Doug Dawson: Will the FCC Maps Get Better?

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.

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