[Senate Hearing 116-354]
[From the U.S. Government Publishing Office]




                                                        S. Hrg. 116-354

                          BROADBAND MAPPING: 
                        CHALLENGES AND SOLUTIONS

=======================================================================

                                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





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                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

                              ----------                              
                                                                   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

                              ----------                              


                       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\
---------------------------------------------------------------------------
    \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?'').
---------------------------------------------------------------------------
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

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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.
---------------------------------------------------------------------------
    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\
---------------------------------------------------------------------------
    \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\
---------------------------------------------------------------------------
    \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.' '')
---------------------------------------------------------------------------
    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\
---------------------------------------------------------------------------
    \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\
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    \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.
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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.
---------------------------------------------------------------------------
    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.
---------------------------------------------------------------------------
    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\
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    \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.
---------------------------------------------------------------------------
    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\
---------------------------------------------------------------------------
    \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.
---------------------------------------------------------------------------
    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.)
---------------------------------------------------------------------------
    \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

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                                 ______
                                 
                               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.

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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.
---------------------------------------------------------------------------
    \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\
---------------------------------------------------------------------------
    \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\
---------------------------------------------------------------------------
    \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\
---------------------------------------------------------------------------
    \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 
---------------------------------------------------------------------------
        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.

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