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.

FCC Further Defines Speed Tests

The FCC recently voted to tweak the rules for speed testing for ISPs who accept federal funding from the Universal Service Fund or from other federal funding sources. This would include all rate-of-return carriers including those taking ACAM funding, carriers that won the CAF II reverse auctions, recipients of the Rural Broadband Experiment (RBE) grants, Alaska Plan carriers, and likely carriers that took funding in the New York version of the CAF II award process. These new testing rules will also apply to carriers accepting the upcoming RDOF grants.

The FCC had originally released testing rules in July 2018 in Docket DA 18-710. Those rules applied to the carriers listed above as well as to all price cap carriers and recipients of the CAF II program. The big telcos will start testing in January of 2020 and the FCC should soon release a testing schedule for everybody else – the dates for testing were delayed until this revised order was issued.

The FCC made the following changes to the testing program:

  • Modifies the schedule for commencing testing by basing it on the deployment obligations specific to each Connect America Fund support mechanism;
  • Implements a new pre-testing period that will allow carriers to become familiar with testing procedures without facing a loss of support for failure to meet the requirements;
  • Allows greater flexibility to carriers for identifying which customer locations should be tested and selecting the endpoints for testing broadband connections. This last requirement sounds to me like the FCC is letting the CAF II recipients off the hook by allowing them to only test customers they know meet the 10/1 Mbps speeds.

The final order should be released soon and will hopefully answer carrier questions. One of the areas of concern is that the FCC seems to want to test the maximum speeds that a carrier is obligated to deliver. That might mean having to give customers the fastest connection during the time of the tests even if they have subscribed to slower speeds.

Here are some of the key provisions of the testing program that were not changed by the recent order:

  • ISPs can choose between three methods for testing. First, they may elect what the FCC calls the MBA program, which uses an external vendor, approved by the FCC, to perform the testing. This firm has been testing speeds for the network built by large telcos for many years. ISPs can also use existing network tools if they are built into the customer CPE that allows test pinging and other testing methodologies. Finally, an ISP can install ‘white boxes’ that provide the ability to perform the tests.
  • Testing, at least for now is perpetual, and carriers need to recognize that this is a new cost they have to bear due to taking federal funding.
  • The number of tests to be conducted will vary by the number of customers for which a recipient is getting support; With 50 or fewer households the test is for 5 customers; for 51-500 households the test is 10% of households. For 500 or more households the test is 50 households. ISPs declaring a high latency must test more locations with the maximum being 370.
  • Tests for a given customer are for one solid week, including weekends in each quarter. Tests must be conducted in the evenings between 6:00 PM and 12:00 PM. Latency tests must be done every minute during the six-hour testing window. Speed tests – run separately for upload speeds and download speeds – must be done once per hour during the 6-hour testing window.
  • ISPs are expected to meet latency standards 95% of the time. Speed tests must achieve 80% of the expected upland and download speed 80% of the time. An example of this requirement is that a carrier guaranteeing a gigabit of speed must achieve 800 Mbps 80% of the time. ISPs that meet the speeds and latencies for 100% of customers are excused from quarterly testing and only have to test once per year.
  • There are financial penalties for ISPs that don’t meet these tests.
  • ISPs that have between 85% and 100% of households that meet the test standards lose 5% of their FCC support.
  • ISPs that have between 70% and 85% of households that meet the test standards lose 10% of their FCC support.
  • ISPs that have between 55% and 75% of households that meet the test standards lose 15% of their FCC support.
  • ISPs with less than 55% of compliant households lose 25% of their support.
  • The penalties only apply to funds that haven’t yet been collected by an ISP.

FCC Says Big ISPs Delivering the Speeds they Market

The FCC recently released the reports from its speed test program for both 2017 and 2018. The reports summarize the results of the FCC’s Measuring Broadband America (MBA) that samples the actual performance of broadband customers by installing measuring devices at their homes. This program began in 2011 and these are the 7thand 8threport from the program. These used to be issued as separate reports, but these reports along with a number of other FCC reports are now being released together in one large annual filing. The link to the reports can be found here. The 2017 report begins at page 349 of the document and the 2018 report on page 463.

These tests are given to volunteer households of large ISPs only – those that cover 80% of all broadband customers in the country. This list of ISPs contains the big cable companies, big telcos, satellite broadband providers.

The primary conclusion of both reports is that “For most of the major broadband providers that were tested, measured speeds were 100% of advertised speeds or better between the peak hours (1 p.m. to 11 p.m. local time).

Frankly, that conclusion is impossible for me to believe and indicates that there is something in this testing program that is different than the reported experience by many customers in the real world. Consider all of the following:

  • It’s possible that the FCC is somehow doctoring the speed data, or at least not reporting all of the data they gather. Ars technica reports that SamKnows, the firm doing the measuring for these tests said they have been collecting data from between 6,000 and 10,000 homes during the time of these tests. But the reports are basing data on about 4,500 locations. This is an FCC that seems adverse to reporting things it doesn’t like, so there is certainly a chance that there is selective editing of the data used to create the report.
  • It’s clear that the reported users in these test results are not from rural America. My experience over the last decade is that virtually nobody in rural America is receiving the advertised broadband speeds. It’s virtually impossible for a rural DSL customer to getthe advertised speeds since they live far away from the core DSLAM modems that provide broadband. It’s worth noting that both reports admit that satellite broadband underperforms.

My experience comes from working extensively in rural America across the country. When we do broadband studies we elicit households to take speed tests so we can see actual performance. Admittedly speed tests have issues and are not as accurate as the measuring being done by SamKnows. They are likely connecting directly to the incoming broadband signal at the modem while most households today use WiFi, which affects self-administered speed test results. But in the many rural speed tests we’ve seen households perform, it’s rare to see a rural customer getting the speed they are paying for, and often they get just a tiny fraction of that speed, with results sometimes barely better than dial-up.

In general I test speed tests because we also do broadband studies for larger towns, and sometimes the speed tests show good performance by the ISP. For example, we studied a City recently with about 40,000 homes and for the most part Comcast was delivering speeds that often exceeded the advertised speeds. This makes me believe that the major speed test sites, while not perfect, are not terrible and can be believed to represent a whole community.

However, I’ve also studied larger communities where a major ISP underperforms across the board. I’ve rarely seen DSL meet advertised speeds for the majority of customers in a community. And I’ve studied communities where the cable company was slower than advertised for everybody.

The FCC results are also hard to believe because we know from the press that there are whole communities where a major ISP underperforms. As an example is a long-running battle in upstate New York where Charter has been delivering speeds at a fraction of the advertised speeds – the performance was so poor that the State is trying to kick Charter out of the state.

I have similar anecdotal evidence at my own house. My ISP is also Charter. They currently tell me that my speed ought to be 200 Mbps but I’m getting about 135 Mbps. Before the recent upgrade I was also getting less than what they said. I’m not unhappy with the 135 Mbps, but if my house was part of the FCC test it would show a connection getting only 2/3 of the advertised speeds.

The ars technica article I cited above is worth reading because they dig deeper into the data. I must admit that I got stopped at the first page of each report where they said that the large ISPs are mostly delivering the speeds they are advertising, because I know for much of the country that is not true. That makes me suspect that there is doctoring of data somehow. Perhaps the results mostly come from larger communities where the speeds are okay. Maybe the FCC is doctoring the data and excluding poor test results. Perhaps the ISPs know which homes are being measured and give them special attention. I don’t know the details of how the report was generated, but I have too much experience in the real world to accept the conclusions that big ISPs deliver the speeds they advertised.

FCC Speed Tests for ISPs

ISPs awarded CAF II funding in the recent auction need to be aware that they will be subject to compliance testing for both latency and speeds on their new broadband networks. There are financial penalties for those failing to successfully meet these tests. The FCC revised the testing standards in July in Docket DA 18-710. These new testing standards become effective with testing starting in the third quarter of 2019. There new standards will replace the standards already in place for ISPs that receive funding from earlier rounds of the CAF program as well as ISPs getting A-CAM or other rate-of-return USF funding.

ISPs can choose between three methods for testing. First, they may elect what the FCC calls the MBA program, which uses an external vendor, approved by the FCC, to perform the testing. This firm has been testing speeds for the network built by large telcos for many years. ISPs can also use existing network tools if they are built into the customer CPE that allow test pinging and other testing methodologies. Finally, an ISP can install ‘white boxes’ that provide the ability to perform the tests.

The households to be tested are chosen at random by the ISP every two years. The FCC doesn’t describe a specific method for ensuring that the selections are truly random, but the ISP must describe to the FCC how this is done. It wouldn’t be hard for an ISP to fudge the results of the testing if they make sure that customers from slow parts of their network are not in the testing sample.

The number of tests to be conducted varies by the number of customers for which a recipient is getting CAF support; if the number is CAF households is 50 or fewer they must test 5 customers; if there are 51-500 CAF households they must test 10% of households. For 500 or greater CAF households they must test 50. ISPs that declare a high latency must test more locations with the maximum being 370.

ISPs must conduct the tests for a solid week, including weekends in every quarter to eliminate seasonality. Tests must be conducted in the evenings between 6:00 PM and 12:00 PM. Latency tests must be done every minute during the six-hour testing window. Speed tests – run separately for upload speeds and download speeds – must be done once per hour during the 6-hour testing window.

The FCC has set expected standards for the speed tests. These standards are based upon the required speeds of a specific program – such as the first CAF II program that required speeds of at least 10/1 Mbps. In the latest CAF program the testing will be based upon the speeds that the ISP declared they could meet when entering the action – speeds that can be as fast as 1 Gbps.

ISPs are expected to meet latency standards 95% of the time. Speed tests must achieve 80% of the expected upland and download speed 80% of the time. This might surprise people living in the original CAF II areas, because the big telcos only need to achieve download speeds of 8 Mbps for 80% of customers to meet the CAF standard. The 10/1 Mbps standard was low enough, but this lets the ISPs off the hook for underperforming even for that incredibly slow speed. This requirement means that an ISP guaranteeing gigabit download speeds needs to achieve 800 Mbps 80% of the time. ISPs that meet the speeds and latencies for 100% of customers are excused from quarterly testing and only have to test once per year.

There are financial penalties for ISPs that don’t meet these tests.

  • ISPs that have between 85% and 100% of households that meet the test standards lose 5% of their FCC support.
  • ISPs that have between 70% and 85% of households that meet the test standards lose 10% of their FCC support.
  • ISPs that have between 55% and 75% of households that meet the test standards lose 15% of their FCC support.
  • ISPs with less than 55% of compliant households lose 25% of their support.

For CAF II auction winners these reductions in funding would only be applied to the remaining time periods after they fail the tests. This particular auction covers a 10-year period of time and the testing would start once the new networks are operational, which is required to be completed between years 3 and 6 after funding.

This will have the biggest impact on ISPs that overstated their network capability. For instance, there were numerous ISPs that claimed the ability in the CAF auction to deliver 100 Mbps and they are going to lose 25% of the funding if they deliver speeds slower than 80 Mbps.

The Fastest ISPs

PC Magazine has been rating ISPs in terms of speed for a number of years. They develop their rankings based upon speed tests taken at their own speed test site. They had about 124,000 speed tests taken that led to this year’s rankings. The scoring for each ISP is a composite number based 80% on the download speed and 20% of upload speeds. To be included in the rankings an ISP needed to have 100 customers or more take the speed test.

You always have to take these kinds of rankings with a grain of salt for several reasons. For example speeds don’t only measure the ISP but also the customer. The time of day can affect the speed test, but probably the type of connection affects it the greatest. We know these days that a lot of people are using out-of-date or poorly located WiFi routers that affect the speeds at their computer.

Measured speeds vary between the different speed tests. In writing this blog I took four different speed tests just to see how they compare. I took the one at the PC Magazine site and it showed my speeds at 27.5 Mbps down / 5.8 Mbps up. I then used Ookla which showed 47.9 Mbps down / 5.8 Mbps up. The Speakeasy speed test showed 17.6 Mbps down and 5.8 Mbps up. Finally, I took the test from Charter Spectrum, my ISP, which showed 31.8 Mbps down / 5.9 Mbps up. That’s a pretty startling set of different speeds measured just minutes apart – and which demonstrates why speed test results are not a great measure of actual speeds. I look at these results and I have no idea what speed I actually am receiving. However, with that said, one would hope that any given speed test would probably be somewhat consistent in measuring the difference between ISPs.

The results of the speed test ‘contest’ are done for different categories of ISPs. For years the winner of the annual speed test for the large incumbents has been Verizon FiOS. However, in this year’s test they fell to third in their group. Leading that category now is Hotwire Communications which largely provides broadband to multi-tenant buildings, with a score of 91.3. Second was Suddenlink at 49.1 with Verizon, Comcast and Cox and closely behind. The lowest in the top 10 was Wow! at a score of 26.7.

Another interesting category is the competitive overbuilders and ISPs. This group is led by Google Fiber with a score of 324.5. EPB Communications, the municipal network in Chattanooga, is second at 136.1. Also in the top 10 are companies like Grande Communications, Sonic.net, RCN, and Comporium.

PC Magazine also ranks ISPs by region and it’s interesting to see how the speeds for a company like Comcast varies in different parts of the country.

Results are also ranked by state. I find some of the numbers on this list startling. For instance, Texas tops the list with a score of 100.3. Next is South Dakota at 80.3 and Vermont at 70.6. If anything this goes to show that the rankings are not any kind of actual random sample – it’s impossible to think that this represents the true composite speeds of all of the people living in those states. The results of this contest also differs from results shown by others like Ookla that looks at millions of actual connection speeds at Internet POPs. Consider Texas. Certainly there are fast broadband speeds in Austin due to Google Fiber where all of the competitors have picked up their game. There are rural parts of the state with fiber networks built by telcos and cooperatives. But a lot of the state looks much like anywhere else and there are a lot of people on DSL or using something less than the top speeds from the cable companies.

But there is one thing this type of study shows very well. It shows that over the years that the cable companies are getting significantly faster. Verizon FiOS used to be far faster than the cable companies and now lies in the middle of a pack with many of them.

This test is clearly not a statistically valid sample. And as I showed above with my results from various speed tests the results are not likely even very accurate. But ISPs care about these kinds of tests because it can give them bragging rights if they are near the top of one of the charts. And, regardless of the flaws, one would think the same shortcomings of this particular test are similar across the board, which means it does provide a decent comparison between ISPs. That is further validated by the fact the results of this exercise are pretty consistent from year to year.

Speed Tests

cheetah-993774Netflix just came out with a new speed test at fast.com which is intended to measure the download speed of Internet connections to determine if they are good enough to stream Netflix. The test only measures the speeds between a user and the Netflix servers. This is different than most other speed tests on the web that also look at upload speeds and latency.

This raises the question of how good speed tests are in general. How accurate are they and what do they really tell a user? There are a number of different speed tests to be found on the web. Over the years I have used the ones at speedtest.net (Ookla), dslreports.com, speed.io, the BandWidthPlace and TestMySpeed.

Probably the first thing to understand about speed tests is that they are only testing the speed of a ping between the user and the test site routers and are not necessarily indicative of the speeds for other web activities like downloading files, making a VoIP phone call or streaming Netflix. Each of those activities involves a different type of streaming and the speed test might not accurately report what a user most wants to know.

Every speed test uses a different algorithm to measure speed. For example, the algorithm for speedtest.net operated by Ookla discards the fastest 10% and the slowest 30% of the results obtained. In doing so they might be masking exactly what drove someone to take the speed test, such as not being able to hold a connection to a VoIP call. Ookla also multithreads, meaning that they open multiple paths between a user and the test site and then average the results together. This could easily mask congestion problems a user might be having with the local network.

Another big problem with any speed test is that it measures the connection between a customer device and the speed test site. This means that the customer parts of the network like the home WiFi network are included in the results. A lot of ISPs I know now claim that poor in-home WiFi accounts for the majority of the speed issue problems reported by customers. So a slow speed test doesn’t always mean that the ISP has a slow connection.

The speed of an Internet connection for any prolonged task changes from second to second. Some of the speed tests like Netflix Ookla show these fluctuations during the test. There are numerous issues for changing speeds largely having to do with network congestion at various points in the network. If one of your neighbors makes a big download demand during your speed test you are likely to see a dip in bandwidth. And this same network contention can happen at any one of numerous different parts of the network.

The bottom line is that speed tests are not much more than an indicator of how your network is performing. If you test your speed regularly then a slow speed test result can be an indicator that something is wrong. But if you only check it once in a while, then any one speed test only tells you about the minute that you took the test and not a whole lot more. It’s not yet time to call your ISP after a single speed test.

There have been rumors around the industry that the big ISPs fudge on the common speed tests. It would be relatively easy for them to do this by giving priority routing to anybody using one of the speed test web sites. I have no idea if they do this, but it would help to explain those times when a speed test tells me I have a fast connection and low latency and yet can’t seem to get things to work.

I think the whole purpose of the Netflix speed test is to put pressure on ISPs that can’t deliver a Netflix-capable connection. I don’t know how much good that will do because such connections are likely going to be on old DSL and other technologies where the ISP already knows the speeds are slow.