With millions of American households stranded in the digital desert, we need to achieve accountability in broadband to make sure the Broadband Equity, Access and Deployment funding achieves its mission. The broadband gaps can be readily identified despite the air of mystery surrounding the topic.

Broadband improvements have been constrained for decades by inaccurate maps, yet the Federal Communications Commission continues to accept dramatically exaggerated availability and capacity claims from internet service providers. The cumbersome challenge process requires consumers and units of government to prove a negative — a logical fallacy.

The Reid Consulting Group and other parties, including Microsoft, have developed robust algorithms to reliably identify actual broadband availability. RCG utilizes Ookla Speedtest Intelligence data due to the large quantity of consumer-initiated tests. In Ohio, as an example, we draw on more than 16 million speed tests reflecting the lived experience from millions of households. We combine the speed test findings with FCC and Census data to deliver irrefutable identification of unserved and underserved locations.

Such methodologies offer State Broadband Leaders the opportunity to reverse the burden of proof in the BEAD program, requiring that ISPs submit concrete evidence supporting their availability and speed claims. As an example, in Ohio, RCG’s maps were accepted as proof of unserved status for the 2022 state grant program. BroadbandOhio then required ISPs to submit substantial proof in their challenge process. In other words, the ISP’s were tasked with proving a positive instead of expecting citizens to prove a negative.

ISPs and the FCC denounce crowdsourced data unless conducted under unusually restrictive conditions. The ISPs have successfully promoted unsubstantiated myths regarding the value of consumer-initiated speed tests.

Myth: Bad tests are because of poor Wi-Fi.
Reality: RCG eliminates speed tests with weak Wi-Fi and includes GPS enabled wired devices. Even first-generation Wi-Fi would saturate a 25 Megabits per second download and 3 Mbps upload connection.

Myth: Residents only subscribe to low-speed packages.
Reality: According to the National Rural Electric Cooperative Association, in areas where rural electric cooperatives offer broadband, 25 to 33 percent of rural subscribers opt for the top speed tier offered. We can clearly see this trend in areas where fiber has been deployed in recent years, as described later in this article.

Myth: People only test when there is a problem.
Reality: Network problems prompt tests, as do resolutions of problems.  RCG recommends focusing on the maximum speed test results to eliminate this “unhappy customer effect.”

Finding the truth: Broadband and the lived experience

In Ohio, RCG analyzed more than 14 million consumer-initiated speed tests over a three-year period. The data reveals a clear pattern of carrier overstatement. The stark visual contrast between the two maps is hard to ignore — and while this study is focused on Ohio, the issue remains nationwide in scope. The sheer magnitude of the overstatements makes the FCC challenge process untenable.

Figure 1: Ohio Broadband Reality vs. FCC ISP stated coverage map.

RCG utilized the “maximum speeds ever seen” at a location for generating maps and coverage figures, but we also examined the results from the average of speed test. Switching between average and maximum speeds does not change the overall picture of broadband availability. As an example, Figure 2 focuses on an area around Bolivar, Missouri. Looking at the maximum speed turns Bolivar itself a deeper green, meaning “better served,” but the rural areas around Bolivar remain predominantly red, meaning “unserved.”  The preponderance of evidence clearly demonstrates that much of the rural area around Bolivar remains unserved, even at maximum speeds.

Figure 2: Map visualization illustrating the difference between viewing average speeds in the Bolivar, Missouri area and maximum speeds documented.

When rating broadband availability in the Bolivar area at the Census block level and overlaying with ISP coverage claims at the H3 R8 level, you can see that many of the unserved and underserved areas have been reported as served to the FCC by ISPs (Figure 3).

Figure 3: Carrier overstatement small scale in Bolivar, Missouri. RCG speed map with FCC H3 R8 hexagon overlay.

Zooming out to examine the entirety of Missouri (Figure 4), the pattern of ISP overstatement becomes quite clear. According to the FCC maps, most of the state is served, whereas the analysis conducted by RCG shows that significant areas remain in need of broadband investment. As with Ohio, the scope of the overstatement in Missouri presents an unreasonable burden on the public to challenge.

Figure 4: Missouri reality vs. ISP Reports, March 2023.

Showing Progress: Change of State Analysis

Change-of-state analysis taps progressive releases of Ookla records to identify areas where broadband speeds have set new highs. This approach works not only for grant funded projects but also private investments. The area surrounding Byesville, Ohio (Figure 5) reveals a significant uptick in test volume, test locations, and speeds from 2020 to 2022. Side-by-side comparison shows a large number of “green” (served) speed test locations where there used to be only “red” (unserved) and “orange” (underserved) results. This change is a direct result of a Charter Communications Rural Digital Opportunity Fund deployment.

Figure 5: The unserved area around Byesville, Ohio before and after broadband deployment.

State Broadband Leaders can use these capabilities to document progress and identify lagging projects. Any service area will always exhibit a mix of speed test results.  Even in an area like Byesville where fiber-to-the-home has been deployed, not all the location “dots” will turn green. However, the preponderance of evidence clearly shows that a funded ISP — in this case, Charter — has made good on its commitment to expanded broadband access. ISPs can help by conducting speed tests at the time of installation from the customer’s premises and by increasing minimum packages to 100/20 Mbps or higher.

There is no mystery to solve — we know how to identify areas lacking broadband services. For many rural Americans, even their telephone services have become unreliable, still dependent on the now-decrepit copper cables built in the 1940s through 1960s. We all depend on a healthy rural economy for our food, water and energy. Let’s make the commitment to build the infrastructure needed to bring these households into the internet age — starting by bringing reality and accountability to the availability maps.

Tom Reid is the president of Reid Consulting Group, a firm specializing in broadband. They work with clients to generate insights, create actionable plans, and identify funding sources to connect unserved and underserved areas. RCG’s engagements in eight states have delivered 6,000 miles of fiber construction with a total project value of $1.6 billion and has secured over $330 million in grant funds on behalf of clients. 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.

Last week, the Senate Subcommittee on Communications, Media and Broadband held a hearing titled “The State of Universal Service.” The Universal Service Fund is our nation’s critical connectivity program that helps ensure that voice and broadband services are available and affordable throughout the country.

Since its creation by Congress in the 1996 Telecom Act, the USF has become a program that millions of families, community anchor institutions and small businesses rely on to get connected. It has been especially valuable for families and businesses that rely on it for work, school and telehealth at home.

The USF spends about $8.5 billion annually to help fund affordable connectivity in rural areas, low-income households, schools, libraries and rural hospitals. Today, the Federal Communications Commission is working to make high-speed broadband as ubiquitous as telephone service, and broadband is the essential communications technology the USF now supports.

While the USF remains vital in an ever-increasing connected world, it is in serious jeopardy of surviving. To fund the programs, telecom providers are required to pay a certain percentage of their interstate and international telecom revenues, known as the “contribution factor.” Typically, telecom providers collect these USF fees from their customers on their monthly bills.

However, the telecom revenues that fund the USF have declined over 60 percent in the last two decades. As a result, the contribution factor has skyrocketed from about 7 percent in 2001 to a historic high of about 30 percent today, as a higher portion of telecom revenues is needed to sustain the fund. That means certain consumers and businesses are now paying an additional 30 percent on top of their phone bills in order to fund the USF.

Telecom revenues continue to decline so rapidly because customers today rely more on broadband services and less on landline and mobile phone services, but broadband revenues do not pay into the USF. While the FCC has modernized each USF program to help support broadband service, it has not modernized its funding mechanism to require broadband services to pay into the Fund even though historically the agency has required supported services to be included in the contribution system.

Without intervention, the contribution factor is predicted to rise to 40 percent by 2025. This is unsustainable and puts the stability of the entire USF at risk. In fact, the contribution factor has become so high that it has led some groups to challenge the USF in federal court as unconstitutional, which also threatens the sustainability of the USF.

Reforming the USF funding mechanism is urgently needed and long overdue

Over 340 diverse stakeholders have come together as the USForward Coalition calling on the FCC to move forward with USF reform by expanding the contribution base to include broadband revenues. This solution is based on the recommendation in the USForward Report (that INCOMPAS helped commission), which was written by USF expert and former FCC official Carol Mattey.

The USForward Report explains that the most logical way to reform the contribution system and sustain the USF is to include broadband revenues in its funding assessment. Under this approach, the contribution factor is estimated to fall to less than 4 percent. It also means that the services that get USF support are paying into it, rather than solely relying on telecom customers, including those that have not made the switch to broadband, such as older Americans.

In fact, some members of Congress understand the urgency of reform and also want the FCC to act. The Reforming Broadband Connectivity Act, for example, is a bipartisan, bicameral bill that would require the FCC to reform the contribution system within one year.

Some question whether large tech companies should be assessed to contribute to the USF, and the short answer is “No.” Tech companies invest $120 billion each year in global internet infrastructure, and unlike broadband providers, these companies do not request or receive USF funding for these investments.

The FCC also lacks the authority to regulate tech companies and doing so would require Congress to act. This would further delay reform and expand the FCC’s regulatory authority over all online content and services — an overreach that many question as too broad since nearly every business today has an online presence and uses the internet to conduct business. Moreover, proposals to target certain tech companies risk skewing the online marketplace and competitive markets.

Some also question whether we still need the USF at all, and the short answer is “Yes.” While Congress allocated tens of billions for broadband, most of this investment is targeted for deployment, yet a significant portion of the USF programs focus on affordability. We not only have to make sure we build out our broadband networks, but also that communities can then afford to subscribe to these services.

The FCC should not wait to reform the USF. The USForward Report sets out a real plan that the FCC can and should implement. Congress should encourage the FCC to act now and save the nation’s critical connectivity program.

Angie Kronenberg is the president of INCOMPAS, where she manages the policy team and its work before federal, state and local governments, as well as leading the association’s efforts on membership and business development. 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.