An analysis of the neutrality of "tech neutrality" in broadband coverage

When the Federal Communications Commission's new broadband maps came out, we were quick to compare the number of unserved locations in the new maps to the number of unserved housing units in the previous Form 477 data. As expected, the number of unserved locations doubled, from 3.6 million to 7.8 million. But that comparison isn’t apples-to-apples. The Form 477 data includes fixed wireless access (FWA) delivered over unlicensed spectrum while the Broadband Equity, Access, and Deployment (BEAD) Program, which is the de facto new definition of broadband, excludes fixed wireless delivered over unlicensed spectrum. The denominator is the same, but the numerators are different. Were unlicensed fixed wireless to be included, there would only be 6 million unserved locations, 23% fewer than the official definition. Almost 700,000 locations that are officially defined as unserved in the new maps would be served (100/20 or better) if FWA were included. 975,000 of the unserved would move to underserved. And 6 million of the original 7.8 million locations would remain unserved. Under this definition, the biggest states would lose the most, but rural states would also be affected. Texas would have 344,000 fewer unserved locations and California would have 134,000 fewer. But Colorado would have 83,000 fewer, Idaho would have 72,000 fewer, and Oklahoma would have 52,000 fewer. In small states, swings of that size would have dramatic consequences on overall BEAD allocations.