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Broadband Mapping & Data

Bryan Darr: Senators Move to Fix the Broadband Map; Here’s How You Can Submit Crowdsource Data

Newly proposed legislation would add 7 months to the challenge process for states and other parties.



The author of this Expert Opinion is Bryan Darr, vice president of Smart Communities at Ookla.

A lot of energy has been expended in the last several months to dispute the FCC National Broadband Map. The focus has been on two primary issues:

  • The first is a disagreement about the number of broadband service locations (BSLs) that exist in each state. Only residential buildings are eligible and many multi-dwelling units (MDUs) are considered a single location.
  • The second issue regards how many of those locations do not have access to broadband service. Those with throughput speeds less than 25 Mbps download and 3 Mbps upload are considered unserved. Locations served with speeds less than 100 down and 20 up are considered underserved.

These counts are important because the number of total locations and unserved locations in each state will define how much funding each state receives of the over $42 billion available through the Broadband, Equity, Access and Deployment Program (BEAD).

The Infrastructure Investment and Jobs Act (IIJA) that established this program was bipartisan, and so is the concern over the current state of the map. The deadline to challenge the accuracy of these location counts passed in January, but many state broadband offices and the legislators that represent them have made it clear they were unhappy with the process. Some of them felt that there was simply not enough time to analyze the data after gaining access to it.

New legislation proposed to “fix” the map

The demand to fix the map became increasingly serious on Friday, March 31, 2023, as Senators Jacky Rosen (D-NV) and John Thune (R-SD) introduced the “Accurate Map for Broadband Investment Act.” Calling the current map “deeply flawed,” the bill aims to provide additional time to challenge the number of BSLs as well as which ones are considered unserved or underserved.

Everyone expects the FCC map to forever be a work in progress as communities grow and networks expand. It has already improved from its first release and it will continue to get better. As we approach a moment in time that will divide up a finite funding pool, accuracy on the metrics has real monetary consequences. Once allocations are made, it will be up to NTIA to work with each state to fund broadband infrastructure projects and connect communities. However, the dollars each state has to work with won’t change.

The newly proposed legislation would add seven more months to the challenge process for states and other interested parties to dispute the map’s accuracy. To ensure that broadband projects aren’t brought to a complete halt, 20% of the funding would be made available on the original timetable, delaying assignment to states of the remaining funds while more scrutiny is applied to the underlying data.

Multiple bites at the apple

There are two agencies, not just one, that will impact which communities get broadband infrastructure assistance and how soon they get it. Up until now, providing input to the FCC for corrections to the map has been the primary focus. But NTIA will be responsible for working with each state broadband office to identify areas of need and approve project awards. These plans will certainly evolve as new evidence is presented.

During the first phase of their mapping effort, the only significant challenges to the map the FCC accepted were for the number of broadband service locations and individual reports of availability not matching those reported by ISPs. There were certainly some individual challenges submitted, but many states were frustrated at the lack of public awareness and participation. Through NTIA, state offices were always going to get a second bite at the apple as far as getting funding to the right communities. Depending upon the outcome of the Rosen/Thune legislation, states may get an extra bite from the FCC apple as well.

Confusion over crowdsource data

The Commission defined a process for crowdsource data to be presented as evidence to support that reported service availability and performance was less than claimed. However, many filers have found this process unclear or difficult, notably in regard to the requirement that all submissions include Broadband Serviceable Location (BSL) identification numbers. To make this process even more difficult, the only file types accepted as additional evidence were formats that lacked geospatial awareness. In other words, they could not easily be imported into a mapping system.

As of late February, the FCC now accepts JSON files in addition to those formats already approved (PDF, DOC, DOCX, JPG and PNG). This new format can include columns for longitude and latitude, making it easier to include crowdsource data evidence, and has the added benefit of making analysis by the FCC significantly more efficient.

Multipurpose research

Crowdsource data evidence has multiple target audiences. The very same evidence developed to submit to the FCC can be used to work with NTIA during the next phase. NTIA is very familiar with how crowdsource data is employed to define “indicators of need,” and used data from Ookla®, M-Lab, and Microsoft extensively to build their National Broadband Availability Map a couple of years ago.

These federal agencies have been the primary concern, but local interests will become very vocal as projects are chosen. Which communities receive grants and in what priority may be vigorously debated. ISPs that compete for expansion areas will need to prove a track record, and the states will need independent evidence on how well they are serving their existing customers. And those providers that stretched the truth on the level of service they actually provide will fight being overbuilt. States should be preparing for local challenges to their own decisions.

Crowdsource data provides the largest pool of evidence to understand the quality of service being delivered to a community. Hundreds of millions of tests across the country means that even less populated states have hundreds of thousands of points to analyze and better understand the availability and performance of each serving network.

How to support your claim with crowdsource data

Crowdsource data from Ookla Speedtest® measurements can easily be overlaid with FCC maps to produce the needed evidence that indicates where services don’t meet minimum broadband standards. Through crowdsource data submissions, broadband offices can dispute existing maps, advocate for federal funding eligibility, and assist federal officials in their mission to improve broadband availability and performance.

Below are some helpful tips for submitting crowdsource data for disputed areas in a format that can meet FCC requirements.

Step 1: Identify Broadband Serviceable Locations (BSLs)

As an example, we are going to focus on an area near Durango, Colorado — a mountainous area that is both difficult and expensive to cover. We start by looking at all of the BSLs represented in the FCC’s map within the area of interest for early 2023.

Step 2: Overlay FCC hexagon system with BSLs

Next, we overlay the BSLs with hexagons where the FCC defines broadband service as being available. The darker the hexagon, the more ISPs claiming to provide service in that area.

Step 3: Layer Speedtest data with FCC hexagon system and BSLs 

By layering Speedtest data from fixed terrestrial operators on top of the hexagons, we can see that Durango and Durango West have high test densities. There are many households packed closely together, making those areas more viable to justify the cost of building high-speed services to them from a purely economic standpoint. Location accuracy for most tests is under 100 meters, so tests will grid into bins measuring approximately 1002 meters (this varies based upon latitude). If there are multiple tests within each bin, they will stack, and we are showing the fastest recorded speed on the top in this view. Speedtest measurements shown are for the four quarters (Q1-Q4, 2022) immediately previous to the published FCC data.

Step 4: Create clusters to see Speedtest data at scale within the FCC hexagon system

To get an idea of the actual volume of Speedtest data we’re looking at, we created a clustered version demonstrating where the number of tests are much greater. Some hexagons have 100+ tests, and a few hexagons have no tests, usually because there are fewer households.

Step 5: View Speedtest performance within the FCC hexagon system

Using that methodology, we can show how the aggregated test results appear within the hexagons defined by the FCC. The red hexagons (levels 8 and 9) demonstrate where the median speed is not meeting FCC minimum standards for broadband. This helps you get an idea of the overall experiences people are having, as well as the maximum speeds experienced in an area referencing the stacked tests previously shown.

Step 6: Create a polygon of Speedtest data with BSLs 

Next, create a polygon that surrounds the community or specific area of interest. Many ISPs have created polygons to capture all of the BSLs that fall within their territories for their service area and technology submissions. In our discussions with the FCC, staffers have suggested following a similar approach for crowdsource submissions.

Step 7: Export the polygon of BSLs as a CSV file

Next, export a CSV file of the locations that are within the polygon, including the Location ID, as directed in the instructions defined by the Broadband Data Task Force (BDTF). The entire FCC submission process has been built around identifying these location IDs for each BSL.

Step 8: Export the polygon of Speedtest data as a JSON file

Using the same polygon, select and export the Speedtest results as a JSON file, including speed and latency measurements, ISP names, timestamps, anonymized user ID, and source test ID.

Step 9: Submit the files to the FCC 

Submit the CSV file as well as the JSON file as additional evidence to the FCC along with any other documents supporting your dispute of the service availability, using one of the accepted file formats. This may include maps defining the area being disputed, documents from residents claiming inadequate or no service, and any other pertinent information.

Step 10: Be prepared to use the evidence to partner with NTIA

The FCC maps will ultimately define how many dollars go to NTIA to determine state funding. NTIA is preparing to use the same map fabric and BSL data as that used by the FCC. This will allow collaboration with all the above parties and will assist with reconciling the differences between the federal stakeholders. You can utilize this same data as you work with NTIA to demonstrate where you would like to focus funding as well as resolving local disputes on broadband availability.

Want to learn more? Watch our recent webinar

We hosted a webinar on March 30, 2023 titled “Using Crowdsource Broadband Data to Dispute FCC Maps”. In this webinar, a panel of experts came together to discuss common challenges in the mapping process and successful broadband mapping projects. Panelists included Jamie Hoffman, Program Manager at the West Virginia Department of Economic Development, Patrick Ryan, Senior Solution Engineer, Telecommunications at Esri, Tom Reid, President at Reid Consulting Group and me, Bryan Darr, VP of Government Affairs at Ookla.

You can watch the recording of the recent webinar here.

Bryan Darr is Vice President of Government Affairs at Ookla. He coordinates Ookla’s outreach to local, state and federal governments and serves on CTIA’s Smart Cities Business & Technology Working Group. This article was originally published on Ookla’s website on April 10, 2023, and is reprinted with permission.

Ookla retains ownership of this article including all of the intellectual property rights, data, content graphs and analysis. This article may not be quoted, reproduced, distributed or published for any commercial purpose without prior consent. Members of the press and others using the findings in this article for non-commercial purposes are welcome to publicly share and link to report information with attribution to Ookla.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to 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.

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.



The author of this Expert Opinion is Tom Reid, president of Reid Consulting Group.

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 The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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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.



Photo of Lori Adams of Nokia, Joe Valandra of Tribal Ready, Megan Beresford of Learn Design Apply, E.J. John of the American Indian Policy Institute (left to right)

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.

Wednesday, May 31, 2023 – Tribal Broadband Deployment

As the NTIA continues to issue awards from the first round of the $3 billion Tribal Broadband Connectivity Program, how are the funded projects progressing? How will they interact with the other ongoing broadband initiatives, such as the Middle Mile and Broadband Equity, Access and Deployment Programs?


  • 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

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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.



Photo of Jim Strizinger

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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