Congressional Research Service, which provides such service to members of Congress, has outlined a host of potential issues with the Federal Communications Commission’s broadband mapping process and the Broadband Equity, Access and Deployment (BEAD) program, and made some suggestions of what Congress may have to do in response.

In an “In Focus” report on the impact of the FCC’s National Broadband Map on BEAD and its $42.5 billion dollars in broadband subsidies, CRS said that among the issues for states and smaller internet service providers are contractual obligations, the resources to challenge the FCC map, and the number of challenges already filed, and potential lawsuits.

The FCC recognizes that the map, a draft of which was released to the public, is an iterative process and sought input on where it might miss the mark on where broadband is and isn't.

The FCC has already received “thousands” of challenges from individuals, according to chair Jessica Rosenworcel.

Also: FCC Launches New Broadband Map

According to CRS, contractual issues involve states' use of data vendors, which may hinder their ability to challenge the FCC's map because if they have leased data they want to use to challenge, there may be use restrictions. “Thus, states may not end up challenging the National Broadband Map — or if they do challenge, they may violate their contract and face legal jeopardy,” CRS said, citing Montana Department of Administration chief data officer Adam Carpenter.

Carpenter also said some of those vendors may be concerned that the third-party vendor the FCC employed to help it come up with the map's location fabric could use that data for their own commercial purposes.

The resource challenge was illustrated by New York state’s October submission of over 31,000 unserved or underserved addresses that the map had not accurately identified. New York clearly had the resources to ferret those out, but CRS points out that other states don’t have such deep pockets. New Mexico, for example, signaled it did not have the staff to fix its map problems by January 2023. Without those fixes, it said, it could miss out on hundreds of millions of dollars in subsidy money.

Among CRS’s suggestions for congressional actions are hearings, potentially mandating an extension to the challenge process, and seeking comment on its eventual resolution of challenges.

The FCC has signaled it wants to resolve map challenges by early 2023 so NTIA can meet its June 2023 timeline for handing out subsidy money to states. NTIA has asked states and territories to submit their challenges by January 13, 2023. 

A bipartisan group of legislators has already reached out to the FCC and NTIA asking for that challenge extension.

The senators want the FCC to extend the deadline for challenges by “at least” 60 days — to March 14, 2023. ■

The bipartisan leadership of the Senate Commerce Committee wants stakeholders to have more time to challenge the accuracy of the Federal Communications Commission’s new broadband availability map given what they said were the "significant flaws" already discovered in the draft map.

That came in a letter Thursday (December 22) to FCC chair Jessica Rosenworcel and National Technology and National Telecommunications and Infrastructure Administration chief Alan Davidson from more than a dozen senators, led by Commerce Committee chair Maria Cantwell (D-Wash.) and ranking member Roger Wicker (R-Miss.).

Last month, the FCC released its first draft of a new broadband availability map meant to more accurately represent broadband coverage as the Biden administration pushes tens of billions of dollars toward its universal broadband pledge.

The agency has been working on gathering better data — officially its Broadband Data Collection (BDC) effort — under orders from Congress in the Broadband DATA Act and on its own dime.

The FCC has conceded the mapping is an iterative process that will be improved by stakeholder challenges.

The FCC was charged by Congress to come up with better maps and NTIA is supposed to use that information to hand out those tens of billions of dollars in broadband subsidy money targeted to where that money is needed most.

Also: FCC Unveils New Broadband Map

Given that dual FCC/NTIA effort, the legislators said, “it is absolutely critical that states, tribes, localities, and stakeholders have the necessary time to help ensure that the FCC’s final maps accurately reflect unserved and underserved areas.”

The senators want the FCC to extend the deadline for challenges by “at least” 60 days — to March 14, 2023.

The legislators cited some examples where the FCC maps don't jive with a Microsoft analysis of where broadband is and isn't, and are clearly troubled by the disparity. For example, they say, in Washington state, 60% of the residences and businesses in one town on Tribal lands were missing from the FCC map, while in Mississippi, the state broadband office says a “tremendous amount” of addresses were missing in “high-growth” areas.

“Based on this initial review, it is clear that states and local communities need more time to review and analyze the maps and submit challenges to the data than the six weeks (which cover the busy holiday season) currently provided,” the senators wrote. ▪️

Could complicated cartography interrupt the nation’s quest to close the digital divide? It certainly seems that way.

Last year, Congress passed the Infrastructure Investment and Jobs Act (IIJA), which included $42.5 billion for states to spend on broadband access through the Broadband Equity, Access, and Deployment (BEAD) Program. There was widespread concern, though, that existing FCC broadband maps did not show coverage in a way that made it possible to target subsidies to unserved areas.

Why does this matter? Because if an area is considered “served,” it won’t qualify for federal subsidies, and people who lack broadband access get left out. Hence the heated debates about the maps.

Congress thus ordered the Federal Communications Commission (FCC) to create much more detailed maps so that the BEAD money could be deployed where it is most needed.

But Congress’s order has an inherent flaw: The assumption that any single map can precisely and accurately display up-the-minute broadband coverage. Specifically, the order reveals three problems.

First, all data has errors. It is unavoidable. Even a completed map that happened to be correct for a moment would become immediately obsolete: New broadband deployments take place by the day, and thus a street that was previously offline could be online by the time you’re done reading this column.

Second, creating a map from data requires making assumptions, and those assumptions have policy implications. Consider the fundamental problem with the current FCC maps: If an ISP serves a single home in a census block, the entire block shows up in the public data as “served,” causing the map to overstate coverage. In a dense city, the block-level estimate of coverage is probably about right since census blocks can be as small as a single apartment complex. If one apartment in a building is served, odds are all the others are, too. But not so for rural or remote areas, where census blocks can stretch for miles. One little house on the prairie with coverage does not mean the others in the block have it.

Congress essentially ordered the FCC to minimize problems created by assumptions needed to aggregate data by collecting connectivity information on every home and business in the country.

Much like pulling up a blanket that’s too short to keep your face warm, thereby exposing your feet, increasing the granularity will result in a lot more errors in the data.

To its credit, Congress seems to have anticipated the existence of measurement error and included a challenge process to the maps in the legislation. This allows anyone to dispute the FCC’s coverage map in order to find and fix these errors.

But the challenge process reveals the third problem: Because money follows the maps, they are inherently political. Not surprisingly, even before the maps debut, everyone with skin in the broadband game is gearing up to contest them.

States want the maps of their territory to show lots of unserved areas in order to, as one consultancy put it, “make sure they don’t miss out on their rightful share of funding.” Internet service providers, meanwhile, are wary of areas they already serve showing up as unserved because a flood of federal funding into those regions threatens their business.

No matter how much effort the FCC puts in -- and by all accounts it has its collective nose to the grindstone -- the one-map-to-rule-them-all effort is an attempt to achieve the impossible.

What’s the alternative? First, we need to drop the belief that 100% accuracy is possible and also recognize that we don’t need a “map,” per se, but data on connectivity. Once we start thinking of it that way it becomes easier to understand that we’re not trying to make pretty pictures. Error and uncertainty are inevitable, but knowing something about that error helps us address it.

Better and more up-to-date information can come from harmonizing existing data sets about internet access, updated whenever a given map has new information. Private sector entities, think tanks, other federal agencies, and states themselves have spent years mapping digital connectivity. Blending those maps together will yield a more accurate picture of America’s digital divide than the FCC’s go-it-alone effort.

Indeed, that’s how third parties will contest the FCC’s maps: By using their own versions and crowing about the discrepancies. But this presents the FCC with an opportunity: Get ahead of those disputes by incorporating as much of that existing information as possible -- and creating a more accurate description of America’s coverage in the process. 

It is impossible to eliminate the political incentives, but a map derived from multiple sets of data will be better -- and less open to criticism -- than a single-source map built by one agency. Officially recognizing the benefits of third-party data and incorporating it in advance of the challenge process might help BEAD funding move forward and avoid years of unwinnable cartographic debates. ■

The vast majority of locations in New York State — 97.4% — are already served with high-speed broadband, raising the issue of just how much broadband subsidy money the Empire State will need from the tens of billions of dollars the Biden administration is putting toward closing the digital divide.

The 97.4% figure is according to the Broadband Assessment Program overseen by the New York State Public Service Commission. States were charged by Congress in the Comprehensive Broadband Connectivity Act of 2021 to conduct an annual assessment and map of broadband availability.

According to that report and map, 5,139,017 locations (97.4%) in New York are served by at least two providers with at least one of those offering high-speed service, defined as speeds of at least 100 Megabits per second downstream and 10 Mbps upstream. 

Also: FCC Slates Broadband Data Collection Webinar

Less than 1% (it does not even register on the above graphic), or only 5,997 locations, are consider underserved, defined as speeds “of at least 25 [Mbps] download but less than 100 Mbps download,“ and with only one ISP.

That leaves 132,601 locations, or 2.5%, unserved, which is defined as having either no fixed wireless service at all, or service “with speeds of less than 25 Mbps download available.“

All those definitions were assigned by the New York State Legislature.

The availability map drew from four data sources: 1) the New York State “Street and Address Maintenance (SAM) Program” for the location fabric; 2) data collected from ISPs; 3) a “Fiber Optic and Coaxial Asset Inventory Program;” and 4) input from the public and other stakeholders.

In a story about the new map, WGRZ Buffalo reported that some of the ISP data comes from the FCC’s Form 477 collection, which has been highly criticized and is still in the process of being revamped.

The PSC did field testing in some of the remotest areas to fact check the ISPs, but the station's consumer reporters said they clearly found some gaps in the numbers.

The PSC provided this caveat about the ISP numbers: “The information contained in this Map has, in part, been collected from ISPs operating in New York who were asked to provide reasonable representations of their respective internet service areas. Determining each ISP‘s service area without a field inspection verification of every address may yield discrete inaccuracies, and while the Department conducted field inspections in the most remote areas of the State of New York to corroborate information received from the various ISPs, it was not feasible to verify 100% of the addresses in the field.” ■

In a victory for local broadcasters, the Federal Communications Commission has decided not to make stations shoulder some of the costs of the agency’s congressional mandate to collect better data on broadband, but, for now, it won't make Big Tech pay a user fee for the benefit tech companies receive from unlicensed spectrum or FCC-administered broadband subsidies.

White the FCC sought more input on a Big Tech fee, it raised some issues that signaled that would be a hard hill to climb.

That came in the FCC's order — plus accompanying notice of proposed rulemaking (NPRM) — setting the regulatory fees it charges the various communications services it oversees.

Also Read: NAB's Gordon Smith Urges FCC to Reverse User Fee Hike

The National Association of Broadcasters, joined by all the state broadcast associations, had pushed back hard on the FCC's proposal to include broadcasters in those who would have to help cover the $33 million Congress told the FCC to spend from its 2021 fee collection to cover the costs of implementing the Broadband DATA Act.

They said that the 5% to 15% fee increase the FCC was proposing was in part due to the regulator having to cover that $33 million earmark, since the FCC was also predicting its expenses would only be going up by 5%.

The FCC supports its ongoing operations by user fees and auction proceeds.

In setting the 2021 fees, the FCC said that it had decided to "adjust" that approach given the unusual circumstances of the one-time $33 million earmark.

The NAB had argued that the $33 million should not be considered an overhead [indirect] cost defrayed over all the communications services because they pertained only to certain of those services and only some of the FCC's core bureaus, i.e. broadband providers.

The FCC said it still considered it an indirect cost, but that “given the one-time nature and magnitude of the earmark, the statutory text, the legislative history, and the record in this proceeding, we exclude one group of regulatees — broadcasters or ‘Media Services’ licensees — from their share of these indirect costs.”

The NAB praised the course change.

“NAB greatly appreciates the FCC’s efforts to revise its original regulatory fee proposal that would have required local radio and television broadcasters to subsidize unrelated work at the Commission,” senior VP Ann Marie Cumming said. “The change is not only the right outcome, but critical to the many broadcasters’ ongoing service to their local communities.”

The NAB had also asked the FCC to make Big Tech companies pay user fees since they derive great benefit from unlicensed spectrum.

Also Read: House Bill Would Make Streamers Pay into Broadband Subsidy Fund

The FCC did not do so, but in a separate NPRM, it sought input on how it might do so, asking the following (while signaling some issues that would have to be addressed, like the impact on a multitude of consumer tech companies): “What would be the proposed methodology for assessing regulatory fees on unlicensed spectrum users? We note that unlicensed spectrum users include a significant number of equipment manufacturers, such as appliance and other home goods equipment, many of which neither apply for nor require authorization by the Commission. Commenters should also explain, to the extent they advocate imposition of regulatory fees on either a subset of users or certain entities benefitting from such use, how to define any new fee category and how to calculate and assess such fees on an annual basis. Alternatively, should the Commission assess regulatory fees on large technology companies based
on a different basis, such as any advantages they receive because of the Commission’s universal service or other activities?”

The FCC oversees a Universal Service Fund (USF) that provides billions of dollars in subsidies for broadband services, and is also overseeing implementation of the Biden Administration's billions of dollars in COVID-19-related broadband subsidies and efforts outside the USF to close the digital divide.

Broadcasters this month pressed the FCC to change course and not force TV and radio stations to pay for a portion of the FCC broadband data collection, from which they said they derive no benefit.

The National Association of Broadcasters, in meetings with the FCC's Office of Managing Director, said that should only make regulated industries pay user fees on activities that have at least minimal relevance to that industry.

Also Read: NAB Says No More Regulatory Free Ride for Google, Facebook

"[F]orcing broadcasters to subsidize over 15% of the costs of the Commission’s
broadband mapping activities – from which broadcasters undisputedly receive no benefit – is fundamentally unfair and runs contrary to the public interest in ensuring that broadcasters can continue to effectively serve the needs of their local communities," they told the FCC.

The FCC supports itself through annual user fees levied on broadcasters and cable operators and satellite operators and their use of licensed spectrum. The fee is calculated according to how many full time employees (FTEs) are employed to regulate the various services.

Also Read: Broadcasters Tell FCC to Leave Satellite Fee Alone

NAB has been arguing that the FCC has boosted their fees to "unsustainable levels," in part thanks to its decision to require broadcasters to pay for some of the added funding Congress has said the FCC needs to use to create better broadband maps, maps it said have zero to do with their service.

Cable broadband operators represented by NCTA-the Internet & Television Association, are no fans of the Biden Administration's new broadband mapping tool, which was unveiled by the National Telecommunications & Information Administration last week.

NTIA billed it as the first interactive map showing "key indicators of broadband needs across the country," combining data from different public and private sources aggregated at the county, census track and census block levels.

The goal said NTIA is to "illustrate the reality that communities experience when going online, with many parts of the country reporting speeds that fall below the FCC’s current benchmark for fixed broadband service of 25 Mbps download, 3 Mbps upload."

But NCTA said the picture is far from reality.

Also Read: FCC, NTIA Team on Spectrum Research

“NCTA has long supported federal efforts to create a reliable, accurate broadband map and we have been working with the FCC on its implementation of the Broadband Data Act," the NCTA said. "Unfortunately NTIA has obscured, rather than clarified, the true state of broadband with this mashup of disparate, and often inaccurate, data sources. In particular, any suggestion that data from M-Lab or Microsoft accurately represents the speeds delivered by cable operators is demonstrably false.”

Richard Bennett, founder of High Tech Forum, said that while the map has some value for digital inclusion activists, it tried "to do too many things," and agrees with NCTA that the M-Lab and Microsoft data are unhelpful.

"Overall, I suspect the Indicators of Broadband Needs tool will further confuse the digital divide debate by introducing bad data to a wider audience," said Bennett.

He said the data doesn't answer questions of how to reach communities with limited interest or ability to use broadband, not because it is a bad map but because the data is already out of date.

Bennett said the digital divide is actually two divides. In unserved areas, nobody can buy high quality at any price, which is a civil engineering problem that Congress loves because the answer is to throw money at it. The other divide, and the bigger problem, is that "for every one person who can’t buy broadband there are two unconnected people who could get it today if they had the means and the interest to do so," he said.

That is a social problem, said Bennett, which Congress hates because it is "messy and complicated."

Microsoft had not responded to a request for comment at press time. M-Lab was not reachable for comment.

Rep. Antonio Delgado (D-N.Y.) has introduced one bill that would require both better broadband speed measurement and tie funding to higher speeds, and re-introduced another to fund challenges to FCC broadband deployment data.

The Broadband Speed Act would require ISPs to report accurate speed data to the FCC on an annual basis. The bill defines accurate speeds as "the actual speeds they are capable of providing, as opposed to what they can potentially provide within 7-10 business days," as the current speed standard allows.

Also Read: Sen. Wicker Wants FCC Oversight Hearing on Broadband Mapping

He said the law will help demonstrate to the FCC where broadband service is matching advertised speeds. And just for good measure, the law would also require that any new FCC broadband funding for deployment require speeds of at least 100 Mbps "to ensure they are built to last."

The Biden Administration has made "future-proofing" broadband buildouts one of its mantras as well.

The second bill, which is co-sponsored by Republican Rep. David McKinley of West Virginia, would improve broadband mapping, something Congress and the FCC have been trying to do for some time. 

The Community Broadband Mapping Act would allow local governments, utility cooperatives, community groups, small ISPs and others to use USDA Rural Utility Service (RUS) grant money to collect broadband coverage data that it could use to challenge any incorrect designations by the FCC.

Also Read: FCC Launching Public Input Mapping Tool

“Flawed service maps compiled by the FCC paint an inaccurate picture of upstate broadband access,” said Rep. Delgado, something the FCC has conceded. Delgado called the bill, and its help with challenges to FCC data, a first step to secure affordable broadband.

"Reliable access to the internet remains a necessity for all Americans no matter where they live," said Rep. McKinley. "Without maps that provide an accurate assessment of internet connectivity, we can’t target resources correctly to parts of the country that need help. This bill will help address this continuing problem."

Sen. Roger Wicker (R-Miss.), ranking member of the Senate Commerce Committee, has called on Committee Chair Maria Cantwell (D-Wash.) to hold an FCC oversight hearing with the FCC commissioners and acting chairwoman Jessica Rosenworcel within the next month focused on broadband mapping.

Also Read: FCC Launching Public Input Mapping Tool

Wicker is looking for a timeline from the FCC, an issue that came up in a hearing earlier this month on "Recent Federal Actions to Expand Broadband: Are We Making Progress?"

At the hearing, both Cantwell and Wicker expressed their hopes that the FCC could get out better maps on where broadband is and isn't as soon as possible, with Wicker saying that Congress was just looking for guidance on how it could help speed that timeline.

At the March 17 hearing, after Wicker had said Rosenworcel recently said a mapping revamp would not be completed until 2022, Cantwell said that she had had a conversation with the acting chairwoman and Rosenworcel had "intimated she thought it was a four-month answer on the mapping."

Wicker referenced that conversation in his letter to Cantwell asking for the hearing, a copy of which was obtained by Multichannel News.

He also pointed out that he and other Republicans had sent a letter to Rosenworcel  asking about her plans and timelines, but that the response they got "simply gave a broad overview of the process of developing new maps, without any target completion date."

"I hope you and I can work together to compel the FCC to address this issue quickly," he told Cantwell. "I am therefore requesting that the Committee hold an FCC oversight hearing within the next month." 

Last month, Rosenworcel created a Broadband Data Task Force to implement "long-overdue" improvements to the commission's broadband mapping and data collection. She has long argued that the FCC should put maps before money when it came to handing out billions of dollars to subsidize broadband service.

FCC acting chair Jessica Rosenworcel said the FCC will be launching a new broadband mapping tool that will allow consumers to weigh in on where broadband is and isn't, information that will be shared with the Broadband Data Task Force.

That task force was formed last month to coordinate the FCC's implementation of a congressional mandate to collect and verify data about broadband availability.

In a new blog post, Rosenworcel outlined the steps she has already taken to collect better data so the FCC can get broadband subsidy dollars to where they are needed most.

In a letter last week, Republicans called on Rosenworcel to get moving on better mapping, but her blog indicates she has already been there and is doing that. Her goal: "a publicly accessible, data-based nationwide map of locations where broadband is truly available throughout the United States."

She has not put a timetable on the effort, though when her predecessor, Ajit Pai, was being pressed for better data, she said though improvements could be made in 3-6 months.

That was also Congress' goal in the Broadband Deployment Accuracy and Technological Availability (DATA) Act, which Republicans have pointed out passed a year ago. Of course, Rosenworcel has only been in the FCC's center seat for a few weeks and Congress only appropriated the funds to overhaul the FCC's broadband data collection late last year.

But in her few weeks as acting chair, she says she has already "procured an expert data architect and design firm to work with the Commission’s own data and IT systems specialists" to design a "complex web of databases, systems and public-facing portals that can support the new Broadband Data Collection data and the several public-facing maps we will generate" and has put out a request for information to "jump start" contracting for creating "the Broadband Serviceable Location Fabric," a common dataset of all locations in the United States where fixed broadband internet access service can be installed."

Rosenworcel said that will be a key to creating "an accurate and comprehensive picture of the availability of fixed broadband service throughout the country."

A bipartisan group of senators has sent a letter to that body's leadership from both parties asking that Congress fully fund already-passed legislation that mandates a suspect network tech rip-and-replace program and better FCC broadband mapping.

Sens. Roger Wicker (R-Miss.), chairman of the Senate Commerce Committee; Deb Fischer (R-Neb.), Jerry Moran (R-Kan.), Todd Young (R-Ind.) and Marsha Blackburn (R-Tenn.) were the lead names on a letter joined by over a dozen more Senate colleagues seeking funding for the Secure and Trusted Communications Networks Act and the Broadband DATA Act.  

Related: Senate Bill Would Boost Rip-and-Replace Eligibility

"Congress needs to ensure Americans have access to secure connectivity. Providing funding for rip and replace and broadband mapping will help achieve this goal," they wrote. 

Outgoing FCC Chairman Ajit Pai has also been pushing Congress to come through with the money for mapping and to help smaller operators deal with the expense of ferreting out and replacing network tech from suppliers like ZTE and Huawei, the first two to be classified as network security threats in need or eliminating.

The senators point out that closing the digital divide depends on knowing where broadband is and isn't, which is why better mapping is imperative.

Also signing the letter were Sens. John Barrasso (R-Wyo.), Richard Burr (R-N.C.), Benjamin Cardin (D-Md.), John Cornyn (R-Tex.), Kevin Cramer (R-N.D.), Mike Crapo (R-Idaho), Steve Daines (R-Mont.), Angus King (I-Maine), David Perdue (R-Ga.), James Risch ( R-Idaho), Pat Roberts (R-Kan.,) Tim Scott (R-S.C.), and Chris Van Hollen (D-Md.).

“I strongly agree with the 18 bipartisan Senators, and especially Chairman Wicker, for their letter urging Senate leadership and appropriations leadership to provide full funding for the Secure and Trusted Communications Networks Reimbursement Program and to implement the Broadband DATA Act," said Competitive Carriers Association President Steven K. Berry. "The Reimbursement Program is vital not only to national security, but also to small, rural telecommunications operators – many of whom provide the only service to customers in their respective areas.  Having to replace affected equipment is a massive financial and personnel undertaking, and carriers depend on congressional funding to continue to provide critical mobile broadband services to their customers.

"Additionally, I couldn’t agree more that the Broadband DATA Act should be funded to ensure more accurate broadband maps.  More accurately identifying unserved and underserved areas will help close the digital divide and will help ensure that every American, no matter where they live, work, or travel, can access necessary mobile broadband services.”

Rep. Mike Doyle (D-Pa.) said that a lot of ISPs, "for whatever reason," claim they have service where they don't, something he said everyone knows "has been going on for years." 

Doyle, chairman of the House Communications Subcommittee, was being interviewed for C-SPAN's Communicators series about why the FCC's broadband maps, which rely on carrier data, have not yet gotten fixed. 

Related: House Democrats Update Broadband Deployment, Adoption Plan 

He said that since Democrats and Republicans agree the maps aren't good, the FCC would just be throwing $20 million out the window by starting to give out most of the Rural Development Opportunities Fund (RDOF) subsidy money. 

FCC chairman Ajit Pai argues that delaying those subsidies would mean taking longer to close the digital divide, and that the initial $16 billion is going to areas identified as unserved, while the issues with the maps are about failing to get money to unserved areas because they are identified as served. 

But Doyle said it was mind-boggling that "given the technology and abilities we have today," he didn't know why the FCC did not have accurate maps" to direct the "precious dollars that aren't growing on trees." 

On closing the homework gap, Doyle pledged that any COVID-19 aid package that moves out of the House would include money for schools and libraries. He said there is bipartisan support for boosting distance learning but that the issue comes down to dollars and how to pay for it, which is usually where the bipartisanship breaks down.  

Democrats want to put $9 billion toward closing the homework gap. 

Doyle's Communicators interview airs on C-SPAN Saturday (July 11) at 6:30 p.m. ET, and on C-SPAN2 Monday (July 13) at 8 a.m. and 8 p.m. ET. 

As FCC chairman Ajit Pai signaled at a Senate Commerce oversight hearing June 24. The FCC will vote next month on implementing the Broadband DATA Act. The act, which passed in March, directed the FCC to collect better data on where broadband is and isn't deployed.  

In a blog outlining the July 16 public meeting agenda, the chairman said that the digital divide can't be closed until the FCC can get that better data, adding that better maps will also be needed to give the public confidence that the divide is being closed. 

Related: House Republicans Push for Broadband Mapping Bucks

He said that Congress was essentially ratifying the FCC's Digital Opportunity Data Collection to collect that better data, launched in 2019. He says that effort will provide maps with unprecedented detail.  

Pai said that the item at the July meeting will combine a Second Report and Order and Further Notice of Proposed Rulemaking that will adopt "specific coverage reporting and disclosure requirements" for both fixed and mobile broadband ISPs. He says it will spell out certification requirements and the metrics for insuring the accuracy of availability data.  

Pai: FCC Needs Mapping Funding From Congress ASAP 

In addition it will have a a process for getting input from states, localities, and Tribal governments, as well as consumers and other stakeholders to make the maps "as accurate as possible." 

Pai also points out that Congress will need to provide at least $65 million to get the maps "off the ground."  

House Energy & Commerce Committee Republican leaders are urging their colleagues to fully fund the FCC's congressional mandate to collect better broadband deployment and availability. 

The President signed the Broadband DATA Act back in March. That law directs the FCC to collect that data--the FCC was independently at work on improving data collection.  

Pai: FCC Needs Mapping Funding From Congress ASAP 

In a letter to Appropriations Committee chair Nita Lowey (D-N.Y.) and ranking member Kay Granger (R-Texas), House Energy & Commerce Committee ranking member Greg Walden (R-Ore.) and Bob Latta (R-Ohio) cited the COVID-19 pandemic as a big reason the FCC needs the funds for better broadband mapping, which is key to bridging the digital divide.   

"Closing the digital divide and promoting broadband deployment have long been bipartisan priorities and funding the Broadband DATA Act will improve those efforts,” they wrote. 

FCC chairman Ajit Pai is praising the President's signature on the Brodaband DATA Act, but suggested, as he has in the past, that without Congress' signature on some checks to pay for it, the legislation will hurt, not help, better broadband availability mapping. 

That came in a statement on the Act's official debut as law late Monday (March 23). 

Related: Pai Says FCC Lacks Resources to Implement Broadband Data Act 

The Act requires the FCC to collect more granular data on where broadband is and isn't and to "establish a process to verify the accuracy of such data." 

"I applaud the President for signing the Broadband DATA Act and thank the leadership of the Senate and House Commerce Committees for their bipartisan work in moving this legislation through Congress," he said. He also said it confirmed the FCC's Digital Opportunity Data Collection approach, already in progress, to come up with more granular data that can be vetted by the public. 

But he said it is imperative that Congress provide the appropriations necessary to implement the act ASAP, as he pointed out he has warned "for some time." 

The Act prohibits the Universal Service Administrative Company, which is already funded, to carry out the mapping Congress requires. Given that, said Pai, "if Congress does not act soon, this well-intentioned legislation will have the unfortunate effect of delaying rather than expediting the development of better broadband maps."

Jonathan Spalter, president of USTelecom, agreed it was time to free up the funds.

“At a time when the nation is collectively relying on its communications infrastructure more than ever, and the indispensability of broadband to families, businesses and educators is coming into full view, modernizing our broadband maps to increase connectivity and narrow the gaps in rural America couldn’t be more necessary," Spalter said.  

“This was a bipartisan effort from start to finish and it shows in the final product. USTelecom members are proud to have played our part in helping to shape this game-changing mapping plan," he added. "Next step: Congress should fully fund this data-driven project so that future federal broadband spending in our nation will be based on the most accurate and granular map we’ve ever had. That’s a big deal.”

The Trump Administration's chief communications policy arm says it has completed a pilot version of the updated National Broadband Availability Map Congress directed it to produce. It is not available for public perusal, though NTIA did provide the above graphic showing the states participating in the pilot. 

The National Telecommunications & Information Administration, part of the Commerce Department, says it will use the pilot to "test the map’s functionality and expand it to other states." 

But NTIA suggested "map" does not do it justice, calling it a "GIS (geographic information system) platform for the visualization and comparison [of various data sets]." 

Congress provided funds for the update, which was done in coordination with the FCC.  

Legislators on both sides of the aisle have complained about FCC data that shows broadband where it isn't. 

The pilot includes data from eight states--California, Massachusetts, Maine, Minnesota, North Carolina, Tennessee, West Virginia, and Utah--as well as federal and commercially available broadband availability data. 

The FCC has its own fixed broadband deployment map, but NTIA says its "map" goes beyond that "form 477" data on fixed broadband deployment--data supplied by carriers--to other data sets--federal and non-federal, with more to be added.  

FCC chair Ajit Pai has acknowledged the need for better tools to collect data about broadband deployment and to improve the current Form 477 reporting process. 

The NTIA map is not available to the public because it includes competitively sensitive non-public data, but eventually a public and non-public version of the final product will be provided. 

The FCC has take the first step toward providing more accurate data on where broadband is, and isn't.

The commission has been under pressure from both sides of the aisle in Congress to improve data collection, and FCC chair Ajit Pai has conceded the data has to get better, particularly so that Universal Service Fund broadband subsidies can be targeted to where they are most needed, furthering his goal of weeding out waste, as well as fraud and abuse, in subsidy programs.

The commission voted unanimously, with two partial dissents by the Democrats, on a Report & Order Thursday (Aug. 1) to create a new Digital Opportunity Data Collection regime based on geospatial broadband coverage maps provided by fixed Internet service providers--it does not apply to mobile broadband, at least not yet.

The Universal Service Administrative Company (USAC) will be charged with the new data collection, and will have to create a portal for collecting the carrier data and allow for crowdsourced challenges to the maps.

Related: Free Press Optimistic About FCC Broadband Data Update

For the time being, the FCC will also continue to collect form 477 data based on census blocks, but at the same time will require fixed broadband suppliers to also provide coverage maps based on shapefiles (in this case the shape is a polygon), which NCTA-The Internet & Television Association had proposed.

NCTA had also suggested retaining the census block-based 477 reporting in the interim so the FCC could still do an apples-to-apples comparison of deployment trends "not associated with the shift in reporting methods."

“Today’s FCC action to improve its broadband data collection practices is a significant victory for consumers that will meaningfully improve the accuracy of broadband maps and enable the Commission to more efficiently target resources to areas that lack broadband access," said NCTA. "Our industry is committed to quickly moving forward with providing the Commission the more granular data and will continue to work with policymakers on solutions that will connect all Americans to the internet.”

USTelecom had wanted the FCC to implement a database of broadband-addressable locations, or what USTelecom called a “Broadband Serviceable Location Fabric” overlay at the same time so the FCC could better pinpoint how many and exactly where service wasn't available. The FCC likes the fabric idea, but said it did not want to wait until that database was developed and its data set of structures and locations served and unserved was available before it started collecting the polygonal shapefile data.

“The Rural Digital Opportunity Fund is a once in a generation opportunity to expand broadband service, and today the FCC made clear it should be governed by the best and most granular broadband availability maps we can deploy," said USTelecom President Jonathan Spalter. "We all know we have to get this right, and that is why we are excited to work with the Commission in nailing down the critical next steps and sequencing to ensure broadband support can be directed to rural communities and enterprises as quickly, efficiently, accurately, and sustainably as possible.”

The FCC will also establish a mechanism for the public to crowdsource the accuracy of the maps. NCTA has said that should only be a supplement to the process. "[T]he Commission will need to determine under what circumstances the results of such testing would be relevant in the proposed crowdsourcing process," NCTA blogged before the decision.

The FCC is asking about how to implement USTelecom's overlay "fabric." NCTA said that is worthy of consideration, but that the "suggested benefit comes at a significant financial and administrative cost to the Commission and providers and there are numerous questions about whether, and how, it will work in the real world. 

In addition to the R&O, which is a final decision, the FCC approve a Further Notice of Proposed Rulemaking seeking comment on whether it should sunset the for, 477 collection, how it can apply the regime to mobile, and technical standards for carriers that might help them supply more precise data. 

NCTA is advising the FCC not to dramatically expand the data collection, saying that the FCC "shouldn't let the mythical perfect in mapping be the enemy of the very good in identifying the unserved."

Chairman Pai framed the new broadband mapping effort as "identifying the declining the number of people without access" by going beyond the census-block level reporting instituted by his predecessors. He said a key is to no longer identify a census block as served if only one person in that block is served. He said it would paint the clearest picture yet of who has broadband and who doesn't.

"[T]oday, we get rid of the Christmas tree and stop driving the Pinto. We’ve heard the message loud and clear that these data sets are no longer good enough," said commissioner Brendan Carr. He said no nibbling around the edges would do and the FCC was starting over. "It is time to kick the Christmas tree to the curb," he said. 

Commissioner Jessica Rosenworcel agreed: "today’s effort to improve the data collection that informs our nation’s broadband maps comes not a moment too soon. Bring it. We need to fix this mess." Rosenworcel dissented in part, however, because of various flaws she saw in the item. One was that the item did not address the existing National Broadband Map. Another was giving USAC the responsibility of overseeing the maps.

But she applauded the effort as a start, and for its use of crowdsourcing.

Commissioner Michael O'Rielly also had problems with USAC overseeing the collection given its work load and his longstanding concerns with USAC's competency and transparency--he has proposed outsourcing USAC's functions.

Commissioner Geoffrey Starks was generally supportive, saying it was a "nudge" in the right direction, but also had issues. “I believe that the order and NPRM, by adopting shapefile reporting and by proposing to create a broadband location fabric, asks many of the right questions as it begins the process of establishing the Digital Opportunity Data Collection. However, while the item makes a few relatively minor fixes to the Commission’s Form 477 data collection, it does not address the most glaring problems with it.”

“The FCC has taken a good first step toward improving the accuracy of its broadband-deployment data," said Free Press research director S. Derek Turner. "The new Digital Opportunity Data Collection process should address the most common complaint about past agency mapping efforts: the potential for overstating deployment in certain rural areas. Free Press has long called for better broadband deployment data from the FCC, and we’re cautiously optimistic that today’s reforms will enhance accuracy while maintaining the public’s full access to this critical information."

"We’re pleased to see the FCC today take a step forward on improving the accuracy of broadband mapping," a Microsoft spokesperson said. "The measures proposed around granularity, leveraging crowdsourcing to obtain additional data including usage information and related efforts to improve accuracy closely mirror our suggestions. If fully enacted, this should provide a more accurate view of where coverage is still lagging and enable the FCC to provide funds that ensure the areas that most need support are receiving it." But the company also says there is more work to be done.

"[W]e encourage the FCC to take the opportunity to improve Form 477 [the current broadband data collection framework]. It’s important that the most accurate data methodology is used to distribute funds and assess progress. We encourage the FCC to act to bring this into alignment, and Congress to continue its work on proposedlegislation that also addresses these important issues. "

“ACA Connects has long agreed with the FCC and many Members of Congress that the FCC’s current broadband deployment data collection needs to be improved by making it more granular and accurate," said ACA Connects President Matt Polka. "At the same time, any new collection requirements should not swamp the many hundreds of small broadband providers that must file with new obligations they are simply not equipped to handle. Based on those objectives, ACA Connects believes today’s action by the FCC, requiring broadband providers to file geospatial coverage data and enhancing this information with crowdsourcing, is a reasonable step forward. That said, the FCC now needs to get the details of the collection correct, including by ensuring smaller providers can easily comply.”

A bipartisan quartet of senators has introduced the latest effort to produce better data on where broadband is and isn't deployed, and it would rely on the shapefiles (a vector data format for storing geographic location information) cable op ISPs say is the way to go. The internet of things world has put a premium on such deployment because it considerably deepens the digital divide. 

Everyone is pretty much in agreement that the current data is seriously flawed--legislators at an oversight hearing used even stronger language--but what to do about it is the sticky wicket. 

Related: NCTA Defends Mapping Proposal 

Sens. Shelley Moore Capito (R-W.Va.), Brian Schatz (D- Hawai‘i), Jerry Moran (R-Kan.), and Jon Tester (D-Mont.) have taken a shot at it via a new bill with a self-explanatory title, the Broadband Data Improvement Act. 

The bill would require more accurate and granular data--both high on the list of the FCC and Congress--and subject that data to an "ongoing and multi-faceted challenge, validation, and refinement process." 

Accruacy would come from replacing form 477 data collection with shapefiles that indicate "actual network coverage." 

Validation would come from: 

1. "The collection of public feedback regarding the accuracy of the map, obtained via a new feedback tool that will be integrated into the online mapping platform.

2. "The acquisition of third-party commercial datasets on broadband availability that areanalyzed and compared against provider-reported data.

3. "Targeted on-the-ground field validation of services in areas where public feedback andthird-party data suggest the map is incorrect."

There would be a periodic challenge process for the public and ISPs to challenge the map created by those shapefiles, with the FCC resolving any challenges and updating the map as needed.  

Federal agencies--USDA, NTIA, FCC--would have to use the map to identify unserved areas and track awarded funds and smaller providers who can't afford the shapefile process would get help to make sure their numbers are as accurate as possible.  

A "Charter" member of NCTA-The Internet & Television Association, which pushed the shapefile approach to better data, was singing the bill's praises.  

“Charter applauds Senator Capito, Senator Schatz, Senator Moran, and Senator Tester for introducing legislation that would make national broadband mapping more accurate and granular and help close the digital divide, especially in rural areas," said the company in a statement. "For policymakers and those without broadband, obtaining accurate mapping information in a timely manner is incredibly important to ensure resources go to those in most need. Senator Capito’s bill which is informed by pilots that use shapefile methodology, will allow policymakers to quickly and cost effectively direct funds to those unserved areas that need it the most.”

“In order to bridge the digital divide, public and private partners need access to accurate and granular data," says Connect Americans Now (CAN) Executive Director Richard Cullen. "We applaud Senators Capito, Schatz, Moran and Tester for their continued focus on developing a more complete understanding of the digital divide impacting rural families."

Can took the opportunity to plug freeing up spectrum in the TV band for wireless broadband.

“[A]ccurate data alone will not connect rural America. While we urge the FCC to continue working with rural champions in Congress to improve its broadband maps," Cullen says. "It is also critical that we continue tearing down the regulatory barriers holding back TV white spaces technology and other innovative solutions that allow internet service providers to deliver broadband to rural consumers at a sustainable price."

“We are excited to see Senators Capito and Schatz introduce this critical measure to help bring the scope of the digital divide into clearer focus," said Morgan Reed, president of ACT | The App Association. "Reasonable minds differ on how best to deploy broadband infrastructure to connect the millions of Americans who currently lack a connection, but we can all agree that policy options must be informed by accurate, granular data. This legislation takes positive steps toward developing a more precise national broadband coverage map.  

“Our member companies make innovative devices and applications across all sectors—from smart agriculture to connected health—that require strong, reliable broadband connections by any means available. However, it is difficult to bring these technologies to market in areas of the country lacking this access and doubly so when the federal government’s support mechanisms are based on broadband maps that are inconsistent with the reality on the ground for our members, their employees, and customers. We look forward to working with the Senators on this issue.”

There was more evidence Thursday (May 9) that one thing Washington can agree on is that there needs to be better data on where broadband is and isn't.

Reps. Bob Latta (R-Ohio), ranking member of the House Communications Subcommittee, and Peter Welch (D-Vt.) have introduced the Broadband Mapping After Scrutiny (MAPS) Act 

The bill would create a challenge process to verify fixed and mobile broadband service coverage data, as there currently is for handing out some broadband subsidies, and would require data to be verifiable, but does not explain how that would happen.

“Our communities know better than a map if they have access to fast, reliable broadband,” said Latta. “While we know these broadband maps are inaccurate," said Latta, "there currently isn’t a way for local governments to challenge them -- the Broadband MAPS Act would change that, making it easier for unserved and underserved communities to make their case to the FCC. Better maps mean better broadband availability.”

Related: Senate Looks into Broadband Mapping Issues

Welch sounded like he was trying to convince a dataholic to get treatment. "It is essential that broadband maps accurately depict broadband deployment, especially in rural areas,” he said. “The first step in solving a problem is admitting there is one."

The bill says that "Not later than 6 months after the date of the enactment of this Act, the Commission shall initiate a rulemaking to establish a challenge process to collect and use fixed and mobile broadband service coverage data submitted to the Commission by private entities and State, local, and Tribal government entities to verify fixed and mobile broadband service coverage data reported to the Commission by fixed and mobile broadband service providers."

The bill will include standards for "consistent and accurate" reporting methods and a way to validate the accuracy of the data submitted.

FCC Chairman has conceded the FCC needs better data and a better process than the one that, he pointed out as recently as Thursday, he had inherited when he got the job.

The FCC was bitten by its current broadband data collection regime when it released a draft deployment report based on wildly overinflated figures for one carrier, though the FCC said the corrected report still showed gains.

THe FCC is currently collecting comment on improving broadband data. USTelecom and NCTA-The Internet & Television Association have both offered up competing proposals on how to gather more granular, and thus more accurate, data.

NCTA-The Internet & Television Association is telling the FCC that perfect broadband mapping in the future is the enemy of good data now, or at least sooner if the FCC adopts its proposal. 

That came in NCTA's response to telco ISPs who have proposed a different approach to improving the mapping of where broadband is and isn't, something cable and telco ISPs, the FCC and Congress all agree it needed.  

NCTA is proposing using shapefiles rather than census blocks as the units for measure for broadband availability. It argues shapefiles provide more granular data, something everybody is also looking for, than the census block approach the FCC is currently using. NCTA says the key advantage is that "unserved areas within served census blocks would no longer be counted as served." 

Related: NCTA Outlines Mapping Proposal

The Broadband Mapping Consortium--comprising USTelecom, ITTA and WISPA--has told the FCC that in NCTA's proposal the resulting data aren't sufficiently accurate. 

In a gentle dismissal of NCTA's entire framework, the consortium told the FCC in an April 12 letter.

"We appreciate the cable industry's thoughtful suggestions," they said, [h]owever, their proposed alternatives lack the key unifying component that the Broadband Mapping Consortium is looking to address in its pilot program, a process that will create more accurate broadband location data that, in turnn, will support far more meaningful and useful broadband availability reporting for communications policy." 

"Horsefeathers," replies NCTA, or the regulatory filing equivalent.  

"As a threshold matter, it is important to put the issue of accuracy into perspective. A consistent theme in the BMC Letter is that only through the use of a yet-to-be-created common template for geocoding locations can broadband data collection and mapping be accurate," NCTA says. "But somehow the imperfect GIS [geographic information system] tools that exist today are powering a wide variety of services, like Airbnb and Zillow, that may not be 100% accurate but nevertheless deliver substantial value to society. Rather than waiting around for a theoretically perfect approach to broadband data collection to materialize, the Commission should move forward with structuring a program that is tolerant of the imperfections that are inherent in any data exercise of this magnitude." 

Beyond that data imperfection issue, NCTA says the coalition has made no convincing argument for any "serious shortcomings" to its approach. 

The FCC is collecting comment on ways to collect better (form 477) data on fixed and mobile broadband availability. It has been under the gun to get a better handle on where broadband is and isn't, since that determines whether it is closing the digital divide generally, the rural digital divide in particular, and whether it is deploying advanced communications in a reasonable and timely manner, which the FCC recently concluded is the case.

The Senate Commerce Committee held a hearing Wednesday (April 10) on an issue that has been heating up over the past few weeks--how the FCC collects and maps data on the availability of broadband connectivity.

Commerce Committee Chairman Sen. Roger Wicker (R-Mass.) said it was crucial to have accurate broadband maps on where broadband is and isn't available at certain speeds if the country wants to close the digital divide. There is pretty general agreement the FCC does not have those accurate maps yet. 

The maps are used to direct broadband subsidies, so if they aren't right, unserved areas can show up as served and vice versa. Wicker said inaccurate maps waste money and stifle opportunity for economic development in rural areas. 

Related: Microsoft: FCC Has to Clean Up Its Broadband Accessibility Data Act

Congress's goal, and the FCC's as well, is to collect more granular and useful data. Wicker said the issue would be a priority for his committee.

Wicker wanted to know how long the FCC's data collection process (form 477) had been deficient.

Tim Donovan of the Competitive Carriers Association said the FCC form was showing its age, as FCC Chairman Ajit Pai has acknowledged, and was not designed to be used to distribute Universal Service Fund subsidies, but instead to show over time where resources were being deployed.

Jonathan Spalter, president of USTelecom, agreed that the process needed to be updated ASAP, as USTelecom is trying to do with its mapping initiative.

Ranking member Sen. Maria Cantwell (D-Wash.) decided not to make an opening statement at the hearing, saying there had been too much talking about mapping and that it was time for action. 

She said there needed to be better data on the cost of build-outs so they could determine what role the federal government should play. 

Sen. Marsha Blackburn (R-Tenn.) made it clear she thought the FCC's form 477-based maps had outlived their usefulness and that it was time to "do some things differently." She said, flatly, that 80% of Mississippi does not have access to high-speed broadband. She also said that as they talked about broadband and mapping and 5G and its revolutionary nature, what Congress needed to do was to make sure that everyone gets to be part of that revolution.

Microsoft has joined in the chorus of those calling for better data from the FCC on where broadband has been deployed, including suggesting Congress may need to step in to force the FCC to up its game. 

That data is used both to determine whether the FCC needs to regulate to boost deployment, and also on where to allocate billions in broadband subsidies.

Microsoft's input came in a blog post by chief data officer John Kahan in advance of a Senate Commerce Committee hearing Wednesday (April 10) on broadband mapping.

There is virtual unanimity--which is a "hen's tooth" on the scarcity scale in Washington these days--that the FCC needs to collect better data.

Microsoft wants broadband deployed to everyone however that can be achieved--government subsidies, municipal buildouts, repurposed and 'fallow' spectrum--but Kahan does not see much progress.

He attributes the two main problems with the FCC data that leads to over-reporting to: 1) if any single customer in a census block can get broadband, the entire block is considered covered, and 2) if an ISP says it is "providing or could…without an extraordinary commitment of resources provide broadband service to an area," it is considered covered even if it isn't and even if an ISP has no plans to cover it anytime soon.

He recommends the Commerce Committee do the following:

1. "Remove 'could provide' from the question in Form 477 [the broadband data collection form]. We should measure actual progress, not hypothetical progress, and make funding decisions on real access data.

2. "Use both availability and actual usage (and/or subscription data) to guide investments and communicate progress moving forward. Both access and usage data sets are critically important in building a full and accurate broadband map, as access data shows the current and near-future plans and usage data helps us understand how access translates into service and verification of the availability of broadband.

3. "Fix the availability data collection and reporting challenges prior to releasing a new report on broadband mapping. Our data science team has reviewed the draft report from the FCC and compared it to our latest usage data. We found that the increase in access reported in that draft document has not translated into broadband usage growth, especially in rural areas. This demonstrates the need to make significant adjustments to methodology prior to release."

The report Microsoft is referencing is the Sec. 706 report on whether advanced communications is being deployed in a reasonable and timely fashion, based on who can currently get broadband, which the FCC says is about 92% of the country and Microsoft maintains isn't even close to that.

Related: FCC Broadband Gains Overstated

The FCC has already had issues with the report, issuing a draft with some inflated carrier-provided coverage data.

Arguably one of the strengths of FCC Chairman Ajit Pai's decision to make public such draft items is that they can be vetted and such errors discovered, though that did not assuage the concerns that error raised that there could be more, given that it is based on ISP self-reporting, and came only after FCC Chairman Ajit Pai had touted the data.

NCTA-The Internet & Television Association has proposed a three-step method for improving the broadband availability data the FCC uses to direct broadband subsidy money, and it involves polygon shapefiles. Yes, polygon shapefiles.

NCTA says using that "nontopological" format for storing location information would provide more accurate data than the current census block reporting, which can overstate coverage. NCTA also says that the FCC could use third parties to collect the data from providers, particularly smaller operators who might not have the wherewithal to convert their data to the files.

That is according to a meeting among a top staffer to FCC Chairman Ajit Pai and executives from NCTA members Cox, Comcast, Charter and GCI.

The FCC is collecting comment on ways to collect better (form 477) data on fixed and mobile broadband availability. It has been under the gun to get a better handle on where broadband is and isn't, since that determines whether it is closing the digital divide generally, the rural digital divide in particular, and whether it is deploying advanced communications in a reasonable and timely manner, which the FCC recently concluded is the case.

The cable trade group took aim at proposals to use address-based reporting, as some have proposed. It said that would require a costly and time consuming exercise in creating a database of every address in the country before that data could be collected. It says shapefile reporting, by contrast, could be achieved fairly quickly, as early as next year. Using the shapefiles is step one of the FCC's proposal. 

Step two is for the FCC to use crowdsourcing to backstop the reported data. Taking a page, and a quote, from Democratic FCC Commissioner Jessica Rosenworcel, they told Pai special counsel Preston Wise that "it is time for the Commission to 'use the wisdom of the crowd to get our maps right.'" NCTA says that after the FCC released maps under the shapefile-based reporting, anyone could challenge them, with the FCC forwarding that challenge to the provider(s), who could correct their next 477 submission if necessary. 

Step three is to focus on pinpointing unserved areas, which the shapefiles will help do. NCTA says an address-based reporting system would be an "unnecessary and wasteful" way to gather location info.