Broadband Mapping & Data
Doug Dawson: Will the FCC Maps Get Better?
The amount of funding to each state is based upon the FCC maps — which are clearly flawed.

It is unfortunate timing that the new FCC maps were issued in the middle of the process of trying to determine the BEAD grant funding. Congress said that the amount of funding that will go to each state must be based upon the FCC maps — and the first draft of the FCC maps is clearly flawed.
The FCC maps whiffed in many cases in counting the location of homes and business, and too many ISPs have clearly exaggerated both the coverage and the broadband speeds that are available to customers. This really bollixes the BEAD grant allocations, but I don’t know anybody who thought the first version of the new maps would have any merit.
Assuming that that grant funding question gets resolved somehow, there remains the bigger issue of whether the new FCC maps will ever accurately portray broadband availability. Is there any hope for these maps to get better? Getting better maps requires improving the three basic flaws of the new FCC maps — the mapping fabric that defines the location of possible customers, the claimed coverage that defines where broadband is available and the broadband speeds available to customers.
The mapping fabric will get better over time if state and local governments decide this is something that is important to fix. Local folks understand the location of homes and businesses far better than CostQuest. But there are two reasons why the fabric might never be fixed.
First, many rural counties do not have the staff or resources to tackle trying to fix the mapping fabric. There are still a lot of counties that don’t have a GIS mapping system that shows the details of every home, business, land plot, etc. But counties with GIS systems are not easily able to count broadband passings. Questions like how to count cabins or farm buildings are always going to be vexing. One of the flaws of asking local governments to fix the maps is that local governments don’t spy on citizens to see which homes are occupied or how many months a year somebody uses a cabin.
State and local governments will quickly lose interest in the mapping fabric
My bet is that once the BEAD funding has been allocated that state and local governments will quickly lose interest in the FCC mapping fabric. I expect a lot of counties will refuse to spend the time and money needed to fix a federal database.
The FCC has held out hope that the coverage areas claimed by ISPs will become more accurate over time. One of the new aspects of the FCC maps is an individual challenge by any homeowner who disputes that a given ISP can deliver broadband to their home. If Comcast incorrectly claims a home can get broadband, the homeowner can challenge this in the FCC map — and if the homeowner is correct, Comcast must fix its mapping claim.
But I have to wonder how many homeowners will ever bother to tackle a broadband challenge. The real kicker is that there is no big benefit to a homeowner to make the challenge. Using this example, Comcast would fix the map, but that doesn’t mean that Comcast is likely to offer broadband to the homeowner who challenged the map — it just means the map gets fixed. Once folks realize that a challenge doesn’t change anything, I’m not sure how many people other than the broadband diehards will care much.
The coverage challenge is only going to get better if ISPs report honestly. Using this same example, there would not be much improvement in the FCC map if Comcast were to fix a false speed claim for a specific homeowner challenge unless Comcast was to fix the maps for neighboring homes — something that a challenge does not require.
The issue that most people care about is broadband speeds. Unfortunately, the new maps are as badly flawed on this issue as the old ones — maybe worse. ISPs are still allowed to claim marketing speeds instead of some approximation of actual speeds — and an ISP gets to define what it means by marketing speeds. For example, it’s hard to dispute a marketing speed if it’s something the ISP displays on its website.
There is another way to fix the FCC’s broadband mapping problems
Other than the challenge process, there is another possible remedy for fixing mapping problems. The Broadband Deployment, Accuracy, and Technology Availability (DATA) Act that created the new maps gives the FCC the ability to levy fines against ISPs that knowingly or recklessly submit inaccurate mapping data.
But does anybody really think that the FCC is going to fine some small local WISP that exaggerates broadband speeds? I have a hard time thinking that the FCC will ever wade into the issue of disputing claims of marketing speeds versus actual speeds. Doing so would just highlight the fact that reporting marketing speeds is acceptable under the FCC rules.
The State of Vermont reacted quickly to the new FCC maps and showed the extent of the problems. The State sent a challenge letter to the FCC saying that 11% of the locations in the FCC mapping fabric don’t exist. Worse, Vermont says that 22% of locations are missing from the FCC map.
Vermont also said the speeds portrayed in the new maps don’t align with its own local mapping effort. The new FCC map shows that over 95% of Vermont homes have access to broadband of at least 100/20 Mbps. The State’s broadband maps show that only 71% of homes in the state can receive broadband at 100 Mbps or faster at the end of 2021.
I really hate to say this, but I doubt that the new maps will ever be significantly better than the old ones. I don’t enjoy being pessimistic, and I should probably let the various challenge processes run the course before complaining too loudly. I think after the flurry associated with allocating the BEAD grant funding ends that most people and local governments will quickly lose interest in the map challenge process. I can’t think of any reason why ISPs won’t continue to misreport broadband speed and coverage if they think it somehow benefits them. And I’m doubtful that the FCC will take any meaningful steps to make the maps better.
Doug Dawson, president of CCG Consulting, has worked in the telecom industry since 1978 and has both a consulting and an operational background. He and CCG specialize in helping clients launch new broadband markets, develop new products and finance new ventures. Dawson also writes the daily blog potsandpansbyccg.com, which covers a wide range of topics for broadband and related subjects. This piece was previously posted on January 10, 2023, and is reprinted with permission.
Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views reflected in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.
Broadband Mapping & Data
Tom Reid: Accountability in Broadband Maps Necessary for BEAD to Achieve Mission
The sheer magnitude of the overstatements in the FCC’s map makes the challenge process untenable.

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.
Broadband Mapping & Data
Tribes Must Be Ready to Challenge State Broadband Maps: Tribal Ready
Tribes needs to be prepared to approach states on what coverage data is not included in state maps.

WASHINGTON, May 31, 2023 – Tribal governments should gather broadband coverage data for the state mapping process, said Joe Valandra, CEO of newly formed Native American-owned data company Tribal Ready at a Broadband Breakfast Live Online event Wednesday.
Historically, tribal data has been excluded or misinterpreted in broadband maps, he said. The $42.5 billion Broadband Equity Access and Deployment program will be allocated to subgrantees by state governments according to state broadband maps.
Tribal governments need to be prepared to approach the state with a data-driven argument about what coverage data is not included in the state map and what changes need to be made, said Valandra.
In turn, state broadband offices need to listen to tribes, added Megan Beresford, director of broadband programs at grant writing company Learn Design Apply.
The $3-billion Tribal Connectivity Program of the National Telecommunications and Information Administration received over $5 billion in grant requests from its application process last year. BEAD allocations, expected to be announced by the end of June, can play a part in addressing the undersubscription of funds to tribal programs, said E.J. John, senior research analyst at the American Indian Policy Institute.
Other federal programs can also support tribal connectivity, said Beresford. The Affordable Connectivity Program allows eligible low-income households to get a discount on broadband of up to $75 per month on tribal lands.
The NTIA announced in May nine new Tribal Broadband Connectivity Program grants of $500,000 each, bringing the program’s total amount disbursed to $1.77 billion.
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.
Panelists
- Lori Adams, Vice President of Broadband Policy & Funding Strategy, Nokia
- Joe Valandra, CEO and President, Tribal Ready
- Megan Beresford, Director of Broadband Programs, Learn Design Apply
- E.J. John, Senior Research Analyst, American Indian Policy Institute
- Drew Clark (moderator), Editor and Publisher, Broadband Breakfast
Panelist resources
As senior director of broadband policy and funding strategy, Lori Adams is a key member of the Nokia Government Affairs Americas Team. She is responsible for developing strategies and tools to enable increased company participation in state, federal, and international programs supporting infrastructure deployment by several of Nokia’s business organizations. Additionally, she focuses on external government relations and communications with stakeholders at all levels of government through direct engagement, filings, and participation in public forums.
Before leading Tribal Ready, Joe Valandra served as the executive director of the Native American Contractors Association (NACA). He also served as the managing director of VAdvisors, LLC, a specialty advisory firm in Washington, DC, and as the chief of staff for the National Indian Gaming Commission (NIGC), a federal regulatory agency with Indian gaming oversight responsibilities. Joe has served in senior executive roles in private and public sectors, including as a board member of numerous companies in multiple industries.
Megan Beresford is the director of broadband programs at Learn Design Apply Inc (LDA). She joined the company mid-pandemic as the digital divide became glaringly evident. Since then, she and her team have helped states, public entities, tribes, and private internet service providers secure over $300 million in broadband infrastructure and digital equity funding.
E.J. John is the senior research analyst at the American Indian Policy Institute at Arizona State University. He is a member of the Navajo Nation who uses his experience working in Tribal government and policy research to promote digital equity for Tribal communities.
Drew Clark (moderator) is CEO of Breakfast Media LLC. He 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.
Painting by Paul Cézanne used with permission
As with all Broadband Breakfast Live Online events, the FREE webcasts will take place at 12 Noon ET on Wednesday.
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Broadband Mapping & Data
South Carolina’s Innovative Broadband Maps Verifies ISPs’ Internet Speeds
South Carolina performs mapping audits to hold ISPs accountable for coverage claims.

WASHINGTON, May 21, 2023 – South Carolina’s innovative state broadband map can accurately identify areas of over-reporting by internet service providers, the director of the state’s broadband office said in a Friday Ask Me Anything! session in the broadband community.
South Carolina processes the same data as does the Federal Communications Commission as it creates its broadband map. However, it also performs audits on the ISPs to ensure they are submitting accurate data. Hence, the state can determine errors in reporting data based on where the ISP’s networks had been deployed previously and where state investments have gone, said Jim Stritzinger, director of the state’s broadband office.
Providers are required to file amended returns with the FCC in the event that South Carolina’s state broadband office flags errors in their reporting information. Errors include misreporting of technology types.
If the reporting errors are not corrected, the state will report the defaulting ISP to the FCC, said Stritzinger, a software engineer with a passion for mapping broadband in the Palmetto state.
A big flaw of the FCC’s maps is that ISPs were able to report advertised speeds, which Stritzinger said were useless.
To enhance the accuracy and reliability of the maps, Stritzinger partnered with broadband data collection company Ookla, and integrated speed test data directly into the mapping system. More than 12 million Ookla speed tests have now been incorporated into the map, with some census blocks containing over 15,000 tests.
In 2021, South Carolina made the decision to no longer accept Digital Subscriber Lines as reliable service anywhere in the state. Doing so opened large regions of the state to investments, said Stritzinger, and will reduce the number of underserved locations.
The state’s next iteration of its map is set to come out sometime before June 30, and will be the state’s first address-level broadband map.
Stritzinger estimated that investments from the Broadband Equity Access and Deployment program will be deployed in 2025. In the meantime, the state will continue working to deploy the American Rescue Plan Act dollars, which allocated $25 billion in several broadband projects, $8 billion of which will go to states and local governments directly.
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