[Senate Hearing 116-354]
[From the U.S. Government Publishing Office]
S. Hrg. 116-354
BROADBAND MAPPING:
CHALLENGES AND SOLUTIONS
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HEARING
before the
COMMITTEE ON COMMERCE,
SCIENCE, AND TRANSPORTATION
UNITED STATES SENATE
ONE HUNDRED SIXTEENTH CONGRESS
FIRST SESSION
__________
APRIL 10, 2019
__________
Printed for the use of the Committee on Commerce, Science, and
Transportation
[GRAPHIC NOT AVAILABLE IN TIFF FORMAT]
Available online: http://www.govinfo.gov
______
U.S. GOVERNMENT PUBLISHING OFFICE
42-446 PDF WASHINGTON : 2023
SENATE COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION
ONE HUNDRED SIXTEENTH CONGRESS
FIRST SESSION
ROGER WICKER, Mississippi, Chairman
JOHN THUNE, South Dakota MARIA CANTWELL, Washington,
ROY BLUNT, Missouri Ranking
TED CRUZ, Texas AMY KLOBUCHAR, Minnesota
DEB FISCHER, Nebraska RICHARD BLUMENTHAL, Connecticut
JERRY MORAN, Kansas BRIAN SCHATZ, Hawaii
DAN SULLIVAN, Alaska EDWARD MARKEY, Massachusetts
CORY GARDNER, Colorado TOM UDALL, New Mexico
MARSHA BLACKBURN, Tennessee GARY PETERS, Michigan
SHELLEY MOORE CAPITO, West Virginia TAMMY BALDWIN, Wisconsin
MIKE LEE, Utah TAMMY DUCKWORTH, Illinois
RON JOHNSON, Wisconsin JON TESTER, Montana
TODD YOUNG, Indiana KYRSTEN SINEMA, Arizona
RICK SCOTT, Florida JACKY ROSEN, Nevada
John Keast, Staff Director
Crystal Tully, Deputy Staff Director
Steven Wall, General Counsel
Kim Lipsky, Democratic Staff Director
Chris Day, Democratic Deputy Staff Director
Renae Black, Senior Counsel
C O N T E N T S
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Page
Hearing held on April 10, 2019................................... 1
Statement of Senator Wicker...................................... 1
Statement of Senator Cantwell.................................... 29
Statement of Senator Fischer..................................... 31
Statement of Senator Rosen....................................... 33
Statement of Senator Blackburn................................... 35
Statement of Senator Tester...................................... 36
Statement of Senator Blunt....................................... 38
Statement of Senator Baldwin..................................... 40
Statement of Senator Capito...................................... 42
Statement of Senator Thune....................................... 44
Statement of Senator Blumenthal.................................. 48
Statement of Senator Sinema...................................... 50
Witnesses
Tim Donovan, Senior Vice President, Legislative Affairs,
Competitive Carriers Association............................... 3
Prepared statement........................................... 5
Mike McCormick, President, Mississippi Farm Bureau Federation.... 9
Prepared statement........................................... 10
Mike Oblizalo, Vice President and General Manager, Hood Canal
Communications................................................. 14
Prepared statement........................................... 16
Jonathan Spalter, President and Chief Executive Officer, United
States Telecom Association..................................... 19
Prepared statement........................................... 20
Chip Strange, Vice President, Strategic Initiatives, Ookla, LLC.. 23
Prepared statement........................................... 24
Appendix
Letter dated April 8, 2019 to Hon. Roger Wicker and Hon. Maria
Cantwell from Caressa D. Bennet, General Counsel, Rural
Wireless Association........................................... 53
Letter dated April 10, 2019 to Hon. Roger Wicker and Hon. Maria
Cantwell from James D. Ogsbury, Executive Director, Western
Governor's Association......................................... 75
Response to written questions submitted to Tim Donovan by:
Hon. Roger F. Wicker......................................... 83
Hon. John Thune.............................................. 83
Hon. Jerry Moran............................................. 83
Hon. Amy Klobuchar........................................... 84
Hon. Richard Blumenthal...................................... 85
Response to written questions submitted to Mike McCormick by:
Hon. Jerry Moran............................................. 85
Hon. Richard Blumenthal...................................... 86
Response to written questions submitted to Mike Oblizalo by:
Hon. Jerry Moran............................................. 86
Hon. Amy Klobuchar........................................... 87
Hon. Richard Blumenthal...................................... 87
Response to written questions submitted to Jonathan Spalter by:
Hon. Jerry Moran............................................. 88
Hon. Richard Blumenthal...................................... 88
Hon. Jon Tester.............................................. 90
Response to written question submitted to Chip Strange by:
Hon. Jerry Moran............................................. 91
Hon. Richard Blumenthal...................................... 91
BROADBAND MAPPING:
CHALLENGES AND SOLUTIONS
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WEDNESDAY, APRIL 10, 2019
U.S. Senate,
Committee on Commerce, Science, and Transportation,
Washington, DC.
The Committee met, pursuant to notice, at 10:09 a.m. in
room SD-G50, Dirksen Senate Office Building, Hon. Roger Wicker,
Chairman of the Committee, presiding.
Present: Senators Wicker [presiding], Thune, Blunt,
Fischer, Capito, Blackburn, Cantwell, Blumenthal, Baldwin,
Tester, Rosen, and Sinema.
OPENING STATEMENT OF HON. ROGER F. WICKER,
U.S. SENATOR FROM MISSISSIPPI
Senator Wicker. All right. We'll go ahead and begin.
Senator Cantwell will be here momentarily.
Today, the Committee gathers to discuss the state of the
Nation's broadband maps.
I'm glad to convene this hearing with my colleague, Senator
Cantwell, who, as I said, will be here in just a moment.
I welcome our witnesses today. Mr. Tim Donovan, Senior Vice
President, the Competitive Carriers Association; Mr. Mike
McCormick, President of the Mississippi Farm Bureau Federation;
Mr. Jonathan Spalter, President and CEO of U.S. Telecom, the
Broadband Association; Mr. Chip Strange, Vice President,
Strategic Initiatives; and Mr. Mike Oblizalo, Vice President
and General Manager of Hood Canal Communications.
In today's digital economy, access to broadband is
essential. It is through broadband that Americans can gain
access to jobs, education, and economic opportunities.
Broadband also powers new industries and enables core
economic sectors, such as agriculture, manufacturing, and
transportation, to be more efficient, productive, and
competitive in the United States and around the globe.
In February, the Federal Communications Commission issued
its Draft 2019 Broadband Deployment Report showing gains in
broadband connectivity throughout the country. However, the
Digital Divide persists for far too many families in
Mississippi and across the Nation.
As I've said before, we are almost one-fifth of the way
through the 21st Century, hard to believe, and we ought to be
able to get all Americans connected soon. To close the Digital
Divide, we need to have accurate broadband maps that tell us
where broadband is available and where it is not available at
certain speeds.
This is critical because maps are used to inform Federal
agencies about where to direct broadband support. Flawed and
inaccurate maps ultimately waste resources and stifle
opportunities for economic development in our rural and
underserved communities.
I hope our witnesses today will speak to the costs, timing,
and potential challenges to collecting more accurate and
granular broadband coverage data, including whether the data
will be too out-of-date to be useful once it is all gathered.
I would also like the witnesses to address how to improve
existing broadband mapping approaches at the FCC and NTIA and
whether the FCC is collecting the right data to determine the
availability of fixed and reliable mobile broadband across the
country.
Improving the Nation's broadband maps starts with better
coordination and information sharing among Federal agencies
responsible for administering broadband deployment programs.
I hope we'll soon have legislation in this regard. It is
important that the FCC, the National Telecommunications and
Information Administration, and the U.S. Department of
Agriculture work cooperatively to coordinate and share
information on broadband coverage data and broadband deployment
programs.
Increased coordination and information sharing would
enhance efforts to develop a more accurate broadband map and to
assure Federal funds are targeted to unserved areas. Improving
broadband maps also requires the collection of more granular
and accurate data about existing broadband coverage.
To that end, I welcome the FCC's ongoing proceeding to
address shortcomings in its Form 477, which is used to collect
broadband deployment data from service providers twice a year.
The data is used to develop a broadband map that helps the
Commission determine areas that are eligible for universal
service support.
An obvious concern with the form, among others, is that it
asks providers to submit data about where they could provide
service to a location within a service interval without an
extraordinary commitment of resources. This service interval is
approximately seven to 10 business days.
I hope the witnesses will comment on ideas being discussed
to replace or supplement the Form 477 data, such as using
location-based proposals or shape-file-based proposals.
In submitting information about where service could be
provided, I'm concerned that this information is represented on
the FCC's Broadband Availability Maps with little verification
about whether the service provider could or would actually
provide the service at the advertised speed.
Incorporating data about where service could be provided
may ultimately lead to overstated broadband coverage and
availability on maps.
So I'd like the witnesses to comment on the value of
maintaining a challenge process after data is collected to
verify the accuracy of the data provided to the FCC.
Developing accurate broadband maps is a priority for this
committee. With so much at stake, it is dependent upon us to
find ways to ensure that we have sound understanding of
existing broadband availability across the country.
The Committee welcomes input from the witnesses on the
appropriate role for Congress in developing accurate maps. I
look forward to a thoughtful discussion on these issues and I
want to welcome all of our witnesses.
And we will hear from Senator Cantwell when she is able to
arrive from the meeting where her services are currently being
requested.
But we welcome our witnesses and we will begin. Your entire
statements will be included in the record. We ask each of you
to summarize your testimony in five minutes.
We will begin with Mr. Tim Donovan. Sir, you are welcome.
STATEMENT OF TIM DONOVAN,
SENIOR VICE PRESIDENT, LEGISLATIVE AFFAIRS,
COMPETITIVE CARRIERS ASSOCIATION
Mr. Donovan. Thank you, Mr. Chairman.
Garbage in, garbage out. Utterly worthless. They stink.
These are just some of the bipartisan statements expressed by
members of this committee regarding the current mobile
broadband coverage maps.
Chairman Wicker, Members of the Committee, thank you for
the opportunity to testify about this problem and solutions to
produce more reliable maps.
CCA is the Nation's leading association for competitive
wireless providers, representing nearly 100 carrier members as
well as vendors and suppliers. Through the recent FCC Mobility
Fund Challenge Process, CCA members have firsthand experience
and motivation to fix the mapping process and continue
deploying mobile broadband services.
It is an exciting time in our industry, as mobile
connections power new technologies and improve the quality of
life across the United States. 5G will super-charge these
services and enable new services, some not yet even imagined.
Current and future technologies depend on robust wireless
networks and without the right policies, Rural America will be
left behind.
Today's hearing is both important and timely. We cannot
close the Digital Divide if we do not know the country's
existing coverage gaps. CCA commends this committee for its
steadfast, bipartisan work to create reliable mobile broadband
coverage maps, including statements, hearings, letters, and
enacting laws to take steps to improve data, including the
Rural Wireless Access Act and the Precision Agriculture
Connectivity Act.
You know that the representation of coverage in your states
is overstated and, in some cases, substantially so. The FCC and
agencies across the government must work in coordination with
industry to produce the most reliable coverage maps possible.
The stakes are too high for anything less than our best
efforts.
I'd like to take a minute to talk about how we got here as
well as offer solutions for a path forward.
Historically, the FCC's Form 477 has served as its tool to
determine the availability of services and to guide
policymaking. However, current policies are not adequate to
allocate USF support.
As recently as December, the FCC used this data to report
that approximately 100 percent of the American population lives
in geographical areas covered by mobile LTE. If this were the
case, we would not be having this hearing today.
Mobility Fund Phase II has proposed to provide $4.53
billion over 10 years to preserve and expand 4G services.
Acknowledging that using Form 477 to determine eligible areas
would prolong any challenge process, the FCC decided to
undertake a new one-time data collection to determine areas
initially eligible for support.
To the FCC's credit, this data collection included specific
parameters; namely, requiring carriers to report where they
provide 4G services with download speeds of five megabytes per
second with 80 percent cell edge probability and a 30 percent
loading factor.
While taking steps to standardize the data should be
commended, we now know that the parameters selected did not
sufficiently improve the accuracy or credibility of the
resulting coverage maps, which continue to dramatically
overstate coverage, especially in rural areas.
This is a significant problem as the challenge process
proved to be overly burdensome, yet insufficient to correct
flaws. A challenger was required to download mapping data from
the portal and research areas where coverage may be overstated,
demonstrate the absence of coverage in each one square
kilometer block throughout an area with Speedtests no further
than 800 meters apart from one another, done between 6 a.m. and
midnight local time, and if these and other burdens are met, a
challenger was required to submit data across at least eight
parameters for each carrier claiming unsubsidized coverage in
an area.
Believe it or not, this description dramatically
oversimplifies the effort a challenger must undertake.
The takeaways from the process for challengers are (1) the
process was so complicated and expensive that challengers large
and small were never able to challenge all the areas they
wanted to and (2) absent a successful challenge, too many areas
will remain ineligible for support.
Despite these problems, entities last year provided the FCC
with over 20 million Speedtests to challenge claimed coverage.
After a preliminary review, the FCC launched an investigation
into the data while suspending the next step of the challenge
process.
The investigation's findings can help improve future data
collections but we already know that more robust
standardization is a problem that should be addressed.
Any model will have shortcomings, but to produce maps that
are more reliable, the FCC must ask carriers to provide a
detailed radiofrequency link budget submission that includes
the most relevant data, including at a minimum: signal strength
standardization, increased cell edge probability, increased
cell loading to more accurately reflect how mobile networks are
used in rural areas, and additional clutter factors.
Further standardizing these bottom line factors will
produce substantially more reliable maps and reduce the need to
expend additional resources to correct data collection flaws.
In conclusion, connectivity for millions of Americans
living in rural areas depends on policy decisions that are
based on reliable real-world coverage data.
Thank you for your ongoing leadership on this critical
issue and for holding today's important hearing.
I welcome any questions you may have.
[The prepared statement of Mr. Donovan follows:]
Prepared Statement of Tim Donovan, Senior Vice President, Legislative
Affairs, Competitive Carriers Association
Chairman Wicker, Ranking Member Cantwell, and Members of the
Committee, thank you for the opportunity to testify about how to base
policy decisions to close the digital divide on reliable broadband
mapping data.
I am testifying on behalf of Competitive Carriers Association
(``CCA''), the Nation's leading association for competitive wireless
providers. CCA is composed of nearly 100 carrier members ranging from
small, rural providers serving fewer than 5,000 customers to regional
and nationwide providers serving millions of customers, as well as
vendors and suppliers that provide products and services throughout the
wireless communications ecosystem.
It is an exciting time in the wireless industry, as mobile
connections are powering new technologies to revolutionize entire
industries and improve consumers' quality of life across the United
States. Specifically, wireless technologies enable telemedicine
services and remote patient monitoring, which increases patients'
access to medical care, particularly in rural areas. Precision
agriculture enables farmers to increase yields while conserving
resources. Distance learning brings the latest lessons and training
programs to students, allowing them to access educational opportunities
previously unimaginable. Today's wireless services also enhance public
safety, economic growth, and opportunities for all Americans.
As impressive as existing wireless networks can be, 5G will
supercharge existing services like telehealth and precision agriculture
and enable new services, such as augmented and virtual reality,
autonomous vehicles, and other innovations not yet invented. As these
technologies develop, it is imperative to provide access and expand
wireless services, or rural areas will be left behind, on the wrong
side of the digital divide.
Today's hearing is both important and timely: we cannot close the
digital divide if we do not know the size and location of our country's
existing coverage gaps. Reliable data is necessary to determine where
mobile broadband coverage does and does not exist. It also is important
to understand that measuring fixed wireline broadband availability is a
separate and distinct challenge from reliably measuring mobile
coverage.
CCA commends this Committee for its steadfast, bipartisan work to
create reliable mobile broadband coverage maps. These efforts include
not only statements and hearings, but also a steady flow of letters
expressing concern to the Federal Communications Commission (``FCC'')
and enacting laws to take steps to improve data, including the Rural
Wireless Access Act and the Precision Agriculture Connectivity Act.
Members of Congress know from hearing from your constituents and
travelling across your states that the representation of coverage in
your states is overstated--and, in some cases, substantially so. While
significant efforts to update coverage maps will take place at the FCC,
agencies across the government should work in coordination to produce
the most reliable coverage maps possible. For example, the Department
of Commerce's National Telecommunications and Information
Administration should continue its ongoing efforts to refresh the
national broadband map and the Department of Agriculture should base
rural broadband funding programs on improved data.
CCA and our members stand ready to work with Congress, the FCC, the
Administration, and all stakeholders to create reliable coverage maps
to appropriately guide policymakers as work continues to preserve and
expand mobile broadband coverage. With our Nation on the precipice of a
major technological change, the stakes are too high for anything less
than our best efforts.
From Form 477 to the Mobility Fund Phase II Data Collection
Historically, the FCC's Form 477 has served as the principal tool
to determine the availability of communications services and to guide
the FCC's policymaking, and is intended to represent where consumers
should expect to receive mobile broadband services at the minimum
speeds advertised by providers. The FCC has an ongoing proceeding to
update the Form 477 to improve the data and to eliminate unnecessary
filing requirements. As recently as last December, the FCC used Form
477 data to report that ``approximately 100 percent of the American
population lives in geographical areas covered by mobile LTE with a
minimum advertised speed of 5Mbps/1Mbps.'' This figure does not match
Congress' or consumers' on-the-ground experience. Once work is complete
to develop reliable maps to determine eligible areas for Mobility Fund
Phase II (``MF II''), lessons learned from the MF II experience can
guide ongoing updates to Form 477.
MF II is proposed to disburse $4.53 billion over ten years to
preserve and expand 4G LTE service in areas without an unsubsidized LTE
provider. Acknowledging that using Form 477 to determine eligible areas
for MF II would prolong any challenge process, the FCC decided to
undertake a new, one-time data collection to determine areas initially
eligible for MF II support. To the FCC's credit, this one-time data
collection included specific parameters, namely requiring carriers to
report where they provide 4G LTE service with download speeds of 5 Mbps
with 80 percent cell edge probability and a 30 percent loading factor.
But evidence supporting final determinations for areas eligible to
receive MF II support must be clear, rigorous, and above all, reliable.
While any steps to standardize the data should be commended, we now
know that the parameters selected did not sufficiently improve the
accuracy or credibility of the resulting coverage maps, which continue
to dramatically overstate coverage in several states--especially in
rural states. Areas where coverage was overstated, absent a successful
challenge, would be ineligible for support to preserve and expand
mobile broadband for a decade.
The MF II Challenge Process Is Overly Burdensome and Insufficient to
Correct Flaws
On February 27, 2018, the FCC released a 53-page public notice
explaining how the MF II challenge map would be generated, the
procedures for filing a challenge, and how the FCC would process
challenges. With the benefit of hindsight, it is now apparent that the
complicated process prevented the FCC from substantially improving its
initial map of eligible areas. As a bipartisan group of eleven Senators
wrote to the FCC last month, ``The Challenge Process for MF-II was
aptly named because collecting and submitting information for the FCC
maps was, indeed, a challenge.'' Here are the basic steps a challenger
was expected to undertake:
Download mapping data from the FCC's portal;
Compare the FCC's data to all available information about
every carrier offering service in an area. If that research
leads a challenger to conclude that the FCC's map is inaccurate
because of other evidence, then it must conduct drive tests and
submit the results to the FCC for consideration;
A challenger may challenge the FCC's map, one square
kilometer at a time. In other words, a challenger must
demonstrate the absence of coverage in each one square
kilometer block throughout an area. To provide some
perspective, many rural areas that could be challenged have
thousands of square kilometer blocks that must be separately
analyzed to determine whether any carrier is providing service;
For each individual square kilometer block, speed tests must
be conducted no further than 800 meters apart from one another,
and done between 6:00 AM and 12:00 AM local time;
The tests must include all unsubsidized wireless companies
claiming coverage inside that block;
Only certain handsets, specified by and purchased from each
operator claiming coverage in the area, may be used;
A challenger must subscribe to rate plans and constantly
monitor usage to ensure service is not throttled or subject to
data caps, which could bias the tests and collect unusable test
results;
A challenger must purchase, mount and calibrate test
equipment on one or more test vehicles, or hire a testing
company to perform the tests;
If a challenger does the testing, it must train up testing
teams and take them away from their work building and
maintaining a network for two or more months;
GPS tracking equipment must be purchased so that the testers
understand where the vehicle is in relation to the one square
kilometer blocks eligible to be challenged, and so tests get
conducted at the required locations inside the blocks, that is,
at the minimum distance separation of 800 meters;
Since the FCC's rules require a challenger to demonstrate
lack of coverage in 75 percent of the grid being challenged,
only grids with accessible roads that can be driven by a normal
vehicle can be challenged. Vehicle-based drive testing must be
done on drivable roads, which in rural areas can be far apart
or otherwise inaccessible due to private or public
restrictions, seasonal closures, or other factors. This is a
significant limitation; indeed, some CCA members report that up
to half of the rural blocks do not have enough drivable roads
to meet the FCC's 75 percent benchmark. So, if a carrier claims
coverage, there can be no challenge;
For each test, a challenger was required to submit: (i) all
speed test measurements collected during the relevant time
frame, (ii) signal strength and latency, (iii) the service
provider's identity, (iv) the make and model of the device used
(which must be from that provider's list of pre-approved
handsets), (v) the international mobile equipment identity
(IMEI) of the tested device, (vi) the method of the test (i.e.,
hardware-or software-based drive test or non-drive test app-
based test), (vii) if an app was used to conduct the
measurement, the identity and version of the app, (viii) the
identity and location of the server used for speed and latency
testing;
While challengers bear the burden of proof, challenged
carriers do not need to provide drive tests to rebut. In lieu
of drive testing, challenged carriers may submit data from
transmitter monitoring software that could show geolocated,
device-specific throughput measurements and other device-
specific information, along with certifications from an
engineer. Producing this level of rebuttal evidence is easier
to do than drive testing.
To provide some perspective on how daunting this challenge process
was, one of CCA's small carrier members undertook to analyze 165,000
separate square kilometer blocks within its service area that it
believed could possibly be incorrectly labeled as ``covered.'' That
company tested several thousand blocks, but had nowhere near the
resources needed to test a substantial portion of the blocks that
appeared to be worth a challenge. One of our larger members spent over
$2 million to hire a testing firm that completed tests in 20 states and
challenged 37,000 one square kilometer blocks. Even with this resource
allocation, the member completed testing in less than 5 percent of the
carrier's overall rural footprint.
The takeaways from this process for challengers are: (i) the
process was so complicated and expensive that challengers large and
small were never able to challenge all of the areas they wanted to, and
(ii) in any area where the FCC incorrectly showed unsubsidized
coverage; absent a successful challenge, there could be no investment
of universal service support. Without eligibility for support, unserved
people living in those areas could wait over a decade or more before
having another opportunity to access mobile broadband services that are
reasonably equivalent to services found in the Nation's more densely-
populated regions.
FCC Investigation
Despite these problems, entities provided the FCC with 20,809,503
speed tests to challenge claimed coverage. In December 2018, FCC
Chairman Pai announced that a preliminary review of the data filed
through the challenge process suggested that the preliminary maps were
an inadequate basis to distribute MF II support, and launched an
investigation into the data while suspending the next step of the
challenge process. CCA appreciates the FCC's continued focus on
ensuring that it has reliable data before allocating limited support
resources. The FCC should use the investigation to understand and
rectify overstated coverage figures, and take steps to improve the next
mobile coverage data collection. While the investigation may uncover
additional concerns, various stakeholders confirm that the lack of a
more robust standardization of parameters for the one-time data
collection was a critical error that should be addressed.
Improved Standards Produce More Reliable Data
Policymakers should apply a specific set of factors to standardize
data collection, better understand carriers' broadband coverage, and
produce more reliable maps. It is important to keep in mind that no
model will 100 percent reflect on-the-ground coverage. That said, steps
should be taken to further standardize modeled coverage. At a minimum,
a detailed Radio Frequency Link Budget submission should include the
following:
Signal Strength. Standardizing the Reference Signal Received
Power (``RSRP'') will base measurements on the same real-world
measurements that wireless networks use to determine cell
selection and handover, among other network functions. As
current Form 477 filings show, these results can be subjective
and vary by equipment vendor and network design. A weaker RSRP
means that the coverage area is larger but that the actual
coverage is less reliable at the cell edge. Also, a weaker RSRP
threshold translates to more path loss allowed between the base
station and the mobile. It is therefore imperative that all
carriers report a standard RSRP level. In rural areas where
sites are isolated, the coverage area doubles with a 5 dB
increase in the Maximum Allowed Path Loss for a single site.
For 4G LTE specifically, a -85 dBm RSRP level per 5 MHz channel
would reflect excellent coverage, while a signal strength of no
lower than -105 dBm per 5 MHz channel would reflect the type of
reliable signal strength that consumers expect. In contrast, a
-120 dBm level per 5 MHz channel could register that a
consumers' device is connected to LTE service, but in reality,
provide for a poor connection that fails to support many
applications or functions.
Cell Edge Probability. Cell edge probability determines the
likelihood that the minimum speed will be possible at the
furthest point from the base station. From data collected
during the ongoing MF II process, it is evident that an 80
percent cell edge probability drastically overstates coverage
capabilities. The FCC should revisit this parameter and adopt a
cell edge probability of 90 percent or higher, as proposed by
several industry stakeholders, including those representing the
largest nationwide wireless carriers as well as those providing
service across rural and regional areas of the United States.
It is worth noting that the industry standard for commercial
operators is to design their networks for at least 90 percent
cell edge probability, and public safety typically designs to
95 percent. In a rural site, using 80 percent extends the cell
radius by about 27 percent and increases the ``covered'' area
by about 60 percent. This additional 60 percent could represent
hundreds of square kilometers of additional ``coverage'' per
site that is mostly insufficient to support reliable service.
Cell Loading. Cell loading determines the extent to which
available resources from a given base station may be used by
consumers while providing minimum coverage speeds. In the MF II
proceeding, the FCC directed reporting providers to evidence a
30 percent load factor, which failed to accurately reflect
network use in rural areas. As Verizon has previously
highlighted, network loading in at least one rural region in
Oklahoma often exceeds 30 percent. In fact, because rural
Americans are often more dependent on mobile broadband service
for Internet access than their urban counterparts, one CCA
carrier member reports that its rural sites utilizing high-
quality, low-band spectrum routinely experience average cell
loading well in excess of 50 percent in the evening hours. In
rural areas, coverage is typically provided by low-band
spectrum, which has limited capacity compared to higher
frequencies, and as a result, these sites are often prone to
being heavily loaded. The FCC should revisit this parameter and
adopt a cell loading factor of at least 50 percent on the
downlink, or higher, to reflect the reality that consumers in
rural areas are more likely to rely on their mobile connection
for their primary or only Internet connection.
Clutter Factors. Clutter factors include environmental
features such as structures, trees, vegetation, topography, or
other objects that affect propagation of a signal from a base
station. With varied geographic features across the country,
clutter factors should match local environments but also must
be appropriately standardized across reported coverage areas.
Submissions for clutter factors also should include clear
indications of the precise loss values assigned to the clutter
and feeder type.
A variety of other factors also form the foundation upon which a
robust Link Budget is based; however, standardizing the bottom-line
factors listed above will produce substantially more reliable maps and
reduce the need to expend additional resources to correct data
collection flaws.
______
Connectivity for millions of Americans living in rural areas
depends on policy decisions that are based on reliable, real-world
coverage data. Armed with improved and more reliable broadband mapping,
policymakers can connect all Americans and lay the groundwork for the
expansive impact that the latest broadband technologies promise for all
consumers. And if designed correctly, a robust data collection will
promote the inclusion of rural and Tribal communities in today's
digital economy. Thank you for your ongoing leadership on this critical
issue and for holding today's important hearing. I welcome any
questions you may have.
Senator Wicker. Thank you very much.
Mr. McCormick, you're recognized.
STATEMENT OF MIKE McCORMICK, PRESIDENT,
MISSISSIPPI FARM BUREAU FEDERATION
Mr. McCormick. Thank you, Mr. Chairman.
Chairman Wicker, Ranking Member Cantwell, and Members of
the Committee, my name is Mike McCormick, and I'm President of
the Mississippi Farm Bureau Federation.
I'm pleased to be here today and I commend you for your
leadership in addressing the critical issues of rural broadband
development and the needs for agriculture in this conversation
and the challenges with current broadband mapping.
I would like to devote my time today to primarily
discussing agricultural needs and challenges and access to
broadband, our experience with the Federal Communications
Commission's Mobility Fund Phase II Challenge Process and why
accurate broadband mapping is so critical to agriculture.
Broadband is no longer a luxury. It's a necessity. Farmers
and ranchers depend on broadband just as they do highways,
railways, and waterways to ship food, fuel, and fiber across
the country and around the world.
However, 29 percent of U.S. farms have no access to
Internet according to USDA. According to the FCC, 30 percent of
rural Americans lack access to adequate broadband compared to
only 2 percent of urban Americans.
Specific to my home state, Mississippi has the lowest
percentage of fixed broadband availability in the Nation with
2.2 million citizens or 72 percent of the Mississippi
population with access to Internet at broadband speeds
according to the FCC.
When looking at the data put together by Microsoft and
other groups, they report that only 487,000 citizens or 16
percent of the Mississippi population use the Internet at
broadband speeds. This 56 point difference in broadband
availability marks a substantial gap in the perceived numbers
of citizens able to participate in a growing digital economy.
From my time traveling the state talking to rural
Mississippians, I feel very confident disputing the 72 percent
of our population has access to the Internet at broadband
speeds.
In February 2018, the FCC released a map showing areas
across the United States presumed eligible to receive support
for the deployment of 4G LTE service as part of the Mobility
Fund Phase II Auction.
In essence, the FCC's map showed that Mississippi was 98
percent covered with mobile broadband services which we clearly
dispute.
In August 2018, we decided to file a formal waiver request
to be allowed to challenge the FCC on the accuracy of these
maps. Our staff began to review mapping data and the technical
requirements to run multiple speed tests applications by
carrier and device in the census block. We quickly determined
that our organization did not have the adequate resources or
staff needed to execute this challenge through this process nor
would the average consumer have this ability either.
We then collaborated with the Mississippi Public Service
Commission and directed our membership to report mobile
broadband speed tests through a program the PSC already had
established.
In November 2018, the PSC submitted more than 8,400
individual consumers' speed test data points to the FCC.
Ultimately, however, through the efforts of Farm Bureau and the
efforts of the Mississippi Public Service Commission, not one
single challenge to the map in Mississippi was successful.
The minimum level of success was largely due to the overall
complexities of the challenge process itself and the
complications that prevent anyone, especially the average
consumer, to successfully participate in this process.
We feel that the FCC must do more to establish an accurate
understanding of the mobile broadband coverage before moving
forward with the Mobility Fund II Program.
Any effort to move forward with the current maps will lock
Rural America into a digital divide for at least another decade
and as efforts to improve access to broadband in rural areas
continue, the ability of the FCC and all other relevant
agencies to utilize accurate coverage maps is and should be of
the highest priority.
Currently, the FCC's National Broadband Map relies on
census block data to determine which areas are served,
underserved, or unserved across the country. Farm Bureau
recommends that more granular data be used to determine areas
of coverage.
Additionally, we recommend that the inclusion of cropland
and ranchland as metrics of the broadband access. With this
need in mind, I commend you, Chairman Wicker and Senator
Klobuchar, for your work to see that the provisions of the
Precision Agriculture Connectivity Act were included in the
2018 Farm Bill.
This legislation is an important step in changing the way
the FCC and other agencies think about rural broadband as we
strive to build the information infrastructure that modern
production agriculture increasingly needs to be successful.
On behalf of the Farm Bureau, I appreciate the opportunity
to provide comments today on the needs of agricultural industry
in the rural broadband conversation and highlight the
importance of accurate broadband maps and how they're developed
so that farmers and other rural Americans are not left out of
the digital economy.
Thank you, and I look forward to your questions.
[The prepared statement of Mr. McCormick follows:]
Prepared Statement of Mike McCormick, President,
Mississippi Farm Bureau Federation
Chairman Wicker, Ranking Member Cantwell, and Members of the
Committee, my name is Mike McCormick and I am the President of the
Mississippi Farm Bureau Federation. I am pleased to be here today to
offer testimony on several issues of importance to farmers and ranchers
across the country.
On behalf of the nearly two-hundred thousand member families of
Farm Bureau in Mississippi and almost six million Farm Bureau member
families across the United States, I commend you for your leadership in
addressing the critical issues of rural broadband deployment and the
challenges with current broadband mapping.
Mississippi Farm Bureau Federation is a statewide organization with
members in all 82 counties. One of the most common themes I hear as I
travel the state as President of our organization is the lack of true,
reliable, and affordable broadband access. Mississippi Farm Bureau
supports the Federal Communications Commission's (FCC) minimum
broadband speed of 25 Mbps downstream and 3 Mbps upstream and is
neutral on the technology used to transmit broadband. Access to
broadband is essential for farmers and ranchers to follow commodity
markets, utilize precision agriculture technologies, communicate with
their customers and, increasingly, for regulatory compliance.
We appreciate the Committee's interest in understanding how farmers
and ranchers are impacted by the lack of connectivity and the
importance of accurate broadband mapping as the Federal government
assesses the broadband needs of Americans that live and work in rural
areas.
I would like to devote my time today primarily to discussing the
agricultural needs and challenges of access to broadband, our
experience with the FCC Mobility Fund Phase II Challenge Process, and
why accurate broadband mapping is so critical.
Importance of Broadband for U.S. Agriculture
Broadband is no longer a luxury, it is a necessity. Farmers and
ranchers depend on broadband just as they do highways, railways and
waterways to ship food, fuel and fiber across the country and around
the world. Many of the latest yield maximizing farming techniques
require broadband connections for data collection and analysis
performed both on the farm and in remote data centers. However, 29
percent of U.S. farms have no access to the Internet according the USDA
report, ``Farm Computer Usage and Ownership, 2017.''
America's farmers and ranchers embrace technology that allows their
farming businesses to be more efficient, economical and environmentally
friendly. Today's farmers and ranchers are using precision agricultural
techniques to make decisions that impact the amount of fertilizer a
farmer needs to purchase and apply to the field, the amount of water
needed to sustain the crop, and the amount and type of herbicides or
pesticides the farmer may need to apply. These are only a few examples
of the ways farmers use broadband connectivity to achieve optimal
yield, lower environmental impact and maximize profits.
Farmers and ranchers cannot take full advantage of such cutting-
edge equipment if they do not have access to reliable, high capacity
fixed and mobile broadband in the field or on the ranch. As technology
advances, those connections will become ever more important in a world
expected to add more than 2 billion people by 2050. Farmers and
ranchers, who already have seen a drastic 50 percent decline in net
farm income in the last four years, must have access to fixed and
mobile broadband to be more efficient, economical and responsive to
environmental needs.
Additionally, agriculture is the backbone of so many small rural
communities that dot the landscape across America. These rural
communities need access to health care, government services, and
educational and business opportunities. For many rural communities,
access can only be gained by using broadband services and sophisticated
technologies that require high-speed connections. According to the
Federal Communications Commission, 30 percent of rural Americans lack
access to 25 Mbps/3 Mbps service, compared to only 2 percent of urban
Americans. Current and future generations of rural Americans will be
left behind their fellow citizens if they are without affordable high-
speed broadband service that enables them to tap into health care and
educational services, government agencies, and new business
opportunities.
Mississippi's Access to Broadband
Specific to my home state, Mississippi has the lowest percentage of
fixed broadband availability in the U.S., with 2.2 million citizens, or
72 percent of the Mississippi population, with access to the Internet
at broadband speeds (25 Mbps/3 Mbps). This data was reported in the
FCC's 2018 Broadband Deployment Report.
However, when looking at third-party private research data put
together by Microsoft and other groups, they report that only 487,000
citizens, or 16 percent of the Mississippi population, use the Internet
at broadband speeds. This 56-percentage point difference in broadband
availability marks a substantial gap in the perceived number of
citizens able to participate in a growing digital economy.
Illustrating these discrepancies further, we created the following
map that uses public data from the FCC, Microsoft and American Farm
Bureau Federation to calculate the difference between FCC usage
percentages compared to actual usage percentages in Mississippi.
According to the FCC my home county, Jefferson County, is listed at 41
percent usage while the Microsoft data shows it at 5.6 percent, which
is a different of -35 percent.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
As I pointed out in my opening comments, the topic of rural
broadband connectivity is the most common thing I hear about from our
membership. With that in mind, I feel very confident disputing the FCC
report which indicates that 72 percent of our state's population has
access to the Internet at broadband speeds.
Mississippi's Engagement in the FCC Mobility Fund Phase II Challenge
Process
In February 2018, the FCC released a map showing areas across the
United States presumed eligible to receive support for the deployment
of 4G LTE service as part of its Mobility Fund Phase II (MF-II)
auction. MF-II is critically important to supporting mobile voice and
broadband coverage, incentivizing the deployment of mobile wireless
service through a reverse auction, and ensuring that 4G LTE service is
preserved and advanced in those areas of the country that lack
unsubsidized service. This Federal funding is vital for providing rural
telecom carriers support to bring about service to rural and
underserved areas. The new Mobility Fund program will succeed only if
it is based on an accurate understanding of current mobile broadband
coverage. What I know from my organization's in-depth review of the
FCC's existing coverage maps is that they are clearly wrong. In
essence, the FCC's map showed that Mississippi was 98 percent covered
with mobile broadband services, which Farm Bureau clearly disputes.
After lengthy discussions with the FCC, members and staff of Farm
Bureaus in other states, and our national organization; we decided to
formally file a waiver request to be allowed to challenge the FCC in
the accuracy of these maps. In August of 2018, Mississippi Farm Bureau
submitted and was granted a waiver by the FCC to participate in the FCC
Mobility Fund Phase II challenge process. As our staff began to review
mapping data and the technical requirements to run multiple speed tests
applications by carrier and device in each census block, we quickly
determined that our organization did not have the adequate resources or
staff needed to execute a valid challenge through this process, nor
would the average consumer have this ability either.
Mississippi Farm Bureau Federation later began discussions with the
Mississippi Public Service Commission (PSC). The PSC has an ongoing
program that allows citizens to submit mobile speed test data to the
Commission in areas that lack mobile 4G service. At that point, we then
collaborated with the Mississippi Public Service Commission (PSC) to
direct our membership to report mobile broadband speed tests through
the PSC's program in hopes that our members could be a part of a
successful effort to challenge the maps.
In November of 2018, the PSC submitted more than 8,400 individual
consumer speed tests data points to the FCC. Of all these data points,
only 3,000 were reviewed and assessed as valid by FCC staff to be
submitted as a successful challenge.
Ultimately, through our efforts and the efforts of the Mississippi
Public Service Commission, not a single challenge in any census block
on the map in Mississippi was successful. This minimal level of success
was largely due to the overall complexities of the challenge process
itself and the complications that prevent anyone--especially the
average consumer to successfully participating in this process. We
firmly believe that the FCC must do more to establish an accurate
understanding of mobile broadband coverage before moving forward with
the Mobility Fund II program.
Importance of Broadband Mapping to Agriculture
As efforts to improve access to broadband in rural areas continue,
the ability of the FCC and all other relevant agencies to utilize
accurate coverage maps is the highest priority With limited funding to
address an estimated $45-65 billion issue and an overabundance of need,
more granular and accurate maps are critical to successfully target and
distribute Federal broadband programs. Currently, the FCC's National
Broadband Map relies on census block data to determine which areas are
served, underserved, and unserved across the country. Census blocks are
too large in rural and remote areas to accurately target broadband
investments. If even one household in a given census block is reported
by a provider as being served, then the entire block is considered
served and is therefore likely excluded from eligibility to receive
Federal funds for rural broadband buildout. There are more than 3,200
census blocks across the country that are larger than the District of
Columbia, and five that are larger than the State of Connecticut. In
fact, census blocks larger than two square miles comprise more than 64
percent of the U.S. land area, which means that every rural area is
impacted by this problem in some way.
Farm Bureau recommends that more granular data be used to determine
areas of coverage. Gathering and, equally as important, verifying the
data to accurately target and distribute the funding is critical to the
success of broadband deployment for rural America. Adjustments in the
data collection matrix to develop the mapping will assist in
identifying areas in rural America where the digital divide is the
widest.
Furthermore, we have been a long-time advocate for the inclusion of
cropland and ranchland as a metric of broadband access. Precision
agricultural equipment requires reliable, high capacity fixed and
mobile broadband connections for data collection and analysis performed
both on the farm and in remote data centers. As more precision
equipment becomes available, farmers cannot take full advantage of that
equipment if they do not have access to reliable, high capacity
broadband in the field or on the farm.
Chairman Wicker, I want to thank you for championing this effort.
You, Senator Manchin and 24 other Senators, including eight of your
fellow committee members,\1\ wrote a bipartisan letter on July 11, 2016
to then FCC Chairman Tom Wheeler supporting the concept of cropland and
ranchland as a broadband metric. The letter reads:
---------------------------------------------------------------------------
\1\ Sens. Tammy Baldwin, D-Wis., Roy Blunt, R-Mo., Shelley Moore
Capito, R-W.Va., Deb Fischer, R-Neb., Ron Johnson, R-Wis., Amy
Klobuchar, D-Minn., Jerry Moran, R-Kan., Gary Peters, D-Mich.
[c]roplands and ranch lands have lagged behind in adequate
mobile coverage, even as demand for coverage has grown. To
address this gap, we urge you to consider a metric of broadband
access in croplands (and farm buildings), in addition to road
miles, to identify these areas of greatest need. ``Cropland''
coverage can be assessed using USDA data for crop operations,
the U.S. Geological Survey's Land Use classification, or other
databases.\2\
---------------------------------------------------------------------------
\2\ Letter to Chairman Tom Wheeler, FCC, from United States
Senators Wicker, Manchin, et. al. July 11, 2016.
Precision Agriculture Connectivity Act & 2018 Farm Bill
With this need in mind, I commend you Chairman Wicker and Senator
Klobuchar for your work to see that the provisions of the Precision
Agriculture Connectivity Act were included in the 2018 Farm Bill. This
legislation will direct the Federal Communication Commission (FCC) and
U.S. Department of Agriculture to work together to identify gaps in
farm and ranchlands mobile broadband coverage. Then, policies will be
recommended to fill 90-percent of those identified gaps by 2025. The
legislation is an important step in changing the way the FCC and other
agencies think about rural broadband as we strive to build the
information infrastructure that modern production agriculture
increasingly needs to be successful. Farm Bureau looks forward to
hearing how the FCC and USDA will accept nominations and will
participate in the nomination process.
Conclusion
On behalf of the Mississippi Farm Bureau Federation, I appreciate
the opportunity to provide comments on the needs of the agricultural
industry in the rural broadband conversation. I appreciate the
Committee's continued commitment to making sure that accurate broadband
maps are developed so that farmers and other rural communities are not
left out of the digital economy. I look forward to continuing to work
with the Committee in advancing the shared goals to which I have
highlighted here today.
Senator Wicker. Thank you very much, Mr. McCormick.
Mr. Oblizalo, welcome.
STATEMENT OF MIKE OBLIZALO, VICE PRESIDENT AND GENERAL MANAGER,
HOOD CANAL COMMUNICATIONS
Mr. Oblizalo. Thank you.
Chairman Wicker, Ranking Member Cantwell, and Members of
the Committee, thank you for the chance to testify on the
importance of rural broadband mapping.
I am Mike Oblizalo, Vice President and General Manager of
Hood Canal Communications. I am a third generation employee of
Hood Canal, a community-based family owned business.
In 33 years with the company, I have worked in all
different aspects at the company. I have overseen all aspects
of our grant projects, including budgets, the engineering, and
the deployment of these networks.
Hood Canal Telephone Company, now known as Hood Canal
Communications, was founded over 85 years ago as a traditional
local exchange telephone company in Union, Washington. Union is
located in Mason County, a sparsely populated rural areas.
Hood Canal has been owned and operated by the Buechel
family since 1956 when there were only 123 telephone consumers
in the exchange. The family's commitment to the local community
led to the additional of cable TV services in 1971, dial-up
Internet in the 1990s, and higher speed broadband in 2000.
Hood Canal currently employs 40 members of our community
and we frequently are recognized, which awards for both our
community involvement and our broadband deployment efforts.
Hood Canal has received several USDA grants and loans to
deploy broadband to tribal areas, upgrade our existing
networks, and expand services into the unserved and
underserved.
Limited resources in a tight financial market make
deployment difficult without financing available from a partner
like the USDA. At the same time, predictable and sufficient
support from the Federal Universal Service Fund is essential
within our traditional incumbent service area to make the
business case for investment and to ensure consumers can obtain
services at affordable rates.
Broadband mapping is significant for companies like Hood
Canal that need to leverage public-private partnerships to
deploy networks and to deliver services in very rural areas.
But the lack of accurate maps makes for a challenging process
to determine potential areas for broadband deployment and
availability of funding.
The accuracy of broadband availability maps is often in
question as maps show service as available where consumers
cannot get them at all and other places these maps show speeds
available at levels that cannot be consistently delivered.
There are several reasons why these issues arise. First,
current broadband maps are based largely on the information
received by the providers. While providers certify the accuracy
on their reports, the processes to verify the information can
vary greatly, if they exist at all.
Second, on the report that feeds into the FCC's Broadband
Map, the census block is reported as simply served if one
location of that block can be served by a provider.
Third, the current standard for reporting an area as served
depends on the advertised rather than actual speeds and also
shows an area served if a provider believes it could deliver
the service at some time soon in the future.
Finally, the current map does not capture build-out in
progress pursuant to the government initiatives, like the FCC's
USF or the RUS landing and grant programs. This means that
there could be a potential for two governmental programs to in
effect overbuild each other, allowing duplicate and competing
networks to be built through two different Federal programs.
Accurate mapping data is critical to delivering and
sustaining services in Rural America--and bad mapping data
risks leaving rural consumers stranded without broadband for
years to come.
False positive locations are locations shown as served when
they are not. This could result in denial of financing or
funding which ultimately hurts the consumer left unserved.
On the other hand, false negative locations are locations
appearing as served when they're already served or in the
process of networks being built to them. This can result in a
waste of financing and funding resources on duplicate networks.
There are many interesting ideas now being considered how
to improve the maps and make them more granular. A more
granular map can certainly help identify more accurately where
broadband is available but granularity alone is not enough.
While getting more granular is useful, a meaningful
challenge process is critical to validate the data prior to any
map being used by the FCC or the RUS to make final decisions on
funding or financing.
Hood Canal continues to strive to provide great services to
its customers of rural Mason County. Only a meaningful
validation process that includes the ability to challenge data
on a baseline map will ultimately provide for both the
granularity and the reliability necessary to ensure these maps
promote the goal of connecting every American and keeping every
American connected.
Thank you.
[The prepared statement of Mr. Oblizalo follows:]
Prepared Statement of Mike Oblizalo, Vice President and General
Manager, Hood Canal Communications
Introduction
Chairman Wicker, Ranking Member Cantwell and members of the
Committee, thank you for the opportunity to testify on the importance
of rural broadband mapping.
I am Mike Oblizalo, Vice President and General Manager of Hood
Canal Communications (HCC) in Shelton, Washington. I am a third-
generation employee of HCC, a community-based, family-owned business. I
have worked for the company for 33 years; and in that time, I have
worked in every position throughout the company, including
construction, splicing traditional cables, and identifying and
engineering new buildout areas. I have overseen all aspects of HCC's
grant projects, including writing applications, creating budget
projections, and the engineering and deployment of networks. I attended
Clover Park Technical College and Michigan State University, and I am
certified in engineering and telecommunication technologies.
Hood Canal Telephone Company (now known as Hood Canal
Communications) was founded over 85 years ago as a traditional local
exchange telephone company in Union, Washington. Union is located in
Mason County, a sparsely populated rural county. HCC has been owned and
operated by the Buechel family since 1956, when there were only 123
phone customers in the exchange. The family's commitment to the local
community led to the addition of cable television service in 1971, and
the company started offering dial-up Internet service in the 1990s. To
respond to customer demand, we migrated quickly to higher speed
broadband service starting in 2000. HCC currently employs 40 members of
our community, and we are frequently recognized for both our community
involvement and broadband deployment efforts within Mason County.
Within the last five years, HCC has won several awards from the Mason
County Chamber of Commerce and North Mason Chamber of Commerce,
including business of the year and volunteer of the year several times.
In 2002, HCC was awarded a U.S. Department of Agriculture (USDA)
Rural Utilities Service (RUS) Community Connect broadband grant to
deploy broadband service on the Squaxin Island Indian Reservation. This
project was extremely successful and brought broadband, cable TV, and
telephone service to the residents and businesses of the Squaxin Island
Indian Tribe. In 2004, we received a RUS loan for $1.77 million to
upgrade our network for better broadband deployment. In 2010, HCC
received another funding award in the amount of $3.6 million from the
USDA Broadband Initiatives Program to expand broadband, telephone, and
cable TV service into unserved and underserved parts of Mason County.
In 2017, HCC received another Community Connect grant for $2.3 million
with a 15 percent matching contribution. This grant allowed us to reach
551 homes and many more areas where growth is anticipated--with
broadband playing a key factor in stimulating that growth. This project
is currently under construction with an estimated completion time of
3rd quarter of 2019.
While HCC continues to extend its facilities into rural Mason
County, limited resources and a tight financial market make deployment
difficult without financing available from a partner like USDA. One of
HCC's goals is to serve the unserved or underserved in our local
community outside of our traditional incumbent serving area. We
continue to strive to meet these goals by looking for public/private
partnerships to deploy facilities.
At the same time, predictable and sufficient support from the
universal service fund (USF) overseen by the Federal Communications
Commission (FCC) is essential within our traditional incumbent local
exchange carrier (ILEC) service area to make the business case for
investment and to ensure that consumers can obtain services at
affordable rates in these deeply rural areas. Today, HCC's ILEC serves
nearly 1000 broadband subscribers and over 700 telephone subscribers,
while our expanded operation serves nearly 5000 broadband subscribers
and over 3000 telephone subscribers, plus an additional 3000 cable TV
subscribers. All told, HCC's service territory contains 1.45
subscribers per route mile. HCC takes great pride in serving these
rural residents of Mason County with essential broadband, telephone,
and cable TV services.
HCC's Experience With Broadband Maps
Broadband mapping is significant for companies like HCC that need
to leverage public-private partnerships to deploy networks and deliver
services in very rural areas. The FCC's broadband map and the mapping
tool maintained by RUS are the primary starting points in determining
where services are lacking and where resources from those agencies
might be leveraged to enable private network investment in rural areas.
But the lack of accurate maps and the need to refer to two different
mapping tools makes for a challenging process to determine potential
areas for broadband deployment and the availability of funding to
enable such deployment.
In fact, we find it is not unusual for ``conditions on the ground''
to look very different from those depicted on national maps. As a
recent example, HCC was evaluating offers of model-based USF support
from the FCC for its traditional ILEC service area--a movement away
from traditional cost-based support to incentive-based support under
the FCC's Alternative Connect America Model (ACAM). At the start of
that process a few years ago, the original ACAM support offer based
upon the FCC's map reflected what appeared to be 39 locations in three
census blocks that were alleged to be served by a competitive provider
other than HCC. We expect that the ACAM offer we will see soon now
reflects what we believe to be a total of 247 competitively overlapped
locations in three census blocks. One might think this is simply the
product of greater broadband deployment over time by that competitor
but based upon reviews of the other company's public information and
substantial familiarity with the physical serving area in question, we
estimate that only 62 of these locations in two census blocks are in
fact served by that competitor.
These concerns are not limited to just our incumbent service area;
we are seeing that imprecise data feeding into imprecise maps also
affects our ability to reach and serve other unserved rural
communities. For example, we have been looking at building in areas in
the northern portion of Mason County outside our traditional service
area. These locations are deeply rural and in very forested terrain.
But, according to the FCC's map, most of this area is currently served
by two different satellite providers that purport to offer speeds of 25
Mbps downstream and 3 Mbps upstream. One of these satellite providers
was just awarded USF support through the FCC's Connect America Fund
auction for this tract, which will keep anyone else from being able to
obtain funding to serve that area. But given the limitations of
satellite service--including lines of sight that are a significant
problem in forested areas, latency, and susceptibility to poor weather
conditions--the likely result is that consumers will lack meaningful
broadband access even though the map will now preclude anyone else from
obtaining funding or financing to deploy better networks and serve
there.
Accurate mapping data is therefore critical to the ability to
deliver and sustain service in rural America--and bad mapping data
risks leaving rural consumers stranded without broadband for years to
come at the very least. Without any validation process or the ability
to challenge the ``FCC Form 477'' reports submitted by providers that
are translated into the FCC's maps, the result is that ACAM and other
USF support is denied in areas where that support is in fact very much
needed--which then translates into rural consumers not getting served.
And that is perhaps the most important part of this problem While
improving the maps on the front end is undoubtedly important, without
any ability to validate or correct on the back end the self-reported
data that gets populated into these maps and then used by the agencies
to decide where funding should go, the end user is ultimately the one
who suffers.
What Drives Inaccurate Broadband Maps?
The accuracy of broadband availability maps is often in question,
as maps show services as available where consumers cannot get them at
all, and in other places these maps show speeds available at levels
that cannot consistently be delivered. The examples above illustrate
these common problems. There are several reasons that these issues
arise.
First, current broadband maps are based mostly, if not entirely, on
information received from providers. While providers certify the
accuracy of their reports, the processes used to verify the information
can vary greatly at the state level and are nonexistent at the Federal
level. Therefore, the maps essentially say whatever the providers who
populate them say. Moreover, the standards for reporting this data vary
and make it very challenging to verify--there is, for example, no
specific standard to ensure a wireless provider is reflecting
reasonable propagation of its coverage.
Second, on the Form 477 form that feeds into the FCC's broadband
map, a census block is reported as served simply because one location
in that block could be served by a provider. In rural census blocks
that can stretch large distances, this means that the delivery of
service to just one customer in a census block can result in the denial
of funding for voice and broadband to another customer located miles
away, yet still in the same census block, who literally has no choices
for such services. This disparity results in many unserved homes and
businesses looking served, especially in rural areas where census
blocks can be large. This issue contributed to the significant decline
in our potential ACAM USF support, despite the fact that we know not
all of the locations in those census blocks are served.
There has already been a lot of concern expressed--especially from
among members of this Committee--about whether the Form 477 data
accurately capture coverage in the mobile context. This focus is
understandable given the efforts to implement the Mobility Fund and the
visceral feeling of having no cell phone coverage in an area where
provider maps say one should. But, as HCC's experience indicates, these
concerns are just as prevalent in the context of fixed voice and
broadband services, too.
Third, the current standard for reporting an area as served depends
upon advertised rather than actual speeds, and also allows an area to
show as served if a provider believes it could deliver service there at
some point soon, rather than having the actual capability to do so in
the near term. In other words, there may be no service actually
installed in a census block, or the speeds actually delivered in that
block may not be equal to what is advertised--and, yet, that area can
show as served.
Finally, the current map does not capture buildout in progress that
is occurring pursuant to governmental initiatives like the FCC's USF or
RUS lending/grant programs. This means that there is the potential for
two governmental programs to in effect ``overbuild each other,''
allowing duplicative and competing networks to be built through two
different Federal programs.
What is the Solution?
My testimony above describes how the ``rubber meets the road'' in
terms of what bad mapping data means when it affects the ability to
serve specific rural areas. ``False positives''--locations shown as
served when they are not--can result in a denial of financing or
funding needed for a small, local committed company like HCC to deploy
and operate a broadband network, especially in rural areas where the
business case for doing so is so difficult. On the other hand, ``false
negatives''--locations appearing as unserved when they are already
served or are in the process of having networks built to them--can
result in a waste of financing and funding resources on duplicative
networks.
The reality is that any map will practically be outdated by the
time it is published. It is also the case that no one is going to
validate independently each piece of data and claimed coverage
submitted by a service provider the moment it is submitted. We
recognize too that there is a balance to be struck in terms of
obtaining more accurate and granular data while trying not to impose
burdens that have providers spending more time reporting coverage than
advancing coverage through network deployment. However, all this does
not mean we should not strive to improve this process.
Many different proposals are being presented to the FCC, and each
of them holds some promise to make the maps much better than they are
today. These proposals warrant significant consideration, and they may
provide a much-needed path forward toward better maps. But, at the end
of the day, as long as any map is based upon self-reported data from
providers and as long as that data is not vetted thoroughly by an
independent source, there will be a need for a challenge process prior
to relying upon the map to make decisions about where funding or
support should either go or be withdrawn. A more granular map can
certainly help identify more accurately where broadband is available,
but a meaningful and robust challenge process will remain critical to
validate both fixed and mobile data prior to any map being used by the
FCC or RUS (or any other governmental agency) to make final decisions
on funding or financing.
For many years, agencies like the FCC and RUS have developed and
used such challenge processes that treat service coverage information
like Form 477 data as informative but not dispositive. When these
processes are used, the maps become a ``baseline'' for determining
where support should or should not go, but the challenge process is
then used to confirm whether the maps are correct and to adjust them
when they are not.
Certainly, the recent experiences with the Mobility Fund show the
value and wisdom of continuing to use a challenge process. Without such
a process, the concerns that have been raised about overstated mobile
coverage would never have been identified. At the same time then, it
has been disappointing to see the FCC moving away from challenge
processes in the fixed service context. Specifically, the FCC has
refused recently to permit any meaningful challenge process at all in
the context of ACAM support, and it is now proposing to eliminate the
existing challenge process to validate Form 477 data in the context of
cost-based USF support--meaning that it would now instead default to
the self-reported Form 477 data effectively as gospel.
If HCC's own experience in rural Washington and the Mobility Fund
experience more broadly provide any lesson, it is that a meaningful
challenge process is a necessity in determining where funding should go
or where it should be denied. We therefore are hopeful that the FCC
will reverse course on its suggestion to eliminate a challenge process
in the context of distributing USF to support fixed networks, and that
it will commit to a data-driven process that ensures rural consumers
are not left on the wrong side of a digital divide due to inaccurate
information. We hope that an evidence-based challenge process will be
used in all contexts going forward to make sure even any improved maps
are as accurate as possible prior to funding or financing decisions
being made by agencies like the FCC or RUS.
Conclusion
HCC continues to strive to provide great service to its customers
in rural Mason County. However, as long as the Federal broadband maps
remain unreliable and riddled with erroneous, overly broad coverage
claims, we will not be able to maximize our efforts to reach all
unserved areas or to sustain services in areas where funding is needed
to do so.
Only a meaningful validation process, including the ability to
challenge data on the baseline map as inaccurate, will provide for the
granularity and reliability that is necessary to ensure these maps
contribute to the ultimate goal of connecting every American and
keeping every American connected.
Senator Wicker. Well, we must have put the fear in these
witnesses. They've all three so far come in under 5 minutes.
Mr. Spalter, we're glad to have you here today, and you are
recognized.
STATEMENT OF JONATHAN SPALTER, PRESIDENT
AND CHIEF EXECUTIVE OFFICER, USTELECOM
Mr. Spalter. I hope I can be consistent.
Thank you very much, Chairman Wicker, Ranking Member
Cantwell, Distinguished Members of the Committee.
I really appreciate the opportunity to be here to discuss
this incredibly important issue. It's really great to be here.
I'm Jonathan Spalter. I'm the President and CEO of
USTelecom. We represent broadband providers, suppliers,
innovators all, who really are united by the commitment to
connecting families, enterprises, and communities, urban,
rural, and everywhere in between to the power and potential of
broadband, and I really want to thank each and every one of the
members of this committee for sharing that commitment.
American broadband companies, to remind, have invested over
a trillion and a half dollars since 1996 of our own capital in
upgrading and expanding U.S. digital infrastructure.
One outcome, and it's a great outcome, for our rural
families, farms and ranches, hospitals, schools, and small
businesses, is that rural broadband access has risen more than
70 percent in the last decade. The beating heart of this
progress has really been our partnership with government
through programs, like the FCC's Connect America Fund.
Our members have worked shoulder to shoulder with
government to bring broadband to our Nation's hardest-to-reach
communities, overcoming challenging distances, terrain, and we
know economics to do so. Indeed, this collective effort has
already connected 5.7 million rural Americans to the high-speed
Internet under CAF II alone.
Connecting the final frontier of broadband requires
substantial resources. It also requires a clear-eyed view of
the challenge and that's where we really are coming up short.
Simply put, our Nation still lacks a comprehensive
connectivity map that can indicate with precision where high-
speed broadband is available and where it is not. You know,
there's a well-known management maxim that if you can't measure
it, you can't manage it. Equally true for broadband is if you
can't map it, you can't deploy it.
All stakeholders, from the Administration to Congress to
consumers to broadband companies to my fellow panelists this
morning, agree that the current yardstick collecting data by
census block is inadequate.
It means if a provider is able to serve a single location
in that block, then every location is considered served. Well,
combining the power of broadband and big data, we can do far
better than this one served/all served approach.
U.S. Telecom's recently launched Broadband Mapping
Initiative pilot is out to prove it. Quite literally, we aim to
map this gap by creating one cohesive national dataset
identifying all broadband serviceable locations. We can do it.
Our pilot begins in two states, Missouri and Virginia. With
the help of allied associations, including WISPA and ITTA, our
pilot will involve companies of different sizes and technology
types, including broadband heroes across the range of our own
membership, including AT&T and Consolidated, CenturyLink,
Frontier, RiverStreet, Verizon, and Windstream, and also our
friends at TDS.
Working together, we're going to harmonize and harness a
range of new digital resources, including satellite imagery,
digitized parcel, and land attribute data, a mix of open source
datasets and commercial software, managed crowdsourcing, and
existing broadband provider address information.
The pilot also will test different methods for reporting
and continually updating this more street level view of service
availability.
Our goal: it's a comprehensive database of all broadband
serviceable locations in our two pilot states and a roadmap for
a government-led effort to expand the system nationwide. We
anticipate the pilot program will be completed by Q3 of this
year and we look forward to sharing the results with the FCC,
with our partners at NTIA, and others, including this
committee.
If our aim is to leave no American behind, then the tools
and instruments we use in both the public and the private
sector must be capable of accurately pinpointing where we must
focus our efforts, our investments, and our scarce public
resources, and when they are, we believe now with our mapping
initiative in sight that broadband providers will be able once
and for all to deliver to all Americans the opportunity to
fully benefit from the global digital revolution our Nation
proudly leads.
Thank you very much. I really look forward to our
discussion this morning.
[The prepared statement of Mr. Spalter follows:]
Prepared Statement of Jonathan Spalter, President and Chief Executive
Officer, USTelecom
Chairman Wicker, Ranking Member Cantwell, and other distinguished
Members of the Committee, thank you for the opportunity to testify at
this important hearing. My name is Jonathan Spalter, and I am the
President and CEO of USTelecom--The Broadband Association.
USTelecom is the Nation's trade association representing broadband
providers, suppliers, and innovators connecting our families,
communities and enterprises to the future. Our diverse membership
ranges from large publicly traded global communications providers,
manufacturers, and technology enterprises, to small companies and
cooperatives--all providing advanced communications services to
markets, both urban and rural and everything in between.
Today's hearing presents a timely opportunity to discuss why
accurate broadband mapping is integral to accelerating the deployment
of broadband infrastructure to all Americans. Broadband service is no
longer a luxury; it is an essential component of our national
infrastructure and economic success, as well as the health, well-being,
safety, and prosperity of every American.
That is why American broadband companies have invested $1.6
trillion of their own capital since 1996--$76 billion in 2017 alone--to
upgrade and expand the Nation's digital infrastructure. As a result,
over the past decade, broadband access in rural homes has risen 71
percent.
USTelecom members also have enjoyed a strong partnership with
government through the FCC's Connect America Fund (CAF) to help deploy
broadband to the Nation's hardest to reach communities. Some of our
members began working on CAF II in 2015 to bring broadband to over 3.6
million rural locations--or more than 9 million Americans over six
years. As of March 1, 2019, these CAF II participants are in aggregate
10 percent ahead of schedule and, as a result, over 5.7 million more
rural Americans have an on-ramp to the internet.
While significant progress is being made, millions remain on the
wrong side of the connectivity gap. Part of the challenge is our Nation
lacks a comprehensive connectivity map indicating precisely where high-
speed broadband service is available and, most importantly, where it is
not.
There is a well-known management adage: ``if you can't measure it,
you can't manage it.'' Today, it is equally true that when it comes to
broadband, ``if you can't map it, you can't deploy to it.'' If our aim
is to leave no American behind, then the tools and instruments we use--
in both the public and private sector--must be capable of accurately
pinpointing where we need to focus our efforts. That is why USTelecom
has launched the Broadband Mapping Initiative pilot.
Why a New Broadband Map?
Currently, the FCC collects deployment data from broadband
providers by census block. Unfortunately, location data on homes and
businesses too often are not accurately reflected in census block or
other available data.
For example, if a provider is able to serve a single location in a
census block, then the FCC considers every location in that block
``served.'' Therein lies the challenge. In some cases, only a fraction
of locations in the block can access broadband services. This issue is
particularly acute in rural areas where census blocks are far larger
than their urban and suburban counterparts and data sources are
lacking. The ``one-served-all-served'' reporting is simply not a
reliable tool to accurately understand broadband availability, nor is
it a viable approach to identifying where scarce Federal support for
broadband deployment should be allocated.
There is broad agreement between industry and government on the
deficiencies of current reporting methods. When the FCC launched an
open proceeding on improving the FCC's broadband data collection
process, Chairman Ajit Pai said, ``Maintaining updated and accurate
data about broadband deployment is critical to bridging the digital
divide. It lets us target our efforts to those areas that most need
it.''
And when the Administration released its American Broadband
Initiative Milestones report, it referenced the need for ``more
comprehensive and granular data'' to provide an improved foundation
upon which to base broadband funding decisions. The report went on to
say, ``With limited funding available, getting better data to target
investments to under and unserved areas remains a high priority across
Federal and state agencies.'' As NTIA Administrator David Redl stated,
``In order to ensure that all Americans have access to broadband, we
need a more precise picture of the current services and infrastructure
that are available.''
Broadband Mapping Initiative Pilot
There is widespread agreement that policymakers need better and
more granular information about areas without broadband before they can
design efficient funding programs to address the problem, avoid
overbuilding, and track progress.
The growing use of competitive reverse auctions to distribute
broadband funding puts an even higher premium on having the best
possible data about the areas up for bid in order to ensure a fair and
cost-effective result. USTelecom members' recent experiences with CAF
programs, however, have revealed the type of granular mapping data
needed to efficiently fund targeted programs for broadband deployment
in rural areas is neither readily available nor consistent.
After working with innovative broadband companies and associations
across the country, and having discussions with key Federal and state
level government stakeholders and Congress, USTelecom launched the
Broadband Mapping Initiative pilot to quite literally ``map this gap.''
Our mission is to create a consistent national dataset identifying
all broadband serviceable locations using a single methodology to
provide a harmonized reference point for broadband reporting. The
Broadband Mapping Initiative pilot, using modern data analytics, will
deliver a more detailed and cohesive view of where broadband is, and is
not.
Here's how USTelecom's proof of concept pilot program will be
implemented:
We will begin in two states--Missouri and Virginia--with the aim of
developing a single, comprehensive next-generation broadband mapping
system for the Nation. With the help of our partners at ITTA and the
Wireless Internet Service Providers Association, our pilot will involve
multiple companies of different sizes and technology types, including
AT&T, Consolidated, CenturyLink, Frontier, RiverStreet, TDS, Verizon,
and Windstream.
Working together, we will utilize new digital resources, including
satellite imagery, digitized parcel and land attribute data, a mix of
open source data sets and commercial software, and existing broadband
provider address information. These data sets will be combined and
organized by conforming addresses, removing duplicates, cross-checking
information with carrier-provided address lists and using managed
crowdsourcing to review records for accuracy. The pilot also will test
different methods for reporting service availability. Carrier size and
technology is likely to influence the method that works best for each
participant, and we anticipate testing several methods including:
reporting by individual address/location; submitting shape files of
service area; and submitting results of propagation maps for fixed
wireless service. Once this process is complete and a full set of
broadband serviceable locations is identified, carriers will be able to
report where they can provide broadband.
Creating a database at this level of granularity is a major
endeavor and enlisting the help of consumers and state officials on the
ground will help confirm, correct, and refine the data. We are
attempting to map in a highly dynamic environment where service
deployment, homebuilding, business development, natural disasters, and
developments in GIS resources create a constantly changing landscape
that must be updated and improved over time. In addition to a
systematic schedule to refresh data and reporting, this pilot is
designed to support a cooperative, collaborative approach to creating
and maintaining an important national data source.
The hoped-for result? A comprehensive database of all broadband
serviceable locations in our two pilot states--and a roadmap for a
collaborative government-led effort to expand the system nationwide.
We anticipate the pilot project will be completed by Q3 of this
year. At the end of that period, USTelecom and its consortium will
submit the pilot results into the record in the FCC's open Form 477
reform proceeding. We expect the pilot will provide clear evidence that
this methodology is scalable and achievable in a timely and cost-
effective manner and should be adopted nationwide.
USTelecom also is closely coordinating with NTIA, which recently
issued a contract for a new mapping platform to update its national
broadband availability map. The initial map will include available
nationwide data for every state combined with additional state-level
data from eight states it has identified as part of a pilot program.
USTelecom looks forward to collaborating with NTIA going forward to
ensure our efforts are coordinated and complementary.
The opportunities associated with accelerating rural broadband
connectivity require an enduring public private partnership. USTelecom
and its member companies stand ready to work with this Committee,
Congress, and the Administration to improve broadband mapping, a
critical step toward closing the digital divide. A sustained effort
will take time and resources, along with partnership, imagination and
innovation, but these are essential if all Americans are going to have
the opportunity to fully benefit from our Nation's global digital
leadership.
Thank you again for this opportunity.
Senator Wicker. Thank you very much, Mr. Spalter.
Mr. Strange, you're welcome.
STATEMENT OF CHIP STRANGE, VICE PRESIDENT,
STRATEGIC INITIATIVES, OOKLA, LLC
Mr. Strange. Thank you.
Chairman Wicker, Ranking Member Cantwell, and Members of
the Committee, thank you for the opportunity to testify today
on how we can collectively improve the vital maps used by you
and other policymakers to help broadband networks reach more
Americans.
My name is Chip Strange, and I'm the Vice President of
Strategic Initiatives at Ookla, LLC, where I'm responsible for
Global Strategic Partnerships, Industry Relations, and
Government Affairs.
I've spent my entire career in the telecommunications
industry with 13 years in strategic and operational roles at
Alltel and later Verizon Wireless and the last 9 years working
in network intelligence and mapping.
Founded and headquartered in Seattle, Washington, Ookla is
a global leader in mobile and broadband network intelligence,
testing applications, and technology. Our family of companies
include Mosaik, a provider of network coverage, spectrum, and
infrastructure data and mapping software, Downdetector, a real-
time digital services monitoring platform; and Ekahau, a
provider of industry standard Wi-Fi network planning and site
survey tools.
Our clients include many of the largest telecommunications
companies in the world--including small, medium, and large
fixed and mobile service providers, telematics, financial
services, and Internet companies in the United States.
Ookla is part of Ziff Davis, the digital media subsidiary
of J2 Global, a Los Angeles, California-based Internet
information and services company.
The strong support from our parent company enables us to
operate like a business many times our size while staying
nimble and focused.
Our flagship platform is Speedtest, which provides
invaluable insights into the performance, quality, and
accessibility of networks worldwide. The Speedtest platform is
available as a native application on computers, mobile devices,
and Apple TVs. It may be integrated into third party mobile
applications, is embedded on consumer routers, and at
speedtest.net.
My written testimony includes some background about our
products, data collection channels, the depth and breadth of
our datasets, and our geospatial expertise. But our most
valuable asset is our team whose commitment to our consumers is
rivaled only by the quality of our data science, our ability to
visualize complex data on maps, and our enthusiasm knowing that
we play a role in improving networks for consumers worldwide.
I sincerely appreciate the opportunity to share a few
considerations for the committee.
The first is that improving broadband maps demands more
aspirational thinking, private sector innovation, and, yes,
considerably more funding. It also requires that the government
focus on analyzing data provided by the private sector, and
less on replicating technologies and creating datasets that
already exist at scale in the marketplace.
Second, accurate broadband availability and performance
data analysis and mapping should be considered national key
performance indicators. The United States should approach
broadband infrastructure data like other economic KPIs to be
consistently measured and analyzed.
Third, we need to embrace and explore diverse perspectives
from the industry, the Federal Government and states, and run
pilot programs to test different data collection options
unbound by regulatory lag.
We have mechanisms to harness the power of consumer
crowdsourcing to increase data density across America,
including data collection vehicles, like drones, commercial
fleets, and other means where unique topographical or
demographic challenges exist.
Federal and state government workforces can be vital
resources to augment existing datasets. FEMA, first responders,
and the Department of Agriculture and other officials can help
build a stronger national broadband map without impacting their
missions. However, we must also establish levels of
methodological uniformity to ensure we don't repeat the
mistakes of the past.
And finally, Internet speed, latency, and quality metrics
will always be key components when assessing the reach and
performance of networks. However, with edge computing,
connected cars, accelerating video consumption, and other
emerging use cases that require highly accessible network
access, new coverage and performance metrics have been
developed to ensure we look at current and future demands and
not settle for yesterday's measurement options.
In conclusion, Ookla has globally respected methodologies,
has developed applications to comprehensively collect massive
amounts of data, has the analytical prowess and data
visualization tools necessary to make sense of it all.
We operate with transparency and have a keen focus on
respecting the privacy of our user communities. We are trusted
by consumers, industry, and governments worldwide, and are
excited to help you get the maps needed to extend broadband
networks to unserved and undeserved areas in the United States.
Thank you. I look forward to your questions.
[The prepared statement of Mr. Strange follows:]
Prepared Statement of Chip Strange, Vice President, Strategic
Initiatives, Ookla, LLC
Introduction
Chairman Wicker, Ranking Member Cantwell and members of the
Committee, thank you for the opportunity to testify today on Broadband
Mapping: Challenges and Solutions.
My name is Chip Strange, and I am the Vice President of Strategic
Initiatives at Ookla, LLC, where I am responsible for global strategic
partnerships, industry relations and government affairs. Headquartered
in Seattle, Washington, Ookla is the global leader in mobile and
broadband network intelligence, testing applications and technology. We
have 195 employees with deep expertise in fixed, mobile and Wi-Fi
network technologies, data science, mapping solutions, applications
development and machine learning. Together, we support many of the
largest telecommunications companies in the world--including large,
medium and small service providers in the United States. We are a data
provider to United States Federal and state governments and the
exclusive global network performance data provider to the intelligence
division of the mobile industry trade group GSMA.
We are part of Ziff Davis, the digital media subsidiary of J2
Global, a Los Angeles, California-based Internet information and
services company.
Ookla's family of companies includes Mosaik, a provider of network
coverage, spectrum and infrastructure data and mapping software;
Downdetector, a real-time digital services monitoring platform; and
Ekahau, a provider of industry standard Wi-Fi network planning and site
survey tools.
One of our core principles is providing transparency on the state
of the Internet to three distinct constituencies--consumers, industry
and governments.
Ookla provides consumers with accurate information on the
quality and performance of their own Internet connections. We
routinely share data insights with consumers through in-depth
articles analyzing the state of global networks and a monthly
updated ranking of countries by mobile and fixed broadband
Internet speed. We also consistently provide expert analysis
and data to members of the press, academia and non-profits that
are seeking substantiated information about networks.
For the telecommunications industry, Ookla provides valuable
benchmarking analytics to optimize and improve networks,
assists operators by validating claims used in advertising
campaigns and helps them position their networks to consumers
and enterprises.
Ookla provides governments and industry associations with
accurate, unbiased and independent data about the performance
and accessibility of the internet.
Ookla is An Unbiased Source of Network Coverage and Performance Data
Our flagship platform is Speedtest, which provides invaluable
insights into the performance, quality and accessibility of networks
worldwide. The Speedtest platform is available as a native application
on computers, mobile devices, and Apple TVs, may be integrated into
3rd-party mobile applications, is embedded on consumer routers, and on
Speedtest.net.
Since the launch of Speedtest in 2006, we have collected 23.4
billion consumer-initiated network performance tests. In 2018 alone,
the global Speedtest community performed approximately 3.65 billion
tests, of which 405 million occurred in the United States.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Ookla's commercial mobile network database is updated quarterly and
includes carrier-reported coverage patterns for 2,500 different
networks built by more than 900 operators globally, of which 238
networks were built by 88 carriers in the United States. Our company's
tower infrastructure database has approximately 451,000 vertical assets
and represents the only curated database of its kind in the United
States. As part of our efforts to paint the most accurate picture of
mobile network availability, in 2018 we began collecting radio
frequency measurements from Speedtest applications, enabling us to
create hybrid mobile coverage maps that fuse both reported and measured
coverage. During March of 2019 alone, Ookla collected over 6 billion
mobile coverage measurements from 13 million devices globally.
Finally, to ensure we have the most accurate network performance
measurements, we have an unprecedented 8,100 Speedtest servers
worldwide, including 1,200 in the United States--and I am proud to say
at least one server in every state and territory. If a consumer is
measuring Internet speeds in Mississippi, it's best to test to the
nearest server, and our methodology dynamically selects the best server
for that individual test to provide a more accurate portrayal of true
Internet performance.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
The culmination of all of these data points means that Ookla has a
comprehensive view--both analytically and geographically--of fixed and
mobile broadband networks across the United States.
Opportunities in Broadband Mapping
As we all know, highly performant broadband networks help fuel
American education, innovation, productivity and economic growth.
Closing the digital divide and ensuring access to state-of-the-art
connectivity is vital for full participation in the 21st century's
educational system and economy. Many of the amazing technologies that
empower businesses--in cities, suburbs, exurbs, rural communities and
on farms--rely on fixed or mobile broadband to thrive.
Here are a few thoughts for the Committee's consideration:
Broadband data is a national key performance indicator.
Accurate broadband availability and performance data, analyses and
mapping should be considered national key performance indicators. The
United States should approach broadband infrastructure data like other
economic KPIs, consistently measured and analyzed. It should not overly
rely on one-time data collection activities, particularly when
collected based only on data mandated by the Federal Communications
Commission. This data is incomplete and out-of-date from the moment it
is relied upon by policymakers. That outcome must and can be fixed.
Fixing poor maps is an economic problem, not a technological one.
Improving broadband maps demands more aspirational thinking,
private-sector innovation and yes, considerably more funding. It also
requires that the government focus on analyzing data provided by the
private sector, and less on replicating technologies and creating
datasets that already exist at scale in the marketplace. Let's leverage
taxpayer dollars to activate and radically improve data density from
successful products already in the market today, instead of the
government building products that compete with the private sector.
Engage communities and embrace new approaches.
We need to embrace and explore diverse perspectives, from the
industry, the Federal government and the states, and run pilot programs
to test different data collection options unbound by regulatory lag. We
have mechanisms to harness the power of consumer crowd-sourcing to
increase data availability across America, including data collection
vehicles like drones, commercial fleets or other means where unique
topographical or demographic challenges persist. Having run a pilot
mobile network data collection program with a large commercial fleet,
it is indeed viable and worth further exploration.
Move beyond the focus on speed.
Internet speed, latency and quality metrics will always be key
components when assessing the reach and performance of networks.
However, with edge computing, connected cars and other emerging use
cases that require highly accessible mobile network access, new
coverage and performance metrics such as percent time spent on LTE and/
or 5G networks are also important to fully assess the quality of mobile
networks. These new metrics will not only help policy makers steer
investment in the right areas but may also be used to assess whether
the entities receiving support are delivering on their promises.
Furthermore, knowing where existing fiber and tower infrastructure
exists will help reduce the costs to taxpayers when the government
subsidizes networks constructed by private companies, while also
accelerating their development.
Deploy government resources the right way.
Federal and state government workforces can be vital resources to
augment existing datasets. State broadband mapping initiatives are
generating pockets of really interesting data. FEMA, First Responders,
USDA and other officials can help our government understand the state
of networks to help build a stronger national broadband map, without
impacting their missions. However, we must establish levels of
methodological uniformity to ensure we don't repeat the mistakes of the
past.
Conclusion
Ookla has globally respected methodologies, has developed
applications to comprehensively collect massive amounts of data, and
has the analytical prowess and data visualization tools necessary to
make sense of it all. We operate with transparency and have a keen
focus on respecting the privacy of our user communities. We are trusted
by consumers, industry and governments worldwide, and we are excited to
help policy makers in the United States get the maps you need to help
extend broadband networks to underserved and unserved areas.
Senator Wicker. Well, thank you very, very much, and let me
ask all of you. Let me start with Mr. Donovan.
How much of a solution is increased coordination like
between the FCC and NTIA? How much of a solution is that?
Mr. Donovan. Increased coordination does go a long way to
informing on the maps. We should be using an all-of-government
approach, to use all resources available, especially seeing as
the status quo has not yet produced a reliable map.
Other sectors of the government, such as the Department of
Interior, are making maps available of where they own resources
that could be used to deploy broadband. If we can combine that
with maps that show where the coverage gaps exist, we can start
looking toward solutions.
Senator Wicker. And, Mr. McCormick, I guess we should add
USDA to that list of agencies.
Mr. McCormick. Yes, sir. I think it's critical for Rural
America and our farmers to have the FCC, your committee, and
USDA collaborating on a way that we can get connectivity to
Rural America.
Senator Wicker. Anyone else want to comment on that? Mr.
Strange, what do you think about Mr. Spalter's pilot program
that he mentioned?
Mr. Strange. Well, I think it's an excellent step. I think
understanding the underlying mapping considerations around
where structures are, where commerce occurs, or where people
live is a vital component. So I applaud the efforts of U.S.
Telecom in embracing that approach.
However, I do believe that we must move with speed. There
are opportunities that exist today to take advantage of
understanding where the networks are today while they work out
their pilot, and while they work out ultimately their plan,
but, no, I applaud the effort.
Senator Wicker. And, Mr. Spalter, you want to respond to
that?
Mr. Spalter. I do appreciate that support, but it's also
important to understand that, yes, we also believe that speed
is important. We believe that if we actually move quickly,
embrace some of these new datasets that are now finally
available in the marketplace, integrate them into a
foundational database that can actually scale and be available
for national use in a comprehensive harmonized perspective on
where locations are and where they're not, we can do it
quickly, we can do it cost effectively, and we can do it in
ways that are actually going to deliver more broadband to more
rural Americans than ever before.
Senator Wicker. Do you think legislation is needed, Mr.
Spalter? You're saying that the agencies need to do this.
Mr. Spalter. There are pilot programs in response to a
current rulemaking process that's undertaken by the FCC in its
effort to modernize the 477 reporting process. It's responsive
to that.
If statutory input is required to actually succeed in
scaling and building a national map that is actually going to
be able to create a pathway for ensuring that all rural
Americans can get broadband and we can use scarce public
resources effectively, then, yes, I think a statutory approach
is important and could be complementary.
Senator Wicker. Does anyone want to speak up in favor of
the Form 477?
[No response.]
Senator Wicker. Let me ask any one of you. How long have we
known that this form is deficient and doesn't ask the right
questions, therefore gets the wrong information? You know,
actually, I just haven't known this myself very long and I
wonder if I've just been looking in the wrong direction.
How long have any of you known about the deficiencies in
Form 477? Anyone want to comment there? Yes, Mr. Donovan?
Mr. Donovan. Well, thank you, Mr. Chairman.
Senator Wicker. Then Mr. Spalter.
Mr. Donovan. So, the Form 477 in its current state, as
Chairman Pai has recently noted, is showing its age after a
decade of service.
I think the challenge here is that the 477 was not designed
to be a snapshot that could be used for distributing resources
on where service is or is not. It was initially designed to
show over time how services were being deployed and while it
may have some utility at that, it's not designed for this
current purpose of distributing Universal Service Fund support.
Senator Wicker. Mr. Spalter.
Mr. Spalter. The 477 reporting process was well conceived
but innovation, as our companies move at lightning speed and
since the inception of 477, we've recognized that it needs to
be modernized and it needs to be modernized in a very quick
clip.
There have been extraordinarily important new datasets,
satellite imagery, land parcel attributes, road segment data,
commercially available datasets now finally have come online.
We need to integrate them and in so doing, which we're trying
to do with our mapping initiative, we think that we can
actually supersede and perfect the 477 process.
Senator Wicker. And that's going to cost some money. Is
that what you're saying?
Mr. Spalter. Nothing is free, but we think we can do so in
a way that's actually going to be enormously cost effective,
particularly in comparison to previous broadband mapping
efforts.
Senator Wicker. Thank you very much.
Senator Cantwell.
STATEMENT OF HON. MARIA CANTWELL,
U.S. SENATOR FROM WASHINGTON
Senator Cantwell. Thank you, Mr. Chairman, and thank you
for holding this hearing and I am forgoing my opening statement
and apologize for being a little bit late. I'm forgoing my
opening statement because I feel like too much talking has been
done about mapping and we need to do more action.
So in that regard, I wish I could put, Mr. McCormick, your
statement from your testimony on a billboard and just shop it
around everywhere. You said, ``Broadband is no longer a luxury.
It's a necessity.''
So when you look at farm communities, and, Mr. Oblizalo,
thank you for being here, you also represent a different kind
of community, rural in nature but not as big on ag but
certainly on seafood and so appreciate you being here. Mr.
Strange, thank you for mentioning the technology that might
help us bridge the gap and make it happen faster without the
same level of investment.
But back to you, Mr. McCormick, this is the overlap between
one of the big juggernauts of the American economy, which also
has the biggest, I think, future opportunity, given that, you
know, we're trying to open world markets and ship product to
new destinations.
Ag represents the largest focal point of why broadband is
so necessary in rural communities. I think you mentioned
200,000 member families in your state. Is that a multiple of
your farms? Is that what that is?
Mr. McCormick. That's just how many members that we have in
Mississippi Farm Bureau. We have about six million members in
the American Farm Bureau system across the United States.
Senator Cantwell. But 200,000, that's a lot of people in
Mississippi. So is that like----
Mr. McCormick. We not only represent farmers, we represent
rural Mississippi, as well.
Senator Cantwell. Oh. So you can be a member of the Farm
Bureau Association?
Mr. McCormick. Yes, yes,----
Senator Cantwell. OK, OK.
Mr. McCormick.--Senator.
Senator Cantwell. So what I'm saying is that's such a big
number and it represents an economic engine that is, you know,
to me once a community has that economic engine, that's when
broadband in my opinion should be required. We just have to
work out the economics of how we're going to make that happen.
But if you have that many members living in rural parts of
the state that could or could not be served, you know, we're
just leaving a lot of innovation behind, a lot of economic
growth behind if we're not serving it, and I just think we have
to stand up for farm country and say it's time to deliver
broadband and the mapping thing, we'll figure it out, but the
real issue is how we're going to deliver it.
So, Mr. Oblizalo or Mr. Strange, do you have any comments
on how we move to the next phase beyond mapping to deliver that
broadband? Any strategy discussions that you'd like to put on
the table?
Mr. Oblizalo. Well, really, we're a provider. I don't deal
a lot with, you know, how to get there. What I focus on is the
communities that we try and serve and there are challenges for
us to provide these services using the different data sources
out there, the FCC, the USDA maps.
If those areas are opened up and funding becomes available
for them, those are definitely opportunities that we would look
at to provide broadband in some of those rural areas that are
truly unserved.
Senator Cantwell. Mr. Strange, do you know a multiple of
what you think that new technology, you know, versus build-out,
say 15 years ago, what new technology costs might be in doing
some of the other technology deployments?
Mr. Strange. So with respect to technology deployments for
the actual broadband infrastructure itself? I can't speak to
that. That's what our carrier and operator clients and people
that are building the networks would know better.
I can speak to the technologies required or needed to
understand what's happening on the ground, however. In that as
the Mobility Fund II Challenge Process has illuminated us all,
which was a very thorough process to go through to try to
understand how can we ensure that the maps are as accurate as
possible. What that has proven, with all of the efforts and
goodwill associated with that--is that it's a really, really
hard problem to solve and we have to be much more creative
about how we approach it.
So I think that one way that we look at it is to think
about all of the money that's invested in the infrastructure
for broadband and ensure that a component of that is in
validating that the maps are correct and verifying that the
build-out that has been promised is occurring. And there are
existing technologies in place to support that effort.
Senator Cantwell. Well, I definitely support having
accurate information, but I think we've got to get to the next
phase of why the gap is there to begin with.
We just have too much competitive disadvantage by not fully
serving these areas and again Hood Canal, you've kept pace and
thank you for doing that in innovative ways, but I think what
we need to do is really have a clear understanding of what the
cost of build-out.
We just were able with CenturyLink to get them to go all
the way to Neah Bay. Well, you know anything about our state,
as you two gentlemen do, you know Neah Bay is a long way away
even from Port Angeles, you know.
So what was the cost of CenturyLink building all the way
out, you know, to Neah Bay and what are the relevant
communities in their challenge and what role should the Federal
Government play in that versus focusing on those providers?
So, anyway, lot to discuss. Thank you, Mr. Chairman, so
much for the important hearing.
Senator Wicker. Thank you.
Senator Fischer.
STATEMENT OF HON. DEB FISCHER,
U.S. SENATOR FROM NEBRASKA
Senator Fischer. Thank you, Mr. Chairman.
Mr. McCormick, broadband connectivity in our homes and
workplaces and schools is essential to our quality of life and
in the ag states, like Nebraska, and in Mississippi, access to
high-speed broadband is also critical for farmers and ranchers
so that they can take advantage of connected technologies that
boost agriculture production.
Mr. McCormick, do you agree that any future maps should
have the capability of also showing which areas, such as
cropland and ranchland, have the broadband connectivity needed
to support economic activities that aren't tied to an address?
Mr. McCormick. Thank you, Senator. We absolutely agree with
that and think that's key of this conversation for Farm Bureau,
is that we need to make sure that rural areas, farmland and
ranchland, are covered under these maps so we can get the
connectivity where our farmers need it to be.
The equipment now is so extremely expensive that we use on
our farms, but a lot of that cost in those units are from
technology and if we aren't connected with the internet, that
technology is useless to that farmer. So he's paid a lot for
those assets that he's not going to be able to use. It's key to
changing the maps to show that we can get some connectivity in
Rural America.
Senator Fischer. You know, agriculture right now, I think,
is the third largest user of the Internet of things, that cool
new technology that's out there that's going to improve
productivity, make farming and ranching more efficient. It's
really an opportunity for better management of our resources
and growth of our economy in this country. So I totally agree
with you that we have to look at how that's going to be made
available.
How do you think we can improve mapping so it doesn't leave
farmers and ranchers on the wrong side of the divide here?
Mr. McCormick. Well, I think one of the keys is going to be
to move away from the census block data and go to more granular
data, smaller areas of use. We're just going to have to be
cognizant of the fact that the need leaves the population
centers and that we've got to look at some type of area
formulation to make sure that the farmland and the ranchland
across the U.S. is connected which is so critically important
to the future of being able to feed not only our country but
the world.
Senator Fischer. And like in Mississippi, Nebraska Farm
Bureau also got a waiver from the FCC to challenge the Mobility
Fund Phase II Map. However, one of their major difficulties in
challenging locations on that Nebraska map was converting the
testing data to shape file format so it could be sent back to
the FCC.
Did Mississippi Farm Bureau have similar difficulties with
that?
Mr. McCormick. We did, Senator. We found very quickly that
we were not equipped to be able to handle this challenge, that
we didn't even have the staffing or the capabilities of doing
it. We worked with the Public Service Commission there and they
asked us to continue it and we did.
We had our members work through this process. We were able
to challenge about 8,400 data points and in the end we were
unsuccessful on all of those, which would look like a failure
but in our part, we wanted to show that this is so complicated
for us that it was impossible and it was absolutely impossible
for a consumer to do.
Senator Fischer. Thank you.
Mr. Donovan, in your estimation, are there technical
hurdles for smaller providers when it comes to incorporating
those shape files and the GIS software?
Mr. Donovan. Thank you. Yes, so for all providers
experiencing challenges with this, there's a reason why of the
106 entities that entered into the portal, only 21 were able to
present valid challenges at the end.
So we've got about a fifth of all entities that were
challenging the map that were able to provide successful
challenges. We've got to do better than that.
On the Internet of things, I want to thank you for your
leadership on Internet of things development. Part of why we
need coverage everywhere is by their nature, things that rely
on mobile networks are mobile. It's not tied to one location.
So from precision agriculture to telehealth cures and other
exciting opportunities, it's important to have robust coverage
everywhere.
Senator Fischer. How can policymakers address the concerns
that we saw with the mapping and the inability to be able to
get that input?
Mr. Donovan. The biggest thing we could do to help is to
start with a better foundational map, to tighten the
parameters. If you have a process that's built on a foundation
of sand, there's very little we can do to keep perfecting it.
We need to go back and make sure that it's a solid foundation
that will reduce the need to have all these challenges and will
start with a better base map.
Senator Fischer. OK. Thank you. Thank you, Mr. Chairman.
Senator Wicker. Here's where you were not a failure, Mr.
McCormick. Through all the effort that you and the Public
Service Commission and other civic-minded Mississippians made,
we determined that the challenge process is simply unworkable
and, frankly, worthless.
The map is inaccurate and it's almost impossible using that
challenge process to demonstrate this. It needs to be fixed and
no program should go forward, unless we are satisfied in the
Congress that the process is going to actually touch areas that
need it.
So maybe you'll be given a chance to respond to that later.
But now it's Senator Rosen's chance for questions and you
are recognized.
STATEMENT OF HON. JACKY ROSEN,
U.S. SENATOR FROM NEVADA
Senator Rosen. Thank you, Mr. Chairman, and thank you for
that great lead-in because I agree with you there.
We must have reliable open source aggregate data, one that
accurately reflects availability and usage while protecting
individuals' privacy. If we don't have that on a platform open
source that everyone can use, we're not going to get good maps
and be able to point the way. If we get this good aggregate
data that everyone can use, that's going to point the way for
us to use multimodal technologies, whether they're broadband,
wifi, air-fi, something we haven't even invented yet that's
going to help us approach this problem across Rural America.
In Nevada, we are the most mountainous state in the Lower
48. So we have terrain issues and we have ranchers and farmers,
as well, but we have rugged terrain. In some states, Nebraska,
the Midwest, they're flat. They don't have terrain issues. They
have long distances. So this reliable open source aggregate
data and the accuracy of that is important.
You know, in Nevada, my state, we have a 100,000 people
without access to broadband. Over a million don't use the
Internet at good broadband speeds. In Elko County, only 79
percent of residents have access to broadband and a lot of them
can't even take advantage of it.
So there is a lot of jarring work ahead of us and so what
I'd really like to ask you. We know there's datasets
everywhere. It's not a question of how much data. It's a
question of how we use the data and how we can help us point
there.
So is there data we're not collecting that you think that
we could put there or what would you suggest to create this
aggregate data platform that all, whether you're a farmer,
whether you're the government, whether you're a provider, end
user, whatever you are, can take this and model it for your
industry? Anyone, please.
Mr. Donovan. Thank you, Senator, and to your point on open
source, having some sort of a public feedback mechanism can
certainly be a positive step in the right direction on how you
fix this, but the fundamental core is when you're asking what
data you're collecting, is how precise you want those answers
to be, and the more precise we can get in terms of the factors
that you're collecting, the tighter your base map will be.
In states like yours, one of the big problems we have in
the challenge process is that to do drive testing, you need
roads.
Senator Rosen. Right.
Mr. Donovan. So it was impossible to challenge much of your
state. Instead, some of the factors--I mentioned in my opening
the cell edge probability and that's how far you get from the
cell and you're likely to receive service.
Going from a 90 percent the industry typically builds to,
to the 80 percent that the FCC asks for changes the cell
parameter by about 27 percent.
Senator Rosen. Oh, I just drove 650 miles from one end of
Nevada to the other to Westwind. Trust me, lots of places that
we didn't have any service on our roads and highways.
Mr. Donovan. We should have given you drive test equipment.
Senator Rosen. I'm telling you, I did, I would have taken
it.
Mr. Spalter. Senator, if I may, first of all, thank you for
your question.
To the point about what kinds of new data do we need to
actually integrate and aggregate to create this vision of a
comprehensive uniform assessment of where locations are
serviceable and where they're not, there is great news to
report.
As Mr. Donovan said that we have now a garbage in, garbage
out approach, we need to go to a data in, data in approach.
Using new kinds of datasets, both commercially available but
also open source, which we propose to do in our National
Broadband Mapping Initiative, that would integrate, for
example, platforms that Microsoft is developing in its rooftop
satellite imagery that have only come online in the last couple
of years, parcel data, land attribute data that has actually
been digitized now and is available through states and
municipalities.
Senator Rosen. Right.
Mr. Spalter. We need to bring road segment data to bear so
that those of us who have been in the business for decades of
trying to deliver very difficult circumstances broadband to
rural Americans can utilize the best resources that are out
there and create a foundational database upon which you----
Senator Rosen. I'm a former software developer. So I
understand that you're only as good as the data you collect. I
believe that we have multi-points to bring this up together so
then we can let the end users download those particular fields
within that data. It will make sense for them to model for
their industry.
So how do we get there? How can we help you pull this
together to create this useful dataset, if you will?
Mr. Spalter. Well, first of all, this hearing and these
public discussions about the necessity and the existential
necessity that we have to get this done right are very
important.
When we complete our Broadband Mapping Initiative Pilot in
Missouri and Virginia, we want to share with you the results of
our finding for your committee's evaluation. We will also share
it with our colleagues that we've been working closely with at
NTIA and the FCC.
We want to be able to then utilize that as much as
crowdsourcing and other types of opportunities for consumers to
actually look and feel and touch this effort so that we can
actually improve our confidence this will be the basis upon
which we can achieve this goal of a workable scalable national
map that will get broadband to where it's needed most in Rural
America.
Senator Rosen. Well, my time is just about up, but I look
forward to that and any help that I can give you, I think it's
really important and something we need to do.
Thank you.
Mr. Spalter. Thank you.
Senator Wicker. And thank you, Senator Rosen.
Senator Blackburn.
STATEMENT OF HON. MARSHA BLACKBURN,
U.S. SENATOR FROM TENNESSEE
Senator Blackburn. Thank you, Mr. Chairman. I sure
appreciate the hearing and it's good to see some of you back
talking about this issue. You would think we would have worn it
out by now, right, but we've still got progress to make.
Mr. Donovan, I have to tell you when you started your
testimony, I was kind of chuckling. I thought he is quoting me
about these 477 maps and it's good to hear you all agree that
they have outlived their usefulness and it is time to just get
past this and do some things differently.
Mr. McCormick, welcome. Having grown up in Mississippi and
having family there, I can tell you 80 percent of that state
does not have access to high-speed Internet or broadband and so
much of what we want to achieve and I will tell each of you I
think that--and I appreciate the Chairman's attention to this,
but as we talk about broadband and the mapping and as we talk
about 5G and all the good things that are in front of us and
the revolutionary nature of 5G, how it is going to be so
different from the previous generations, what we have to do is
make certain that the mapping and the access to broadband is
going to be there when consumers say wow, this is fantastic,
why didn't we know this was coming, and we know this will be a
reaction because we saw this reaction when we went from analog
to digital and this will be just as revolutionary.
Mr. Strange, I want to start with you. Prior to the merger
with Ookla, Mozaik was headquartered primarily in Memphis.
Post-merger, is Memphis going to continue to be an important
part of Ookla?
Mr. Strange. Thank you, Senator. And, yes, it most
certainly is, and interestingly enough, a great deal of Ookla's
geospatial or mapping expertise exists in our Memphis office.
And we're happy to say that the integration has gone very well
there.
Senator Blackburn. Excellent. That is great. Senator
Manchin and I sent a letter earlier this year talking about the
need for technology-neutral platforms and that type approach to
mapping.
So, Mr. Strange, talk a little bit about the crowdsourcing
that you all can do with the geospatial technologies.
Mr. Strange. Yes, Senator. So, crowdsourcing can be a much
more vital component to our national mapping initiatives than I
think the Federal Government has utilized thus far.
Mr. Donovan mentioned extending drive test capabilities
into rural parts of the country when lawmakers are traveling
around. If you simply downloaded our publicly accessible Speed-
test application, you could collect similar type of information
and then all of that gets rolled up for use by a Federal agency
that is licensing it.
Just to speak to the scale of our footprint, in the United
States alone, consumers are performing around a little more
than one million consumer-initiated speed tests every day. So
that is a user actually hitting go on the Speed-test
application.
If we were to more fully activate that capability and
extend those technologies and those options out into Rural
America, into the farmlands, attach these capabilities on to
more heavy machinery, more vehicles, more consumers, you're
going to be able to activate a much larger dataset, unlike----
Senator Blackburn. We'll have a more accurate mapping and
the scalability of it is possible----
Mr. Strange. Absolutely.
Senator Blackburn.--because it is app-based and you're able
to--an individual can download and participate----
Mr. Strange. That's correct.
Senator Blackburn.--and send it right back to you.
Mr. Donovan, I want to come to you. When I handled Ray
Baum's Act in the House and we pushed that forward, of course,
getting money out and then with the Ag Bill, the 600 million in
RUS, I'd like to hear from you quickly about how you think that
money is being used in that pilot program, what kind of
expansion are you seeing, and what we can do to further
utilization of those funds.
Mr. Donovan. Thank you, Senator. So briefly, that window
for that funding is about to open. One of the best ways that we
can make sure that it goes the right places is to use more
targeted maps, you know.
Speaking with your colleagues on the Agriculture Committee
earlier this year, Secretary Perdue said the FCC maps are fake
news and not reliable for using for distributing funds. So we
can work together with coordination across industries, across
different organizations of the government to make sure that
those funds are well targeted.
Senator Blackburn. I yield back.
Senator Wicker. Thank you, Senator Blackburn.
So, Mr. Donovan, that Act is really just now ready to be
implemented.
Senator Tester.
STATEMENT OF HON. JON TESTER,
U.S. SENATOR FROM MONTANA
Senator Tester. Thank you, Mr. Chairman, and I want to
thank all the witnesses for being here.
Look, in my early parents' time on the farm, rural
electrification was being done and done pretty successfully,
although, you know, it had some problems. There was the same
old stuff. The investor-owned utilities didn't want co-ops to
come in and it's interesting that nonetheless they got the job
done and rural electrification happened and, quite frankly,
Rural America was allowed to grow and expand and I think the
same kind of parallels could be drawn with broadband.
I think you would all agree that the maps are inaccurate.
Are they inaccurate just because some of the companies
overstate their coverage to keep subsidized companies out or is
there another agenda there? Go ahead, Mr. Donovan, or anybody
else that wants to.
Mr. Donovan. So a primary flaw is that the parameters that
the FCC asks carriers to report data are overstated, so that
carriers can report data that is both correct in terms of what
the FCC asks for, as well as not useful for what you or I would
consider to be reliable.
Senator Tester. OK. But why would they report data that's
inaccurate? Why would the carriers do that? You can be honest.
This stays in this room.
Mr. Donovan. So smaller carriers, you know, serving these
rural areas, it's their neighbors that they're serving. If you
overstate your coverage, you're going to hear about it and
that's why small carriers have pushed to have more accurate and
tighter parameters included in the process.
Senator Tester. Well, I would just say this. I mean, I
guess my thought is it probably has something to do with the
competition and people see an area and they don't want somebody
else moving into it, whether it's got service or not. They
might move into it someday. I may be oversimplifying it, but in
the end, in rural areas, if we're going to move into the 21st
Century, this is pretty basic stuff as electricity was in the
1940s. So this is pretty basic 21st Century economy.
And so, I mean, whose responsibility should it be for
verifying the accuracy of the data? Is it the regulator, the
consumer, the competitors, third parties? Who's primarily
responsible for verifying the accuracy because we're going to
have them in here next week and just tear them apart?
Mr. Donovan. So the FCC does have an enforcement
investigation going on right now.
Senator Tester. So would you say that they're the primary
people?
Mr. Donovan. Right now, yes, the regulator is in charge of
the verification and the carriers verify that it's correct.
Senator Tester. So it's--yep.
Mr. Donovan. I think the bigger question that's been raised
for the hearing today is whether they're asking the right
questions.
Senator Tester. Yes. Well, you know, I'm a farmer. I'm not
part of the FCC. It would seem to me that there's job to ask
the right questions. Wouldn't it seem to you that? I mean,
we're not talking about putting a man on the moon here, right?
Mr. Spalter. If I could, Senator, it is true that the FCC
reposes authority to verify the data that it is required and
asks for----
Senator Tester. Yes.
Mr. Spalter.--carriers through its 477 process, but again
there have been advancements that we are integrating into our
broadband mapping initiative that allow for broader
verification beyond the FCC but through crowdsourcing
mechanisms, through allowing once a map is actually finally
scaled for consumers who actually go in and verify----
Senator Tester. Yes.
Mr. Spalter.--adequacy of the data,----
Senator Tester. Right.
Mr. Spalter.--the migration of the data to new
circumstances, and create feedback loops so that consumers
through crowdsourcing and through direct access to the database
actually can become part of the solution.
Senator Tester. So they could give feedback back to the FCC
to make sure that the decisions that are being made are
accurate?
Mr. Spalter. And the accuracy of the underlying map itself.
Senator Tester. OK. All right. Sounds good. Mr. Donovan, I
just got about 50 seconds left, but a couple months ago, your
boss sat before this committee. I asked him what we need to do,
what your members need to do to address the Huawei issue. He
said that they need direction from authorities. Two months
later it's been.
Have you received any direction from authorities?
Mr. Donovan. We are in the process of having continued
discussions with some of your colleagues as well as some of the
intelligence community to make sure that carriers have the
information that they need.
Senator Tester. So where are you at in that process without
giving away any classified information or are you at the point
where the decision's going to be made as to what's happening
there or what?
Look, I'm not on Intel. I'm not on Armed Services. I'm not
on Foreign Affairs. But this doesn't smell quite right to me
and so if there's a problem, we need to get folks in the room
who know what the problem is and we need to make a decision to
either get this equipment out or not worry about it anymore.
Are we close to that?
Mr. Donovan. I think we are, sir. One of the challenges
that we still have is identifying, you know, exactly what needs
to come out and making sure that carriers in these rural areas
have the resources necessary to do so.
Senator Tester. All right. Well, we look forward to your
input on that and then we'll get it moving forward.
Thank you, Mr. Chairman. Thank you, guys.
Senator Wicker. Senator Tester, you're right. We're in the
21st Century. We're one-fifth of the way through the 21st
Century and here we are with so many unserved Americans.
I think you were also suggesting that it might be for
someone to come in to this committee room in the future and
suggest that these maps were anywhere near worthy of even
looking at and being guided by would be just utterly
ridiculous.
Senator Tester. I think you read that suggestion correctly.
Senator Wicker. I thought I got the impression there.
Senator Tester. Yes, you did.
Senator Wicker. We may not quite have the solution, but we
know what isn't the solution.
Senator Blunt.
STATEMENT OF HON. ROY BLUNT,
U.S. SENATOR FROM MISSOURI
Senator Blunt. Thank you, Chairman.
I assume this question might have been asked already, but
does anyone here think the maps are worth relying on?
[Witnesses shake heads no.]
Senator Blunt. So, you know, in our state,----
Senator Wicker. Negative response of all five.
Senator Blunt. I saw that. Nobody thinks--nobody on this
panel thinks the maps are worth relying on. I don't think
anybody on this committee thinks the maps are worth relying on.
We have some specific underserved areas, unserved areas that
could have been served with a better map even in the last round
of the distribution of money.
Fifty-one percent of rural Missourians don't have access to
high-speed broadband, which is above the national average and
very concerning, going to be a critically important part of the
ability to compete in the future, and I think is important in
the next 10 years as the telephone was 70 years ago, and we
need to make the same kind of commitment.
So the Missouri General Assembly is trying to make money
available. They're actually--they have so little faith in the
maps that they're thinking about coming up with their own maps.
I know, Mr. Spalter, we're one of the states you're looking
at. Could you talk about your process a little bit and maybe
why Missouri and states like Missouri were selected to be part
of that, and then are there other mapping proposals or other
projects out there that link up with this in a way that we're
going to come up with some better information based on what
you're doing?
Mr. Spalter. Thank you for that question, Senator Blunt,
and we're very proud and glad to actually launch our pilot,
including in Missouri.
The inception here was very clear. We need to do better to,
if we are going to actually have a broadband map that works, we
actually have to be able to map to serviceable locations where
they are but also where they're not and so what we are doing is
aggregating new data sources, both public and private open
sourcing commercial, contributed by our companies, contributed
by third party companies, to actually create a foundational
database that will allow for a very clear delineation of where
serviceable locations currently exist.
We're going to de-duplicate and improve the confidence
score of that data through crowdsourcing. We're going to layer
on geo-coding, specific geo-location attributes to the
locations that we find. Then we're going to invite our broadest
range of technology providers to overlay on top of this
foundational database their shape files and other types of data
that will ultimately be able to then be provided to our
government partners, the FCC, which is we're doing this work in
response to their rulemaking on 477 modernization, and our hope
is that this will become the foundation for a single harmonized
comprehensive national broadband map that shows where America's
broadband serviceable locations are and where they're not.
When that happens, this will become a tool that will be
able to be complementary to any government initiative in
developing maps, be it at the FCC, at the NTIA, where we've
been closely coordinating with their project that they're
elaborating in eight states, or even beyond, but we all know,
as we've discussed here in this hearing, that we have to start
with a new view of creating a foundational database with these
new data assets that have come online just in the last couple
of----
Senator Blunt. So you'll be able to use geo-positioning and
other things to show that maybe one small section of a census
track may have been barely served but that doesn't mean you can
check the track off as an area that has had broadband service?
Mr. Spalter. Absolutely. But the other innovation is that
we can go beyond address level reporting to actually reporting
where locations are, be they residences or schools or hospitals
or barns or granaries or ranch facilities.
This is the new frontier. We can go from broadband to the
mailbox to broadband to actually where it's needed most which
are not only the locations that are served but where they're
currently unserved.
Senator Blunt. Mr. Donovan, do you have any idea of why
there--would there have been any advantage--what would be the
advantage of exaggerating your coverage area if--let's assume
you didn't just make up the coverage but you, benefit of the
doubt, you sort of exaggerated your coverage, is this just to
keep competitors out or why is that a problem with these maps?
Mr. Donovan. Well, part of it is a reflection of how people
are using their mobile devices today. It's no longer just a
cell phone that you want enough service to make a voice call.
Instead, now you need to have the data connectivity to access
all of these incredible innovations, machine-to-machine
technologies, Internet of things.
The reliance on having access to robust data services is
ever-more important and having that access is drilling down to
a more granular level of service to be able to have the service
levels that you'd expect to be able to run those applications.
Senator Blunt. OK. Thank you, Chairman.
Senator Wicker. But aren't you being a little kind, Mr.
Donovan? Senator Blunt's question was what possible motivation
might there be for such an exaggeration?
Mr. Donovan. If you don't have reliable maps, then small
carriers serving rural areas will not be able to access
programs, like the Universal Service Fund, to be able to
preserve and expand their services. So it will control how many
resources are going into your states to expand coverage.
Senator Wicker. What about larger carriers exaggerating?
Mr. Donovan. So larger carriers are operating on a
nationwide scale and so they have maps that oftentimes look at
a higher resolution level. So it's a challenge that needs to
direct the nationwide carriers to also provide the same
standardized info that some of the smaller carriers would
provide.
Senator Wicker. I'm not making any conclusion there. I just
thought it was an interesting line of questioning that we might
ought to give more attention to Senator Blunt.
Senator Baldwin.
STATEMENT OF HON. TAMMY BALDWIN,
U.S. SENATOR FROM WISCONSIN
Senator Baldwin. Thank you, Mr. Chairman.
So we've heard today about the burdensome nature of the
Mobility Fund II's Challenge Process and I've heard the same
thing firsthand from wireless companies in Wisconsin who want
to invest in rural and unserved areas but instead have expended
a lot of time and resources on challenging the accuracy of the
FCC's map.
At a hearing last August, Commissioner Rosenworcel and I
discussed our over-reliance on industry alone to tell us
service exists, whether that data is submitted by incumbents or
through those costly efforts undertaken by other companies as
part of the challenge process, and we've heard today from
several witnesses about crowdsourcing from consumers as a way
to get better data.
But I'd also like to get some perspectives on an idea that
Commissioner Rosenworcel and I discussed that Federal agencies
that are already operating in rural areas should do more to
bear the burden of having accurate maps.
There are Federal resources and personnel on the ground,
like, for example, the Postal Service vehicles that deliver
mail and Forest Service personnel working in our national
forests, and I think we should be able to leverage their
presence to contribute to our knowledge of what's truly
available to consumers in those places, particularly with
regard to wireless coverage.
Mr. Donovan, given your members' experience on the ground
testing as part of the Mobility Fund Challenge Process, do you
agree that it makes sense to leverage those kind of Federal
resources to collect more accurate data on broadband service?
Mr. Donovan. Thank you, Senator. Yes, it does. So any model
propagation of where service will exist is just that, a model,
and you still need to have some verification of real-world
testing.
We do need to start with a better starting point.
Otherwise, regardless of who you assign to verify that, the
task is too large. One of my members spent over $2 million
testing their service area, including your state, and even with
that resource load, only got to about 5 percent of their rural
service footprint.
So the challenge is too immense with the current map that
we have. There is a role for verification and the FCC can
certainly play a role in that, but we need to start off in a
better place.
Senator Baldwin. Thank you.
Mr. McCormick, you also testified about the Farm Bureau's
engagement in this challenge process. Do you agree that these
additional resources, such as using Federal employees and
equipment that's on the ground across the United States, would
be helpful?
Mr. McCormick. Thank you, Senator. We would suggest using
any tools in the toolbox that we could possibly use to help
this mapping situation, especially those in rural areas, and
getting away from just using access to addresses and to focus
on ranchland and farmland as a critical need in this process. I
think those two entities could definitely help.
Senator Baldwin. Mr. Strange, your company has a tremendous
amount of experience with consumer-driven testing of broadband
speed and quality. There's been a lot of discussion today about
the value of crowdsourcing and improving the accuracy of
broadband maps.
Part of the reason for our conversation today is that our
reliance largely on industry-provided data has not given us the
quality of maps that we really need, but I don't want us to
simply trade one type of data for another unless we're
absolutely sure that it provides better information.
So, Mr. Strange, if we depend more heavily on information
provided by consumers through testing apps, like your own, how
can we ensure that that is reliable quality data that can be--
I'm particularly interested in the comparisons across geography
and technology.
Mr. Strange. Thank you for the question, Senator, and I
would say that, first of all, I don't believe as high-quality
datasets that we produce at Ookla that we will be able to ever
replace information provided by the service providers
themselves as part of a comprehensive national broadband map.
I do think that there are options about where that
information sits and how it's being used. I certainly won't
speak for operators' intentions, as Chairman Wicker pointed
out, but in my time at an operator and this has long since
passed there was always concern about giving information to the
regulator for fear of downstream consequences, right, and so
that's why you wind up with carriers following very
prescriptively what they're instructed to do by the FCC when
mandated to give them data.
With respect to crowdsourcing, I think that regardless of
how we cut the data up, we have to get measurements in the
field and crowdsourcing can be a huge activator for that.
Speaking of Federal agencies and those resources that are
deployed nationally, we certainly should use them as resources.
But we also need to do so without impacting their mission,
which is how it's much easier for us to be able to support that
because we can have an application running on an existing
device that they don't necessarily have to interact with that
can help us collect information very broadly. This is as simple
as our downloading our Speedtest application from the Play
Stores or sitting down and talking about what precisely we want
to collect from the geographies that are different and ensuring
that we collect the right data in the right place--and we have
the technologies to do so.
Senator Wicker. Thank you, Senator Baldwin.
Senator Capito.
STATEMENT OF HON. SHELLEY MOORE CAPITO,
U.S. SENATOR FROM WEST VIRGINIA
Senator Capito. Thank you, Mr. Chairman. Thank all of you
for being here. I'm sorry I was not here for the rest of the
testimony, lots of meetings going on at the same time.
You know, I find this whole hearing just so frustrating. I
represent West Virginia. We have some of the lowest deployed
broadband in the country. I feel like we've been talking about
this over and over and over again to try to figure out why we
can't get service to other places. We hear different reasons
and then the inaccuracy of the maps and all this.
So I think you'll find in a bipartisan way we're really
interested in helping you and everybody else solve this issue.
So I guess my first question, West Virginia is going to be
a part of the new NTIA Updating the Eight State Partners
because we have a Broadband Council that's been very aggressive
with this because we've decided that the FCC and others can't
meet this challenge. We're going to have to do it ourselves.
I guess the one thing I would ask is, do you find that
with--and I'll just throw it open to whoever--with the
inaccuracy of the data that we have right now that we know is
inaccurate, has this been part of a move that has snuffed out
competition in the more rural areas and the more diverse areas
because we don't have competition. We're getting more and more,
but we don't have competition. Nobody's competing for these
last mile kinds of deployment of broadband.
Does anybody have a comment on what the effect of poor
mapping has done for the competitive environment in the areas
that are still left under-and unserved? Yes, Mr. Donovan.
Mr. Donovan. Well, Senator, so we have a bit of a Catch-22
here. In these rural areas, you are only eligible for resources
in places where there is no unsubsidized competitor, but if we
have the map saying that there's an unsubsidized competitor,
then you're not eligible for the money. So it brings it
straight to the core of today's hearing that there are
resources and programs available to help states like yours have
expanded service, but we need to make sure that the right areas
are eligible so that competitors can go into those markets, bid
for support, and build out service.
Senator Capito. So the way it's structured and with the
poor mapping has led to a non-competitive environment in a lot
of places, which is what's slowing it up.
So I'm on a bill with Senator Klobuchar because we're
concerned, we're on the Rural Broadband Council, that the
deployment in urban areas is not apples to apples as it is in
the rural areas. I mean that's pretty obvious. So we want to
get the standards that we're expecting in the urban areas, we
want to get our standards in the rural areas to be at least
comparable and so far we haven't seen that.
Does anybody have a comment on that initiative?
Mr. Donovan. Well, it's not anything new. Congress has
directed the creation of Universal Service Fund Program to have
reasonably comparable services in urban and rural areas. The
challenge now is to make sure that we look at what is
considered to be reasonably comparable and that's the services
that the program is delivering.
As we're now a fifth of the way into the 21st Century, that
needs to include having access to the latest wireless
technologies.
Senator Capito. The other excuse why West Virginia in
particular doesn't have as good deployment of broadband is our
terrain. We are the Mountain State. I hope you've visited
there. It's very nice. And I have a hard time believing that
because I believe for decades we've been talking about--we've
been able to communicate with people on the moon and we can't
figure out a way to deploy broadband in a mountainous state.
So I think it's just an excuse again as to why we haven't
had deployment into maybe the less profitable areas than more
populated areas.
Does anybody have a comment on the challenges of deploying
broadband in terrain and what that would do toward the
availability of broadband?
Mr. Donovan. So, Senator, the funds are generally
distributed now on a reverse option basis. So the carrier that
can bid the least to provide coverage over the most square
miles wins the support.
One thing that should help for states like West Virginia in
Mobility Fund Phase II is the now inclusion of a terrain
factor.
Senator Capito. Right. We got that in there.
Mr. Donovan. So as long as we make sure those areas are
eligible, that terrain factor will help.
Senator Capito. Mr. Spalter, did you have a comment?
Mr. Spalter. I do, very briefly. First of all, thank you
for introducing your legislation with Senator Klobuchar and
advancing our future for mapping.
It is true that terrain, distance, and other factors do
impede and make more expensive different kinds of broadband----
Senator Capito. Right.
Mr. Spalter.--deployment to pull fiber to various terrains,
particularly in mountainous areas where the underlying
topographies can be challenging.
We know that, you know, for pulling a mile of fiber, a
linear mile of fiber can range anywhere from $20,000 linear
mile to over a $100,000 linear mile, depending on where you
actually--what kind of terrain you're traversing.
So these are real economic impediments that have to be
thought through in a public-private way and why we actually
need to continue to focus on our goal of extending the
opportunities for direct grant support through mechanisms like
the FCC's Universal Service Funds and Connect America Funds
added by and accelerated by national comprehensive and
harmonized maps of where broadband serviceable locations are
and where they're not and if we can do both, we're going to be
able to, I think and I hope, still competition, potentially----
Senator Capito. Right.
Mr. Spalter.--make the costs of broadband deployment less,
and actually most importantly serve our ultimate goal of
getting rural broadband to more rural Americans.
Senator Capito. And at the root of it is the accuracy of
the data that we have in hand. Thank you.
Mr. Spalter. Absolutely.
Senator Wicker. Thank you, Senator Capito.
Senator Thune.
STATEMENT OF HON. JOHN THUNE,
U.S. SENATOR FROM SOUTH DAKOTA
Senator Thune. Thank you, Mr. Chairman.
Mr. Oblizalo, can you elaborate on your company's
experience with the different Federal maps and how they've
guided or affected your business decisions and then perhaps
provide any specific examples where you think errors in the
maps have led to your inability to deploy broadband in
particular service areas and harmed consumers?
Mr. Oblizalo. Yes. Definitely. We serve very rural portions
of Mason County. We're always looking for funding available,
whether it's through the reverse auction and the USDA grants to
expand out.
Just recently, we're building a community connect grant
right now. There's a census block that is served, the census
being served, but it's clearly not. So these customers are
going to be left unserved. It is a wireless product that we
need to provide but that's an example.
Another example is a section, as Ranking Member Cantwell
talked about, on the Olympic Peninsula, that again is being
served by two satellite providers, two facility-based providers
and neither of them provide services in these areas. So, again,
these customers are left unserved also in this area.
So we really look at use of maps, FCC and the USDA's, to
try and figure out how to get funding to serve these
communities that are truly left behind.
Senator Thune. This is for anybody that wants to answer it,
but if agencies, like the Rural Utilities Service and USDA and
the FCC, collect broadband information in the same format,
could that help them coordinate where to target funding to
avoid overbuilding?
Mr. Spalter. Harmonization coordination between government
agencies that are in the business of developing broadband maps
is absolutely critical to support it. We've had consultations
with our colleagues in all of the agencies that are trying to
stoke the broadband engine in America. We think that that is
absolutely critical. The more coordination the better.
Senator Thune. Yes. Everybody, I assume, agrees with that.
Yes. Well, it would be nice if that would happen.
Mr. Donovan, you mentioned in your testimony that the
challenge process for Mobility Fund Phase II was overly
burdensome. What mechanisms and procedures should be in place
to make this process more efficient and reliable?
Mr. Donovan. Thank you, Senator. So in states, like South
Dakota, one of the large problems we found with the challenge
process was that the requirement to have multiple data points
within one kilometer square grids meant that large portions of
your state were unable to be checked via drive testing. There
just aren't the roads to be able to collect sufficient data
points.
So to fix that, you know, the single biggest thing we could
do is to start with a map that requires less verification, to
start with a more granular map, but beyond that, a challenge
process that includes a larger buffer zone to make sure that if
you have data proof that there's no service along different
portions of a highway and then the highway turns, you can
assume that there's no service if there are no towers in
between that, and that should be a valid challenge. You
shouldn?t have to have one kilometer square grid road patterns
in order to be able to verify whether or not there's service.
Senator Thune. If the maps are inaccurate, what would you--
and to any of you--say are the most harmful implications
specifically in rural areas from a Federal funding perspective?
Mr. Spalter. Overbuilding, duplication, poor stewardship of
Federal public resources, delay and slowing down of the actual
delivery of broadband to communities and enterprises and
families that need it most.
Senator Thune. Anybody else have anything to add to that?
Covered the gamut.
Mr. Oblizalo. I agree that it ends up in over-reporting and
underreporting of these areas and those are like the false
positives I talked about in my testimony.
Some areas can be said as being served but they're truly
not and these customers are going to be left unserved or even
if the broadband maps don't show programs that I am currently
building out and I could have a competitor come in and build
into my area that I'm currently looking at using USF funds for
to build out.
So definitely issues and I think there definitely needs to
be a challenge process and process.
Senator Thune. OK. All right.
Mr. Donovan. Senator, so I think my colleague mentioned
that the customer experience, you know, that's the ultimate
concern at the end of the day is consumers in Rural America who
are getting left behind. You know, consumers on the street
don't care about what the radio frequency link budget is to
establish a map. They know if they have service or if they
don't, and so we need to get closer to having something that
makes sure that these consumers are able to take advantage of
the services brought by Internet today, but also all the
innovations that are coming with the wave of 5G that's on the
horizon.
Senator Thune. All right. Thank you all very much. Thank
you, Mr. Chairman.
Senator Wicker. Senator Blunt for a follow-up question.
Senator Blunt. Well, on the 5G topic, and I may have missed
this discussion earlier and I can look at the record for that,
but really two questions would be, one, is 5G going to be an
even bigger challenge for Rural America than where we have been
with the previous versions and, two, are there any unique rural
solutions, like satellite deployment or something that makes
this work in ways that it wouldn't work otherwise?
I have a feeling that it would be easy based on at least
the urban installation of 5G. If that's the only model, it's
going to be real easy for Rural America to get further behind
instead of catch up faster. So is that right, and what do we do
to--are there discussions that you all believe have benefit as
to how to find unique solutions to Rural America on 5G that
wouldn't need to be the same solution in a more urban
environment?
Mr. Donovan. Senator, you're exactly right. So 5G will be
built upon today's 4G services and if you're in rural areas, if
you start to fall behind on your Gs, you may never catch up.
So how do you get there? One of the differences in urban
and rural deployments, some of it's going to be the spectrum
frequencies that you use in rural areas, you're more likely to
use low band or mid band spectrum. There's currently several
proceedings on some of that mid band spectrum that balances
both some of the speed and capacity capabilities as well as
propagation characteristics to make sure it travels far enough
in rural areas. So we need to make sure that that spectrum is
available in rural areas.
It does contribute back to one of the issues we found with
the current data collection for the map, that as you do use low
band spectrum, that tends to get loaded faster, meaning that
because while it does travel further distance, it doesn't have
some of the same capacity. So you need to make sure that the
FCC is asking for a significantly higher loading factor to
account for the way that people in rural areas are actually
using their wireless services.
Senator Blunt. Can we just go down the line here? Mr.
McCormick.
Mr. McCormick. One of the issues that was spoken about just
a little while ago was the difficulty of terrain and the
ability to get broadband access because of that terrain.
One of the things that I found talking to some of the ISPs
in our area is that pine needles on pine trees are some of the
bigger deflectors of broadband signal because the width of the
pine needles are exactly the same size as the band width.
They're tremendously--it's like a wall of trying to get that
through that.
So I hope when we're talking about getting this to rural
areas that we understand all of the complexities of the
terrain, not just mountains or whatever. It's going to be
things like pine trees and other things that may not have been
thought about at this point that's going to be an impediment to
get it to rural areas.
Senator Blunt. OK. Mr. Oblizalo.
Mr. Oblizalo. Yes. We struggle in Washington, too, like the
terrain, the deployment, weather conditions, the dense forest,
the foliage that we have up there. There's a lot of issues with
wireless or if it's a cellular device.
Senator Blunt. But with 5G, you're obviously not going to
be able to put--you're unlikely to put a new booster every--the
equivalent of the city block or two blocks. So what are we
going to be able to do?
Mr. Oblizalo. With wireless? I am not a wireless expert by
any means. I am a landline facility-based. We usually build
fiber to the home in our area.
Senator Blunt. Mr. Spalter.
Mr. Spalter. Sure. Thank you. Our 5G future as a nation is
going to be built and based on our ability to pull fiber as
ubiquitously and as extensively and as quickly everywhere, not
just in our urban environments but in our suburban, ex-urban
and, most importantly, our rural areas.
We've come to talk about our 5G future as wired wireless
and so we need the policies, we need the resources, and we need
the facilities to be able to dig the trenches, pull the fiber,
climb the poles, and privilege that activity if we're going to
succeed in the global race in 5G.
Senator Blunt. Do you think that's going to happen with 5G
in Baltimore?
Mr. Spalter. I hope so. I hope it's going to happen not
only in Baltimore but----
Senator Blunt. Do you think it will be pulled wire? Do you
think it will be pulled wire?
Mr. Spalter. The final last mile of any 5G wireless network
is built and based on the fiber-based backhaul opportunities
that actually exist through the wire-line businesses, like Mr.
Oblizalo's and many of our members that are trying to develop
these dense, secure, scalable fiber networks that are
indispensable and on which 5G wireless networks ultimately
rely.
You mentioned also, Senator, about satellite. Yes,
satellite technologies can help deliver the benefits of
broadband. We know that. Some of our members, like CenturyLink,
are working in places like Whitmore, Colorado, to partner with
companies like HughesNet to deliver last mile broadband to most
rural hardest-to-reach farming communities and that kind of
community.
But we know that satellite companies have to be able to
deliver the same quality of service under the same terms on a
level playing field as any other competitor in the broadband
ecosystem. Some did extremely well in the CAF II auction
process and have come back and have asked for variances in
quality standards for voice telephony, which is so important to
rural Americans.
We say yes, let a thousand flowers bloom and technologies
deliver broadband but make sure it's all done on a level
regulatory playing field where we all can fairly compete not
only for customers but for Federal resources.
Senator Blunt. Mr. Strange, I'm beyond my time but not to
leave you out, anything you want to add to that?
Mr. Strange. I will just add that with respect to 5G
specifically in Rural America, there are certainly some on the
mobile side or on the wireless side, there are fixed wireless
opportunities utilizing 5G technologies.
Tim referenced the mid band spectrum that can be supportive
of that. Some of your millimeter wave and very, very high
frequency spectrum that's available in the marketplace today is
not going to be as useful in an extremely rural area, but I do
believe that there are opportunities for 5G in Rural America.
We just have to make sure that they have access to the spectrum
and access to ultimately the fiber networks to help them
deliver them.
Senator Blunt. Thank you.
Senator Wicker. OK. Mr. Spalter, we didn't get rural
electrification till we actually ran the power out to the end
of the dirt road.
Mr. Spalter. Yes.
Senator Wicker. Are you saying satellite can help, but as a
general rule, we're going to have to big time run fiber out to
the end of the dirt road?
Mr. Spalter. AS quickly and as best as we can in public-
private partnerships working with facilities, like the FCC's
Connect America Fund, and with our smart modern regulatory
frameworks that will incentivize more investment, more
innovation from the part of our companies to be able to do so.
Senator Wicker. Well, you know, this isn't a 5G hearing,
but I think Senator Blunt has touched on a very, very important
subject that we'll need a lot more discussion about. So thank
you, Senator Blunt, and thank you.
Senator Blumenthal.
STATEMENT OF HON. RICHARD BLUMENTHAL,
U.S. SENATOR FROM CONNECTICUT
Senator Blumenthal. Thank you, Mr. Chairman, and thank you
to Senator Wicker for having this very, very important hearing,
and to you for giving us the benefit of your insights and
expertise in this area.
I know a lot of ground has been covered. I'd like to come
back to the issue of pricing data. As you know, there's really
very little transparency on the costs of broadband across the
country. The Form 477 data tells us where broadband might be
accessible but not whether it's affordable, and I think it's
important for Congress and Federal agencies to understand how
pricing differs across the United States and whether broadband
is affordable, really affordable to individual consumers and to
communities that regard it as important and all do.
A consumer might have the option of high-speed broadband
but if that service is priced out of reach then it might as
well not be available. So the Pew Research Center has published
several excellent studies that demonstrate that cost remains a
key obstacle to broadband adoption. If we don't understand how
price factors into the Digital Divide, we won't address the
obstacles facing fixed-income Americans or ordinary working
people.
So let me ask all of the witnesses in the limited time, and
I apologize, limited time that I have. Advocates, researchers,
journalists have been asking for transparency on broadband
pricing for more than a decade.
Would you support requiring the disclosure of price
information in the Form 477 data? Maybe we can just begin and
go down the table.
Mr. Donovan. So, we do not survey our members for what
price offerings they have, but I'm happy to talk with our
members and get back to you with additional information.
Senator Blumenthal. Well, I appreciate that, if you're
unable to give me a position today.
Mr. McCormick. Senator, the same with Mississippi Farm
Bureau Federation. We wouldn't have a policy on that exact
question, but we would certainly be willing to get back with
you on that.
Mr. Oblizalo. Senator, we use the National Exchange Carrier
Association's tariff for our set rates. All of our information,
all of our rates and speeds are listed on our website. So we
would not have a problem sharing that information on the 477.
Senator Blumenthal. So you'd have no problem with it. The
two prior comments were in effect they'll have to get back to
us, is that correct?
Mr. Oblizalo. Yes, like I said, we're public and we sell to
the end user.
Senator Blumenthal. Great.
Mr. Spalter. We would have to evaluate that very carefully
on a company by company basis, Senator Blumenthal. There are
existing requirements, statutorily and otherwise, truth-in-
billing and beyond, that would require accuracy in pricing
data.
Our mapping exercise initiative is not focused on pricing.
It's about finding serviceable and non-service locations.
Ultimately, however, the 477 process, if it were to ingest any
such pricing data on a required basis, it is our sincere hope
that that data would not be used to get into the business of
rate regulation.
Mr. Strange. Senator, I work for Ookla and we are a data
company that keeps up with network performance globally on both
mobile and fixed broadband networks. So it's not an area that I
have the expertise to even comment on.
Senator Blumenthal. I take your answers for what they are
and I would welcome any supplemental views you can provide.
Let me ask another question. Would you support including an
assessment of economic barriers to broadband access in the
FCC's Broadband Deployment Report? Let's go down the table
again.
Mr. Donovan. Sure, we are open to discussing how you could
include some of those factors in the broadband report.
Mr. McCormick. Certainly out of my area of expertise, but I
think we would support that.
Mr. Oblizalo. Yes, we would support that, too.
Mr. Spalter. Additional datasets that can provide a more
comprehensive and holistic view of availability in the United
States are important. We would love to evaluate that question.
Mr. Strange. Again, it's an area that's outside of my
expertise. I wouldn't even want to comment.
Senator Blumenthal. My time has expired, but I would
welcome that you do explore these issues and that you come back
to us with any views that you have because, I'm stating the
obvious, economic barriers are as important as physical
barriers to broadband access. If you can't afford it, you won't
have it, even if it's theoretically available.
So thank you, Mr. Chairman.
Senator Wicker. Thank you, Senator Blumenthal.
Senator Sinema.
STATEMENT OF HON. KYRSTEN SINEMA,
U.S. SENATOR FROM ARIZONA
Senator Sinema. Thank you, Mr. Chairman, and thank you to
our witnesses for being here today.
Arizonans in rural and tribal areas need access to fast
high-quality broadband. As we know, broadband is no longer a
luxury, it's a necessity, and it's crucial for rural Arizonans
because broadband is an essential tool for developing our
economy, educating our families, and providing quality health
care.
But reports show that as many as a 162 million Americans do
not have access to the Internet at broadband speeds, which
prevents our communities from implementing new advancements.
Next week, for instance, I'll be attending a roundtable in
Show Low with the VA and community partners. We'll be
discussing the problems they're having with telehealth because
of the lack of fast mobile broadband in the region.
And one of our tribes, the Havasupai Tribe in Northern
Arizona, cannot access their online charter high school because
they don't have sufficient broadband access. So obviously we
need to do better.
And as we heard from you all today, the first step to
addressing this problem is fixing the massively flawed
broadband maps. Inaccurate maps delay the spending of Federal
broadband funds and misdirect those dollars to the wrong
places.
It's vitally important that we make these maps as accurate
as possible as soon as possible and we need to get these
billions of Federal dollars working to improve the broadband
access for Arizonans in our rural and tribal areas.
So I appreciate your thoughts on how to improve the
accuracy and specificity of the maps and I remain committed to
working in a bipartisan way to improve broadband access for all
Arizonans.
My question is for Mr. Oblizalo.
Mr. Oblizalo. Oblizalo.
Senator Sinema. Oblizalo. Almost as difficult as my name,
but I welcome the thoughts of all of our witnesses today.
So we know that these inaccurate maps are preventing funds
from flowing to some of our rural and tribal areas, like Show
Low and Havasupai, the areas that need the investment most. So
before we commit to another round of investment, we want to
make sure we're spending our money in the proper locations.
Of all the proposals that have been discussed today, which
do you believe provides the best combination of accuracy and
granularity and can be implemented quickly in rural places,
such as Show Low, Arizona?
Mr. Oblizalo. Well, that's a good question. I know there's
a lot of different mapping ideas out there being observed and
looked at and how do you make that more granular map to provide
those services to those rural areas.
I have not evaluated each map. I don't know exactly how
they do it, but the granularity is very important and also I
believe there's a challenge process. So if there is a tribal
land or an area that is underserved that funds can be applied
for to bring broadband services to them.
Senator Sinema. Thank you. My next question--did any of the
others want to respond? Yes?
Mr. Strange. Yes, thank you, Senator. So I think one of the
solutions is to ensure that we have--we're measuring before
we're funding, as you certainly alluded to. And the fastest way
to do that is to get the lightest-weight tools available to
both consumers as well as anyone who has the capability--
Federal or state employee--performing some of these tasks.
And to the point of granularity, our capabilities are
getting down to a level where we can understand at a 10 meter
level of granularity what the service quality is for the
wireless networks, and that's just with our Speedtest
applications that are publicly available.
We can continue to refine and collect different types of
information with targeted applications also, but that's just
with our consumer capabilities. So a fast way to get to market
is to quickly assess these datasets or quickly assess the
networks in these rural areas and the quickest way to do that
is to activate the existing base of consumers and users of
applications that are already in the market.
Mr. Spalter. Let me just, if I could,----
Senator Sinema. Yes.
Mr. Spalter.--Senator Sinema, we have initiated a proof of
concept on our National Broadband Mapping Initiative not so
that we alone will be able to develop and scale a national
comprehensive harmonized map but we can create the foundational
database upon which we can actually get there.
So I would suggest that we don't have yet the apples to
apples comparisons of which map might be the right one or the
wrong one. We all know, what we all agree is that we still need
to aggregate existing new data sources that we're seeking to
do. Our companies are putting skin in the game to be able to c
rack the code to this problem so that we can finally and
comprehensively determine and have a clear line of sight of
where there are serviceable locations and as importantly where
there are not, mapping that negative space, and with that
foundational data base, then the government agencies, like the
FCC, can build and scale that map and then we can do an
evaluation and further verification of its refinement.
Senator Sinema. Thank you. Mr. Chairman, my time has nearly
expired. Can I ask one follow up question to Mr. Spalter?
Senator Wicker. Yes, ma'am.
Senator Sinema. Thank you. As we know, U.S. Telecom
launched the Broadband Mapping Initiative Pilot Program.
My question is, how does your pilot program manage areas in
Arizona where we don't have street addresses, which would
include many of our rural areas and almost all of our tribal
communities, and how long will it take to complete the database
in every state, considering this complication, so we can
actually utilize the dollars?
Mr. Spalter. That's a great question, Senator, and it's
precisely because there are so many locations that are not
connected with addresses in Arizona, in your tribal lands, and
across the country.
We're really trying to put our shoulder to solving this
problem. The way that we're doing that is we're going to be
aggregating with our proof of concept the new data sources, the
new data bases, the new digitized datasets that are provided
not only by commercial enterprises, public enterprises, at the
Federal, state, and municipal level, aggregating into one
unique platform, conform it for accuracy, in other words clean
it out, geo-code it, and then be able to scale it.
We think with our pilot, we're expecting to get the pilot
done by the end of Q3 of this year, we can have a full--once we
actually then return it back to our colleagues at the FCC and
NTIA and this committee for analysis, we can actually have a
fully formed national scaled comprehensive map of broadband
serviceable locations, we call it a fabric, within 2 years.
Senator Sinema. Thank you. Thank you so much, Mr. Chairman.
Senator Wicker. Thank you, Senator Sinema.
I want to thank our talented and knowledgeable witnesses.
The hearing record will remain open for two weeks. During
this time, Senators are asked to submit any questions for the
record. Upon receipt, the witnesses are requested to submit
their written answers to the Committee as soon as possible but
by no later than Wednesday, April 24, 2019. If witnesses do not
comply, they'll be sentenced to 1 month of dial-up.
[Laughter.]
Senator Wicker. At this point, I conclude the hearing and
thank the witnesses, the staff, and the members.
[Whereupon, at 12:01 p.m., the hearing was adjourned.]
A P P E N D I X
Rural Wireless Association
April 8, 2019
Hon. Roger Wicker,
Chairman,
Senate Committee on Commerce, Science, and Transportation,
Washington, DC.
Hon. Maria Cantwell,
Ranking Member,
Senate Committee on Commerce, Science, and Transportation,
Washington, DC.
Dear Chairman Wicker and Ranking Member Cantwell:
The Rural Wireless Association (``RWA'')\1\ applauds the Senate
Committee on Commerce, Science, and Transportation (the ``Committee'')
for convening the upcoming hearing regarding the current state of the
Nation's broadband maps and for its ongoing efforts to ensure accurate
broadband coverage data is reported so that Federal broadband subsidies
are targeted at and awarded to those carriers who continue to serve
America's underserved and unserved populations.
---------------------------------------------------------------------------
\1\ RWA is a 501(c)(6) trade association dedicated to promoting
wireless opportunities for rural telecommunications companies who serve
rural consumers and those consumers traveling to rural America. RWA's
members are small businesses serving or seeking to serve secondary,
tertiary, and rural markets. RWA's members are comprised of both
independent wireless carriers and wireless carriers that are affiliated
with rural telephone companies. Each of RWA's member companies serves
fewer than 100,000 subscribers.
---------------------------------------------------------------------------
RWA and its members have been active participants in various
proceedings before the Federal Communications Commission (``FCC'' or
``Commission'') in which broadband coverage data has been at issue.
Recently, RWA and its members have been involved in the FCC's ongoing
Mobility Fund Phase II (``MFII'') proceeding, through which
approximately $4.5 billion in support will be made available over a 10-
year period to primarily rural areas that lack unsubsidized 4G LTE
service.
RWA has provided insight and offered solutions related to the MFII
proceeding, particularly focusing on the wireless broadband coverage
data submitted by the Nation's largest carriers, which, in conjunction
with universal service fund (``USF'') subsidy data, is being used by
the FCC to establish the map of areas presumptively eligible for MFII
support. On multiple occasions RWA has expressed grave concerns about
the coverage data that has been submitted by certain major carriers,
including Verizon and T-Mobile, and has pointed out that, despite what
the submitted data says, some underlying carrier coverage is in fact
nonexistent. Additionally, RWA has pushed to bring to the attention of
the FCC valid coverage data that can and should be utilized over that
which has been provided by certain major carriers.
On August 6, 2018, RWA filed an Informal Request for Commission
Action asking the FCC to investigate the 4G LTE coverage claimed by
Verizon in the MFII proceeding.\2\ Specifically, RWA argued that
Verizon should re-file data in order to correct its overstated
coverage. RWA was able to identify and verify the non-existent Verizon
coverage in part due to over 37,440 miles of drive-testing performed by
its member, Panhandle Telecommunication Systems, Inc. (``Panhandle''),
a wireless carrier providing service in rural Oklahoma.
---------------------------------------------------------------------------
\2\ See Universal Service Reform--Mobility Fund, WC Docket No. 10-
90, WT Docket No. 10-208, Informal Request of the Rural Wireless
Associations, Inc. for Commission Action (Aug. 6, 2018), attached
hereto as Appendix A.
---------------------------------------------------------------------------
Then, on December 26, 2018, RWA filed yet another Informal Request
for Commission Action, this time asking the FCC to investigate the 4G
LTE coverage claimed by T-Mobile.\3\ RWA was able to demonstrate that
well over 90 percent of the 2.2 million test points tested by its
members, Panhandle, Pine Belt Communications, Inc. (``Pine Belt''), and
Sagebrush Cellular, Inc. (``Sagebrush''), in disparate parts of the
country failed to achieve the 5 Mbps download speed threshold that T-
Mobile claimed to be present. Indeed, in many locations, there was
simply no T-Mobile coverage at all, despite the carrier claiming that
such coverage existed.
---------------------------------------------------------------------------
\3\ See Universal Service Reform--Mobility Fund, WC Docket No. 10-
90, WT Docket No. 10-208, Informal Request of the Rural Wireless
Association, Inc. for Commission Action (Dec. 26, 2018), attached
hereto as Appendix B.
---------------------------------------------------------------------------
RWA and its members are not the only ones to have discovered these
major coverage misstatements. According to a recent story aired by
National Public Radio,\4\ the State of Vermont's Department of Public
Service (``Vermont DPS'') has conducted its own exhaustive drive-
testing--covering over 6,000 miles of highways and country roads in the
Green Mountain state--to gauge the actual coverage of six service
providers, including Verizon and T-Mobile. Just as RWA found based on
its members' drive-tests, Vermont DPS noted a stark contrast between
claimed 4G LTE coverage and actual 4G LTE coverage amongst the
country's nationwide carriers. Recently, Vermont DPS published an
extensive report\5\ and created individual static maps displaying
purported carrier coverage overlaid with actual drive-test results.\6\
Vermont DPS even developed an interactive coverage map\7\ to showcase
these findings. The drive-test study conducted by Vermont DPS, which
shows clear evidence of T-Mobile over-stating its rural coverage, has
been submitted as part of the record in a hearing conducted by the
House of Representatives Subcommittee on Communications and Technology
in its review of the proposed merger between T-Mobile and Sprint
Corporation.\8\
---------------------------------------------------------------------------
\4\ See ``One Man's Quest to Prove Vermont Has Terrible Cell
Service,'' All Things Considered, National Public Radio (aired Feb. 1,
2019).
\5\ See ``Mobile Wireless in Vermont,'' Vermont Department of
Public Service (rel. Jan. 14, 2019), attached hereto as Appendix C.
\6\ See Static Maps, Vermont Department of Public Service.
\7\ See Interactive Wireless Coverage Map, Vermont Department of
Public Service.
\8\ See Protecting Consumers and Competition: An Examination of the
T-Mobile and Sprint Merger, Hearing Before the House of Representatives
Subcommittee on Communications and Technology (Feb. 13, 2019).
---------------------------------------------------------------------------
These time-consuming and expensive carrier-and agency-initiated
coverage tests conducted over the last year constitute important
evidence that at least two nationwide carriers are misstating coverage
in the FCC's MFII proceeding, thereby creating an artificial coverage
map that, if accepted without further investigation, will fail to
target MFII support where it is needed the most. RWA and its members
have expressed these same concerns to the FCC on multiple occasions;
however, to date the agency has failed to investigate the coverage data
submitted by Verizon or T-Mobile. Accordingly, by filing this letter
and the attached appendices in the hearing record, RWA calls the
Committee's attention to the coverage tests conducted by RWA members
and the Vermont DPS and to the problems Verizon's and T-Mobile's
coverage misstatements are causing for small, rural carriers that are
trying to connect those parts of America that need assistance the most.
Respectfully submitted,
Caressa D. Bennet,
General Counsel.
______
Appendix A
Before the
Federal Communications Commission
Washington, DC. 20554
In the Matter of )
)
Connect America Fund ) WC Docket No. 10-90
)
Universal Service Reform-- ) WT Docket No. 10-208
Mobility Fund
INFORMAL REQUEST OF THE RURAL WIRELESS ASSOCIATION, INC. FOR COMMISSION
ACTION
Pursuant to Section 1.41 of the Federal Communications Commission's
(``FCC'' or ``Commission'') rules,\1\ the Rural Wireless Association,
Inc. (``RWA'')\2\ files this Informal Request for Commission Action
(``Informal Request'') regarding the Mobility Fund Phase II (``MF-II'')
Challenge Process. RWA's members are in the middle of the Challenge
Process but are expending enormous time and financial resources in
their efforts due to inaccurate data submitted by Verizon. RWA requests
that the Commission investigate the 4G LTE coverage claimed by Verizon
and require re-filing of Verizon's data to correct its overstated
coverage.
---------------------------------------------------------------------------
\1\ 47 C.F.R. Sec. 1.41.
\2\ RWA is a 501(c)(6) trade association dedicated to promoting
wireless opportunities for rural telecommunications companies who serve
rural consumers and those consumers traveling to rural America. RWA's
members are small businesses serving or seeking to serve secondary,
tertiary, and rural markets. RWA's members are comprised of both
independent wireless carriers and wireless carriers that are affiliated
with rural telephone companies. Each of RWA's member companies serves
fewer than 100,000 subscribers.
---------------------------------------------------------------------------
I. Background
In August 2017, the Commission decided to implement a new, one-time
data collection with specified data parameters tailored to MF-II.\3\
The Commission required mobile wireless broadband providers to file
propagation maps and model details with the Commission indicating their
current 4G LTE coverage, as defined by download speeds of 5 Mbps at the
cell edge with 80 percent probability and a 30 percent cell loading
factor.\4\
---------------------------------------------------------------------------
\3\ Universal Service Reform--Mobility Fund, Order on
Reconsideration and Second Report and Order, WT Docket No. 10-208, at
7 (rel. Aug. 4, 2017) (``Second R&O'').
\4\ Second R&O at 34.
---------------------------------------------------------------------------
The FCC used the 4G LTE coverage information, in conjunction with
universal service fund (``USF'') subsidy data, to establish the map of
areas presumptively eligible for MF-II support.\5\ The FCC released the
initial eligible areas map on February 27, 2018.\6\ On the same date,
the FCC released a Public Notice establishing the procedures to be used
in the MF-II challenge process.\7\ In that item, the FCC determined
that speed test measurements submitted to support and/or respond to a
challenge to an area that is initially deemed ineligible for MFII
support must be no more than 500 meters apart from one another. The FCC
decided to assess challenges using a uniform grid with cells of one
square kilometer and a ``buffer'' with a radius equal to one-half of
the maximum distance parameter, i.e., 250 meters. After reviewing
detailed data\8\ regarding the burden a challenger would experience as
a result of these parameters, the FCC reconsidered its procedures and
extended the buffer radius from 250 to 400 meters.\9\
---------------------------------------------------------------------------
\5\ Second R&O at 10-11, 34.
\6\ Mobility Fund Phase II Initial Eligible Areas Map Available;
Challenge Window Will Open March 29, 2018, Public Notice, DA 18-187, WT
Docket No. 10-208 (rel. Feb. 27, 2018). The FCC made minor changes to
the map in late May 2018 to reflect corrected coverage by a single
mobile provider and adjustments to underlying coverage and subsidy
data. See Updated Version of Map of Areas Presumptively Eligible for
Mobility Fund Phase II Now Available, Public Notice, DA 18-540, WT
Docket No. 10-208 (rel. May 22, 2018).
\7\ Connect America Fund, Universal Service Reform--Mobility Fund,
Public Notice, WC Docket No. 10-90, WT Docket No. 10-208, DA 18-186
(rel. Feb. 27, 2018) (``Challenge Process PN'').
\8\ See generally Letter from Caressa D. Bennet, General Counsel,
RWA, and Erin P. Fitzgerald, Regulatory Counsel, RWA, to Marlene H.
Dortch, Secretary, FCC, WT Docket No. 10-208 et al. (Mar. 21, 2018)
(``RWA Mar. 21, 2018 Ex Parte'') (focusing on challenges to certain
ineligible areas in Alabama, Kansas, Montana, North Dakota, Oklahoma,
and Wyoming).
\9\ Challenge Procedures Reconsideration Order at 4.
---------------------------------------------------------------------------
The Challenge Process started on March 29, 2018, and was originally
scheduled to conclude on August 27, 2018. However, Chairman Pai has
directed the FCC to extend the challenge process deadline by 90
days.\10\ RWA members are anxiously awaiting the release of a Public
Notice that will officially extend that deadline for an additional 90
day period to allow completion of the challenges. Challengers are
currently submitting the results of their speed tests (showing that
qualifying 4G LTE service with download speeds of 5 Mbps is not
available at a given location) to the Universal Service Administrative
Company (``USAC'') challenge process portal. After challengers submit
their speed test data, the USAC system will draw a circular ``buffer''
around each speed test point. If the total buffered area in a grid cell
exceeds 75 percent of the cell's challengeable area, then the system
will deem the challenge to be presumptively successful with respect to
that square kilometer cell. Challenged carriers will then have the
opportunity to submit data rebutting the challenge. RWA continues to
receive reports from its members that the cost of participating in the
Challenge Process is requiring hundreds of hours of time and hundreds
of thousands of dollars to disprove Verizon's overstated coverage--time
and money that would have been better spent investing in their networks
to further deploy LTE in rural America.
---------------------------------------------------------------------------
\10\ Letter from Ajit Pai, Chairman, FCC to Senator Roger Wicker
(May 30, 2018) committing to extend the Challenge Process by 90 days.
---------------------------------------------------------------------------
II. Verizon's Claimed 4G LTE Coverage Is Grossly Overstated
RWA and others have expressed serious concerns regarding overstated
unsubsidized 4G LTE coverage as it relates to eligibility for MF-II
funding.\11\ In particular, RWA, Panhandle Telecommunications Systems,
Inc. (``PTCI''), and a coalition of radio frequency engineering firms
(``RF Engineer Coalition'') have expressed serious concerns regarding
Verizon's claimed unsubsidized 4G LTE coverage.\12\ The Oklahoma
Panhandle has a total area of 14,778.47 square kilometers--almost all
of which Verizon claims to cover with 4G LTE coverage.\13\
---------------------------------------------------------------------------
\11\ See Letter from Caressa D. Bennet, General Counsel, RWA, and
Erin P. Fitzgerald, Regulatory Counsel, RWA, to Marlene H. Dortch,
Secretary, FCC, WT Docket No. 10-208 et al., at p. 2 (Mar. 21, 2018)
(expressing concern that ``the challenge process . . . will impose
significant and unnecessary costs on prospective challengers, and allow
overstated mobile wireless coverage to stand unchallenged in most
places'') (``RWA Mar. 21, 2018 Ex Parte''); Application for Review of
the Rural Wireless Association, Inc., WC Docket No. 10-90, WT Docket
No. 10-208, at p. 3 (Mar. 29, 2018) (noting that an ``inaccurate
picture of mobile wireless coverage'' will likely stand unchallenged in
most places); see also Kendra Chamberlain, FierceWireless, FCC's
Mobility Fund II Will Primarily Benefit Western Half of U.S., (Feb. 28,
2018) (quoting CCA President and CEO Steven Berry: ``CCA has been a
fervent supporter of Congress's goal and the Commission's efforts to
use reliable data to determine eligible areas for support in Mobility
Fund II based on an efficient challenge process that is robust,
targeted, and strikes a reasonable balance without overly burdening
small carriers . . . Unfortunately, that is not possible based on the
initial eligible areas map that the FCC released today. It is now clear
that the parameters the FCC directed carriers to use in its one-time
data collection have failed to produce a credible map of eligible
areas, and it is most disappointing that absent significant changes,
the Commission will fall short of Congress's mandate for Universal
Service''); see also Reply of United States Cellular Corporation, WC
docket No 10-90, WT Docket No. 10-208, at p. 4 (May 7, 2018) (stating
``[i]f this Commission is serious about accelerating broadband
investment to areas that need it most, then it is critically important
that areas needing investment are not blocked out due to maps that
overstate coverage''); see also Opposition of Smith Bagley, Inc. to
Verizon Application for Review, WT Docket No. 10-208, WC docket No. 10-
90 (July 13, 2018) (recognizing that ``if the [challenge process]
testing parameters are too rigorous, less challenges will be
undertaken'' and that ``this result must be avoided because it would
increase the likelihood that inaccuracies in unsubsidized coverage
claims made by incumbent carriers will go undetected'').
\12\ See Letter from Caressa D. Bennet, General Counsel, RWA, and
Erin P. Fitzgerald, Regulatory Counsel, RWA, to Marlene H. Dortch,
Secretary, FCC, WT Docket No. 10-208 et al., at p. 2 and Attachment C
(Apr. 20, 2018) (``RWA Apr. 20, 2018 Ex Parte''); see also Letter from
RF Engineer Coalition to Marlene H. Dortch, Secretary, FCC, WT Docket
No. 10-208 et al. (July 5, 2018) (``RF Engineer Coalition Ex Parte'');
see also Letter from Caressa D. Bennet, Counsel to Panhandle
Telecommunication Systems, Inc., to Marlene H. Dortch, Secretary, FCC,
WT Docket No. 10-208 et al., at pp. 1-2 and Attachment (July 13, 2018)
(``PTCI Ex Parte'').
\13\ Verizon Wireless Interactive Map (last visited June 28, 2018)
(showing 4G LTE coverage throughout nearly all of the Oklahoma
Panhandle); see also RF Engineer Coalition Ex Parte at p. 2 (stating
that Verizon's map is not far removed from the coverage depicted in the
portal).
---------------------------------------------------------------------------
Concerns regarding Verizon's overstated 4G LTE coverage are borne
out in filings by the RF Engineer Coalition and PTCI. PTCI has stated
that, as discussions surrounding MF-II and the accompanying challenge
process began in earnest, the company hired a professional engineering
firm (Monte R. Lee and Company or ``MRL'') to estimate Verizon coverage
using data inputs reflecting specific cell site locations,
observational estimates of radio height and antenna placement on
towers, 700 MHz spectrum, and service that reflects the customer
experience.\14\ MRL, a member of the RF Engineer Coalition, stated that
it used publicly-available information and the FCC-adopted 5 Mbps
downlink standard to produce a map that estimated that Verizon's
coverage area should be approximately 6806.49 square kilometers in the
Oklahoma Panhandle--not even half of the LTE coverage area Verizon
publicly claims to serve.\15\
---------------------------------------------------------------------------
\14\ PTCI Ex Parte at p. 1.
\15\ RF Engineer Coalition Ex Parte at p. 2; see also Verizon
Wireless Interactive Map (last visited June 28, 2018) (showing 4G LTE
coverage throughout nearly all of the Oklahoma Panhandle).
---------------------------------------------------------------------------
Since this estimated propagation map was compiled, PTCI has driven
more than 37,000 miles in order to compile data for the MF-II challenge
process.\16\ PTCI's speed test data collection included a total of
402,573 test points--drive tests taken using Verizon-specified devices
that are on plans not subject to network prioritization or
throttling.\17\ Of the total test points collected, 357,374 (88.8
percent) tested below 5 Mbps download speed or did not register 4G LTE
service at all on Verizon-designated handsets.\18\ The results of the
speed tests taken by PTCI largely bear out MRL's initial Verizon
propagation projections.\19\
---------------------------------------------------------------------------
\16\ PTCI Ex Parte at p. 2.
\17\ RF Engineer Coalition Ex Parte at pp. 2-3.
\18\ PTCI Ex Parte at p. 2; see also RF Engineer Coalition Ex Parte
at p. 3.
\19\ PTCI Ex Parte at p. 2.
---------------------------------------------------------------------------
RWA echoes the concerns and questions raised by the RF Engineer
Coalition relating to Verizon's claimed 4G LTE coverage, and its
conformance with standard RF engineering practices and the Commission's
filing requirements. In particular, RWA urges attention to LTE RSRP
level, propagation model, and clutter factors and how Verizon's inputs
could have impacted the accuracy of its coverage data.\20\
---------------------------------------------------------------------------
\20\ Verizon responded to the RF Engineer Coalition Ex Parte on
July 27, 2018. See Letter from Alan Buzacott, Executive Director,
Federal Regulatory Affairs, Verizon, to Marlene H. Dortch, Secretary,
FCC, WT Docket No. 10-208 et al. (July 27, 2018). The RF Engineer
Coalition has submitted a reply, noting its continued concerns. See
Letter from RF Engineer Coalition to Marlene H. Dortch, Secretary, FCC,
WT Docket No. 10-208 et al. (Aug. 3, 2018).
---------------------------------------------------------------------------
III. The Commission Should Require Verizon to Refile Accurate 4G LTE
Coverage Maps to Ensure That MF-II Support Is Targeted
Appropriately
Verizon's overstated coverage has yielded a coverage map that will
result in a challenge process that fails to target MF-II support where
it is needed. RWA, PTCI, United States Cellular, Smith Bagley, and
others have expressed concerns regarding the tremendous costs of MF-II
Challenge Process participation. Overstated 4G LTE coverage by a
nationwide provider like Verizon has increased those costs
significantly, to the detriment of the challengers with whom Verizon
competes.
Data submitted to the Commission indicates that Verizon has
overstated its coverage by more than 50 percent in the Oklahoma
Panhandle. As a result of Verizon claiming this coverage, PTCI has been
forced to undertake significant drive-testing of the area--an
undertaking that the company estimates will cost close to $1 million--
more than half of which could have been avoided, but for overstated
Verizon coverage.\21\ $1 million is a hefty price tag to test an area
comprised of only three counties.\22\ Other RWA members are seeing
similar Challenge Process costs. Pioneer Cellular, also based in
Oklahoma, estimates that it will take 20 drivers 75 days to complete
testing in the 24,010 drive-testable, challengeable square kilometers
of its licensed service territory. Like PTCI, Pioneer expects to spend
nearly $1 million to complete the challenge process. This includes
$600,000 in labor costs, $247,000 in mileage, $48,000 for handsets, and
$96,000 for data usage. Sagebrush Cellular, based in Montana, expects
to spend more than $1.5 million to participate in the challenge
process. This figure includes $275,000 for project management and other
labor, $62,000 for mapping and $1,178,000 for drive testing expenses.
---------------------------------------------------------------------------
\21\ PTCI Ex Parte at p. 5.
\22\ The Oklahoma Panhandle consists of Cimarron County, Texas
County and Beaver County.
---------------------------------------------------------------------------
A Commission investigation into the 4G LTE coverage claimed by
Verizon, and a determination that Verizon must re-file where coverage
data is inaccurate could save prospective challengers millions of
dollars apiece.\23\ More importantly, it will open up the challenge
process to numerous additional challengers who are currently deterred
from participating in the process by the enormous cost involved. Based
on the experience of RWA members, even where carriers choose to
participate, many such carriers are forced to pick and choose where to
challenge due to the cost of participating. This is not the robust
challenge process envisioned by the Commission.
---------------------------------------------------------------------------
\23\ It could also reduce risks faced by those doing the testing.
See PTCI Ex Parte at p. 5 (noting that drive testers must protect
themselves from rattlesnakes, feral hogs, bobcats, and other dangers).
---------------------------------------------------------------------------
Requiring Verizon to correct its coverage so that it is in
conformance with standard RF engineering practices will yield an
accurate picture of where qualifying coverage exists and allow funding
to be targeted to those areas. In addition, Verizon should not be
allowed to abuse the FCC challenge process by filing a sham coverage
map as a means of interfering with the ability of rural carriers to
continue to receive universal service support in rural areas. Failure
by the Commission to enforce its coverage map requirements against
Verizon will undermine the Challenge Process which, in turn, will harm
rural carriers, and the customers they serve, who are reliant on
receiving support in areas where unsubsidized carriers like Verizon do
not serve.\24\
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\24\ See House of Representatives Energy & Commerce Committee
Hearing, Oversight of the Federal Communications Commission 2018,
Opening Statement of Mike Doyle (D-PA) (stating ``Chairman [Pai] has
claimed that he cares about rural broadband deployment, but the
Commission in its zeal not to burden major wireless carriers with
reporting where they have wireless service deployed imposed as part of
Mobility Fund II a bizarre and onerous challenge process that requires
rural providers to hire people to walk through cornfields and backyards
trying to prove that communities don't have wireless service. And if
those companies can't afford to send people up, the Commission will
assume these communities are connected. Now tell me, how does that help
the 24 million Americans without access to high-speed broadband?'').
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IV. Conclusion
For the reasons discussed above, RWA urges the Commission to
investigate the 4G LTE coverage claimed by Verizon and require re-
filing of Verizon's data to correct its claimed coverage. In
particular, RWA encourages the Commission to consider issues raised by
the RF Engineer Coalition relating to LTE RSRP level, propagation
model, and clutter factors. RWA looks forward to its continued work
with the Chairman, Commissioners, and Commission staff in this
proceeding.
Respectfully submitted,
RURAL WIRELESS ASSOCIATION, INC.
By: Caressa D. Bennet,
General Counsel,
Erin P. Fitzgerald,
Regulatory Counsel.
August 6, 2018
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
______
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
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[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
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Appendix B
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of )
)
Connect America Fund ) WC Docket No. 10-90
)
Universal Service Reform-- ) WT Docket No. 10-208
Mobility Fund
INFORMAL REQUEST FOR COMMISSION ACTION
RURAL WIRELESS ASSOCIATION, INC.
Caressa D. Bennet,
General Counsel.
Date: December 26, 2018
Table of Contents
Summary
I. BACKGROUND
II. T-MOBILE'S CLAIMED 4G LTE COVERAGE IS GROSSLY OVERSTATED
III. THE COMMISSION SHOULD INVESTIGATE BACKHAUL CAPACITY ISSUES
IN THE AREAS IN WHICH T-MOBILE CLAIMED TO PROVIDE QUALIFYING 4G
LTE COVERAGE AND WHETHER T-MOBILE USED PROJECTED COVERAGE FOR
ITS DATA SUBMISSION
IV. T-MOBILE FILED PROJECTED COVERAGE DATA
V. CONCLUSION
______
Summary
RWA requests that the Commission investigate the 4G LTE coverage
claimed by T-Mobile USA, Inc. as part of the one-time data collection
for the Mobility Fund Phase II reverse auction process. After RWA
members conducted their own drive testing of T-Mobile's coverage in
their respective service areas, RWA determined that T-Mobile's data
submitted to the FCC regarding its claimed coverage of these areas at 5
Mbps or greater download speeds was not accurate or supported. Based on
evidence available to RWA members it became evident that T-Mobile did
not have the requisite backhaul facilities to support 5 Mbps download
speeds at the time it submitted its data to the FCC. It further appears
that T-Mobile continued to build out areas that it counted as covered
even though this build out occurred after T-Mobile's January 4, 2018
deadline for submitting actual coverage.
RWA encourages the Commission in its investigation to obtain and
analyze the following information related to the timing of T-Mobile's
cell sites built in rural areas in the past three years: (1) date power
installed at cell site; (2) date 4G LTE RAN installed at cell site; (3)
date backhaul installed at cell sites; (4) type of backhaul installed
at cell sites and the capability of the backhaul facilities in place at
the time to support 5 Mbps download speeds; (4) date cell sites were
provisioned; and (5) date commercial service was launched at each of
the cell sites.
To the extent the Commission determines that data submitted by T-
Mobile has been fabricated or has been based on projected future
coverage, RWA requests that the Commission consider taking appropriate
action including, but not limited to, (1) barring T-Mobile from
participating in the Mobility Fund Phase II reverse auction; (2)
requiring T-Mobile to reimburse challengers for their costs associated
with the challenge process; and/or (3) issuing appropriate sanctions
for misrepresentation of information submitted by T-Mobile under
penalty of perjury.
______
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of )
)
Connect America Fund ) WC Docket No. 10-90
)
Universal Service Reform-- ) WT Docket No. 10-208
Mobility Fund
INFORMAL REQUEST FOR COMMISSION ACTION
Pursuant to Section 1.41 of the Federal Communications Commission's
(``FCC'' or ``Commission'') rules,\1\ the Rural Wireless Association,
Inc. (``RWA'')\2\ files this Informal Request for Commission Action
(``Informal Request'') regarding the Mobility Fund Phase II (``MF-II'')
Challenge Process. For the reasons discussed below, RWA requests that
the Commission investigate the 4G LTE coverage claimed by T-Mobile USA,
Inc. (``T-Mobile'') and require T-Mobile to resubmit its MF II coverage
data using the actual coverage that it had in place during the August
4, 2017--January 4, 2018 time frame as required by the Commission's
rules,\3\ rather than projected coverage data that appears to have been
used. To the extent the data submitted by T-Mobile has been fabricated
or has been based on projected future coverage, RWA requests that the
Commission consider taking appropriate action including, but not
limited to, (1) barring T-Mobile from participating in the Mobility
Fund Phase II reverse auction; (2) requiring T-Mobile to reimburse
challengers for their costs associated with the challenge process; and/
or (3) issuing appropriate sanctions for misrepresentation of
information submitted by T-Mobile under penalty of perjury.\4\
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\1\ 47 C.F.R. Sec. 1.41.
\2\ RWA is a 501(c)(6) trade association dedicated to promoting
wireless opportunities for rural telecommunications companies who serve
rural consumers and those consumers traveling to rural America. RWA's
members are small businesses serving or seeking to serve secondary,
tertiary, and rural markets. RWA's members are comprised of both
independent wireless carriers and wireless carriers that are affiliated
with rural telephone companies. Each of RWA's member companies serves
fewer than 100,000 subscribers.
\3\ See FCC, Mobility Fund II 4G LTE Data Collection Instructions
(``Mobile wireless broadband providers must submit polygons in a
shapefile format representing geographic coverage nationwide (excluding
Alaska, but including U.S. territories) for 4G LTE deployed in each
frequency band and bandwidth as of August 4, 2017, or later.'') (last
visited Dec. 26, 2018).
\4\ Pursuant to Commission requirements, carriers submitting 4G LTE
coverage data were required to do so under penalty of perjury. See
Universal Service Reform--Mobility Fund, Order on Reconsideration and
Second Report and Order, WC Docket No. 10-90, WT Docket No. 10-208, FCC
17-102, at 39 (Aug. 4, 2017) (stating that ``providers shall submit.
. .a certification, under penalty of perjury, by a qualified engineer
that the propagation maps and model details reflect the filer's
coverage as of the generation date of the map. . .''). To the extent T-
Mobile misrepresented the information, it should be sanctioned. See,
e.g., California Public Broadcasting Forum v. FCC, 947 F.2d 505 (D.C.
Cir. 1991) (upholding FCC denial of a broadcast license renewal
application where licensee misrepresented its reasons for darkening
station); WADECO, Inc. v. FCC, 628 F. 2d 122 (D.C. Cir. 1980)
(upholding FCC disqualification of applicant for a broadcast
construction permit based on applicant's misrepresentation of its
financial qualifications); Brandywine-Main Line Radio, Inc. v. FCC, 473
F.2d 16 (D.C. Cir. 1972) (upholding FCC denial of a broadcast license
renewal application where licensee misrepresented its program plans).
---------------------------------------------------------------------------
I. BACKGROUND
In August 2017, the Commission decided to implement a new, one-time
data collection with specified data parameters tailored to MF-II.\5\
The Commission required mobile wireless broadband providers to file
propagation maps and model details with the Commission indicating their
current 4G LTE coverage, as defined by download speeds of 5 Mbps at the
cell edge with 80 percent probability and a 30 percent cell loading
factor.\6\
---------------------------------------------------------------------------
\5\ Universal Service Reform--Mobility Fund, Order on
Reconsideration and Second Report and Order, WT Docket No. 10-208, at
7 (rel. Aug. 4, 2017) (``Second R&O'').
\6\ Second R&O at 34.
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The FCC used the 4G LTE coverage information, in conjunction with
Universal Service Fund (``USF'') subsidy data, to establish a map of
areas presumptively eligible for MF-II support.\7\ The FCC released the
initial eligible areas map on February 27, 2018.\8\ On the same date,
the FCC released a Public Notice establishing the procedures to be used
in the MF-II challenge process.\9\ In that item, the FCC determined
that speed test measurements submitted to support and/or respond to a
challenge to an area that is initially deemed ineligible for MF-II
support must be no more than 500 meters apart from one another.\10\ The
FCC decided to assess challenges using a uniform grid with cells of one
square kilometer and a ``buffer'' with a radius equal to one-half of
the maximum distance parameter, i.e., 250 meters.\11\ After reviewing
detailed data\12\ regarding the burden a challenger would experience as
a result of these parameters, the FCC reconsidered its procedures and
extended the buffer radius from 250 to 400 meters.\13\
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\7\ Second R&O at 10-11, 34.
\8\ Mobility Fund Phase II Initial Eligible Areas Map Available;
Challenge Window Will Open March 29, 2018, Public Notice, DA 18-187, WT
Docket No. 10-208 (rel. Feb. 27, 2018). The FCC made minor changes to
the map in late May 2018 to reflect corrected coverage by a single
mobile provider and adjustments to underlying coverage and subsidy
data. See Updated Version of Map of Areas Presumptively Eligible for
Mobility Fund Phase II Now Available, Public Notice, DA 18-540, WT
Docket No. 10-208 (rel. May 22, 2018).
\9\ Connect America Fund, Universal Service Reform--Mobility Fund,
Public Notice, WC Docket No. 10-90, WT Docket No. 10-208, DA 18-186
(rel. Feb. 27, 2018) (``Challenge Process PN'').
\10\ Challenge Process PN at 24.
\11\ Challenge Process PN at 24.
\12\ See generally Letter from Caressa D. Bennet, General Counsel,
RWA, and Erin P. Fitzgerald, Regulatory Counsel, RWA, to Marlene H.
Dortch, Secretary, FCC, WT Docket No. 10-208 et al. (Mar. 21, 2018)
(``RWA Mar. 21, 2018 Ex Parte'') (focusing on challenges to certain
ineligible areas in Alabama, Kansas, Montana, North Dakota, Oklahoma,
and Wyoming).
\13\ Challenge Procedures Reconsideration Order at 4.
---------------------------------------------------------------------------
The Challenge Process started on March 29, 2018, and was originally
scheduled to conclude on August 27, 2018.\14\ However, the FCC extended
the challenge process deadline by 90 days to November 26, 2018 in light
of data submitted by RWA regarding the significant burdens of the
challenge process, including specific estimates of the amount of time
required to conduct speed tests in certain areas.\15\
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\14\ The initial MF-II map of presumptively eligible areas was
published on February 27, 2018, and the challenge window opened on
March 29, 2018. Because the 150th day from the opening of the challenge
window would fall on August 26, 2018, which is a Sunday, the challenge
window was scheduled to remain open through August 27, 2018, the
following business day. See 47 CFR Sec. 1.4(d), (j); Universal Service
Reform--Mobility Fund, Public Notice, Mobility Fund Phase II Initial
Eligible Areas Map Available; Challenge Window Will Open March 29,
2018, WC Docket No 10-90, WT Docket No. 10-208, DA 18-187, Feb. 27,
2018.
\15\ Universal Service Reform--Mobility Fund, Order, Notice of
Proposed Rulemaking and Memorandum Opinion and Order, WC Docket No. 10-
90, WT Docket No. 10-208, FCC 18-124, at 5, 8 (rel. Aug. 21, 2018).
---------------------------------------------------------------------------
Twenty-one Challengers submitted the results of their speed tests
(showing that qualifying 4G LTE service with download speeds of 5 Mbps
is not available at a given location) to the Universal Service
Administrative Company (``USAC'') challenge process portal.\16\ On
December 7, 2018, Federal Communications Commission Chairman Ajit Pai
announced that the agency had ``launched an investigation into whether
one or more major carriers violated the Mobility Fund Phase II. .
.reverse auction's mapping rules and submitted incorrect coverage
maps.'' \17\ Further, the Commission ``has suspended the next step of
the challenge process--the opening of a response window--pending the
conclusion of this investigation.'' \18\
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\16\ Universal Service Reform--Mobility Fund, Public Notice, WC
Docket No. 10-90, WT Docket No. 10-208, DA 18-1225 (rel. Dec. 3, 2018).
\17\ Press Release, FCC Launches Investigation Into Potential
Violations of Mobility Fund Phase II Mapping Rules (Dec. 7, 2018).
\18\ Id; see also Lynn Stanton, Pai Foresees `Very Busy' Agenda for
FCC in 2019, TRDaily (Dec. 14, 2018) (stating ``As to whether he was
frustrated at having to suspend action in the Mobility Fund Phase II
process pending an investigation of whether major carriers violated FCC
rules by submitting inaccurate data on areas they already serve with 4G
LTE, Chairman Pai said, `Look, to me, it's not just professional, it's
personal. When I fly home to Kansas City and I drive about three and a
half hours south to my hometown, I can tell you once you get to the
outer Kansas City suburbs, you see the bars on your phone start to drop
and soon thereafter there's no service at all for long stretches. And I
understand personally the costs to many of these communities for not
having wireless coverage. During one of my trips to Mission, S.D., for
example, I heard about a woman on the Indian reservation near there.
She was found dead in her home, and she was clutching her cellphone.
She dialed 911 38 times, but the call never went through, because she
didn't have wireless coverage. This is really a matter of life and
death in some circumstances.' Asked what the consequences should be for
carriers that submitted inaccurate data, he said, `That's a question
that's inextricably intertwined with the enforcement investigation that
I announced last week and so I can't comment on what the remedies or
penalties might be as a result of that might be.' In response to a
question about what other ways the FCC could obtain data on coverage,
Mr. Pai said, `Some steps have already been taken.. . .Going forward we
want to know that we have accurate data.' Asked whether the Commission
would delay a decision in its review of the proposed merger of T-Mobile
US, Inc., and Sprint Corp. pending the outcomes of the MF-II data
investigation, Chairman Pai said, `Oh, boy, that's a double
hypothetical! I mean, not just the merger, the merits of which I can't
talk about, but also the impact that a concurrent enforcement
investigation might have on any merger. Again, I haven't announced the
identities of any carriers that we might be investigating, so I can't
obviously opine about what impact that may or may not have on the
transaction that's pending.' '')
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RWA has received reports from its members that the vast majority of
tests by RWA members of T-Mobile test points resulted in download
speeds below 5 Mbps or did not register 4G LTE service at all on T-
Mobile-designated handsets.\19\ These same members spent hundreds of
hours and hundreds of thousands of dollars to disprove T-Mobile's
overstated coverage--time and money that would have been better spent
investing in their networks to further deploy LTE in rural America.
---------------------------------------------------------------------------
\19\ See Declaration of Mike Kilgore at 8; Declaration of Jana
Wallace at 5; and Declaration of John Nettles at 6.
---------------------------------------------------------------------------
II. T-MOBILE'S CLAIMED 4G LTE COVERAGE IS GROSSLY OVERSTATED
The record is replete with filings by RWA and others detailing
concerns about overstated coverage by Verizon.\20\ However, only
recently did RWA become concerned about overstated coverage by T-Mobile
because such overstated coverage did not become apparent until after
the challenge process data had been submitted by challengers and more
closely analyzed.\21\ RWA members Sagebrush Cellular, Inc.
(``Sagebrush''), Panhandle Telecommunication Systems, Inc.
(``Panhandle''), and Pine Belt Cellular, Inc. (``Pine Belt'')
challenged T-Mobile coverage in their service areas.\22\ Concerns about
overstated coverage by T-Mobile are borne out by RWA members'
respective challenge results submitted in the FCC portal.\23\ In ex
parte meetings with the FCC on December 6, 2018, RWA members, inter
alia, discussed their findings and their conclusion that the near total
inability of T-Mobile to document 5 Mbps download speeds in the rural
areas tested by RWA members and claimed by T-Mobile to have qualifying
coverage calls into question the veracity of the original data
submitted by T-Mobile prior to the January 4, 2018 deadline.\24\
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\20\ See, e.g., Universal Service Reform--Mobility Fund; WC Docket
No. 10-90, WT Docket No. 10-208, Ex Parte Letter from Radio Frequency
Engineering Firm Coalition to Ms. Marlene H. Dortch, Secretary, FCC
(July 5, 2018); Universal Service Reform--Mobility Fund; WC Docket No.
10-90, WT Docket No. 10-208, Ex Parte Letter from Radio Frequency
Engineering Firm Coalition to Ms. Marlene H. Dortch, Secretary, FCC
(Aug. 3, 2018); Universal Service Reform--Mobility Fund; WC Docket No.
10-90, WT Docket No. 10-208, Ex Parte Letter from Shawn Hanson, CEO,
Panhandle Telecommunication Systems, Inc. to Ajit Pai, Chairman, FCC
(Sept. 7, 2018); Universal Service Reform--Mobility Fund; WC Docket No.
10-90, WT Docket No. 10-208, Informal Request of Smith Bagley, Inc. for
Commission Action (Oct. 18, 2018).
\21\ Ex Parte Letter from Caressa D. Bennet, General Counsel, Rural
Wireless Association, Inc. to Marlene H. Dortch, Secretary, FCC (Dec.
10, 2018) Universal Service Reform--Mobility Fund, WT Docket No. 10-
208, WC Docket No. 10-90, (``RWA Ex Parte'').
\22\ See Declaration of Mike Kilgore at 8; Declaration of Jana
Wallace at 5; and Declaration of John Nettles at 6.
\23\ See Declaration of Lynn Merrill at 5 and Attachments A, B,
and C.
\24\ See Declaration of Mike Kilgore at 8; Declaration of Remi
Sun at 5-7; Declaration of Jana Wallace at 5; Declaration of Lynn
Merrill at 6, and Declaration of John Nettles at 6.
---------------------------------------------------------------------------
RWA member Sagebrush, a wholly owned subsidiary of Nemont Telephone
Cooperative, Inc. (``Nemont''), is a commercial mobile radio service
(``CMRS'') provider offering service in northeast and south central
Montana, as well as portions of North Dakota and Wyoming. Sagebrush
covers over 17,000 square miles, the vast majority of which is rural
and remote in nature, including the Crow and Fort Peck Indian
Reservations.\25\ Sagebrush's T-Mobile speed test data collection
covered a total of 443,055 test points. Of the total test points for
which data was collected, 434,501 (98.07 percent) tested below 5 Mbps
download speed or did not register 4G LTE service at all on T-Mobile-
designated handsets.\26\
---------------------------------------------------------------------------
\25\ See Declaration of Mike Kilgore at 4; Declaration of Jerry
Tilley at 4; and Declaration of Remi Sun at 4.
\26\ See Declaration of Lynn Merrill at 5 and Attachment A.
---------------------------------------------------------------------------
RWA member Panhandle, a wholly owned subsidiary of Panhandle
Telephone Cooperative Inc. (``PTCI''), is a CMRS provider offering
service in the Oklahoma Panhandle in Cimarron, Beaver, and Texas
counties. Panhandle's T-Mobile speed test data collection covered a
total of 1,246,009 test points. Of the total test points collected,
1,222,385 (98.10 percent) tested below 5 Mbps download speed or did not
register 4G LTE service at all on T-Mobile-designated handsets.\27\
---------------------------------------------------------------------------
\27\ See Declaration of Lynn Merrill at 5 and Attachment B.
---------------------------------------------------------------------------
RWA member Pine Belt, a wholly-owned subsidiary of Pine Belt
Communications, Inc. (``PBC''), provides mobile telephone, SMS, and
wireless broadband services in five Alabama counties (Choctaw, Dallas,
Marengo, Perry and Wilcox). Pine Belt's T-Mobile speed test data
collection covered a total of 657,524 test points. Of the total test
points collected, 591,908 (90.02 percent) tested below 5 Mbps download
speed or did not register 4G LTE service at all on T-Mobile-designated
handsets.\28\
---------------------------------------------------------------------------
\28\ See Declaration of Lynn Merrill at 5 and Attachment C.
---------------------------------------------------------------------------
Three challengers collected data for 2,346,588 total T-Mobile test
points.\29\ When 2,248,794 (95.8 percent) of 2,346,588 test points
tested by only three challengers fail, it calls into question all of
the data submitted by T-Mobile.
---------------------------------------------------------------------------
\29\ See Declaration of Lynn Merrill at 5 and Attachments A, B,
and C.
---------------------------------------------------------------------------
III. THE COMMISSION SHOULD INVESTIGATE BACKHAUL CAPACITY ISSUES IN THE
AREAS IN WHICH T-MOBILE CLAIMED TO PROVIDE QUALIFYING 4G LTE COVERAGE
AND WHETHER T-MOBILE USED PROJECTED COVERAGE FOR ITS DATA SUBMISSION
Drive testing data coupled with a professional engineering analysis
and ``boots on the ground'' observations obtained before and during the
challenge process demonstrate that T-Mobile's backhaul facilities in
place by January 4, 2018 were insufficient to support the qualifying 5
Mbps download speeds claimed by T-Mobile.\30\ During the MF-II
challenge window, Sagebrush took speed tests in the area surrounding T-
Mobile towers in both Glasgow, MT and Scobey, MT.\31\ Upon reviewing
the speed test data and noting the high number of points that tested
below 5 Mbps download speed or did not register 4G LTE service at all,
Sagebrush questioned whether T-Mobile had sufficient backhaul to
support the 5 Mbps download speeds it reported to the FCC in its
January 4, 2018 MF II coverage filing.\32\ Sagebrush management, who
also serve as management of Sagebrush's affiliated telephone companies,
reviewed each telephone company's circuit installation records to
determine if circuits had been installed to support backhaul for T-
Mobile's cell sites in northeastern Montana and Williston, North
Dakota.\33\ Sagebrush also conducted a review of the FCC's Universal
Licensing System (``ULS'') to determine if T-Mobile had sufficient
backhaul capacity to support the claimed qualifying coverage as of
January 4, 2018.\34\
---------------------------------------------------------------------------
\30\ See Declaration of Lynn Merrill, P.E. at 6-7.
\31\ See Declaration of Michael Kilgore at 9.
\32\ See Declaration of Michael Kilgore at 10 .
\33\ See Declaration of Michael Kilgore at 13.
\34\ See Declaration of Mike Kilgore at 12.
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T-Mobile did not have sufficient backhaul capability, as of January
4, 2018, to support 5 Mbps download speeds in the Glasgow, Montana
vicinity. Currently, T-Mobile is using a backhaul circuit at its
Glasgow, Montana cell site capable of supporting 5 Mbps download
speeds, but this circuit wasn't installed by the January 4, 2018 4G LTE
coverage reporting deadline.\35\ T-Mobile has two microwave paths
licensed in Glasgow, Montana, but these licenses were not granted by
the FCC until February 13, 2018\36\--again, after the January 4, 2018
deadline. More relevant, however, is the fact that, according to
photographic evidence, no microwave facilities were installed or placed
into operation by the January 4, 2018 deadline.\37\ While photographs
taken in December 2018 show a microwave dish on the site,\38\
photographic evidence shows that T-Mobile was using satellite backhaul
at the Glasgow site as of February 13, 2018. However, satellite
backhaul cannot typically support download speeds of 5 Mbps.\39\
---------------------------------------------------------------------------
\35\ See Declaration of Remi Sun at 7.
\36\ Call signs WRAS250 and WRAS266, granted February 13, 2018.
\37\ See Declaration of Jerry Tilley at 7-8, evidencing the fact
that no microwave facilities are installed at the Glasgow site as of
February 13, 2018.
\38\ See Declaration of Jerry Tilley at 8 and Attachment B--
Glasgow.
\39\ See Declaration of Lynn Merrill at 7.
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Throughout the challenge window period, T-Mobile also relied solely
on satellite backhaul at its Scobey, Montana site.\40\ Sagebrush's
affiliate, Nemont Telephone Cooperative, Inc., (``Nemont''), is the
only wireline telephone company capable of providing a backhaul circuit
to T-Mobile's Scobey site sufficient to support 5 Mbps download speeds
and it has not done so.\41\ T-Mobile obtained a microwave license for
the Scobey site on September 13, 2018, long after the January 4, 2018
4G LTE coverage reporting deadline, yet it never installed the
microwave backhaul facilities as is evidenced by the photographs
attached to the Declaration of Jerry Tilley taken on December 19,
2018.\42\
---------------------------------------------------------------------------
\40\ See Declaration of Jerry Tilley at 6.
\41\ See Declaration of Jerry Tilley at 6.
\42\ See Declaration of Jerry Tilley at 6 and Attachment A--
Scobey.
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RWA requests that the Commission investigate the timing associated
with T-Mobile's construction and operation of the Scobey cell site.
When did the cell site receive power? When were satellite backhaul
facilities installed? When was the Radio Access Network (``RAN'')
equipment installed and provisioned? It is one thing to construct a
cell site and another to place it in operation and yet another to
provision it for LTE service that supports 5 Mbps download speeds.
Claiming 4G LTE qualifying coverage before it became available violates
the challenge process rules and would mean that T-Mobile made material
misrepresentations when it certified its coverage data.
The majority of T-Mobile's satellite backhaul facilities deployed
in northeast Montana do not appear to support download speeds of 5
Mbps.\43\ For context and as a way of explaining T-Mobile's motivation
to attempt to quickly build out cell sites in northeastern Montana, RWA
reminds the FCC that on December 21, 2016, the Wireless
Telecommunications Bureau granted T-Mobile License LLC a conditional
waiver of Section 27.14(g)(1) of the Commission's rules, which would
otherwise accelerate--by two years, to June 13, 2017--the end of
license term and related construction requirements for three 700 MHz
licenses.\44\ The Bureau required T-Mobile to file a 40 percent
coverage benchmark filing by January 21, 2018, showing that it provided
signal coverage and offered service to at least 40 percent of the
geographic area of each License area.\45\ T-Mobile claims to have done
so as is evidenced by its report filed with the Commission on January
11, 2018.\46\ In its efforts to meet its buildout requirement
expeditiously, T-Mobile relied on satellite backhaul.\47\
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\43\ See Declaration of Lynn Merrill at 7 and Attachment A.
\44\ Request for Waiver of Section 27.14(g)(1), WT Docket No. 16-
319, Letter to Steve B. Sharkey, T-Mobile License LLC, from Roger S.
Noel, Chief, Mobility Division, Wireless Telecommunications Bureau, FCC
(Dec. 21, 2016).
\45\ Id. at p. 6.
\46\ See File No. 0008059621, Call Sign WQJQ805 (Jan. 11, 2018);
See also e.g., Exhibit 1, depicting T-Mobile buildout map for license
call sign WQJQ805 in BEA144 at a -118 dBm. RWA notes that the coverage
in this report may be overstated. The coverage and number of cell sites
depicted on the map do not appear to match up. Coverage is shown on the
map with no corresponding cell site to support the coverage. Is this
coverage representative of projected coverage? Or did T-Mobile in its
haste leave off the cell sites that would support the -118 dbm
coverage? While filed in a different proceeding, this January 11, 2018
Report is also suspect and should be investigated as a separate matter.
\47\ See Declaration of Jerry Tilley at 6, 9-11 and Attachments
A, C, D, and E depicting satellite equipment installed on T-Mobile
sites.
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It is apparent from Commission records that T-Mobile had been
working on parallel tracks to meet its 700 MHz 40 percent buildout
deadline by January 21, 2018. In doing so, it primarily used satellite
backhaul, but also separately pursued the installation of microwave
and/or circuit backhaul for its Montana sites. However, few--if any--of
these microwave backhaul facilities or circuits appear to have been
installed prior to the January 4, 2018 4G LTE coverage reporting
deadline. Yet, it appears as if T-Mobile went ahead and included these
sites as if it had sufficient backhaul capacity to support 4G LTE
qualifying coverage. While T-Mobile states that it uses satellite
backhaul in a ``tiny fraction'' of its sites,\48\ photographs show that
satellite backhaul is (or was recently) used throughout a significant
portion of Sagebrush's service area--at T-Mobile sites near Scobey,\49\
Tampico,\50\ Frazer,\51\ and West Lustre.\52\ T-Mobile's claims that
its sites with satellite backhaul ``are fully capable of delivering
download speeds of 5 Mbps'' \53\ are not supported by challenge
evidence gathered near Scobey and Glasgow, which show that more than 98
percent of the test points tested by Sagebrush in northeast Montana
failed to meet a 5 Mbps speed threshold.\54\ Given T-Mobile's
substantial reliance on satellite backhaul, the inability of satellite
backhaul to deliver download speeds of 5 Mbps, and the testing results
seen in Sagebrush's service area, it is more than conceivable that T-
Mobile submitted projected coverage as of January 4, 2018, believing
that it could fill in the gaps with backhaul improvements and buildout
of its 600 MHz licenses before the time came to refute any submitted
challenges. (The Commission has now extended the time period between
January 4, 2018 and when challenged carriers are able to respond to
challenges by calling for an investigation and further delaying when
challenged parties have the opportunity to refute challenges.)
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\48\ Universal Service Reform--Mobility Fund, WT Docket No. 10-208,
WC Docket No. 10-90, Ex Parte Letter from Kathleen O'Brien Ham, Senior
Vice President, Government Affairs, T-Mobile, to Marlene H. Dortch,
Secretary, FCC, at p. 2, n. 4 (Dec. 14, 2018) (``T-Mobile Ex Parte'').
\49\ See Declaration of Jerry Tilley at Attachment A--Scobey. The
photos in this attachment are from December 2018 and do not show
microwave facilities installed.
\50\ See Declaration of Jerry Tilley at Attachment C--Tampico. This
photo was taken after the January 4, 2018 4G LTE coverage submission
deadline, sometime between January 15 and February 15, 2018 and does
not show microwave facilities installed.
\51\ See Declaration of Jerry Tilley at Attachment D--Frazer. This
photo was taken after the January 4, 2018 4G LTE coverage submission
deadline, sometime between January 15 and February 15, 2018 and does
not show microwave facilities installed.
\52\ See Declaration of Jerry Tilley at Attachment E--West Lustre.
This photo was taken after the January 4, 2018 4G LTE coverage
submission deadline, sometime between January 15 and February 15, 2018
and does not show microwave facilities installed.
\53\ T-Mobile Ex Parte at p. 2, n. 4.
\54\ See Declaration of Lynn Merrill at Attachment A.
---------------------------------------------------------------------------
Based on Sagebrush's drive test results, photographic evidence
demonstrating the lack of microwave or circuit backhaul capabilities
besides satellite backhaul, and the records of the timing of the
installation of wireline circuits in northeastern Montana, RWA submits
that it is appropriate for the Commission to investigate T-Mobile to
determine if T-Mobile based its reported 4G LTE coverage on what it
projected it would have in place after January 4, 2018. In conducting
its investigation, the FCC should obtain records from T-Mobile related
to when it installed radio access network equipment, power, and
backhaul facilities at its Glasgow and Scobey sites, as well as the
type of facilities installed at its Glasgow, Montana cell site. RWA
believes that this site did not support qualifying coverage on or
before January 4, 2018 and that, to the extent any qualifying coverage
became available, it only became available after the deadline.
IV. T-MOBILE FILED PROJECTED COVERAGE DATA
In addition to demonstrating that T-Mobile overstated coverage
where it did not have backhaul facilities capable of supporting its
claims, the challenge data demonstrates that T-Mobile has built sites
after the January 4, 2018 filing date to cover areas claimed by T-
Mobile within the challenge area. Initial drive test results revealed
that T-Mobile did not have qualifying coverage in many areas where T-
Mobile claimed to have qualifying coverage.\55\ Over the course of the
testing period (and well past the January 4, 2018 deadline for
submitting coverage data) qualifying coverage would suddenly appear
weeks or months after the initial drive testing took place.\56\ As
discussed below, this strongly suggests that T-Mobile relied on
projected coverage when submitting its initial coverage data by the
January 4, 2018 deadline. One example of this projected coverage is the
OK 01919A (Balko) site pictured below.
---------------------------------------------------------------------------
\55\ See Declaration of Jana Wallace at 6.
\56\ See Declaration of Jana Wallace at 6.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
In the January 2018 filings, T-Mobile claimed to cover the Balko,
OK area.\57\ When the MF-II maps were made available for challenge,
Panhandle was unable to locate any cell sites in the Balko, OK
area.\58\ Based on this information, the absence of any cell sites in
Balko and the absence of any T-Mobile facilities in this area other
than a microwave cell site shown just south of Perryton, TX on the map
above, one would expect the claimed coverage in Balko, if correct,
could only have been provided by backhaul facilities utilizing the
microwave cell site shown just south of Perryton, TX on the map
above.\59\ If this were the case, one would expect the T-Mobile service
to become worse the farther north and away from Perryton a test was
conducted.\60\ However, this mapped data illustrates the opposite.\61\
With green representing download speeds below 5 Mbps, the coverage is
shown to improve around Balko, OK.\62\ The test data collected from
challenges show download speeds above the 5 Mbps threshold around the
OK 01919A (Balko) site location that was installed in March of 2018,
but poor download speeds to the south, closer to the Perryton cell
site.\63\ Because the test points show that service greatly improves
the farther away from the Perryton cell site a test is conducted, the
only logical reason for this area to be covered at or above 5 Mbps
during the challenge process is that the OK 01919A (Balko) site was
turned on to fill in the areas that were not sufficiently covered by
the January 4, 2018 deadline yet were claimed as covered.\64\ During
the period Panhandle drove test this area, coverage appeared after the
area had been initially tested, sometimes weeks or months after initial
testing occurred.\65\
---------------------------------------------------------------------------
\57\ For a further discussion of the included map, see Declaration
of Lynn Merrill at 8.
\58\ See Declaration of Lynn Merrill at 8.
\59\ See Declaration of Lynn Merrill at 8.
\60\ See Declaration of Lynn Merrill at 8.
\61\ See Declaration of Lynn Merrill at 8.
\62\ See Declaration of Lynn Merrill at 8.
\63\ See Declaration of Lynn Merrill at 8.
\64\ See Declaration of Lynn Merrill at 8.
\65\ See Declaration of Jana Wallace at 6.
---------------------------------------------------------------------------
Why would there be no coverage in the first half of the Challenge
Process and then coverage suddenly appear later? Did T-Mobile project
its future coverage in hope that it would have the coverage in place by
the time the Challenge Process ended? Was the data submitted by January
4, 2018 based on projected network roll out dates? Certainly, the vast
gulf between T-Mobile's claimed coverage and the drive test data
showing minimal qualifying coverage necessitates asking these
questions.\66\ In trying to find answers, challengers with landline
telephone company affiliates reviewed records related to the
installation of backhaul circuits at the T-Mobile sites. These records
demonstrate that, in most cases, the installation of the circuits
occurred after the January 4, 2018 deadline, meaning that the coverage
claimed by T-Mobile could not have been in place prior to the January
4, 2018 deadline. These records are subject to the FCC's Customer
Proprietary Network Information (``CPNI'') rules and are not being
provided at this time.
---------------------------------------------------------------------------
\66\ See Declaration of Lynn Merrill at Attachments A, B, and C
(depicting Sagebrush, Panhandle, and Pine Belt T-Mobile test data).
---------------------------------------------------------------------------
RWA urges the Commission to prohibit carriers that filed overstated
coverage, projected coverage, or false coverage from participating in
the MF-II reverse auction, and to order those carriers to pay the costs
incurred by entities that participated in the Challenge Process.
Nationwide carriers should also not be allowed to abuse the FCC
challenge process by filing sham coverage maps as a means of
interfering with the ability of rural carriers to continue to receive
universal service support in rural areas. Failure by the Commission to
enforce its coverage map requirements against T-Mobile will undermine
the Challenge Process which, in turn, will harm rural carriers, and the
customers they serve.\67\ RWA also notes for the record that, according
to consumers weighing in on Reddit, a vast portion of rural areas lack
T-Mobile LTE coverage and these rural consumers are not happy with the
level of service being provided by T-Mobile.\68\ In addition to RWA
members determining through expensive drive testing that qualifying
coverage does not exist in its areas, the public is speaking loud and
clear across the United States that T-Mobile coverage maps do not
support its claims.
---------------------------------------------------------------------------
\67\ See House of Representatives Energy & Commerce Committee
Hearing, Oversight of the Federal Communications Commission 2018,
Opening Statement of Mike Doyle (D-PA) (stating ``Chairman [Pai] has
claimed that he cares about rural broadband deployment, but the
Commission in its zeal not to burden major wireless carriers with
reporting where they have wireless service deployed imposed as part of
Mobility Fund II a bizarre and onerous challenge process that requires
rural providers to hire people to walk through cornfields and backyards
trying to prove that communities don't have wireless service. And if
those companies can't afford to send people up, the Commission will
assume these communities are connected. Now tell me, how does that help
the 24 million Americans without access to high-speed broadband?'').
\68\ See e.g., Reddit Blog ``T-Mobile says it did not overstate 4G
LTE coverage to FCC'' https://www.reddit.com/r/tmobile/comments/a7lzx6/
tmobile_says_it_did_not_overstate_4g_lte_coverage/ (last checked Dec.
26, 2018).
---------------------------------------------------------------------------
V. CONCLUSION
For the reasons discussed above, RWA urges the Commission to
investigate the 4G LTE coverage claimed by T-Mobile to determine if T-
Mobile claimed qualifying coverage before it was available. To the
extent T-Mobile claimed qualifying coverage before it was available,
the Commission should require re-filing of T-Mobile's data as of
January 4, 2018 to correct its overstated coverage. In particular, RWA
encourages the Commission to obtain and analyze the following
information related to the timing of T-Mobile's cell sites built in
rural areas in the past three years: (1) date power installed at cell
site; (2) date 4G LTE RAN installed at cell site; (3) date backhaul
installed at cell sites; (4) type of backhaul installed at cell sites
and the capability of the backhaul facilities in place at the time to
support 5 Mbps download speeds; (4) date cell sites were provisioned;
and (5) date commercial service was launched at each of the cell sites.
This information should be provided to the Commission under penalty of
perjury and made available for public scrutiny. RWA further requests
that the Commission consider taking additional action as appropriate,
including, but not limited to, (1) barring T-Mobile from participating
in the Mobility Fund Phase II reverse auction; (2) requiring T-Mobile
to reimburse challengers for their costs associated with the challenge
process; and/or (3) issuing appropriate sanctions for misrepresentation
of information submitted by T-Mobile under penalty of perjury.
RWA looks forward to its continued work with the Chairman,
Commissioners, and Commission staff in this proceeding.
Respectfully submitted,
RURAL WIRELESS ASSOCIATION, INC.
By: Caressa D. Bennet,
General Counsel.
December 26, 2018
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
______
Appendix C
Vermont Department of Public Service
Mobile Wireless in Vermont
January 15, 2019
Mobile Wireless Coverage in Vermont
In October and November of 2018 The Department of Public Service
(PSD) conducted a drive test of the state of mobile wireless coverage
in Vermont. The initiative was undertaken primarily to demonstrate that
good cause exists to expand the territory in the state that is deemed
eligible for forthcoming Federal grants. When the test results were
completed and submitted to the Federal Communications Commission (FCC),
the PSD analyzed the results to derive insights about mobile wireless
service in the state. This report describes the drive test process,
provides a summary of the results, and explains how the information was
assessed by the FCC for the grant process.
FCC Mobility Phase II program
The FCC, through the Mobility Phase II program, intends to direct
up to $4.53 billion in support through reverse auctions to bidders that
commit to offer mobile wireless service in eligible areas throughout
the Nation. When the program was announced only a small amount of
territory in Vermont was eligible for this funding. Under the FCC rules
for the program, areas without access to wireless service providing 5
Mbps will be eligible for the grants. To identify these areas, the FCC
directed service providers to submit information, on a confidential
basis, depicting the area where they believe consumers have access to
service with at least 5 Mbps. The FCC identified the eligible areas as
those areas where no company asserted that it offers service at 5 Mbps
or better. This process resulted in only 1,310 square kilometers of
eligible areas in Vermont, out of a total territory of approximately
25,000 square kilometers.
The FCC also authorized a process by which states could challenge
asserted wireless coverage in ineligible areas. After reviewing
confidential maps submitted by providers that purport to show the
extent of coverage it was clear that many of the areas purportedly
served in fact very likely lacked service. The PSD undertook a test of
all major roads in the state to determine where mobile wireless service
is actually available from a consumer perspective. The data gathered by
the Department through its participation in the challenge could render
significantly more territory in Vermont eligible for this grant
process.
Drive Test Methodology
Because the primary purpose for the Department's drive test effort
was to participate in the FCC challenge process, the PSD developed a
methodology to generate data that would meet the rigorous
specifications laid out by the FCC for a challenge. The FCC developed a
map that divides each state into thousands of one-kilometer square
blocks. In order to successfully challenge coverage in a block, a
challenger was required to submit results of download speed tests
conducted within that block which demonstrate speeds below 5 Mbps.
Separate results had to be submitted for each provider that allegedly
serves that block, within the part of the block they purportedly serve.
Moreover, the FCC specified that to successfully challenge service in a
block, a challenge must encompass 75 percent of the test area, where
each test point was afforded a radius of 400 meters.
Some states prepared challenges by reviewing the confidential maps
submitted by the providers and targeting testing in small areas. Other
participants chose to challenge service for only individual providers
in select areas. Analysis of initial proof-of-concept tests showed that
a drive test sticking to main roads would not be very efficient at
meeting the FCC requirement to test 75 percent of the territory of a
block. Meeting the 75 percent threshold would require several tests at
least 400 meters apart within each block. This could be met if the
route went directly through the middle of a block. In most cases
however, the main roads transect the blocks obliquely, that is, along a
side or a corner. In these blocks, a drive test would not meet the 75
percent requirement. The PSD lacked time or budget to conduct a test
thoroughly enough to meet the 75 percent threshold on a wide basis. The
PSD considered testing only small targeted areas with a goal of testing
on side roads to meet the 75 percent threshold in those areas.
Ultimately, the PSD decided that the results of a drive test throughout
the state could provide insight beyond the challenge process.
Therefore, the PSD determined that it would conduct a drive test of all
major roads (roads that receive Federal aid) even though only a portion
of the transected blocks would reach the 75 percent threshold.
The PSD identified an Android smartphone application, G-NetTrack,
that recorded the results specified by the FCC. An initial review
demonstrated that while the app recorded results for the three required
parameters (latency, signal level, and download speed) each was
recorded with a different timestamp and location. It would be difficult
to put this information in the format required by the FCC for the
submission. PSD staff contacted the app developer who agreed to update
the app to include all three parameters in a data sequence with a
single timestamp and location in the results log file. Deployment of
the app required the assistance of the Vermont Agency of Digital
Services (ADS). ADS configured an Internet server to host a file
containing thousands of pictures. The app on the smartphones was
configured to attempt to download this file and record the results at
set intervals.
The PSD configured the application to conduct a test sequence
lasting 20 seconds, consisting of a 10 second download test, 5 second
ping test, and a 5 second pause. The PSD acquired handsets and service
for each of the six facilities-based providers that asserted service in
the state: AT&T, Sprint, T-Mobile, U.S. Cellular, Verizon Wireless, and
VTel Wireless. The PSD configured the app to continually repeat the
test sequence on each handset while the drive tests were underway. With
an average speed of 40 Miles per hour (18 meters per second), the test
every 20 seconds produced data with about 360 meters between result
locations. The product of this effort is a set of 187,506 download
speed test results at locations along all of the major roads in the
state.
Statewide Results
The Department employed the one-kilometer square blocks developed
by the FCC to generalize the results. This generalization is helpful
for analysis and to view the information in maps at large scales, such
as for a statewide view. For each carrier, the PSD determined the
average download speed recorded in each block using the following five-
tier classification system:
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
It is important to keep in mind that while this generalization is
indicative of the coverage, it is not meant to assert the availability
of such coverage throughout each block. In fact, there can be
significant variation in coverage within any block. Users should refer
to the individual download speed tests visible on the interactive maps
for more precise information.
The chart below compares the average download speeds obtained by
each carrier in the tests. For each carrier, the chart lists the
percentage of blocks where the average recorded download speed falls
into five different speed tiers.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Analysis of this data shows these key findings:
The two largest carriers, AT&T and Verizon, have a similar
number of blocks where they have at least some service: 72
percent for Verizon and 74 percent for AT&T;
65 percent of the tested blocks have service from both AT&T
and Verizon;
54 percent of the tested blocks are served by both AT&T and
Verizon at speeds better than 0.256 kbps;
15 percent of the tested blocks have no service from either
AT&T or Verizon;
Verizon has the largest number of blocks with the highest
speeds, 31 percent for Verizon vs. 13 percent for AT&T and 15
percent for T-Mobile;
There are 106 blocks served only by VTel Wireless, including
47 where the download speed was less than 0.256 kbps.
Blocks were there is no recorded speed test for that carrier are
the result of the nature of the drive test. While the drive test
recorded data for all carriers along the same routes, the tests were
not exactly synchronized, so not all carriers have results in all
blocks.
Vermont FCC Challenge Submittal
The FCC employed an automated process to review the results of the
drive test submitted by the PSD. In order to challenge service in a
given one-kilometer block, challengers were required to submit download
speed tests within the asserted coverage area in that block for each
carrier that asserted coverage. The process identified 4,186 blocks
where the challenge was successful. Of these, 789 blocks met the
requirement to test 75 percent of the block. In another 3,397 blocks,
the challenge was only provisionally accepted because the tests
submitted covered less than 75 percent of the block. The process
rejected the challenge in 1,879 one-kilometer blocks. Of these rejected
blocks, 1,607 were apparently rejected because all of the tests for all
carriers that asserted service in that block exceeded 5 Mbps. Another
272 blocks had tests that demonstrated less than 5 Mbps, (including 194
blocks showing no service at all) but were rejected because the
specific location of the tests fell outside of the company's asserted
coverage area. Many of these rejected blocks are adjacent to the
identified Eligible Area.
The table below depicts the quantity of blocks and the quantity of
E-911 Business and residential buildings within these blocks for
different categories of blocks.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Analysis of this information shows these key findings:
The drive test transected only 23 percent of the blocks in
the state, but these blocks contain 65 percent of the buildings
in the state;
The challenge in 30 percent of the transected blocks were
rejected, largely because the service recorded exceeded 5 Mbps;
Only 13 percent of the transected blocks met the 75 percent
threshold;
Testing the 70 percent of the blocks that the drive test did
not transect would require a significant effort, and only a
small portion would meet the 75 percent threshold.
Interactive Map
The Department prepared an interactive map service depicts mobile
wireless coverage for each of the six facilities based providers
operating in Vermont: AT&T, Sprint, T-Mobile, U.S. Cellular, Verizon
Wireless, and VTel Wireless. The map is accessible on the Department
website.
Use the two buttons in the upper right to navigate the site:
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
The layer for each provider includes two maps: a coverage map with
information prepared by the service provider, and the results of a
drive test conducted by the Vermont Department of Public Service in
October and November, 2018.
COVERAGE MAP: The coverage maps, shown in pink, were submitted by
the provider to the Federal Communications Commission and indicate
where the provider believes consumers should expect to receive data
service with at least 200 kbps, as of December 31, 2017. This publicly
available information was downloaded from the FCC website; it was
produced by the individual providers and the PSD makes no claim about
its accuracy. For VTel Wireless, users may optionally enable the VTel
Wireless ARRA service territory map by clicking Layer button, then the
right arrow next to VTel.
DRIVE TEST MAP: PSD staff employed the android smartphone
application G-NetTrack to conduct download speed tests at approximately
300 meter intervals along all federal-aid highways. The results of the
drive tests are show with five colors, as follows:
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
The drive test data is presented in two formats, depending on the
scale of the map (how far the user zooms in or out):
DATA TEST POINTS: When zoomed-in to a neighborhood scale,
the service depicts the results of the 187,000 individual data
tests. Clicking on an individual point will provide the
information from that test, including the timestamp, the
download speed (in Mbps), the latency (the round-trip time for
a request to a website, in milliseconds), and the signal
strength (RSRP in dBm).
AVERAGE SPEED BLOCKS: When zoomed-out beyond the
neighborhood scale, the map depicts blocks, one kilometer
square, that show the average of the download speeds recorded
within that block. This generalization of information provides
users an indication of coverage in a neighborhood when viewed
at different scales. THIS DOES NOT INDICATE SERVICE THROUGHOUT
A BLOCK. Users should zoom-in to view the individual download
speed test points and judge accordingly.
In addition to the data for each individual provider, the Layer
button allows users to select two additional views:
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
The COMPOSITE layer depicts the blocks that contain download tests,
color coded by the average of all of the tests, for all carriers,
conducted in that block. This includes data for all carriers, and thus
masks variation in coverage between individual providers. Clicking on
an individual block will show the average results for each provider in
that block. Results listing ``999.000'' indicate no test was conducted
for that carrier in that block.
The CHALLENGE layer depicts the status of each block in the
submission of the PSD in the FCC Mobility Fund Phase II Challenge
process. Blocks are depicted in one of three colors. Blue blocks are
where the challenge was rejected, either because a.) the block is
already largely eligible, or b.) because no tests below 5 Mbps were
submitted. Blocks that are red and pink were accepted because tests
with results less than 5 Mbps for each carrier that asserted coverage
were submitted. Blocks in red met the requirement for testing 75
percent of the block. The challenge for the blocks in pink may be
considered but did not meet the 75 percent territory requirement. This
layer also includes the original ``eligible area'' in purple, areas
where no carrier asserted that it provides service.
Difficulty meeting the 75 percent threshold:
Of the 4,186 tested blocks, 3,397 did not meet the 75 percent
threshold. Here are some examples that demonstrate the difficulty of
meeting this requirement.
For instance, see Grid_Col 4,768/Grid_Row 2,413. The PSD challenge
for this block was accepted and the challenged area was calculated to
be 57.65 percent. The PSD tests were all along the main road, Route 12.
There are no other roads in this block, and the steep terrain would
make additional testing in this cell by hiking treacherous. Moreover,
the buildings in the area would be along the roads, so testing the area
of the block lacking roads is highly inefficient.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Blocks rejected because the tests were ``Outside Challengeable areas of
a block''
Of the 1,879 blocks where the tests were deemed invalid, 194 were
blocks where the tests demonstrate no service from any carrier, and 78
show service less than 5 Mbps from any carrier. These were likely
rejected because the tests were not conducted within the
``challengeable'' area of a block. That is, the tests need to be
conducted not only within the block, but for each carrier, the test
must be conducted within the portion of the block that the carrier
claimed it served. This is problematic if the carrier asserts that it
serves a part of a block with no roads.
For example see Grid_Col 4768/Grid_Row 2414. Most of the cell is
allegedly served, and is thus ineligible, with just a few pixels that
lack asserted coverage. By chance the PSD tests in this cell fell
within these few pixels.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
As an another example, see the four blocks around Grid Col 4753,
Grid_Row 2408. The tests were all along the roads in Eligible areas,
while the area with asserted coverage lies in the roadless areas on the
hills above.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
______
Western Governors' Association
April 10, 2019
Hon. Roger Wicker,
Chairman,
Committee on Commerce, Science, and Transportation,
United States Senate,
Washington, DC.
Hon. Maria Cantwell,
Ranking Member,
Committee on Commerce, Science, and Transportation,
United States Senate,
Washington, DC.
Dear Chairman Wicker and Ranking Member Cantwell:
Western Governors appreciate the Committee's attention to the
important matter of broadband mapping accuracy as you convene your
April 10, 2019 hearing on Broadband Mapping: Challenges and Solutions.
Attached please find three Western Governors' Association (WGA) policy
resolutions that address broadband deployment:
WGA Policy Resolution 2019-04, Health Care in Western
States;
WGA Policy Resolution 2018-13, Workforce Development in the
Western United States; and
WGA Policy Resolution 2017-09, Western Agriculture.
Also attached is a July 16, 2018 letter to National
Telecommunications and Information Administration Assistant Secretary
David J. Redl expressing concern about the use of census block-level
reporting in the Federal Communication Commission's Form 477 reporting
process.
I request that these documents be included in the permanent record
of the hearing, as they articulate Western Governors' policy positions
and concern on this important issue.
Please contact me if you have any questions or require further
information. In the meantime, with warm regards and best wishes, I am
Respectfully,
James D. Ogsbury,
Executive Director.
Attachments
______
Western Governors' Association
Policy Resolution 2019-04
Health Care in Western States
A. Background
1. Ensuring access to high-quality, affordable health care services
is an important element of maintaining and enhancing the
quality of life in western states for our growing populations.
It is the basis for healthy communities and healthy economies.
2. Western states face unique challenges in health care, including
growing rates of substance use disorder, provider shortages in
underserved and rural areas, and limited access to broadband.
Low population densities and the vast distances between
population centers also make it difficult for providers to
establish economically-sustainable health care systems in rural
areas.
3. Distance and density also inhibit construction of the technology
infrastructure that would provide or improve broadband
connectivity in underserved and rural areas. Expanding
broadband access provides numerous quality-of-life benefits for
rural Americans, including economic development, social
connectivity, education, public safety, and access to
telehealth and telemedicine.
4. The health care sector faces severe personnel shortages in
western states, despite efforts of Western Governors, such as
the foundation of Western Governors University and other
medical training programs in western states, to ensure adequate
numbers of qualified medical personnel. This challenge is
particularly acute in the West's underserved and rural areas.
Ensuring access to health care services requires an adequate
number and distribution of physicians, nurses and other trained
health care professionals. Population growth, aging residents,
and challenges involving Tribal health care and services for
veterans require a renewed focus on developing our Nation's
health care workforce.
5. Western states struggle with access to behavioral health
services and higher-than average suicide rates. The ten states
with the highest suicide rates in the Nation are all located in
the West.
6. Substance use disorder (SUD), including alcohol and drug misuse,
is a major public health and safety crisis affecting nearly 21
million Americans. It is particularly prevalent in western
states where individuals are more likely to have SUD during
their lifetime. SUD crosses all social and economic lines and
tragically takes the lives of tens of thousands of Americans
every year. While state and Federal progress has been made to
fight this epidemic, additional efforts are necessary to help
bridge prevention and treatment gaps in western states.
7. In many cases, health disparities and barriers to accessing
health care are particularly acute for certain populations in
the West. A better understanding of the role that social
determinants play in health outcomes can inform the development
of effective health policy to increase access for these
populations.
8. Western states have a unique body of experience, knowledge and
perspective with respect to health care. The Western Governors'
Association (WGA) is ideally situated to collect and
disseminate information, including best practices, case studies
and policy options, that states can use to improve the
foundation for health care services and advocate for shared
policy priorities on behalf of their citizens.
B. Governors' Policy Statement
1. Federal efforts to address health care workforce and access
needs should reflect early, meaningful and substantive input
from Governors, who are best positioned to assess the needs of
their states and help develop solutions to meet these needs.
State-federal collaboration and coordination are integral to
addressing these health care challenges. Wherever possible, and
where appropriate, the Federal government should respect state
authority and maximize flexibility granted to states and
Governors.
2. The Federal government should work with states to facilitate the
deployment of broadband to underserved and rural areas,
recognizing that adequate broadband access has a direct
correlation on rural populations' ability to access telehealth
and telemedicine.
3. Despite efforts by Western Governors to address the shortage of
qualified health care workers, significant challenges remain.
Governors urge the Federal government to examine and implement
programs to ensure states have an adequate health care
workforce--including in primary care and other in-demand
specialties--that is prepared to serve diverse populations in
urban, suburban, and rural communities. Governors also support
efforts to increase the diversity of the health care workforce
to improve health outcomes for all.
4. Western Governors support efforts to improve the quality and
quantity of behavioral health services available to our
residents, as these services are essential to reducing suicide
rates and treating a range of behavioral health conditions,
including substance use disorder.
5. The Federal government should work toward treating addiction as
a chronic illness and work with Western Governors to develop
strategies for addressing substance use disorder that work in
concert with state efforts and recognize regional variations in
substance use disorder patterns.
C. Governors' Management Directive
1. The Governors direct WGA staff to work with Congressional
committees of jurisdiction, the Executive Branch, and other
entities, where appropriate, to achieve the objectives of this
resolution.
2. Furthermore, the Governors direct WGA staff to consult with the
Staff Advisory Council regarding its efforts to realize the
objectives of this resolution and to keep the Governors
apprised of its progress in this regard.
Western Governors enact new policy resolutions and amend existing
resolutions on a bi-annual basis. Please consult westgov.org/
resolutions for the most current copy of a resolution and a list of all
current WGA policy resolutions.
______
Western Governors' Association
Policy Resolution 2018-13
Workforce Development in the Western United States
A. Background
1. Workforce development efforts contribute to the economic well-
being of western states by enabling people to find fulfilling,
well-paying jobs, fostering economic mobility, and ensuring
that businesses have access to the skilled employees they need
to thrive.
2. Western states had an average unemployment rate of just under
4.0 percent in March 2018.\1\ Many businesses report that they
cannot find qualified candidates for open positions. At the
same time, many jobseekers are unable to find good jobs for
which they are qualified.
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\1\ Bureau of Labor Statistics, Local Area Unemployment Statistics,
May 18, 2018.
3. Workforce development challenges are particularly acute in rural
communities, which are commonly characterized by higher rates
of unemployment, a lack of economic diversity, geographic
isolation, and limited infrastructure, including access to
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broadband.
4. Economic equity continues to be a problem across states, with
people of color and people with disabilities, regardless of
career preparation and credential levels, seeing poorer rates
of employment and earnings than majority populations.
5. There are 6.6 million unfilled jobs in the United States due in
part to a shortage of workers with the skills and
qualifications to fill those positions.\2\ The largest gap is
in middle skills jobs, which require more than a high school
diploma but less than a four-year degree.
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\2\ Bureau of Labor Statistics, Job Openings and Labor Turnover
Summary, May 8, 2018.
6. Postsecondary education and training is critical in today's
economy. Almost 80 percent of jobs in the United States require
a postsecondary credential, including certificates, associate
degrees, four-year degrees, and licenses.\3\
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\3\ National Skills Coalition, United States Middle-Skill Fact
Sheet, February 2017.
7. On average, those holding a bachelor's degree earn more than
those who have not attained that degree, but those who do not
reach that level of education can still find good employment.
There are 30 million jobs that don't require a four-year degree
and pay at least $35,000 per year with a median salary of
$55,000.\4\
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\4\ Carnevale, A.P., Strohl, J., and Ridley, N., Good Jobs that Pay
Without a BA: A State-by-State Analysis. Georgetown University Center
of Education and the Workforce, 2017.
8. Education systems have not kept pace with economic realities.
Student success is traditionally perceived, and measured, as
moving directly from high school to a four-year degree program.
Today, only 20 percent of students successfully complete that
traditional pathway to their career.\5\ The rest are finding
their own pathways to success, which may include entering the
world of work or pursuing other types of credentials. Many,
however, encounter obstacles.
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\5\ U.S. Department of Education, National Center for Education
Statistics, The Condition of Education 2017, May 2018.
9. On average, only about one-third of high schoolers are engaged
in school, meaning that two-thirds are not actively involved in
or enthusiastic about school.\6\ Three million young adults
ages 16-24 are not participating in either work or
education.\7\
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\6\ 2016 Gallup Student Poll Snapshot Report
\7\ Brookings, Employment and disconnection among teens and young
adults: The role of place, race, and education, May 2016.
10. Additionally, many Americans start a college degree but do not
complete it, leaving them with the burdensome costs of higher
education but no wage benefit--35 million people over 25 have
some college credits but no degree.\8\
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\8\ U.S. Census Bureau, Educational Attainment in the United
States: 2017, December 14, 2017.
11. As students increasingly pursue indirect routes to higher
education, over 70 percent of students enrolled in
postsecondary education are now ``nontraditional students'' who
may be older, working full or part time, or caring for
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children.
12. Technology will continue to be a disruptive force in the labor
market, driving potentially drastic changes in the labor
demands of certain industries. It is expected that many jobs
that will be in demand in 2030 do not yet exist. Workers will
need to be able to acquire new skills over their careers to
adapt to change. Up to one-third of U.S. workers in 2030 may
need to learn new skills or move into a new occupation due to
the impacts of automation.\9\
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\9\ McKinsey Global Institute, Jobs Lost, Jobs Gained: Workforce
Transitions in a Time of Automation, December 2017.
13. To address these issues, Western Governors have prioritized a
variety of workforce development efforts, from better aligning
education with labor market demands to expanding workforce
services and training opportunities for the unemployed and
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underemployed to attracting more skilled workers.
14. Western states are also leading the way on expanding work-based
learning opportunities for both students and adults. Work-based
learning programs, including registered apprenticeships, allow
people to acquire in-demand skills while earning a salary.
15. Employer leadership is critical to ensure that workforce
development efforts are satisfying the needs of an ever-
changing economy. Businesses in the West have taken an active
role in working with educational institutions and workforce
agencies but increasing industry participation will remain
critical.
B. Governors' Policy Statement
1. Western Governors recognize that there are many pathways
students can take to a successful career, including short-term
education and skills training or work-based learning programs
such as registered apprenticeships. Students and jobseekers
should have access to understand their options and the
potential outcomes of these programs.
2. Facilitating lifelong learning is essential to prepare for the
impacts of technology on the labor market. Western Governors
encourage Congress to increase student access to short-term
education and skills training programs in reauthorization of
the Higher Education Act, including through expanding the Pell
Grant program to include high-quality short-term training
programs leading to industry-recognized credentials. These
flexible work-force oriented funds should be coupled with plans
to adopt and report outcomes metrics tied to employment and
earnings to maximize the success of this policy in equipping
workers for high-opportunity jobs and careers.
3. Western Governors also support the expansion of work-based
learning programs, including registered apprenticeships.
Western Governors encourage Congress and Federal agencies to
support and incentivize state-, local-, and industry-led
partnerships to create and scale work-based learning and
apprenticeship programs. New Federal investments in
apprenticeships should align with existing efforts to foster a
coherent system with minimal duplication at the federal, state,
and local level.
4. Career and technical education (CTE) helps expose students to
their career options and develop skills they will need in the
workforce. Western Governors call on Congress to reauthorize
and fully fund the Carl D. Perkins Career and Technical
Education Act. Reauthorization of the act should take into
consideration the following principles:
Governors and states are in the best position to
determine how to use Federal CTE funding to meet the unique
needs of their economies.
High-quality CTE programs should lead to in-demand,
high wage careers; include career and academic advising;
include pathways to four-year degrees, for example through
articulation agreements or stackable credentials; and
develop employability skills through integrated education
and training, work-based learning or leadership
opportunities.
5. Western Governors note that Federal funding for workforce
development through the Workforce Innovation and Opportunity
Act supports economic growth and job creation in the states.
Western Governors request that the 15 percent reserve for
statewide activities be maintained. This funding allows
Governors to be flexible in addressing state needs and supports
innovation.
6. Western Governors encourage the Federal agencies, including the
U.S. Department of Labor and U.S. Department of Education, to
coordinate their efforts to better align Federal workforce
development, career and technical education, and higher
education programs.
7. Western Governors recognize the benefits of measuring and
reporting outcomes by institution and program. Reporting
completion rates, employment and earnings will provide useful
information for students and their families and help promote
the success of these programs to prepare students for in-demand
jobs and careers in their regions. Western Governors encourage
Congress to include the College Transparency Act in
reauthorization of the Higher Education Act, to adopt and
report on earnings, employment, and credential attainment
metrics by education provider and individual program in a
manner that protects student privacy and ensures data security.
8. Employers play an important role in state workforce development
efforts. Western Governors support efforts to incentivize
employers to play a more active role in talent development,
through partnership with state workforce development agencies
and educational institutions or investments in the skills and
training of their employees.
9. Rural communities are at risk of falling further behind in
skills necessary for the economy of the future due to a lack of
broadband access. Western Governors encourage Federal agencies
and Congress to continue to deploy resources to solve this
urgent need.
10. Professional licensing requirements vary by state and can create
a barrier to mobility for professionals in western states.
Where possible, Western Governors should work together to
minimize this barrier.
C. Governors' Management Directive
1. The Governors direct WGA staff to work with Congressional
committees of jurisdiction, the Executive Branch, and other
entities, where appropriate, to achieve the objectives of this
resolution.
2. Furthermore, the Governors direct WGA staff to consult with the
Staff Advisory Council regarding its efforts to realize the
objectives of this resolution and to keep the Governors
apprised of its progress in this regard.
Western Governors enact new policy resolutions and amend existing
resolutions on a bi-annual basis. Please consult www.westgov.org/
resolutions for the most current copy of a resolution and a list of all
current WGA policy resolutions.
______
Western Governors' Association
Policy Resolution 2017-09
Western Agriculture
A. Background
1. Agriculture and forestry in the western states and territories
are significantly different than in other regions of the
country. We have greater variations in soil, climate, terrain,
commodities and production practices, and water availability.
2. Farms, forests, and rangelands are important contributors to the
economies and quality of life of western states. Among other
important values, western agricultural and forest lands are
primary sources of open space, wildlife habitat, water
supplies, and diverse rural economic opportunities in the
recreation, food, fiber, energy and bio-based product
industries.
3. Trade promotion plays an important role in ensuring that western
agricultural products and food have an opportunity to compete
with products produced and subsidized internationally.
4. Western states have seen some of the most significant increases
in per-capita veteran populations since 2000, including surges
in returning veterans under the age of 25. It is estimated that
nearly 25 percent of all veterans live in rural areas. These
veterans have slightly lower rates of employment compared to
veterans living in urban areas and to their non-veteran rural
colleagues.
5. Responsible management of Federal lands is a significant concern
for Western Governors. Western states include more than 75
percent of our national forest and rangeland ecosystems. These
public lands serve as critical economic drivers, and they
provide numerous conservation benefits, water supply, and
recreational opportunities for Western communities and the
Nation.
6. The West's network of land-grant universities and colleges,
including Cooperative Extension Service programs, continue to
provide national leadership in research to develop more
resilient seeds and crops, manage soil health, advance
technology deployment in the bio-based economy and conduct on-
farm research experiments that help farmers and ranchers be
more effective and efficient.
7. Western Governors recognize that nutrition assistance programs
can meet the needs of children and the most vulnerable, while
creating economic opportunity across the agriculture supply-
chain from the store where food is purchased, all the way back
to the farm. Western Governors acknowledge recent efforts to
reduce rates of nutrition program fraud and abuse, deliver
programs under budget, and improve program effectiveness.
8. Many agricultural producers in the West rely on irrigation water
delivery systems that are shared among multiple producers and
operated by an irrigation district, canal company, or mutual
ditch company.
B. Governors' Policy Statement
1. Western Governors support funding for the U.S. Department of
Agriculture (USDA) Market Access and Foreign Market Development
Programs to promote opportunities for western producers to
increase export revenues and encourage trade agreements that
maximize benefits for the West's farmers, ranchers and forest
landowners.
2. Western Governors support adequate funding for the USDA
Specialty Crop Block Grant Program (SCBGP) that provides
critical research, education, and promotion tools to the fruit
and vegetable producers.
3. Western States have experienced sharp declines in farm income
and farm prices since 2013. Western Governors support a farm
safety net that recognizes past deficit reduction contributions
of the agricultural sector and maintains funding for other key
commodity, conservation, crop insurance, research, energy, and
export promotion programs. In particular, Western Governors
note that the Conservation title of the 2014 Farm Bill
contributed to deficit reduction, saving taxpayers $6 billion
by consolidating 23 programs into 13, streamlining and
targeting delivery to farmers, ranchers, and foresters. Western
Governors support farm bill funding levels based on need rather
than baseline budget targets.
4. Western Governors encourage the expansion of programs that can
meet the unique educational, training, technical and financial
needs of new, beginning and veteran farmers and ranchers and
other USDA programming that can help returning veterans develop
and expand business opportunities in rural communities.
5. Western Governors continue to support collaborative, targeted
and voluntary conservation to address locally identified
natural resource issues for farm, range, and forest resource
concerns on private and public lands, such as soil health, air
and water quality, drought and wildfire resilience, wildlife
habitat conservation and invasive species. Western Governors
support the role of conservation title programs in providing
voluntary solutions to threatened and endangered species, water
quality impairments, groundwater recharge, and other regulatory
concerns potentially facing producers.
6. Western Governors support an increase in the role that state and
local governments have in managing public lands for multiple
uses, including agriculture.
7. Western Governors continue to urge Congress to provide a
comprehensive solution for the current approach to budgeting
for wildland fire for the Departments of Interior and
Agriculture. Any fire budget solution must address the chronic
problem of the rising costs of wildfire and the complicating
problem of mid-season budget transfers when appropriated
funding becomes insufficient. A comprehensive fix is needed to
address capacity constraints and allow for a predictable
program of work for agencies to fulfill their management
responsibilities.
8. Western Governors acknowledge significant progress toward
achieving forest restoration goals by using authorities granted
in the 2014 Farm Bill. Western Governors support permanent
authorization of the Insect and Disease designation provisions
of section 602 of the 2014 Farm Bill and the elimination of
project constraints from section 603 for condition class or
fire regimes outside of the Wildland Urban Interface (WUI).
Western Governors also support creating additional flexibility
to Good Neighbor Authority to address conflicting language on
road construction and reconstruction and the uses of program
income. The lack of flexibility restricts opportunities for
states to partner in shared stewardship work across boundaries.
9. Within the context of comprehensive wildland fire budget reform,
existing law and forest plans, Western Governors support the
use of new tools to streamline environmental analysis to
increase the pace and scale of restoration activities.
Specifically, Western Governors support creation of a new pilot
program to prioritize landscape-scale environmental analysis
for restoration projects envisioned over geographies greater
than 100,000 acres. This pilot program should allow for
predictable project-scale implementation and adaptive
management. Western Governors believe Federal agencies should
develop guidance to build consistency in environmental analysis
and bring agency practice in conducting environmental
assessments (EAs) more in line with the administrative policy
intent of streamlined, summary documents. Western Governors
affirm that Congress should resolve outstanding issues with
potential requirements to reinitiate endangered species
consultations following the adoption, amendment or revision of
an appropriate management plan.
10. Western Governors support Congress establishing a restoration
categorical exclusion (CE) based on a record of analysis from
the past five years of projects where agency analysis and a
decision recognized a finding of no significant environmental
impact. Western Governors support allowing Federal agencies to
analyze only the action and no-action alternatives when a
project is collaboratively developed, unless a third
alternative is proposed during scoping and meets the purpose
and need of the project. Western Governors also support
rewarding successful implementation of collaborative projects
through funding, retained-receipt authority, or other capacity
to pursue subsequent projects.
11. Western Governors support efforts to expand research funding to
address drought, a changing climate and extreme weather risks
facing western producers.
12. Western Governors encourage the effective use of extension and
other partnerships to deliver practical tools, technologies and
information to farmers, ranchers and forest landowners.
13. Nutrition assistance programs should continue to allow
flexibility for states to respond to unique economic
conditions, serve all eligible participants without drastically
reducing benefits, and encourage continued pursuit of
transparency and accountability in program administration.
14. Western Governors support changes to Conservation Title programs
that remove existing contracting barriers for western
producers, and make the Farm Bill's conservation title programs
more accessible and relevant to western producers and their
associations.
15. Western Governors support coordinated state and Federal action
to expand markets for wood products that can achieve forest and
rangeland restoration objectives and foster rural employment
and income opportunities. Western Governors support coordinated
financing and grant support from USDA Rural Development
programs and the USDA Forest Service to advance wood product
business development, infrastructure, and demonstration
products in the areas of mass timber construction and biomass
energy.
16. Western Governors support the USDA, Animal and Plant Health
Inspection Service (APHIS) and Agriculture Research Service
(ARS). APHIS works in partnership with state departments of
agriculture to monitor, prevent and control infestations of
invasive pests and diseases and curtail or minimize wildlife
conflicts, which can cause widespread environmental and
economic damage and safety hazards. APHIS works in cooperation
with other Federal agencies, states, territories, counties and
private entities to implement management programs. ARS conducts
research to develop and transfer solutions to agricultural
problems of high national priority, and shares information to
ensure high quality, safe food and other agricultural products.
ARS research helps sustain a competitive economy; enhance the
natural resource base and the environment; provide economic
opportunities for rural communities and society as a whole,
and; provide the necessary infrastructure to create and
maintain a diverse workplace.
17. Western Governors support the continued efforts of the Rural
Utilities Service to provide financial assistance for drinking
water, wastewater facilities and broadband connectivity in
rural and remote areas, particularly in communities that have
minimal or no such infrastructure. Expanding broadband access
to rural America will allow citizens to compete in a global
market and have access to IT health care, education and public
safety resources.
18. Western Governors support the recommendations identified over
the course of the WGA National Forest and Rangeland Management
Initiative, and incorporate those recommendations related to
the reauthorization of the Agricultural Act into this
resolution by reference.
C. Governors' Management Directive
1. The Governors direct WGA staff to work with Congressional
committees of jurisdiction, the Executive Branch, and other
entities, where appropriate, to achieve the objectives of this
resolution.
2. Furthermore, the Governors direct WGA staff to consult with the
Staff Advisory Council regarding its efforts to realize the
objectives of this resolution and to keep the Governors
apprised of its progress in this regard.
Western Governors enact new policy resolutions and amend existing
resolutions on a bi-annual basis. Please consult www.westgov.org/
resolutions for the most current copy of a resolution and a list of all
current WGA policy resolutions.
______
Western Governors' Association
July 16, 2018
David J. Redl,
Assistant Secretary for Communications and Information,
National Telecommunications and Information Administration,
U.S. Department of Commerce,
Washington, DC.
Dear Assistant Secretary Redl:
As Executive Director of the Western Governors' Association (WGA),
I am pleased to have the opportunity to provide comments on the
importance of improving the quality and accuracy of broadband
availability data, particularly in rural areas. High-quality data is
necessary to ensure that public broadband deployment efforts are cost
effective and prioritize areas that either wholly or significantly lack
access.
WGA is an independent organization representing the Governors of 19
western states and three U.S. territories in the Pacific. The
Association is an instrument of the Governors for bipartisan policy
development, information-sharing and collective action on issues of
critical importance to the western United States.
Western states contain many rural areas that lack sufficient access
to broadband, as evidenced by the Connect America Funding Phase II
eligible areas and the Federal Communication Commission's (FCC)
recently updated broadband map. This widespread lack of connectivity
limits communities' access to health care and public safety resources;
prevents businesses from competing in the digital economy and
diminishes students' access to education and training opportunities.
WGA Policy Resolution 2018-13, Workforce Development in the Western
United States, expresses the support of western Governors for
congressional and Federal efforts to deploy broadband to rural
communities to promote workforce development efforts.
Federal efforts, such as the Rural Utilities Service's new
broadband pilot program, are critical to closing the digital divide.
WGA is concerned, however, that the FCC's updated broadband map is not
sufficiently accurate nor granular enough to support efficient and
effective broadband deployment in the West.
Through the Form 477 reporting process, the FCC considers a census
block ``served'' if a single residence in the block has access to
broadband. This reporting protocol overstates broadband availability in
larger, rural census blocks common in western states. WGA is also
concerned that the use of ``maximum advertised,'' not ``actual,''
speeds when mapping broadband coverage does not accurately portray the
service that customers receive.
On behalf of Western Governors, I encourage you to pursue
meaningful partnerships with states to help address these concerns.
Please let WGA know how we may meaningfully contribute to your efforts
to improve the quality of broadband data and ensure the efficient and
effective use of Federal funds to promote broadband deployment.
Sincerely,
James D. Ogsbury,
Executive Director.
______
Response to Written Question Submitted by Hon. Roger F. Wicker to
Tim Donovan
Question. Mr. Donovan, in your testimony you state that
policymakers should apply a specific set of factors to standardize data
collection for broadband maps. Please explain why the inclusion of
standardized data relating to Signal Strength, Cell Edge Probability,
Cell Loading, and Clutter Factors would help produce better broadband
maps? Would legislation be helpful in ensuring that those factors are
included in the FCC's data collection and broadband mapping processes?
Answer. Signal strength, cell edge probability, cell loading and
clutter factors are parts of a technological link budget that determine
the transmission to a receiver, which is ultimately the experience of
the wireless user. Standardizing, and in the case of clutter factors
disclosing, these aspects at the levels included in my testimony will
help produce a mobile coverage map that more closely reflects the on-
the-ground experience. With regard to using the resulting map to
determine areas initially eligible for support through programs like
the Mobility Fund II, more reliable maps will allow policymakers to
better target support to appropriate areas and reduce the chances of
overbuilding. Further, starting the process with maps based on more
reliable data will reduce the need for an excessively burdensome
challenge process, such as the experience in the challenge process last
year, which we now know was fatally flawed.
Legislation is helpful to ensure that the above-mentioned RF
factors are included in the FCC's data collection and broadband mapping
process, and will produce more accurate coverage maps that are based on
your constituents' experience. Together, these modifications will help
policymakers to more accurately target future support, and CCA
encourages the advancement of legislation to accomplish this important
policy goal.
______
Response to Written Question Submitted by Hon. John Thune to
Tim Donovan
Question. I convened a subcommittee hearing last month on rural
broadband deployment. During that hearing, we heard testimony from
Justin Forde of Midco, a company that uses a fixed wireless broadband
connection into parts of South Dakota. Fixed wireless covers areas like
farmland, and knowing that these areas are covered by broadband is
critical for precision agriculture. Can you explain the benefits of
mapping broadband coverage as ``shapes'' and whether or not this would
be valuable to show broadband availability in a more practically useful
way?
Answer. Shapefiles demonstrate coverage over a particular
geographic area. Wireless broadband coverage shapefiles have the
benefit of showing all areas where one can reasonably anticipate
coverage meeting the characteristics that the shapefile data is based
upon. This is valuable to identify wireless broadband availability to
the extent that the shapefile data is created using reliable data; if
data is not based on engineering principles, a shapefile could indicate
significant areas where coverage is expected but not available at the
predicted levels, which limits the utility of the shapefile data
overall.
______
Response to Written Questions Submitted by Hon. Jerry Moran to
Tim Donovan
Question 1. My office has heard from constituents in Kansas,
including your member company Nex-Tech Wireless, about their concerns
with the FCC's one-time collection of 4G LTE coverage data from
carriers that produced the critically flawed initial eligibility map
published in February 2018. Your testimony identified a number of
weaker standards for data submissions that contributed to the initial
eligibility map not adequately reflecting on-the-ground mobile
broadband coverage in Kansas. Are there any other factors besides those
that you listed in your testimony that you believe contributed to the
flawed map?
Answer. In addition to the RF factors included in my testimony, on-
the-ground mobile broadband coverage may be weaker than coverage
estimates because modeled propagation is often based on individual cell
sites. This does not adequately reflect an environment with multiple
base stations. In the real world, sites often include several antennas
operating using various frequencies, as well as radiating coverage that
can overlap with other sites, particularly near the cell edge. When
this overlap takes place, intersite or intercell interference can have
the effect of reducing coverage compared to modeled coverage, as the
device must operate with increased interference. In rural areas in
particular, this can lead to significant areas where models predict
coverage at the 5 Mbps download level suggested in the Mobility Fund II
Initial Eligible Areas Map that when tested will fail to have this
level of service available.
Question 2. The fact that the Mobility Fund eligibility map is
reliant upon private citizens and carriers to contest the accuracy of
mobile broadband data collected by the FCC based on standards that the
agency set remains concerning to me. Acknowledging that initial data
collection processes need to be improved upon, do you think that there
will continue to be a role for public challenge processes to improve
the Mobility Fund eligibility map that determine the allocation of
Federal resources?
Answer. The FCC's Mobility Fund II challenge process placed an
enormous burden on challengers, which proved unworkable to sufficiently
improve the current coverage map. However, beyond government actors or
carriers, the public, including groups like the Kansas Farm Bureau,
could only participate in the Mobility Fund II challenge process
through successfully obtaining a waiver.
Because any modeled coverage is just that--a model--there will
remain a role for a challenge process to ensure the appropriate
allocation of Federal resources to support preserving and expanding
broadband service. With sufficient improvements to the data collection
process, the baseline for determining challenged areas will have fewer
false positives and dramatically reduce the burden on challengers.
In addition to improving the underlying data, CCA also supports
improvements to the challenge process itself to further reduce the
burden on government, industry, and public participation.
Question 3. As the Chairman of the Appropriations Subcommittee with
jurisdiction over the National Telecommunications and Information
Administration (NTIA), I have interest in seeing how NTIA could build
upon the data collection of the FCC in its Form 477 process. More
specifically, we have appropriated substantial resources in recent
years to NTIA to broaden and update the National Broadband Map using
their developed state partnerships. While NTIA has already announced
its partnership with eight states to contribute data and other inputs
into the map, would you agree that adding more state partnerships to
contribute to the map would likely improve the overall accuracy of the
map?
Answer. States, tribes, municipalities, organizations and consumers
often know where they receive wireless service and where coverage gaps
exist. Further partnerships can contribute to improving the overall
accuracy of the map by relying on their expertise, which the FCC
acknowledged by including state and local governments in the challenge
process. However, improving the reliability of the data collected by
the FCC, including through the Form 477 process, will help all of these
entities in improving the map by beginning the process with more
reliable data.
______
Response to Written Question Submitted by Hon. Amy Klobuchar to
Tim Donovan
Question. Last Congress, my bipartisan bill with Senator Capito,
the Measuring the Economic Impact of Broadband Act, passed the Senate
without opposition, and we will be reintroducing our bill in the coming
weeks. Our bill would require the Department of Commerce to conduct an
analysis of the effects of broadband deployment and adoption on the
U.S. economy. Do you believe that more accurate data on the economic
benefits of broadband deployment could help us target investments to
rural areas where they are needed most?
Answer. Congratulations on your work to pass S. 1289, the Measuring
the Economic Impact of Broadband Act, through the Senate by unanimous
consent earlier this year. Additional and more accurate data regarding
the economic benefits of broadband deployment supports enhanced
policies to preserve and expand wireless service ubiquitously
throughout the United States. With additional data, policymakers can
clearly understand how increased access yields significant economic
benefits particularly in rural areas. Last year, a CCA-commissioned
study, available at https://ccamobile.org/wp-content/uploads/2018/10/
CCA-Airwaves-report-v.-final
.pdf, found benefits in the healthcare, transportation, and agriculture
sectors specifically from increased broadband deployment.
As carriers work to deploy the latest wireless technologies, rural
areas stand to benefit the most from enhanced connectivity. CCA
supports efforts to demonstrate these benefits to foster continued
investment in wireless deployment in rural America.
______
Response to Written Questions Submitted by Hon. Richard Blumenthal to
Tim Donovan
Pricing Data. The Form 477 data provides information on where
broadband may be accessible but not whether it is affordable. While
companies could take initiative and publicly disclose their pricing
practices, very few choose to do so. Companies should not inhibit
pricing disclosure because they fear competition, they should encourage
standards that increase access and provide more affordable plans to
consumers.
Question 1. At the hearing, I asked you if you would support
including an assessment of economic barriers to broadband access in the
FCC's Broadband Deployment Report. Everyone expressed a willingness to
consider this request and provide feedback. Would you support inclusion
of assessment of economic barriers to broadband access in the FCC's
Broadband Deployment Report?
Answer. CCA members connect customers in some of the hardest to
serve areas in the country, where economic barriers can be significant.
The barriers to high capacity broadband expansion are primarily
economic, especially in areas with sparse population density, not
technological. A deeper understanding of these barriers can help
provide information needed to close the digital divide, and accordingly
CCA does not oppose efforts to include this information in the FCC's
Broadband Deployment Report.
Question 2. When asked if you would support more transparent
broadband pricing, you stated that you do not survey your members on
the price offerings they currently have. After consulting with your
member companies about their practices, will you commit to supporting
the disclosure of price information in Form 477 data? If not, why not?
Answer. CCA member carriers' plans and pricing are publicly
available, and carriers offer a variety of pre-and post-paid service
plans to provide all consumers with options that meet their needs. CCA
members have also historically led the industry and advancing new
offerings that offer consumers increased services and transparency.
Because this information is publicly available and changes frequently
through service updates, various promotions, and competitive pressures,
inclusion on the biannual Form 477 filings would not provide consumers
with current information or information that is not already available.
Question 3. Do your members maintain records of how much they
charge for service? If so, please describe the parameters of this
recordkeeping. Is it broken down by geography, speed tier, or
promotional offerings? How frequently is this data collected and how
long is it stored? Is the data stored in a machine readable format? If
none of your members maintain records on pricing, please explain why
this is the case and how your members are able to maintain accurate
billing practices without this information.
Answer. There is not an industry standard storage or billing
methodology, and CCA members maintain their records through a variety
of in-house and contracted services. Accordingly, break downs by
geography, speed tiers, promotional offerings, frequency, and storage
will vary across different carriers.
______
Response to Written Questions Submitted by Hon. Jerry Moran to
Mike McCormick
Question 1. One of the few reassuring takeaways from the
developments around the Mobility Fund eligibility map was the
leadership demonstrated by the Kansas Farm Bureau in the challenge
process. It is my understanding that the Kansas Farm Bureau was one of
the first entities to petition for a waiver to participate in the MFII
challenge process, and they coordinated heavily with many of their
counterparts from other states, including the Mississippi Farm Bureau.
How important was it for entities like the Kansas and Mississippi Farm
Bureaus to coordinate with each other to identify best practices in
their efforts to fix these maps?
Answer. We feel that it is vital for organizations with similar
constituencies to collaborate and coordinate together to fix the maps.
We worked closely with the Kansas Farm Bureau as we began our challenge
process. Our friends in Kansas were vital in advising us along the way
as we developed a strategy to work in Mississippi on this issue. Moving
forward, if FCC is able to better correct the maps, groups like Farm
Bureau with large state memberships could serve as a key player to help
validate the accuracy of the maps.
Question 2. Your testimony indicated that the Mississippi Farm
Bureau collaborated with the state's public service commission to
submit mobile speed test data. On the other hand, the Kansas Farm
Bureau took a ``crowdsourced'' approach in which their members
submitted challenge tests directly to the FCC's portal. Would you
please describe the benefits and drawbacks of each approach?
Answer. The Kansas Farm Bureau truly led the way for most of the
other state Farm Bureaus in their efforts to challenge the accuracy of
the FCC maps. The ``crowdsourced'' approach in Kansas was a very
effective way to surface major areas of concern and then formally
execute a valid challenge with all technical requirements. Due to a
lack of adequate staffing, technical expertise, and time to crowdsource
this data and then go out and execute the formal testing, we could not
participate effectively in the process. The public service commission
also had the same challenges with staffing and technical expertise. If
we have a second opportunity to participate in another challenge
process, ``crowdsourcing'' raw data will be something that we look at
very closely.
Question 3. As the Chairman of the Appropriations Subcommittee with
jurisdiction over the National Telecommunications and Information
Administration (NTIA), I have interest in seeing how NTIA could build
upon the data collection of the FCC in its Form 477 process. More
specifically, we have appropriated substantial resources in recent
years to NTIA to broaden and update the National Broadband Map using
their developed state partnerships. While NTIA has already announced
its partnership with eight states to contribute data and other inputs
into the map, would you agree that adding more state partnerships to
contribute to the map would likely improve the overall accuracy of the
map?
Answer. Yes, we agree that more state partnerships to contribute to
a new mapping effort would be very helpful in working with NTIA to aid
in the development of more accurate broadband maps.
______
Response to Written Question Submitted by Hon. Richard Blumenthal to
Mike McCormick
Pricing Data. The Form 477 data provides information on where
broadband may be accessible but not whether it is affordable. While
companies could take initiative and publicly disclose their pricing
practices, very few choose to do so. Companies should not inhibit
pricing disclosure because they fear competition, they should encourage
standards that increase access and provide more affordable plans to
consumers.
Question. At the hearing, I asked you if you would support
including an assessment of economic barriers to broadband access in the
FCC's Broadband Deployment Report. Everyone expressed a willingness to
consider this request and provide feedback. Would you support inclusion
of assessment of economic barriers to broadband access in the FCC's
Broadband Deployment Report?
Answer. Although Farm Bureau is an organization that has limited
technical capabilities to adequately respond to these types of
questions, we are comfortable indicating that we would support
inclusion of assessment of economic barriers to broadband access in the
FCC's Broadband Deployment Report.
______
Response to Written Question Submitted by Hon. Jerry Moran to
Mike Oblizalo
Question. As the Chairman of the Appropriations Subcommittee with
jurisdiction over the National Telecommunications and Information
Administration (NTIA), I have interest in seeing how NTIA could build
upon the data collection of the FCC in its Form 477 process. More
specifically, we have appropriated substantial resources in recent
years to NTIA to broaden and update the National Broadband Map using
their developed state partnerships. While NTIA has already announced
its partnership with eight states to contribute data and other inputs
into the map, would you agree that adding more state partnerships to
contribute to the map would likely improve the overall accuracy of the
map?
Answer. While I do believe that more data could help to improve the
overall accuracy of the National Broadband Map, and data from all 50
states would be needed for the map to truly be considered a
``National'' map, ultimately we will need more granular data and
verification of submitted data in order to have more accurate maps.
This is especially true given Federal agencies' reliance on the map
when making funding or financing decisions. An inaccurate map can mean
all the difference between a location receiving or not receiving
broadband service. Therefore, whether it's through new state
partnerships to complement NTIA's existing state partnerships, or
through efforts by the FCC and USDA to improve their maps, we must
strive for both more granularity and a robust challenge process of the
collected data. As I stated in my testimony before the Committee, ``A
more granular map can certainly help identify more accurately where
broadband is available, but a meaningful and robust challenge process
will remain critical to validate both fixed and mobile date prior to
any map being used by the FCC or RUS (or any other governmental agency)
to make final decisions on funding or financing.. . .Only a meaningful
validation process, including the ability to challenge data on the
baseline map as inaccurate, will provide for the granularity and
reliability that is necessary to ensure these maps contribute to the
ultimate goal of connecting every American and keeping every American
connected.''
______
Response to Written Question Submitted by Hon. Amy Klobuchar to
Mike Oblizalo
Question. Last month, I introduced the Improving Broadband Mapping
Act with Senators Capito, Manchin, and Hoeven to direct the Federal
Communications Commission (FCC) to initiate a rulemaking to consider
using consumer-reported data, as well as state and local data, to
improve the accuracy of its broadband maps. Do you believe that using
consumer-reported data, as well as state and local data, could help
improve the accuracy of FCC maps?
Answer. There are several ways to improve the accuracy of broadband
maps. First, greater granularity is an important goal to help minimize
the ``false positives,'' which are the census blocks that are
considered served simply because a single location in that block is
served. Shapefiles are a tool that would increase the accuracy of
reported data and improve upon the current reporting system. Consumer-
reported data, as well as state and local data, could be other tools
used to help improve the granularity and accuracy. However, there are a
few issues that could affect the consumer speeds at the home, older
WIFI standards, consumer hardware issues, malware ect. It is important
to note that no single tool will be a ``silver bullet'' that would lead
to perfect results. No matter what tools are used to improve
granularity and accuracy, there must be validation and challenge
processes implemented prior to the use of any mapping data. Therefore,
the key elements of any sound mapping strategy must include: more
granular data, standardized reporting procedures, and the adoption of
validation and challenge processes.
______
Response to Written Questions Submitted by Hon. Richard Blumenthal to
Mike Oblizalo
Pricing Data. The Form 477 data provides information on where
broadband may be accessible but not whether it is affordable. While
companies could take initiative and publicly disclose their pricing
practices, very few choose to do so. Companies should not inhibit
pricing disclosure because they fear competition, they should encourage
standards that increase access and provide more affordable plans to
consumers.
Question 1. At the hearing, I asked you if you would support
including an assessment of economic barriers to broadband access in the
FCC's Broadband Deployment Report. Everyone expressed a willingness to
consider this request and provide feedback. Would you support inclusion
of assessment of economic barriers to broadband access in the FCC's
Broadband Deployment Report?
Answer. Barriers to both availability and adoption must be better
understood and addressed to achieve the ultimate goal of universal
broadband. Although neither availability nor adoption can be achieved
overnight, and while clearly no one can be ``forced'' to adopt
broadband even when it is available, it is important to assess and then
design strategies that promote both availability and adoption. All this
being said, I am not a lawyer and I therefore cannot speak specifically
to what the Broadband Deployment Report can or must measure or contain
as a matter of law. But taking account of both availability and
adoption would seem to be an important part of making good policy.
Question 2. During the hearing, you indicated support for
disclosing pricing data through Form 477. Can you explain your
company's existing recordkeeping practices as it relates to pricing? Do
you maintain records on how much you charge for service? If so, please
describe the parameters of this recordkeeping. Is it broken down by
geography, speed tier, or promotional offerings? How frequently is this
data collected and how long is it stored? Is the data stored in a
machine readable format?
Answer. Hood Canal Communications' billing system tracks the
pricing by a customer's specific broadband tier of service or bundle.
Based on the customer's needs, our staff recommends the tiered service
that they feel will have the most benefit to the customer. The pricing
and tier of service is collected on a monthly basis through our billing
vendor and by advice of counsel we store the data for six years. The
data can be exported from the billing software into a machine-readable
format.
Question 3. In 2016, the Federal Communications Commission adopted
a `Nutrition Label' that provided an easily readable, standardized
disclosure form that ISPs could use to communicate pricing information
to consumers. The FCC adopted this label as a safe harbor for
compliance with the 2015 Open Internet Order's transparency rule. Would
you support reinstating the label so consumers can easily understand
and compare ISP services?
Answer. As the manager of a small business living in the community
I serve, I support giving our customers--my neighbors--sufficient and
clear data for them to understand how our services are priced and to
make informed judgments about service options. Any number of options
should be available to providers, including potential ``nutrition
labels,'' to achieve this goal of appropriate disclosures. There is
likely no ``one-size-fits-all'' disclosure that will work in all cases,
and such disclosures may need to be tailored to reflect conditions on
the ground such as the various kinds of offerings made available by
providers.
______
Response to Written Question Submitted by Hon. Jerry Moran to
Jonathan Spalter
Question. As the Chairman of the Appropriations Subcommittee with
jurisdiction over the National Telecommunications and Information
Administration (NTIA), I have interest in seeing how NTIA could build
upon the data collection of the FCC in its Form 477 process. More
specifically, we have appropriated substantial resources in recent
years to NTIA to broaden and update the National Broadband Map using
their developed state partnerships. While NTIA has already announced
its partnership with eight states to contribute data and other inputs
into the map, would you agree that adding more state partnerships to
contribute to the map would likely improve the overall accuracy of the
map?
Answer. The accuracy of any broadband mapping effort will benefit
from the inclusion of multiple inputs and from the review by multiple
parties, including state broadband mapping programs. Ideally, there
will be a consistent national map based on consistently reported data,
which states can supplement and review for accuracy. One of the key
challenges that currently exists with mapping of broadband in the
United States is the ability to get not just accurate, but also
consistent geo reference (latitude and longitude) points of the
locations that need broadband service. USTelecom is encouraged by state
broadband deployment and mapping efforts. At the same time, our members
whose service includes multiple states have observed that the
inconsistencies in broadband availability data collection is an issue
that needs to be solved. We support NTIA's efforts to build a platform
to collect and display broadband availability data. Ideally, the data
that populates NTIA's platform will be consistent and harmonized at the
national level, with active input and review from all states. USTelecom
will continue to coordinate closely with NTIA in order to rapidly
develop a sustainable, cost-effective, comprehensive and scalable
national broadband map so we can accomplish our shared goal of closing
the digital divide once and for all.
______
Response to Written Questions Submitted by Hon. Richard Blumenthal to
Jonathan Spalter
Pricing Data. The Form 477 data provides information on where
broadband may be accessible but not whether it is affordable. While
companies could take initiative and publicly disclose their pricing
practices, very few choose to do so. Companies should not inhibit
pricing disclosure because they fear competition, they should encourage
standards that increase access and provide more affordable plans to
consumers.
Question 1. At the hearing, I asked you if you would support
including an assessment of economic barriers to broadband access in the
FCC's Broadband Deployment Report. Everyone expressed a willingness to
consider this request and provide feedback. Would you support inclusion
of assessment of economic barriers to broadband access in the FCC's
Broadband Deployment Report?
Answer. Ensuring that all Americans can take advantage of the
opportunities created by broadband access requires a clear focus on
ensuring that all consumers have access to broadband networks where
they live and work. In addition to efforts to facilitate broadband
deployment, it is equally important that consumers who wish to purchase
broadband are able to afford such access. Thus, understanding the
barriers to increased broadband adoption, including economic barriers
to access, is an important topic. Should the Commission determine that
the Broadband Deployment Report is the best way to provide an
assessment of economic barriers to access broadband, then we support
that effort. As its name implies, the FCC's Broadband Deployment Report
has historically focused on physical deployment--whether a consumer has
access to a network or not. Thus, there may be other vehicles to
explore this challenge as well.
Question 2. When asked whether you would support the disclosure of
price information, you stated that you would have to evaluate very
carefully on a company-by-company basis. After consulting with your
member companies about their practices, will you commit to supporting
the disclosure of price information in Form 477 data? If not, why not?
Answer. The purpose of the FCC Form 477 and the Commission's newly
instituted Digital Opportunity Data Collection effort is to determine
how many households have access, and lack access to broadband, and to
determine with as much granularity as possible the location of those
who lack access. This information is critical to many FCC broadband
policymaking decisions, including its essential universal service fund
(USF) programs that provide support for high-cost rural areas that
would otherwise be uneconomic to serve. The Form 477 data has always
been used for this purpose and should continue to be. Pricing data
varies from company to company, can vary based on the type of plan or
package a customer chooses, regularly changes and is often highly
variant due to promotional packages for customers in the same area, and
would be extremely challenging to keep up to date via a reporting
process that is semi-annual. Simply put, as compared to reporting on
whether a location does or does not have broadband (yes or no at
different speeds), the ability to accurately capture pricing
information is very challenging and would potential be misleading at
any point in time for the reasons discussed above. Such information is
also not relevant to broadband deployment by carriers, the purpose of
the Broadband Deployment Report.
Question 3. Do your members maintain records of how much they
charge for service? If so, please describe the parameters of this
recordkeeping. Is it broken down by geography, speed tier, or
promotional offerings? How frequently is this data collected and how
long is it stored? Is the data stored in a machine readable format? If
none of your members maintain records on pricing, please explain why
this is the case and how your members are able to maintain accurate
billing practices without this information.
Answer. The pricing plans of companies and how they maintain
records of individual customer payment plans varies by company.
Question 4. Does USTelecom collect any information about pricing
from its members? If so, please describe this information. Is it broken
down by geography, speed tier, or promotional offerings? How frequently
is this data collected and how long is it stored? Is the data stored in
a machine readable format?
Answer. USTelecom does not collect pricing data from its members.
Question 5. During the hearing, you mentioned that your members
comply with many ``truth in billing'' rules. Please list these rules
and any statutes where those rules are codified.
Answer. 47 C.F.R. Sec. 64.2401 of the Commission's rules require
that a telephone company's bill must: (1) provide a brief, clear, non-
misleading, plain language description of the service or services
rendered to accompany each charge; (2) identify the service provider
associated with each charge; (3) clearly and conspicuously identify any
change in service provider; (4) contain full and non-misleading
descriptions of charges; (5) identify those charges for which failure
to pay will not result in disconnection of the customer's basic local
service; (6) provide a toll-free number for customers to call in order
to lodge a complaint or obtain information; (7) place charges from
third parties that are not telephone companies in a distinct section of
the bill, separate from telephone company charges; and (8) provide a
separate subtotal for third-party charges in the separate bill section
and on the payment page. Telephone companies also must notify
consumers, on their websites and at the point of sale, of any options
they offer to block charges from third parties that are not telephone
companies.
Question 6. During the hearing, you mentioned that using Form 477
to collect pricing data could lead the FCC to invoke its rate
regulation authority. Given that this authority has been rarely, if
ever, used in the broadband context, why are you concerned about this?
How would pricing transparency lead to rate regulation?
Answer. As an information service, the FCC presently lacks the
authority to regulate the rates of broadband Internet access service.
That could change if a future FCC reverses the FCC's Restoring Internet
Freedom decision and declares broadband to be a telecommunications
service. As a matter of law and policy, USTelecom would oppose such a
decision, but it is a regulatory possibility. The point that the FCC's
authority has rarely, if ever, been used to directly regulate broadband
rates is a good one (although the 2015 Open Internet Order did subject
broadband service to Title II of the Act and opened the door for rate
regulation). Congress could remove the FCC's authority to rate regulate
broadband which members of both parties have historically opposed given
the competitive nature of the broadband market. Absent such action,
there is always the overhang of potential rate regulation. FCC mandates
to collect pricing data could potentially be misused to subject telecom
carriers--and only telecom carriers--to rate regulation which would
negatively impact investment and innovation.
Question 7. In 2016, the Federal Communications Commission adopted
a `Nutrition Label' that provided an easily readable, standardized
disclosure form that ISPs could use to communicate pricing information
to consumers. The FCC adopted this label as a safe harbor for
compliance with the 2015 Open Internet Order's transparency rule. Did
USTelecom support this nutrition label and would you support
reinstating the label so consumers can easily understand and compare
ISP services?
Answer. USTelecom was not a member of the FCC's Consumer Advisory
Committee which adopted the broadband ``Nutrition Label'' and did not
take a position on the process. USTelecom is a strong supporter of the
FCC's existing open Internet transparency rule, 47 CFR Sec. 8.1, which
requires Internet service providers to publicly disclose information
about their network management practices, performance characteristics,
and commercial terms of broadband Internet access service offerings.
Failure to comply with the rule can lead to FCC enforcement penalties
and providing misleading information to consumers inconsistent with the
disclosures required by the FCC's transparency rule could lead to FTC
enforcement as a violation of Section 5 of the FTC Act. There is no
evidence to suggest the current rules are not working as intended or
insufficient to protect consumers. Moreover, the highly competitive
broadband market results in significant consumer outreach about
broadband service offerings, including price, all of which is made
publicly available on company websites and through other advertising
mechanisms. In short, the combination of the FCC's transparency rule
and market forces appears to be working.
______
Response to Written Questions Submitted by Hon. Jon Tester to
Jonathan Spalter
Question 1. Previously before this committee, I asked a small
carrier about improving access to exchanges that are owned by price-
capped carriers but are not being served. Mr. Spalter, what is the
biggest barrier your companies' face that keep them from selling
exchanges to smaller rate-of-return carriers?
Question 2. If there were a Federal mechanism designed to
incentivize the transfer of rural exchanges away from large price-cap-
carriers to small rate-of-return carriers, is that something your
companies would support?
Answer. There are a number of interlocking bureaucratic, logistical
and financial challenges that can deter the sale of network exchanges.
The legal and transaction costs of each property sale or swap is
substantial, such that large carriers prefer selling larger portions of
their network in a single transaction. The network management costs
required to become a regional carrier of scale also can be inhibiting
for smaller carriers. The acquiring small carriers may also lack the
necessary collateral to complete such a transaction. However, a number
of government resources could enable more transactions. Government
secured loans, tax credits for buyers and sellers, waiving capital
gains taxes, and providing for recovery of legal and administrative
fees might remove some of the financial obstacles. Additionally,
carriers build their networks on different platforms, using operating
systems that are not interchangeable. The physical architecture of even
adjacent networks can require significant investments in hardware and
software to ensure compatibility. Additional government resources to
help defray these costs would be helpful. While these are ways to ease
the financial burdens associated with the sale of properties, they do
not address the overall goal of upgrading the service in these areas.
We support allowing the free market to work in whatever manner
makes sense for both types of carriers unencumbered by artificial
limiters. That said, it is important to remember that the sale of these
properties to a small carrier does not increase the level of government
support available for that area Congress should emphasize, and indeed
prioritize, sufficient and predictable high cost support to spur
broadband deployment and enable continued operations in these areas
regardless of whether it is served by a price cap or rate of return
carrier.
______
Response to Written Question Submitted by Hon. Jerry Moran to
Chip Strange
Question. As the Chairman of the Appropriations Subcommittee with
jurisdiction over the National Telecommunications and Information
Administration (NTIA), I have interest in seeing how NTIA could build
upon the data collection of the FCC in its Form 477 process. More
specifically, we have appropriated substantial resources in recent
years to NTIA to broaden and update the National Broadband Map using
their developed state partnerships. While NTIA has already announced
its partnership with eight states to contribute data and other inputs
into the map, would you agree that adding more state partnerships to
contribute to the map would likely improve the overall accuracy of the
map?
Answer. Thank you, Senator Moran, for the question. Engaged
stakeholders with broadband datasets and intimate knowledge of the
unique demographic and topographic characteristics of their states can
improve broadband mapping efforts. However, we should initially focus
on states that have broadband data expertise, and not slow down NTIA's
progress. More importantly, while adding more state data is a net
positive, we must have methodological uniformity to ensure that the
quality of the data, and ultimately the quality of the maps, is
consistent across all states and territories. We do not want to repeat
the mistakes of the State Broadband Initiative, which had widely
varying approaches to determining if an area was served by broadband
networks.
Fortunately, crowdsourced data collection and analytical
capabilities, like those provided by Ookla, can fill in where granular
information is lacking, while also serving as a data verification
layer. I firmly believe that a multifaceted approach--which includes
data from many parties with large datasets backed by strong data
science and methodologies--will help ensure that you and other
policymakers have the best information needed to efficiently and
comprehensively expand broadband networks where needed.
The funding provided by Congress to NTIA to stand up a more
accurate national broadband map is a good start and I appreciate your
leadership in this area. We need to ensure that the agencies tasked
with collecting and managing data are resourced appropriately. High
quality broadband availability and performance datasets, and more
importantly the downstream networks built using them, are vital to the
economic and social prosperity of our Nation.
Dedicated, annual recurring funding instruments are needed to
ensure we consistently measure the state of broadband networks over
time. One option is to stipulate that a percent of every taxpayer
dollar used for broadband expansion will be dedicated to accurately
measuring before we fund. This will help ensure we are better stewards
of taxpayer money by building the right networks in the right places,
while also not funding broadband expansion where privately funded
networks already exist.
______
Response to Written Question Submitted by Hon. Richard Blumenthal to
Chip Strange
Pricing Data. The Form 477 data provides information on where
broadband may be accessible but not whether it is affordable. While
companies could take initiative and publicly disclose their pricing
practices, very few choose to do so. Companies should not inhibit
pricing disclosure because they fear competition, they should encourage
standards that increase access and provide more affordable plans to
consumers.
Question. At the hearing, I asked you if you would support
including an assessment of economic barriers to broadband access in the
FCC's Broadband Deployment Report. Everyone expressed a willingness to
consider this request and provide feedback. Would you support inclusion
of assessment of economic barriers to broadband access in the FCC's
Broadband Deployment Report?
Answer. Yes, I would support the inclusion of an assessment of
economic barriers to broadband access in the FCC's Broadband Deployment
Report.
[all]