Mass Confusion over FCC Mapping

I understand why folks are confused about the Federal Communications Commission's maps, because there are several major mapping timelines and issues progressing at the same time. The first issue is the FCC mapping fabric. The FCC recently encouraged state and local governments and internet service providers (ISP) to file bulk challenges to the fabric by June 30. The first mapping fabric issued in June 2022 was largely a disaster. Most experienced folks that I know in the industry are unhappy with the fabric because its definition of locations that can get broadband is drastically different than the traditional way that the industry counts possible customers, which is commonly called "passings." Meanwhile, ISPs were instructed to use the original mapping fabric to report broadband coverage and speeds – the FCC 477 reporting process. There have been some revisions to the fabric due to challenges that were made early, but some of the folks who made early map challenges are reporting that a large majority of the challenges they made were not accepted. The FCC’s speed reporting rules still include a fatal flaw in that ISPs are allowed to report marketing broadband speeds rather than actual speeds. This has always been the biggest problem with FCC 477 reporting, and it’s the one bad aspect of the old reporting that is still in place.

Finally, the National Telecommunications and Information Administration (NTIA) is required to use the FCC maps to determine how much Broadband Equity, Access, and Deployment (BEAD) grant funding goes to each state. NTIA announced that it will report the funding allocation on June 30. That date means that none of the mapping challenges that states and counties have been working on will be reflected in the maps used to allocate the grant funding. The NTIA announcement implies that only the earliest challenges to the maps might be included in the database used to determine the number of unserved and underserved locations in each state. States that have already made challenges know that those numbers include a lot of mistakes and missed a lot of locations. Not only will the NTIA decision on funding allocation not include the large bulk challenges filed or underway by many state and local governments, but it won’t reflect the latest 477 reporting being submitted on March 1, 2023. This whole mapping process is the very definition of a slow-motion train wreck.