Broadband Communities

SEP 2018

BROADBAND COMMUNITIES is the leading source of information on digital and broadband technologies for buildings and communities. Our editorial aims to accelerate the deployment of Fiber-To-The-Home and Fiber-To-The-Premises.

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BROADBAND POLICY 5 6 | B R O A D B A N D C O M M U N I T I E S | w w w. b r o a d b a n d c o m m u n i t i e s . c o m | A U G U S T / S E P T E M B E R 2 0 1 8 If an ISP's service is so poor and unavailing that fewer than 10 percent of households subscribe to it, consumer decisions should be prima facie evidence that broadband is unavailable. Can you think of even one other essential service to which fewer than 10 percent of households subscribe? Can you imagine fewer than 10 percent of households subscribing to electric service? Failure of households to subscribe to a service should be a sufficient demonstration that the National Broadband Map is wrong and service is not available. Let's not rely on the 477 data in that circumstance. Instead, let's take the word of the local residents. OVERCOMING THE PRESUMPTION OF SERVICE If the National Broadband Map can't be relied on, applicants to the RUS broadband pilot program need a procedure to demonstrate that the areas they propose to serve are currently unserved. I suggest they take the following steps: 1 Identify the census blocks in the area and download the FCC's 477 data for those census blocks. e census blocks in which no ISP claims 10 Mbps/1 Mbps service count as unserved. 2 For census blocks in which an ISP claims 10 Mbps/1 Mbps service, identify the provider(s) and check whether their service offerings meet all four criteria for broadband. If no ISP meets all criteria, count the census block(s) as unserved. 3 For those census blocks in which an ISP claims 10 Mbps/1 Mbps and the service offering meets the broadband criteria, employ the FCC testing protocols adopted July 6, 2018, specifically with respect to the time of testing, frequency and number of tests to be performed. e tests should be performed at peak times at the locations of subscribers to ISPs that claim 10 Mbps/1 Mbps service. e FCC requirement for the number of test locations depends on the number of ISP subscriber locations, as shown in Table 1. 3 Using Table 1, determine the number of test locations based on the number of subscribers in the area that will be tested. It may be difficult to get data on the number of an ISP's subscribers. ough the FCC collects such data, it does not make the data public, except in the aggregate by technology. One could make a good faith assumption that the number of subscribers within the test area is proportionate to the aggregate data (see, for example, https://www.fcc.gov/internet-access- services-reports). As this number is being used only to establish the number of test locations, such an estimate would be appropriate. If the FCC or the ISP were to make the individual data publicly available, ISP-specific data could be used. 4 Identify test locations for subscribers at the requisite service level. is step will be the most difficult because, despite the 477 data, there may be few, if any, such subscribers. If a good faith effort to locate subscribers fails to turn up enough to conduct the requisite tests, the area should be considered unserved. 5 Conduct tests from a sufficient number of test locations to determine the percentage of tests that meet or fail to meet the 10 Mbps/1 Mbps standard. If 90 percent or more locations fail, the area should be considered unserved. 6 If fewer than 90 percent of the locations fail, use the percentage of failures to calculate the number of unserved households and adjust the area in which the applicant is seeking funding. For example, locate the DSLAMs in an area and determine whether successful tests are at households closer to a DSLAM than failed tests. If so, adjust the proposed application to account for the distance sensitivity of the ISP's technology. 7 Prepare an application that can show through a variety of tests and measures that 90 percent of the households in the area lack broadband. 8 If an ISP contests an application as including an area already served, the RUS should require testing specific to the area and at least as rigorous as the FCC testing protocol. If the National Broadband Map no longer carries a presumption of service, contrary evidence gathered by an applicant should shift the presumption. Furthermore, the ISP's tests should be made available to the applicant and to the community. To the extent that an ISP can demonstrate the requisite service to specific areas in the application, those areas should be removed. My perspective on the National Broadband Map comes from time spent working with the data inside the FCC and outside the FCC from the time at which the FCC stopped using the State Broadband Initiative data and switched to the 477 data. e SBI data was inconsistent, and the 477 data is unreliable. Policymakers should not use data they know to be unreliable without allowing for challenges to the data. e steps I have outlined recognize the shortcomings in the data and permit a targeted approach for the RUS broadband pilot. v Jonathan Chambers, formerly chief of the FCC's Office of Strategic Planning, is a principal of Conexon, which works with rural electric membership cooperatives to bring fiber to the home to rural communities. Contact him at jonathan@ conexon.us. Number of Subscribers at Locations per State and Tier Combination Number of Test Locations 50 or fewer 5 51–500 10 percent of total subscribers More than 500 50 Table 1: FCC Testing Protocols

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