Broadband Mapping & Data
As States Struggle to Challenge FCC Map, Local Communities Can Help Maximize BEAD Funding
Panelists compared the FCC’s process to flying a plane while it’s being built.

WASHINGTON, January 6, 2023 — As the deadline to challenge the Federal Communications Commission’s national broadband map approaches, many state offices are struggling with the process — whether due to limited resources, contractual restrictions or both. Engaging local organizations and communities in the planning process can help states successfully utilize grant funding, said panelists at a webinar hosted Thursday by rural broadband trade association NTCA.
The central problem with the FCC’s mapping process is not the process itself, but rather the way that the project’s timeline has been compressed, said Michael Romano, executive vice president of the NTCA. Not only did the FCC get off to a slow start because of difficulties finding a contractor, the decision to use the map to allocate billions of dollars in grant funding is rushing the map’s completion.
“There is, I think, a good blueprint for the plane to be built — but it’s being built while it’s being flown,” Romano said.
Stakeholders who are attempting to challenge the fabric’s data are hindered by the fact that the fabric is not yet finalized, and providers may have yet to capture certain locations. This may also compromise the allocation of funds from the $42.5 billion Broadband Equity, Access and Deployment program.
“When the FCC map came out, it showed Texas at being over 98 percent served, which was news to us… we know there’s a lot of unserved and underserved areas out there that the map does not show correctly,” said Jennifer Prather, CEO of Texas-based telecommunications company Totelcom. “However, this week when we looked at the state map, it actually looks like it might be worse.”
Texas began to work on a state broadband map largely in order to challenge the FCC’s map, Prather said. But Texas’ map is using a different vendor than the one used by the FCC, which has caused some challenges.
The Texas Broadband Development Office contracted with LightBox, while the FCC’s national map was created by CostQuest. If Texas uses LightBox data to challenge the FCC’s map, that data can be used by CostQuest in its commercial products — which would violate Texas’ agreement with LightBox.
Although the challenge process is designed to increase the map’s accuracy, it may actually exacerbate discrepancies if some states energetically participate in the process and others are unable to do so, Romano said.
Collaboration with local community organizations is key
A challenge for many state broadband offices is a lack of experienced staff. For example, Texas’ state broadband office was created in 2021 and still only has three full time employees — who will soon be tasked with distributing billions of dollars. As a result, other private and local entities are playing an important role in the process.
“It has been really important for us to reach out early, early on to the communities around us that we want to serve,” Prather said. “Again, that is really something that a community-based provider — such as we are — has that no one else can touch, because we are trusted.”
Nationally led planning can turn into “building networks for networks’ sake” instead of considering effective and ongoing use cases, Romano said.
By contrast, tailoring network construction to the needs of specific areas can help ensure the network’s success, whether that entails “trying to keep birdshot out of it during hunting season or farm equipment from ripping it down,” Prather said.
Community input has been particularly important in the determination of anchor institutions. The BEAD program expands the traditional definition of anchor institution and allows state broadband offices to propose additional types of institutions for inclusion.
For example, after experiencing widespread electricity failures in 2021, some Texas communities may want to strengthen connections to solar farms or battery banks, Prather said. “While it might not be a traditional anchor institution, we’re taking that back to the state broadband office… We’re trying to get these things included.”
Local organizations will be key to making the most of BEAD funding, said Scott D. Woods, vice president of community engagement and strategic partnerships at Ready.
“We have enough independent organizations that are in it for the right reasons — they want to actively end the digital divide, want to make sure this money flows into unserved and underserved communities that have been traditionally digitally redlined,” Woods said.
Focus should be on fiber, to the greatest extent possible
BEAD funding will not be enough to provide 100 percent of customers with a fiber connection, but the focus should be on getting fiber to as many people as possible before considering alternate technologies, Prather said.
Romano agreed, pointing out that past efforts to close the digital divide have failed because of an unwillingness to use fiber unless it can be a universal solution.
“What we’ve seen in too many broadband programs in the past is this thinking of, ‘Well, I won’t connect anyone until I can connect everyone, and therefore I’m not going to try to use the best possible technology.’”
One important advantage of fiber is its sustainability over time.
Even if the initial deployment cost is higher, fiber often comes out ahead once long-term upgrade and maintenance costs are taken into consideration, Prather said.
Romano noted that while some BEAD-funded networks will be self-sustaining, many others will require ongoing support after the grant funding is exhausted.
“It’s not just about getting people connected,” he said. “It’s about keeping them connected and keeping the services affordable and upgraded over time.”
The future-proof nature of fiber is also important, particularly as connectivity needs continue to grow.
The current definition of an “underserved” location is one that lacks access to reliable broadband service with a speed of at least 100 Megabits per second (Mbps) download and 20 Mbps upload. However, this standard is still far too low to meet many consumers’ needs, panelists said.
Targeting 100 Mbps download and 20 Mbps upload can sometimes “get you laughed out of an office, because that’s just not the reality of what we’re seeing today,” Prather said. This problem will only be exacerbated in the future, given the quick pace at which speed needs are growing with the much slower pace of broadband funding.
Broadband Mapping & Data
Some States Confused about Changes to NTIA Model Challenge Process
The new guidelines specify that only subscribers of 100 * 20 Mbps service will have speed tests accepted.

WASHINGTON, September 20, 2023 – The National Telecommunications and Information Association has changed the model challenge process for main broadband program to specify that the agency’s standard will only accept speed tests from locations with extremely high-capacity broadband.
The new guideline, which the NTIA characterizes as a clarification, means that only subscribers of service at 100 Megabits per second (Mbps) upstream and 20 Mbps downstream will have their speed tests accepted.
This specification means that all those considered “underserved” will not be eligible to challenge actual speed measurements with speed tests.
The agency’s model process under the Broadband Equity, Access and Deployment program was first released on June 28 as a template for states to accept and process challenges to their broadband map data ahead of allocating their portions of the $42.5 billion in BEAD funds.
Speed tests, conducted by subscribers while meeting certain methodological standards, show their actual internet speeds are one form of evidence states can accept in these challenges. The program considers areas with access to speeds in excess of 100 Mbps upload and 20 Mbps download – 100 * 20 Mbps – to have adequate broadband access and makes them ineligible for funding. Money is targeted at areas receiving speeds below 100 * 20 Mbps, called “underserved,” and areas receiving below 25 * 3 Mbps, called “unserved” areas.
Other ways to challenge reported coverage
There are other ways reported coverage can be challenged. The availability of reported coverage can be contested, for example, with evidence providers do not offer plans at the speed they are recorded as providing in government data.
The initial release of the model process included the sentence “If the household subscribes to a speed tier of between 25/3 Mbps and 100/20 Mbps and the speed test results in a speed below 25/3 Mbps, this broadband service will not be considered to determine the status of the location.”
In the updated version — changed on August 30, 2023, according to the NTIA’s change logs — does away with this, specifying “only speed tests of subscribers that subscribe to tiers at 100/20 Mbps and above are considered.”

Screenshot of the updated model challenge process language.
That means, for example, speed tests from a subscribers to a 80 * 10 Mbps plan showing they receive speeds of 23 * 2 Mbps would not be accepted. Only tests from subscribers to 100 * 20 Mbps or faster showing lower speeds would count toward changing that location’s service designation.
The NTIA said this update does not constitute a change in policy, but was made to clarify an existing rule: only locations marked as served can challenge on the basis of speed.

Screenshot of the original model process, stating speed tests from subscribers between 100*20 and 25*3 Mbps showing actual speeds below 25*3 could be used to disqualify the advertised coverage.
The new specification has caused confusion
This has caused confusion in some state broadband offices. Jessica Simmons, executive director of the Georgia Broadband Program said her office was under the impression that consumers who subscribe to an internet plan offering speeds in the underserved range could submit – through an allowed challenger like a nonprofit or state government office – speed tests showing that they receive speeds below the unserved threshold.
“Rather than clarification, it did seem like a policy shift to us,” she said. “We believed it seemed clear that an underserved location could be changed to unserved.”
States are required to submit their challenge processes in the first volume of their BEAD initial proposals – documents outlining implementation plans for the program – on December 27.
Georgia released volume one of its proposal on Tuesday. Simmons and her four-person team made sure to change the language in their proposal to reflect the new model process.
“If it’s coming from the NTIA, you know, we’ve got to get our plan approved,” she said.
In total, 14 states and Puerto Rico have released their volume one. They all base their challenge processes heavily on the NTIA’s model, with all but three adopting it in full. Vermont, Delaware, and Ohio made minor changes that do not relate to speed test processing.
Eight use the language around speed tests from the original model.
Broadband Mapping & Data
Broadband Breakfast Webinar on Broadband Geospatial Planning
A tutorial for investors, broadband providers, and political leaders

Broadband Breakfast is pleased to host a webinar on Broadband Geospatial Planning: A tutorial for investors, broadband providers, and political leaders.
The event, featuring the BroadbandToolkit.com software, is free to attend and publicly available. It took place on Tuesday, September 12 at 2 p.m.
Signup to obtain a copy of the recording and the slides from the event.
The world is data-driven. As the broadband industry assembles to discuss BEAD implementation it is important to understand the essential role of data-driven planning. What kind of data exists? How can it be visualized? How can investors identify compelling opportunities? How can state leaders ensure that limited public funds are directed to projects that will cost-effectively improve the lives of many? How must state leaders prioritize expenditures to comply with BEAD rules? What analytical tools do governments and broadband providers need to make clear-headed infrastructure deployment decisions? How do economics drive decision-making? How can states properly incentivize the private sector to achieve public goals?
This tutorial will take a hands-on approach looking at available tools and data sets, using publicly available BroadbandToolkit.com software and a few other data sources. Participants will emerge with an appreciation of the available resources and how they might be used to answer critically important questions.
Signup to obtain a copy of the recording and the slides from the event.
Broadband Mapping & Data
Area Challenges Could be Key for State Mapping Efforts: Experts
The next phase of broadband mapping is going to be very much state-driven, said panelists.

WASHINGTON, September 6, 2023 – An optional provision in the National Telecommunications and Information Administration’s model BEAD challenge process could be key for states as they work to create accurate broadband maps, experts said on Wednesday.
The Broadband Equity, Access and Deployment Program provides states over $42 billion to expand broadband infrastructure. Part of the implementation process involves consumers and providers submitting challenges to the state’s claim on whether a location is already served with an adequate internet connection.
In the NTIA’s model challenge process – published in June as a template for states – if six or more locations in a census block group allege the same technology from the same provider is slower than state data indicates, an “area challenge” is initiated. This designates the entire block group as challenged.
Normally, the challenger must provide evidence that their service is worse than advertised in order to successfully change their location’s status in the state’s data. But under area challenges, the provider must prove that they provide the reported service to the entire census block.
“It’s really important to think about the area challenge,” Dustin Loup, director of community development at Ready, a software company that makes tools for state broadband offices and grant applicants, said at a Broadband Breakfast Live Online event.
He emphasized that the area challenge provision would allow states to collect information on areas that might be labeled incorrectly by using broadband providers’ infrastructure rather than crowdsourcing speed tests from individual consumers.
“There’s no way you’re going to be able to go out and collect data for 500 locations in a census block group,” he said. “But you can almost certainly find six willing participants.”
The Federal Communications Commission’s broadband coverage map – known as the fabric – is widely alleged to be inaccurate. That makes state and local efforts to collect accurate coverage data essential for getting BEAD-funded projects in areas that need them, according to other experts at the event.
“This is a big, big issue,” said Tom Reid, founder of broadband consulting firm Reid Consulting Group. “It is going to be very much state-driven.”
“The state challenge process is essentially an acknowledgement that the FCC maps don’t go far enough,” Loup added.
States are not required to use the NTIA’s model process, and those that do are not required to enforce the area challenge provision, but they are required to submit detailed plans for a challenge process with volume one of their initial BEAD proposals.
Those proposals are due December 27. Some states, like Virginia and Louisiana, have released these ahead of schedule and are adopting the NTIA model challenge process guidelines.
J. Randolph Luening, founder of BroadbandToolkit.com, a suite of mapping tools and datasets for state broadband providers, expressed concern that separate state methodologies could lead to more confusing about the true state of broadband coverage in the U.S.
Chris Scharrer, founder of rural broadband mapping company DCS Technology Design, emphasized the importance of requiring providers to provide evidence for their reported coverage, citing differences in ISP-reported speeds and those detected by on-the-ground testing.
Gerry Lawlor, co-founder of broadband mapping company Hexvarium, said the challenge process could end up distracting state broadband offices from working with providers to ensure coverage for the highest cost communities.
Our Broadband Breakfast Live Online events take place on Wednesday at 12 Noon ET. Watch the event on Broadband Breakfast, or REGISTER HERE to join the conversation.
Wednesday, September 6, 2023 – What’s New in Broadband Mapping
The success of the Broadband Equity, Access, and Deployment program may hinge upon accurate data for distributing infrastructure funding. But broadband mapping remains a formidable challenge. The FCC’s broadband map has already served as the basis for state-by-state allocation decisions. But will one much-maligned tool be enough for state broadband offices as they formulate coverage areas within their states’ communities? Join a range of stakeholders for this special Broadband Breakfast Live Online as we all seek to understand the intricacies of broadband mapping through a range of software databases.
Panelists
- Tom Reid, President and Founder, Reid Consulting Group
- Dustin Loup, Director of Community Development, Ready.net. Coordinator, Broadband Mapping Coalition
- Gerry Lawlor, Co-founder, Chief Executive Officer, Hexvarium
- J. Randolph Luening, Founder and CEO, BroadbandTookit.com
- Chris Scharrer, Founder, DCS Technology Design
- Drew Clark (moderator), Editor and Publisher, Broadband Breakfast
Panelist resources:
- Tom Reid: Accountability in Broadband Maps Necessary for BEAD to Achieve Mission, Broadband Breakfast, June 1, 2023
- Broadband Mapping Coalition Seeks to Bring Openness Back to Internet Data, Broadband Breakfast, June 17, 2022
- Mapping Expert Dustin Loup Joins Ready as Director of Community Development, Ready.net, July 18, 2023
- Key Principles for the Data-driven State Broadband Office, Ready.net, July 25, 2023
- Running a Robust, Transparent, Efficient Challenge Process, Ready.net
- Ask Me Anything! with Gerry Lawlor, Co-Founder and CEO of Hexvarium, Broadband.io, June 30, 2023
- Commercial Mapping Products Positioned to Compliment, Challenge FCC Map, Broadband Breakfast, November 21, 2022
- Fiber Broadband Association Announces High Cost Area Planning Tool for BEAD Projects, Broadband Breakfast, August 21, 2023
- 45 years ago, I installed my first Broadband Coax drop!, Chris Scharrer, Broadband.io, August 20, 2023
- States must not succumb to defeatism on broadband data and mapping, Drew Clark, Broadband.io, February 12, 2023
- Broadband Maps Are a Mess, So Now Let’s Focus on Actually Improving Them, Drew Clark, Broadband Communities and Broadband Breakfast, July 30, 2019
Tom Reid, President and Founder of Reid Consulting Group (RCG) has nearly 40 years of experience in the technology sector. His experience is extensive, advising both public and private-industry clients on strategic planning, technology architecture, competitive bidding, and project management. For fifteen years RCG has been in the forefront of broadband expansion, building deep experience in stakeholder engagement, GIS mapping, engineering, and statistical analysis. RCG’s rigorous, multi-source mapping methodology can identify the true extent of broadband need in any region, providing a strong basis for state and federal investment.
Dustin Loup is the Director of Community Development with Ready.net. He also coordinates the Broadband Mapping Coalition and advises on the Digital Inclusion Leadership Program for the Marconi Society. Prior to joining Ready, Dustin served as the Broadband and Digital Equity Project Director for Washington State University Extension.
Very much the accidental telecom executive, Gerry Lawlor has started and led multiple ISPs both regionally and nationally. His broadband adventures started out of necessity after leaving Manhattan in 2011 for remote rural living on a pacific northwest island. Working with his local electric co-op, he led Rock Island Communications which has been one of the most successful Co-op led broadband initiatives. He moved to T-Mobile in 2018 and led the national development and deployment of its Fixed Wireless Access (FWA) line of business. Prior to making his mark in the telecom sector, Gerry led global businesses in the financial industry, where he developed his passion for bringing meticulous research and a unique, boundary-pushing approach to data analysis.
J. Randolph Luening is the founder and CEO of Signals Analytics, LLC and the creator of BroadbandToolkit.com, an entity that delivers powerful business planning tools to FCC auction participants and to others developing fixed or mobile telecommunication business cases. Mr. Luening has contributed to the wireless telecommunications industry as an influential industry insider over the past three decades. An expert is mobile operator economics, his areas of focus include the economics of next generation mobile networks, small cells, emerging business models, and consumer behavior. Previously as a Senior Director at Vodafone, and more recently as a consultant, his work has benefited telecommunications operators in the US, Europe, and Asia.
Chris Scharrer started in the cable industry in 1978, as an installer, and held positions in construction, operations, and engineering, eventually becoming Division VP and CIO for a major, 800-person global professional services firm. Stepping away from the corporate world in 2008, Chris founded DCS Technology Design, within the professional services industry, to bring excellence in Telecommunication Infrastructure Design for all types of intelligent building and smart community applications. With Covid, and in response to the lack of reliable and trusted ISP service area maps, DCS refocused its mission to develop methodologies that produce highly accurate Rural Broadband accessibility data, and helping Michigan municipalities locate thousands of previously missed or mis-reported homes and businesses that do not have access to Broadband and qualifying them for needed grant funding, ensuring inclusive accessibility for all residents.
Breakfast Media LLC CEO Drew Clark has led the Broadband Breakfast community since 2008. An early proponent of better broadband, better lives, he initially founded the Broadband Census crowdsourcing campaign for broadband data. As Editor and Publisher, Clark presides over the leading media company advocating for higher-capacity internet everywhere through topical, timely and intelligent coverage. Clark also served as head of the Partnership for a Connected Illinois, a state broadband initiative.
As with all Broadband Breakfast Live Online events, the FREE webcasts will take place at 12 Noon ET on Wednesday.
SUBSCRIBE to the Broadband Breakfast YouTube channel. That way, you will be notified when events go live. Watch on YouTube, Twitter and Facebook.
See a complete list of upcoming and past Broadband Breakfast Live Online events.
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