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Kirsten Compitello: The Need for a Digital Equity Focus on Broadband Mapping

Incorporating equitable processes and outcomes from the start is crucial to avoid perpetuating continued inequalities.

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The author of this Expert Opinion is Kirsten Compitello, National Broadband Digital Equity Director at Michael Baker International

Broadband for all is in the spotlight right now, and closing the digital divide is recognized as a national priority. The divide goes far beyond access and touches issues of costs, ownership, culture, awareness, skills, and more. As we enter into a period of major statewide planning and deployment efforts, incorporating equitable processes and outcomes from the start is crucial to avoid perpetuating continued inequalities in access, adoption, and literacy.

Digital equity is not just a value statement: it’s a commitment to inclusive and equitable decision making at every stage of broadband deployment, from planning to service delivery.

Ensuring equitable representation at the table

Embedding digital equity analysis into mapping is especially critical at this moment in time as we prepare for historic broadband funding. This funding is an opportunity to rebalance systemic patterns of exclusion and ensure rapidly deployed planning and implementation funds are fairly dispersed.

The Digital Equity Act provides $2.75 billion to establish three grant programs that promote digital equity and inclusion, including the State Digital Equity Planning Grant Program, a $60 million grant program for states and territories to develop digital equity plans. In creating these Statewide Digital Equity Plans, extensive outreach to and collaboration with underserved, unserved and historically marginalized populations will prove critical. These discussions will be much more informative and effective in guiding successful policies, programs and projects if they are rooted in clear understanding of social, economic and environmental patterns alongside broadband access maps.

Documenting the effects of digital exclusion

Access is not an equal term: reducing it simply to speed of service available neglects the social and economic complexities that determine how and where users are affected by a lack of broadband. In short, mapping where the infrastructure exists only tells part of the story. Data analysis needs to layer in demographic and economic information in order to reveal patterns of exclusion and identify root causes.

To better understand community impacts, our team at Michael Baker developed data visualization tools such as a Digital Equity Atlas which takes the next step toward analyzing how broadband gaps disproportionately impact segments of the population. The methodology looks at Title VI and Environmental Justice data to reveal where poor connectivity correlates to social factors including low income, senior populations, English as a Second Language, households without a vehicle and more. As an example, the Southwestern Pennsylvania Commission leveraged the Digital Equity Atlas to prioritize new broadband expansion projects that stand to benefit the greatest number of at-risk or marginalized households. These households should not be last in line to see broadband investment finally bringing greater connectivity and opportunities to their doorsteps.

Fulfilling Broadband Equity, Access, and Deployment program requirements

Federal reporting requirements for upcoming Investment in Infrastructure and Jobs Act funding call for a proven and documented understanding and analysis of digital equity needs, from planning to projects in the ground.

The IIJA’s Broadband Equity, Access and Deployment Program provides $42.45 billion to expand broadband access by funding planning, infrastructure deployment and adoption programs across the country. Statewide Five-Year Action Plans, funded through this program, will require government agencies and their partners to take an integrated digital equity approach.

From planning through the ensuing reporting requirements, establishing digital equity strategies and a clear rubric for measuring success in achieving digital equity goals is a must for agencies. These entities must demonstrate how projects funded through BEAD improve digital equity. A strong data-driven baseline – such as the Digital Equity Atlas – will be a necessary starting point for agencies to track and monitor the effect of each new deployment on surrounding households. These data-driven metrics will also be a win for state and local governments to tell the story of their successes with clear data to back it up.

Setting a goal for sustainable inclusivity

As the consumption of internet content continues to rise and as broadband for all projects bring connectivity to the unserved, baseline expectations for broadband service and speed will only continue to grow. If we aren’t careful, new categories of have-nots will emerge: for example, those who pay high fees for minimum speeds versus those with lower fees for premier plans and Gig speeds. The currently unserved will gain access to service, but many will continue to struggle with basic internet skills, navigating through complex terms of service, or even simply finding time to schedule installation without missing a day of work.

To create a truly equitable society, everyone – no matter age, ability, location or status – needs access to affordable and reliable broadband; internet-connected devices; education on digital technology and best use practices; tech support and online resources that help users participate, collaborate and work independently.

By grounding our planning in equitable practices from the very first step, we can help to ensure that everyone is able to benefit from Internet for All.

Kirsten Compitello, AICP, is the National Broadband Digital Equity Director at Michael Baker International. This piece is exclusive to Broadband Breakfast.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

Broadband Breakfast is a decade-old news organization based in Washington that is building a community of interest around broadband policy and internet technology, with a particular focus on better broadband infrastructure, the politics of privacy and the regulation of social media. Learn more about Broadband Breakfast.

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Broadband Mapping & Data

States Face Roadblocks in Challenge Processes, FCC Tries to Facilitate

The BEAD timeline looms large for many who worry that two months is insufficient time to correct the map.

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Photo of Kirk Burgee, chief of staff for the FCC's Wireline Competition Bureau

WASHINGTON, November 30, 2022 – As state broadband offices scramble to submit challenges to the national broadband map, the Federal Communications Commission is working to provide much-needed resources to help stakeholders through the often-opaque challenge processes.

The FCC’s new broadband map, released in November, provides location-level data of broadband availability nationwide. The map is comprised primarily of two datasets: a list of all broadband serviceable locations – the “fabric” – and provider-submitted availability data. The accuracy of both can be challenged by the public through designated processes.

The FCC has endeavored to create a consumer-friendly challenge-process, said Kirk Burgee, chief of staff for the Wireline Competition Bureau. “We do try to make the process as flexible and accessible as it can be consistent with getting effective challenges and resolving them correctly,” he explained.

Burgee spoke at an FCC webinar held Wednesday to demystify the fixed-availability bulk-challenge process.

The FCC’s availability data will largely determine the distribution of the $42.45 billion Broadband Equity, Access, and Deployment program among the states. The National Telecommunications and Information Administration, the subdivision of the Department of Commerce which administers the BEAD funds, has advised the public to submit challenges by January 13, 2022, to ensure they are considered for BEAD grants – scheduled to be announced in June.

The immediate stakes of accurate mapping

If the FCC’s data is inaccurate when the NTIA calculates the allocations, some states could be shorted on badly needed funding. Some industry players say the map is concerningly inaccurate, and others say the FCC’s challenge processes may prove prohibitively complex.

Georgia has yet to submit fabric challenges, although it intends to, wrote Joshua Hildebrandt, the state’s director of broadband initiatives, in correspondence with Broadband Breakfast.

“So far, we have encountered a number of hurdles that have made a quick challenge submission difficult to do,” Hildebrandt explained. “Georgia is fortunate to have a considerable amount of data, which helped us create one of the nation’s first public statewide address-level broadband service maps.

“However, even with all of this applicable data in-house,” he added, “The FCC’s process for challenging fabric locations on a one-by-one basis still requires substantial effort and time.”

“The fabric is an enormous challenge, but we are very disappointed in the quality of the fabric and, more importantly, the insistence on using it and moving forward,” David Lukens, Connecticut’s broadband-mapping coordinator, told Broadband Breakfast.

“The FCC’s burdensome challenge process incentivizes…challenges focused only on potential BEAD project area,” he added.

Several state broadband officials told Broadband Breakfast that they have, by necessity, thus far submitted fabric challenges primarily for unserved areas, leaving the FCC’s data for numerous locations in better-served areas uncorrected. Some say, however, that they will submit additional challenges going forward.

The challenge process may work, but some say time is running short for BEAD

Spokespeople for the FCC and CostQuest have routinely acknowledged the errors in the map’s first draft and urged stakeholders to submit challenges to correct them. Some experts, including Scott Wallsten of the Technology Policy Institute, say inaccuracies are inevitable, but the challenge process will largely ameliorate them in time.

The BEAD timeline looms large for many who worry that less than two months – the interval between the map’s November release and January 13 – is insufficient time to correct the map. And like any massive undertaking, smaller entities struggle to keep up.

Kansas’ broadband director, Jade Piros de Carvalho, told Broadband Breakfast her small team lacks the bandwidth to submit a bulk challenge at all. Piros de Carvalho has encouraged her fellow Kansans to submit their own challenge. “Currently the FCC shows KS at about 5 percent unserved. We are more likely closer to 15 percent unserved, and that difference will have a direct negative impact on the dollars we receive,” she wrote Monday.

Maine will take a multi-stakeholder approach that will mobilize communities and regional partners, Andrew Butcher, president of the Maine Connectivity Authority, told Broadband Breakfast. In addition, the state itself plans to submit bulk-availability and fabric challenges by January 13, Butcher said.

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Broadband Mapping & Data

Right Track or Wrong Track on Mapping? Panel 2 at Digital Infrastructure Investment

Panel 2 video. Join the Broadband Breakfast Club to watch the full-length videos from Digital Infrastructure Investment.

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Video from Panel 2 at Digital Infrastructure Investment: Moderated by David McGarry, Reporter, Broadband Breakfast, with Bryan Darr, Executive Vice President of Smart Communities, Ookla, Mike Conlow, Director of Network Strategy, Cloudflare, and Jim Stegeman, President, CostQuest Associates.

For a free article summarizing the event, see ‘It Is a Concern’: FCC Contractor Responds to Commercial Conflict Concerns Over Map Challenge Process: CostQuest’s CEO said states need to look at their vendors if they pose a problem challenging FCC map data, Broadband Breakfast, November 17, 2022

Access Premium content for Broadband Breakfast Club members. Login to your account below. Or visit Broadband Breakfast Club to signup.

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Broadband Mapping & Data

FCC Maps Have ‘Misleading’ Satellite Claims, Need Clarity on Challenge Process: Advocacy Group

The commission published the initial draft of its map Friday, unleashing a storm of controversy in the industry circles.

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Photo of Jenna Leventoff from Internet Law & Policy Foundry

WASHINGTON, November 23, 2022 – Advocacy group Public Knowledge alleged in a letter on Tuesday that the Federal Communications Commission’s newly released map includes “misleading” coverage claims of satellite broadband providers and asked the commission to demystify the national broadband map’s bulk challenge process.

The commission published the initial draft of its map Friday, unleashing a storm of controversy in industry circles. While many agree that the map’s granular, location-level model is superior to the previous Form 477–based, census-block model, some worry that much the new map’s data is deeply inaccurate.

“State broadband offices, local communities, and community based organizations have noted a number of inaccuracies in the new broadband maps,” Public Knowledge wrote in its filing, authored by Jenna Leventoff of the advocacy group, and submitted on behalf of her, Harold Feld, and Greg Guice of Public Knowledge.

The group argued the map overestimates the capabilities of satellite broadband. “Satellite broadband, in theory, is capable of serving most locations in the country,” the filing reads. “However, in practice, satellite providers cannot serve the whole country at broadband speeds.”

The NTIA, in its notice of funding opportunity for the BEAD program, classified locations served exclusively by satellites as unserved. In August, the FCC rescinded Starlink’s $885 million grant from the Rural Digital Opportunity Fund, alleging unreliability. Besides private advocates such as think tank TechFreedom, FCC commissioners Nathan Simington and Brendan Carr have criticized the agency’s RDOF flip-flop. Starlink appealed in September.

Problems with the challenge process

Public Knowledge also took issue with the process by which the public can challenge the maps’ accuracy. “Although eager to challenge those inaccuracies,” it wrote, “Many expressed confusion over the bulk challenge process, with one even noting that they did not think it was possible.” The advocacy group also asked the commission to clarify the treatment of submitted speed test data.

The FCC scheduled a webinar on the bulk-challenge process for fixed-availability data for November 30, at 4 p.m. ET.

Regardless of accuracy, the FCC’s data will shape the National Telecommunications and Information Administration’s state-by-state allocations from the $42.5 billion Broadband Equity, Access, and Deployment program, which are scheduled to be announced in June 2023. To ensure challenges are factored into the NTIA’s decision making, the agency has encouraged potential challengers to submit data before January 13, 2023 – less than two months after the map was made available.

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