State challenge processes are not a panacea for broadband map issues

Should states run their own broadband mapping challenges? States could choose to award grants in an technology-aware manner, adding 3.1 million locations currently served or underserved by DSL or 25/3 fixed wireless, which would have the same — or an even better — effect. There are 218,878 locations where a DSL offering is advertising 100 Mbps download throughput and 20 Mbps upload throughput or better, and there is no other offering to the location that would serve them at 100/20. Do we need a lengthy challenge process to determine that these locations should get upgraded service? I certainly don’t think so. I think it would be fair to states' residents if we consider (1) anyone served only by DSL, or (2) underserved by a 25/3 offering to be eligible for a broadband upgrade with this generational funding opportunity. It takes us up from 7.8 million unserved to 10.8 million unserved, and actually lowers the underserved from 5 million to 2.3 million (because so many became unserved). It’s technology-aware and it’s fair.