Time to Stop Talking about Unserved and Underserved

I work with communities all of the time that want to know if they are unserved or underserved by broadband. I’ve started to tell them to toss away those two terms, which are not a good way to think about broadband today.

The first time I remember the use of these two terms was as part of the 2009 grant program created by the American Recovery & Reinvestment Act of 2009. The language that created those grants included language from Congress that defined the two terms. In that grant program, unserved meant any home or business that has a broadband speed of less than 10/1 Mbps. Underserved was defined as homes having speeds above 10/1 Mbps but slower than 25/3 Mbps.

As far as I can tell, these terms have never been defined outside of broadband grant programs. However, the terms began to be widely used when talking about broadband availability. A decade ago, communities all wanted to know if they were unserved or underserved.

The terms began to show up in other grant programs after 2009. For example, the FCC’s CAF II grant program in 2015 gave money to the largest telephone companies in the country and funded ‘unserved’ locations that had speeds less than 10/1 Mbps.

The same definition was used in the ReConnect grants created by Congress in 2018 and 2019. Those grants made money available to bring better broadband to areas that had to be at least 90% unserved, using the 10/1 Mbps definition.

The biggest FCC grant program of 2020 has scrapped the old definition of these terms. This $20.4 billion Rural Digital Opportunity Fund (RDOF) grant program is being made eligible to Census blocks that are “entirely unserved by voice and with broadband speeds of at least 25/3 Mbps”. That seemingly has redefined unserved to now mean 25/3 Mbps or slower broadband – at least for purposes of this federal grant program.

There are also states that have defined the two terms differently. For example, following is the official definition of broadband in Minnesota that is used when awarding broadband grants in the state:

An unserved area is an area of Minnesota in which households or businesses lack access to wire-line broadband service at speeds that meet the FCC threshold of 25 megabits per second download and 3 megabits per second upload. An underserved area is an area of Minnesota in which households or businesses do receive service at or above the FCC threshold but lack access to wire-line broadband service at speeds 100 megabits per second download and 20 megabits per second upload.

It must also be noted that there are states that define slower speeds as unserved. I’m aware of a few state broadband programs that still use 4/1 Mbps or 6/1 Mbps as the definition of unserved.

The main reason to scrap these terms is that they convey the idea that 25/3 Mbps broadband ought to be an acceptable target speeds for building new broadband. Urban America has moved far beyond the kinds of broadband speeds that are being discussed as acceptable for rural broadband. Cable companies now have minimum speeds that vary between 100 Mbps and 200 Mbps. Almost 18% of homes in the US now buy broadband provided over fiber. Cisco says the average achieved broadband speed in 2020 is in the range of 93 Mbps.

The time has come when we all need to refuse to talk about subsidizing broadband infrastructure that is obsolete before it’s constructed. We saw during the recent pandemic that homes need faster upload speeds in order to work or do schoolwork from home. We must refuse to accept new broadband construction that provides a 3 Mbps upload connection when something ten times faster than that would barely be acceptable.

Words have power, and the FCC still frames the national broadband discussions in terms of the ability to provide speeds of 25/3 Mbps. The FCC concentrated on 25/3 Mbps as the primary point of focus in its two recent FCC broadband reports to Congress. By sticking with discussions of 25/3 Mbps, the FCC is able to declare that a lot of the US has acceptable broadband. If the FCC used a more realistic definition of broadband, like the one used in Minnesota, then the many millions of homes that can’t buy 100/20 Mbps broadband would be properly defined as being underserved.

In the last few months, the FCC decided to allow slow technologies into the $16.4 billion RDOF grant program. For example, they’ve opened the door to telcos to bid to provide rural DSL that will supposedly offer 25/3 Mbps speeds. This is after the complete failure in the CAF II program where the big telcos largely failed to bring rural DSL speeds up to a paltry 10/1 Mbps.

It’s time to kill the terms unserved and underserved, and it’s time to stop defining connections of 10/1 Mbps or 25/3 Mbps as broadband. When urban residents can buy broadband with speeds of 100 Mbps or faster, a connection of 25/3 should not be referred to as broadband.

Testing the FCC Maps

USTelecom has been advocating the use of geocoding to make broadband maps more accurate. As part of that advocacy, the association tested their idea by looking at the FCC mapping in parts of Virginia and Missouri.

What they found was not surprising, but still shocking. They found in those two states that as many as 38% of households in rural census blocks were classified as being served, when in fact they were unserved. In FCC-speak, served is a home that has broadband available of 25/3 Mbps or faster. Unserved means homes having either no broadband available or that can buy broadband slower than 10/1 Mbps.

This distinction has huge significance for the industry. First, it’s been clear that the FCC has been overcounting the number of homes that have broadband. But far worse, the FCC has been awarding grants to provide faster broadband in unserved areas and all of the places that have been misclassified have not been eligible for grants. We’re about to enter the biggest grant program ever that will award $20.4 billion, but only to places that don’t have 25/3 Mbps speeds – meaning these misclassified homes will be left out again if the maps aren’t fixed soon.

The USTelecom effort is not even complete since several cable companies in the state did not participate in the trial – and this might mean that the percentage of homes that are misclassified is even larger. The misclassified homes are likely going to be those in census blocks that also contain at least some homes with fast broadband. Homes just past where the cable company networks start might be listed as being capable of buying a gigabit, and yet have no broadband option.

The existing FCC maps use data that is reported by ISPs using the Form 477 process. In that process, ISPs report speed availability by census block. There are two huge flaws with this reporting method. First, if even one customer in the census block can get fast broadband, then the whole census block is assumed to have fast broadband. Second, many ISPs have been reporting marketing speeds instead of actual speeds, and so there are whole census blocks counted as served when nobody can get real broadband.

The trial also uncovered other problems. The ISPs have not been accurate in counting homes by census block. Many ISPs have never accurately mapped their customers, and so the test found numerous examples of customers reported in the wrong census blocks. Additionally, the counts of buildings by census block are often far off, due in part to the confusing nature of rural addresses.

The bottom line is that the FCC has been collecting and reporting highly inaccurate data concerning rural broadband. We’ve known this for a long time because there have been numerous efforts to test the maps in smaller geographic areas that have highlighted these same mistakes. We also have evidence from Microsoft that shows that a huge number of homes are not connected to the Internet at speeds of at least 25/3 Mbps. That’s not just a rural issue, and for the Microsoft numbers to be true there must be a massive number of urban homes that are getting speeds slower than what is being reported to the FCC.

As dramatic as this finding is from USTelecom, it doesn’t tell the whole story. Unfortunately, no mapping strategy is going to be able to truthfully report the broadband speeds for DSL and fixed wireless. The speed of these products varies by home. Further, there is no way to know if a given home can utilize these technologies until somebody tries to connect them. Perhaps this isn’t important for DSL since there is almost no rural DSL capable of delivering 25/3 Mbps broadband. But any mapping of the coverage area of fixed wireless is going to be suspect since many homes are impeded from seeing a tranmitting antenna or else receive slower speeds than their neighbors due to impediments. The USTelecom effort is mostly fixing the boundary issues where homes are assumed to have broadband today but don’t. The 38% misreporting would be much higher if we could somehow magically know the real capabilities of DSL and fixed wireless.

The current FCC didn’t create this problem – it goes back several FCCs ago to the start of the 477 reporting system. However, I have to wonder if this FCC will change its mind about the status of rural broadband in the country even with better maps. The current FCC released broadband data for 2016 that included a huge error. A new ISP, Barrier Free had reported serving 25/3 broadband in census blocks covering 62 million people, when in June of that year the company didn’t yet have any customers. The FCC gleefully reported that the number of homes without broadband had dropped by 25%, mostly due to this reporting error. Even after correcting the error the FCC still declared that broadband in rural America was on the right trajectory and didn’t need any extraordinary effort from the FCC. I’m sure they will decide that rural broadband is fine, even if the number of unserved homes jumps significantly due to better mapping.