The Federal Communications Commission is considering whether it should collect more accurate data about broadband deployment in the US, but cable and telecom lobby groups are urging the FCC to maintain the status quo.
Currently, the FCC’s “Form 477” data collection program requires Internet service providers to identify the census blocks in which they provide residential or business Internet service and the maximum speeds offered in each block. ISPs are also supposed to identify the census blocks that are near enough to their networks that they could provide service within a reasonable timeframe.
This data helps the FCC evaluate the progress of broadband deployment, identify geographical areas that would benefit from government funding, and determine whether regulatory changes or new rules are needed to spur deployment and competition. But while a census block is the smallest geographic unit used by the US Census Bureau, it doesn’t provide the best possible data for determining whether an individual house or apartment building has Internet service. The reason is that an ISP could serve one building inside a census block and be counted as serving that entire block, even if it doesn’t serve the block’s other homes.
The FCC could solve this problem by requiring ISPs to report whether they serve each street address or household, and the commission recently asked the public to submit comments on whether it should do so. But broadband lobby groups are urging the FCC to maintain the census block-level reporting, saying that reporting whether they can offer service at individual homes would be too burdensome on ISPs.
Getting accurate data about broadband deployment is a problem both for the FCC and individual consumers. ISPs have sometimes mistakenly told people moving to a new home that broadband service is available at their new address when, in fact, it is not.
If the lobby groups succeed in blocking any change, this situation could persist.
“Costs on broadband providers”
“The commission should not use Form 477 to collect deployment data below the census block level,” NCTA-The Internet & Television Association, the cable industry’s primary lobby group, told the FCC in a filing on Tuesday.
The FCC already expanded the reporting requirement from the census tract to the census block level in 2013, NCTA noted. “Implementing this new requirement placed considerable new burdens on broadband providers, requiring many companies to devote significant resources to updating their internal records and sorting data in ways that do not serve a business purpose,” the group said.
NCTA acknowledged that this change helped the commission “target broadband subsidies to areas where they are most needed and avoid providing unwarranted support in areas where companies are willing to invest private capital.” But the group also argued that making the data even more accurate would not have a similarly beneficial effect.
“Every proposal to collect more or different data imposes costs on broadband providers,” the NCTA wrote. “At the same time, in many cases the availability of more granular deployment data may not lead to any meaningful improvement in the commission’s decisions relative to the granular census block level data the commission already collects. For example, there is no need for more granular data regarding census blocks located in urban areas because such blocks tend to be small and service generally is available uniformly throughout such blocks.”
NCTA acknowledged that there might be value in collecting more granular data in sparsely populated areas, where the availability of broadband at one street address is less likely to mean that every street address in the block is covered. But NCTA still argued that using the Form 477 program to collect that data would not be “economically feasible.”
Many cable companies do not track exactly which addresses they can offer service to, according to the NCTA:
To determine all of the street addresses serviceable by its existing facilities (whether already connected, reachable by drops, or reachable by line extensions that can be constructed within a typical service interval) within its service areas, a company would likely have to expend significant funds to identify (from third-party sources, such as county tax records and postal records) potential addresses within those service areas requiring investigation, pay vendors to standardize the address formats, analyze the addresses individually against the locations of its plant, conduct field inspections in a large percentage of the census blocks where they currently have facilities, and then manually create records for each address.
Better data brings benefits for public
The US has about 6.2 million populated census blocks (another 4.9 million blocks lack any residents). There are more than 130 million housing units.
Proponents of collecting address-level data argue that census blocks are so large in rural areas that more granular data is needed.
Here’s what the Utah Governor’s Office of Economic Development (GOED) told the FCC:
Basing data collection, planning efforts, and funding decisions on census blocks is problematic, particularly in blocks which are large, remote, and include terrain that makes it difficult to install infrastructure. For example, in Utah, the largest populated census block is 947 square miles. Under the current Form 477 submission process, any census block that is partially covered would be ineligible for all federal broadband programs, even if only a small percentage of households or census block area is covered.
The FCC should work with ISPs and state broadband mapping programs to “collect actual provider service footprints” using geospatial technology, the Utah state office said.
“Rural areas may have large census blocks in which only a few people have access to Internet service,” the non-profit Institute for Local Self-Reliance (ILSR) told the FCC.
Address- or street-level data would be the most useful for analyzing rural areas, the advocacy group said. “For rural census blocks, at least knowing which road segments Internet Service Providers can reach will help with estimating how much of the population in a rural census block actually has access,” the ILSR said.
The ILSR also suggested an alternative to address-level data that might be easier to compile. ISPs could report which road segments they can reach in rural areas, the group said:
This information should be easier to compile than geocoding addresses and can be compared to locations of small towns and other roads. Most state and local governments have information on their road networks publicly available, and providers can use that as a starting point.
Other ISPs lobby against changes
USTelecom, which is led by AT&T, Verizon, and others, took a similar stance as NCTA. The FCC “should not seek to collect broadband deployment data that is more granular than at the census block level, because such a change would be unduly burdensome to providers and would not provide the Commission with better data on broadband deployment,” the lobby group wrote.
USTelecom conceded that sub-census block data “could be useful for census blocks that have an area greater than two square miles.” But the group also said that reporting street segments or “best-efforts addresses” in those blocks should be voluntary instead of mandatory. “Many providers do not currently use street segment data, [and] to add it to providers’ systems would be difficult,” the group said.
Comcast and Verizon also provided opinions about sub-census block data. Comcast said that its database for cable service already “includes all of the locations the company serves and the locations the company could serve, but not all of the locations it cannot serve.” Reporting addresses that aren’t served wouldn’t necessarily be a requirement; the FCC is seeking comment on whether to require ISPs to report all addresses where service is available.
Comcast’s data on its new fiber-to-the-home Internet offering is apparently less extensive than its cable service, as Comcast said it “would need to undertake a site-by-site analysis to determine whether new locations could be served by its ‘all-fiber’-based product.”
Comcast did acknowledge that “producing data at a service address level could provide some new insight into broadband deployment.” If the FCC decides to require address-level information, “it should remain mindful of these concerns today and work to minimize the burdens,” Comcast said.
Verizon, meanwhile, said the commission should maintain its fixed broadband data collection without making it more granular.
Verizon also says the commission should not make its mobile data collection more granular. The FCC currently requires mobile voice and broadband subscriber information to be reported at the state level, but the commission is proposing to require reporting at the census tract level instead. The US is divided into about 74,000 census tracts.
Verizon argued against this proposal, saying that “mobile users may not use their service at their billing address. In dense urban areas, for example, census tracts may be quite small—perhaps even a few blocks—and so census level data would provide a false sense of precision about where devices are used.”
FCC recognizes benefits… and downsides
The FCC’s Notice of Proposed Rulemaking (NPRM) discusses the benefits of collecting address-level data for fixed broadband but also says that doing so would impose burdens on ISPs.
“For example, having national, granular broadband deployment data could greatly assist with any future disbursement of high-cost funds or universal service reverse auctions, assist consumers with locating broadband competition in their area, and with other broad public policy goals,” the FCC said. The commission sought public comment on the benefits of such data and comment on potential methods for making reporting of such data easier.
But FCC Chairman Ajit Pai has consistently argued that the FCC should reduce requirements imposed upon ISPs, saying that “[e]very dollar spent complying with unnecessary regulations is a dollar that could have been better spent deploying next-generation technologies.”
Not surprisingly, then, the FCC’s NPRM also sought comment on the burdens of increased reporting. “Collection of data by street address, for example, could increase the complexity and burden of the collection for both the commission and the filers,” the FCC said.
The deadline for submitting comments passed on Tuesday of this week. There is no set timeline for when the FCC has to make a final decision.