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'Tweaking a Broken System'

Shapefiles Broadband Mapping Draft Gets Kudos, Brickbats; Less Coverage Predicted

Proposed changes to how the FCC collects broadband deployment data should be some improvement over the oft-criticized Form 477-centric approach, though it also opens a potential can of worms with its crowdsourcing component, experts told us. Others see a catastrophic failure in the agency's not bringing retail pricing data into the mix. "It's tweaking a broken system," said Penn State telecom professor Sascha Meinrath. The proposal's on the FCC agenda for Aug. 1 (see 1907110071).

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Service territories of cable and fiber-to-the-home deployments would be much better defined under the Digital Opportunity Data Collection (DODC) proposal, though the shapefiles mapping wouldn't be watertight since there still would be occasional holes in ISPs' own data, said CCG Consulting President Doug Dawson. He said the biggest effect likely would be in suburbs and, especially, small rural towns. Counties seeking USF funding often also don't know exactly where service is available, and should have far more concrete data under the polygons approach, he said.

University of Virginia assistant professor Christopher Ali agreed shapefiles would be a big improvement over census block-based mapping and "a good working compromise." But he said the FCC is asking for questionably valuable information when providers are supposed to include areas they could cover within 10 days. He said puffed-up numbers are already a concern for many.

Even more significant is the FCC's pointing to a longer-term goal of address-based mapping, said NTCA Vice President-Industry Affairs and Business Development Mike Romano. He said ISP compliance with the shapefile approach likely won't be a bigger a burden than Form 477s are now, with many operators already having access to shapefiles. He said that approach also could ultimately alleviate work for providers by eliminating many of the false positives that cause disputes when the ISP is seeking universal service funding.

The FCC will have access to far more granular data via shapefiles submissions, but how it crunches that data and uses it in policy decisions on universal service will be just as important, said Steve Blum, president, California community broadband consultancy Tellus Ventures. That amount of data "is going to be really hairy to work with," he said. Crunching that amount of data wouldn't be difficult for Silicon Valley firms, but IT data capabilities of government agencies typically aren't on that level, he said. Meanwhile, companies looking to the map for market analysis would have to figure out how to reconcile census block-based demographic data with the new broadband availability data, he said.

For the FCC, broadband mapping is about how best to target its “scarce universal service dollars,” it said in the draft order. Under its DODC approach, fixed broadband service providers would have to submit to a Universal Service Administrative Co. portal maps showing where they have broadband-capable networks and make service available. Along with locations of service, providers would have to submit maximum download and upload speeds available there and what technology is used to provide the coverage.

Crowdsourced information on the accuracy of the maps also would be submitted to the USAC portal, the draft order said. The DODC order leaves in place "for now” Form 477 data collection, though it removes certain requirements. Under the draft, providers’ minimum advertised or expected speed data for mobile broadband would no longer be treated as confidential, saying it’s not competitively sensitive. Service providers would need to report 5G technology deployments as part of their Form 477 filings, it said.

The accompanying Second Further NPRM seeks comment on incorporating mobile wireless coverage data and location-specific fixed broadband deployment data already reported to the High-Cost Universal Broadband portal into DODC. It also asks whether rules are needed for reporting fixed wired broadband deployment that will give consistent results for similarly situated filers, and about routes to better satellite broadband data for purposes of the DODC. On crowdsourcing, it asks how quickly fixed providers would have to correct any data where they don’t refute the alleged lack of coverage and whether there should be a dispute resolution process if there’s a disagreement whether access is available. DODC eventually will replace Form 477, at least for granular deployment data, and the FNPRM asks about discontinuing the broadband deployment data collection part of Form 477.

The new FCC approach could face challenges on reporting speeds because speed can vary notably from one household to the next with technologies like DSL and fixed wireless, Dawson said. Crowdsourcing also has some inherent challenges and "is not going to be a panacea" but can at least let map users know about trends or a cluster of concerns in an area, Romano said. The FCC will have to take on advisement whether it adjusts the map based on crowdsourced input, or just flags an area as disputed, he said. NTCA will discuss crowdsourcing issues with the FCC up until the sunshine period, seeking clarity on how that input is to be addressed and incorporated, he said..

Penn State's Meinrath said the broadband mapping process needs to be led by researchers and scientists, with a focus on peer review and using the right tools. The lack of a pricing component is "mind-boggling" since price is the single biggest issue in broadband adoption, he said.

The U.S. spends substantially on universal service, and needs data on who's subscribing alongside who could subscribe, said Angela Siefer, National Digital Inclusion Alliance executive director. Connected to that is pricing data, she said. "If it doesn't happen with the cooperation of the ISPs, it's going to happen without their cooperation," perhaps in an independent, crowdsourced approach, she said.

It would be nice to click on a point on a map and get all the data one would want about available broadband service, including pricing, but "I'm not sure that's the FCC's job," said Tellus' Blum. Getting a definitive pricing figure is problematic because prices are "all over the map," he said.

Some experts said the shapefiles approach could make broadband deployment look like it's going backward, with it reflecting far more homes without access than currently estimated. NTCA's Romano said "a decent amount of census blocks" in rural America that today are listed as served aren't served in entirety.