled anywhere in rural America you know that there are big cellular dead spots everywhere. I’ve been to dozens of rural counties all across America in the last few years and every one of them has parts of their counties without good cellular coverage. Everybody living in rural America can point to areas where cellphones don’t work.

The issue boils down to the FCC mapping used to define cellular and broadband coverage. The maps for this program were compiled from a one-time data request to the cellular carriers asking for existing 4G coverage. It’s obvious by the protests that the carriers claim cellular coverage where it doesn’t exist.

In August, the Rural Wireless Association (RWA) filed a complaint with the FCC claiming that Verizon lied about its cellular coverage by claiming coverage in many areas that don’t have it. This is the association of smaller wireless companies (they still exist!). They say that the Verizon’s exaggerated coverage claims will block the funding to many areas that should be eligible.

The Mobility Fund II program allows carriers to challenge the FCC’s maps by conducting tests to identify areas that don’t have good cellular coverage. The smaller carriers in the RWA have been filing these challenges and the FCC just added 90 additional days for the challenge process. Those challenges will surely add new eligible coverage areas for this program.

But the challenge program isn’t going to uncover many of these areas because there are large parts of the country that are not close to an RWA carrier, and which won’t be challenged. People with no cellular coverage that are not part of the this grant program might never get good cellular coverage – something that’s scary as the big telcos plan to tear down copper in rural America.

The extent of the challenges against the Verizon data are good evidence that Verizon overstated 4G LTE coverage. The RWA members I know think Verizon did this purposefully to either block others from expanding cellular networks into areas already served by Verizon or to perhaps direct more of this new fund to areas where Verizon might more easily claim some of the $4.5 billion.

To give Verizon a tiny amount of credit, knowing cellular coverage areas is hard. If you’ve ever seen a coverage map from a single cell tower you’ll instantly notice that it looks like a many-armed starfish. There are parts of the coverage area where good signal extends outward for many miles, but there are other areas where the signal is blocked by a hill or other impediments. You can’t draw circles on a map around a cell tower to show coverage because it only works that way on the Bonneville Salt Flats. There can be dead spots even near to the cell tower.

The FCC fund is laudable in that it’s trying to bring cellular coverage to those areas that clearly don’t have it. But there are countless other holes in cellular coverage that cannot be solved with this kind of fund, and people living in the many smaller cellular holes won’t get any relief from this kind of funding mechanism. Oddly, this fund will bring cellular coverage to areas where almost nobody lives while not addressing cellular holes in more populated areas.