Numerous times in the past few weeks I have heard representatives from the NTIA, the FCC, and others say that the new FCC Broadband Map “will never be perfect.” We can concede a basic truth to that statement, just as we can say that “no measurement will ever be free from error”, or “no two snowflakes are identical.” What bothers me is that this phrase seems to be asking us to accept a flawed map as good enough. It strikes me as a call to lower our expectations, to settle for something less than we should rightfully expect.
I’ve been a mapping and geospatial professional for more than 38 years and it is understood in this discipline that a map is a highly simplified representation of reality. Many choices and compromises must be made in deciding how to select, generalize, render, and label the features included in a map. Every one of these choices can be considered a failure to achieve perfection. Does that diminish the usefulness of the map? Au contraire! That is precisely how we make the map most useful for its intended purpose. That’s what geospatial professionals are trained to do. We filter out unnecessary information and take pains to provide a truthful representation of the salient content.
In the early days of my career, we called ourselves Cartographers, descended from a rich tradition of mapmaking. In those days, an abundance of care and thought went into the art and craft of map design and we were always striving to create the best map possible. There is less emphasis today on map design and more on database content, with the map being only one of the countless ways to display the geospatial database. That said, the underlying principles that make the map (or geospatial database) accurate, correct, current, complete, and therefore, useful, reliable, and trustworthy for its intended purpose, have not changed at all.
I am not going to offer a review of the sources of error in creating geospatial data, or in the design of geospatial databases, or the range of methods available to collect and validate the data that populates a geospatial database, or the myriad of choices that happen along the way. There are plenty of resources available for anyone seeking to understand those things. Instead, I want to explain the importance of the new FCC Broadband Map and why we should all strive to make it as accurate as we can.
The new FCC Broadband Map is incredibly important
A map is most often a piece of supplementary information, something that illustrates an issue being considered, but the map is generally not the basis of all key decisions to be made about a program. We have the opposite situation with the $42.45 billion Broadband Equity, Access, and Deployment (BEAD) Program. In BEAD, the new FCC Broadband Map is the system of record and it will be used to allocate the amount of funding that each state will receive, as well as for determining which specific locations (among more than 100 million “broadband serviceable locations” across the US) are eligible to receive BEAD funds to extend broadband service to those locations.
BEAD represents a massive national investment in broadband to finally close the digital divide in this country. This is one of the most consequential investments our country has ever made, on par with bringing electricity and telephone service to every home in the US or building the Interstate Highway system. It is also an investment that everyone cares about. Few public policies have as effectively galvanized public opinion in support of such a large national investment. The stakes are very high. We have to get it right. How do we do that? We have to get the map right.
A challenging Challenge Process
A lot could be said here about the overall strategy that the FCC used to develop its new map, and I definitely have opinions on that1. But it’s too late for a re-do. The urgency of the BEAD program requires that we accept the mapping strategy as it exists and focus our energies on making the map as good as it can be. The FCC map is a combination of a new commercial database of broadband serviceable locations licensed from CostQuest and paired with information about broadband services self-reported by nearly 3,000 broadband providers offering those services. It is not ideal. We know it contains many errors. We must now fix it. And fix it, we will.
I would love to tell you that the Challenge Process for fixing the map is simple, straightforward, and fully transparent. Alas, that remains a wish. Part of the confusion is that there are two main pathways to submit corrections. For consumers, corrections submitted through the map interface as either a “Location Challenge” or “Availability Challenge” are a lower-tier set of inputs that the FCC categorizes as “crowdsourcing”. These crowdsourced submissions are optional on the part of the broadband providers to address, and FCC is not required to adjudicate these crowdsourced submissions. It is my impression that most members of the public incorrectly believe that by submitting a crowdsourced challenge, a decision to accept or reject their specific input will occur.
The real Challenge Process (in my view) is what FCC calls the Bulk Challenge Process, for eligible entities to file multiple corrections via a certification process where the filer attests to the accuracy of the submission under penalty of perjury. Each of these certified challenges must be adjudicated within specified timeframes. In fact, what happens with a bulk submission is that the bundle is unpacked into individual challenges, each one addressing a single correction at a single location. Each challenge is tracked individually as it proceeds through the process.
AppGeo, where I work, has been preparing bulk challenge submissions for multiple states and we have as clear a view of the process as anyone. We’ve now had enough challenges work their way through the process to offer some advice to others.
If you are a citizen, understand that you are submitting crowdsourced information that probably will not be evaluated2. A better approach will be to get your challenge information included in a bulk challenge submittal. My view is that state broadband offices are best positioned to collect, aggregate, and submit these challenges. Doing so will change them from optional to required adjudication by the FCC. Ask your state broadband office to do this.
If you are working at the state level, such as in a state broadband office, you absolutely need to participate in the bulk challenge process. Work with your state geospatial office, if you aren’t already, as they will have data and expertise that can help you. Get outside help. The process is complex and the workflows you will need in preparing bulk challenges across your state can be daunting. If you are contemplating skipping the challenge process, please think again. The data analysis you will undertake for the challenge process will be valuable for your work at the state level, even if you are less concerned about the FCC map. You can also convert crowdsourced information into bulk challenge submissions, and I urge you to do that as the best way to get those challenges taken seriously.
If you are the NTIA or FCC, I would like to suggest a revision to your messaging about the map. Rather than telling people that the map will never be perfect, tell them that your strategy is counting on them to help you get the map right. Explain why the map is so incredibly important and how to participate in the process that will make the map as good as it can be, because it’s not “just a map” in the usual sense – it is the basis for the key decisions in how the BEAD program operates. I would also encourage you to be clearer about how the challenge process works and more transparent in all elements of the process. For those of us filing challenges, we could use more guidance on how evidence will be evaluated and how your adjudication process works.
If you are a bulk challenge filer, keep at it. There will be new releases of the broadband serviceable location “fabric” data twice per year, and also new releases of the broadband availability data twice per year (all at different release dates), so there will be four opportunities every year to assess the latest data and prepare new challenges. For challenges that have been rejected by the FCC, evaluate whether those can be resubmitted with additional evidence. And finally, prepare clear and compelling documentation to explain your processes and the sources of evidence you are using.
This process may not be ideal, it may not be what we wish for, but it’s the process we have and we should use it effectively. We need to treat the accuracy of the FCC Broadband Map at the highest level of importance, and that means we have to be vigilant and continue to challenge the map to make it as good as it possibly can be. Please don’t rationalize and accept errors on the premise that “the map will never be perfect”. None of us should be willing to settle for anything less than our best efforts.
1A future blog can explore ideas on how FCC could transition to a different mapping strategy going forward.
2For clarity, the FCC may not evaluate your crowdsourced submission at the individual location level, but rather will look for overall patterns of crowdsourced submissions that may indicate issues related to a specific broadband provider across their footprint, as an example, or other anomalies or inconsistencies.