I know there is so much that is top of mind for NTCA members these days, but that doesn’t mean we should take our foot off the gas when it comes to the importance of better mapping, considering it’s at the heart of so much in the rural broadband space.
Congress charged the FCC in early 2020 with creating a national broadband availability map. It took some time for Congress to follow up with the funding to build the map, and then there were a few further hiccups in getting work underway. But the commission started collecting data in 2022, and we are now five versions into the national broadband map.
As FCC Chairwoman Jessica Rosenworcel noted in November of last year (when the third version of the map was published), millions of availability and location challenges had helped to refine the map. And work has of course continued since then. It is only fair to say that the national broadband map is better than any broadband availability dataset before it, and that it keeps getting better.
But we are in no position to declare “mission accomplished” or even “good enough” when it comes to the national broadband map. NTCA members and many other stakeholders are concerned that we’re missing the forest for the trees by celebrating “drip-drip-drip” substantive improvements every six months without more seriously considering material process improvements. There’s also the concern that new bad data makes its way onto the map from time to time, necessitating a new set of battles to clean that up.
After five turns of the map, we have a decent basis to figure out what has and hasn’t worked in making the map better, and we should use that experience to refine the process for reporting and challenges as soon as possible. In fact, given that the map is being used for all kinds of funding decisions, there’s no time to waste in tackling the changes needed to make the map better still.
The FCC recently released “updates” to its Broadband Data Collection (BDC) efforts that included clarifications regarding how availability reports will be audited and what providers whose reports are challenged will need to do to reassert coverage claims. The item also seeks comment on other procedural elements of the BDC. While many of these steps are welcome, they frankly only scratch the surface in addressing “lessons learned” from development of the map to date – more concrete improvements are desperately needed to make this a map that can be relied upon in making important funding and policy decisions.
NTCA and a group of members recently visited the FCC to highlight flaws in the map and to provide several specific recommendations on how they can be fixed. In the end, many of the persistent problems in the current map can be traced back to two underlying flaws:
- The ability to report coverage based upon advertised speeds with little tie to actual user experience or even detailed technical standards for making such claims; and
- Overly rigid challenge processes that hinder the ability to assess real-world conditions or the actual user experience.
In this recent FCC meeting, we walked through examples of how these problems play out in the national broadband map and funding programs, including:
- Providers creatively reasserting coverage after losing availability challenges;
- Providers’ claiming performance levels that do not match user experience as measured through substantial speed testing;
- Providers reporting widespread coverage despite the fact that they have few, if any, subscribers months or even years after initially “offering” service;
- Providers reporting coverage at certain speeds, but directing customers to call to confirm that service is actually available; and
- Programs who claim the ability to serve any one customer in a given area but clearly would be unable to serve every customer in that area.
We need to kickstart a serious conversation as soon as possible on process improvements to make more informed decisions going forward based upon the national broadband map. As just one example, it is astounding that fixed wireless providers must provide back-up data for coverage claims if they file one way, but they can just provide a brief explanation of their claims if they report in another way. Such disparities make no sense, as they encourage providers to supply less information and frustrate the FCC’s own ability to review claims. Just as astounding is the FCC’s recent backsliding proposal to do away with an engineering certification for availability reports. The FCC has never enforced this to start, and with significant concerns still swirling around map accuracy, it’s hard to fathom the logic of now eliminating such an accountability measure altogether.
Rather than living with the status quo “drip-drip-drip” of iterative improvements to the map – or worse still, stepping backward and making it easier to report coverage without back-up for the claims made – we need to accelerate efforts to make the map the reliable resource that Congress wanted it to be in driving the effective use of data in distributing dollars. NTCA’s recommendations for these improvements can be summarized as follows:
a. Adopt objective BDC reporting standards that reflect a network’s proven technological capabilities, so that an ISP’s website advertising isn’t the final arbiter of what is and isn’t available;
b. Create public “heat maps” to highlight where numerous challenges and crowdsourcing concerns arise in an area;
c. Enable greater use of performance/speed test data to inform challenges and adopt other reforms to the challenge processes;
d. Apply meaningful consequences for chronic overreporting of availability, as compared to the “no harm, no foul – just file better next time” regime that applies today; and
e. Do not reduce or eliminate broadband funding for an entire area based upon coverage claims unless objective technical standards confirm that a provider realistically could serve every customer in that area.
These kinds of common-sense changes should not be a heavy lift, and they are all justified by widespread experience with the national broadband map over five iterations. The FCC has done hard work getting the national broadband map to where it is, and it is not a criticism to highlight the additional steps needed to ensure this map realizes its promise. But we are far past the time where the discussion should be about limited “updates” to how the map is created, and we certainly shouldn’t be talking about backsliding on the kinds of documentation that providers supply to back up their claims. We look forward to working with consumer groups, the states, other industry stakeholders, the FCC and interested members of Congress in ensuring that the national broadband map is better positioned to do the job for which it was created. That extra effort will lead to better outcomes for rural consumers.