Confirmed: FCC Wireless Coverage Maps Stink
Friday, December 6, 2019
Confirmed: FCC Wireless Coverage Maps Stink
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Round-Up for the Week of December 2-6
Having accurate and reliable mobile broadband deployment data is critical to policymakers as well as to consumers. Unfortunately, a new study released by the Federal Communications Commission this week confirms that accurate data are not publicly available. For people who live in rural areas, the news is not a revelation; they have been voicing frustration to their representatives for some time. Members of Congress received the message and passed it on to the FCC.
“The accuracy or the value of the map is nearly nil in my view,” said Sen. Jerry Moran (R-KS) in March 2018. "Utterly worthless," Sen. Roger Wicker (R-MS) agreed at the same hearing.
“In a lot of Vermont, we have no-G,” said Rep. Peter Welch (D-VT). “These maps are bogus.”
Sen. John Tester (D-MT) has, perhaps, been the bluntest: “The maps stink, basically.”
The FCC established the Mobility Fund Phase II (MF-II) to make up to $4.53 billion in Universal Service Fund support available over 10 years to primarily rural areas that lack unsubsidized 4G Long Term Evolution (LTE) wireless service. MF-II is important to supporting mobile voice and broadband coverage, incentivizing the deployment of mobile wireless service through a reverse auction, and ensuring that 4G LTE service is preserved and advanced in those areas of the country that lack unsubsidized service.
Under the challenge process framework established by the FCC in the MF-II Challenge Process Order, mobile providers were required to submit current, standardized coverage data on qualified 4G LTE service. This data is used, in conjunction with subsidy data from the Universal Service Administrative Company (USAC), to establish the map of areas presumptively eligible for MF-II support (initial eligible areas map). Interested parties had an opportunity to challenge an initial determination that an area is ineligible for MF-II support, and challenged providers will then have an opportunity to respond to challenges.
In response to many concerns, the FCC, in December 2018, launched an investigation into whether one or more major mobile providers violated the requirements to submit coverage maps to the Commission. The investigation was led by the Rural Broadband Auctions Task Force in coordination with the FCC's Office of Economics and Analytics, Enforcement Bureau, Wireless Telecommunications Bureau, Wireline Competition Bureau, and the Office of Engineering and Technology.
FCC Enforcement Bureau field agents conducted speed tests of the Verizon, U.S. Cellular, and T-Mobile networks. FCC field agents measured on-the-ground network performance in 12 states across six drive test routes, conducting a total of 24,649 tests and driving nearly 10,000 miles in the course of this testing. Field agents also conducted 5,916 stationary speed tests at 42 distinct locations in nine states. FCC staff analyzed the speed test data from the staff tests, the carriers, and individuals and communities who had challenged the carriers' coverage maps.
FCC staff discovered that the coverage maps submitted by Verizon, U.S. Cellular, and T-Mobile likely overstated each provider’s actual coverage and did not reflect on-the-ground performance in many instances. Only 62.3% of staff drive tests achieved at least the minimum download speed predicted by the coverage maps—with U.S. Cellular achieving that speed in only 45.0% of such tests, T-Mobile in 63.2% of tests, and Verizon in 64.3% of tests. Similarly, staff stationary tests showed that each provider achieved sufficient download speeds in fewer than half of all test locations (20 of 42 locations). In addition, FCC staff was unable to obtain any 4G LTE signal for 38% of drive tests on U.S. Cellular’s network, 21.3% of drive tests on T-Mobile’s network, and 16.2% of drive tests on Verizon’s network, despite each provider reporting coverage in the relevant area.
As the FCC staff point out, mobile providers are legally responsible for submitting accurate and reliable coverage maps to the Commission. It is incumbent upon mobile providers to accurately model their networks, to test and retest these models, and to improve continually the accuracy of their projections so that their submissions can be confidently relied upon by policymakers and the public.(1)
So, obviously, Verizon, U.S. Cellular, and T-Mobile face huge fines for submitting false data.
Not so much.
Jon Brodkin reports that there won't be any meaningful consequences for the carriers because, an FCC spokesperson said, "the investigation did not find a sufficiently clear violation." In a call with reporters, a senior FCC official said that staff was unable to determine whether the carriers' exaggerations were deliberate. The official said that the investigation did not establish a clear violation of a specific rule even though the maps submitted by carriers were based on industry-standard propagation models and that the FCC's own tests made it clear that industry models do not reflect on-the-ground experience.
Benton Senior Fellow and Public Advocate Gigi Sohn said, “You won’t improve coverage maps if you don’t deter bad behavior, regardless of the verification improvements. Even in the face of clear evidence that these 3 carriers lied about their cellular coverage, will this Chairman do anything to punish them?”
The FCC staff offered the Commission a number of recommendations to address the shortcomings exposed by their research:
- Staff recommends that the FCC terminate the Mobility Fund-II challenge process. Despite the extensive efforts of staff and challengers that contributed to the challenge process, the submitted coverage maps are not a sufficiently accurate basis upon which to continue a process meant to address coverage disputes at the margins. The challenge process was not designed to correct generally overstated coverage maps.
- Staff recommends that the FCC issue an Enforcement Advisory on broadband data accuracy in the Form 477 filing, and, separately, for future Digital Opportunity Data Collection filings. Broadband data accuracy should be made a top priority going forward and providers should be put on notice about the penalties that could arise from coverage filings that violate federal law. [Of note, the Mapping Accuracy Promotion Services Act (H.R. 4227), currently making its way through the House), would specify that it is unlawful for a person to willfully, knowingly, or recklessly submit inaccurate broadband service data. The bill has broad bipartisan support.]
- Staff recommends that the FCC assemble a team with the requisite expertise, resources, and capacity to audit, verify, and investigate the accuracy of mobile broadband coverage maps submitted to the Commission. The FCC should further consider seeking appropriations from Congress to carry out any necessary drive testing. This team should specifically analyze the most recent filings of Verizon, U.S. Cellular, and T-Mobile to determine if they complied with FCC rules that prohibit providers from reporting coverage where they provide none.
- Staff recommends that the FCC adopt several changes in its mobile data collections. For its Mobility Fund-II, the FCC adopted the most granular and standardized mobile coverage collection it had ever undertaken. The staff analysis in this report, and the staff and challenger speed tests upon which the analysis relies, are an unprecedented examination into how accurately the coverage maps submitted by mobile providers to the FCC reflect on-the-ground, consumer experiences. This analysis indicates that the coverage data submitted by several providers did not accurately reflect actual on-the-ground coverage in many cases, and thus indicates that FCC mobile data coverage collections should become more standardized, more detailed, and include actual speed test data. Providers should submit more than just projections of coverage; providers should be required to submit actual speed test data sampling that verifies the accuracy of their propagation models. The FCC should adopt policies, procedures, and standards that allow for submission, verification, and disclosure of mobile coverage data and also convene a workshop of stakeholders on best practices for the generation and submission of accurate mobile broadband data.
- Staff recommends that the FCC standardize the propagation map parameters and assumptions that providers use to generate their coverage data. The propagation map parameters adopted in the Mobility Fund-II Challenge Process Order, as well as the coverage and other data required by that Order, should serve as the starting point, but key elements could be further standardized to determine more accurately where consumers can expect to obtain a mobile broadband connection.(2) Based on what the FCC staff learned from this process, in the future the Commission should be able to obtain more accurate mobile coverage data by specifying additional technical parameters. Specifically, the FCC should adopt mobile broadband coverage data specifications that include, among other things, minimum throughput and/or signal strength (as appropriate), standard cell loading factors and cell edge probabilities, maximum terrain and clutter bin sizes, and standard fading statistics. For any modeling with minimum throughput parameters, the FCC should require that providers assume the minimum values for whatever additional propagation model parameters would be necessary in order to accurately determine the area where a handset is demonstrated to achieve performance with download and upload speeds no less than the requirement meeting the cell edge probability. The FCC should allow for refinements of propagation models based on experience in any given area but should not allow elimination of elements such as clutter and fading that play a major role in the likelihood of connectivity. Additionally, all data submissions should require an engineering certification.
- The FCC should collect additional, more detailed data from mobile providers on the inputs and assumptions that underlie their propagation models, including the locations and specific characteristics of certain cell sites used for mobile wireless service, the modeling software that is being used, the entire link budget and values, and terrain data source. To ensure the integrity and reliability of submitted maps, the FCC should also require that all filers submit sufficient actual speed test data sampling that verifies the accuracy of the propagation model used to generate the coverage maps. Actual speed test data is critical to validating the models used to generate the maps.
A press release from FCC Chairman Ajit Pai acknowledged the staff recommendations while announcing plans to scrap the Mobility Fund in lieu of what would be called the 5G Fund. As planned, the 5G Fund would make up to $9 billion, allocated through a reverse auction, in Universal Service Fund support available to carriers to deploy 5G mobile wireless services in rural America. The fund would target hard-to-serve areas with sparse populations and/or rugged terrain; at least $1 billion would be set aside specifically for deployments facilitating precision agriculture. Stay tuned in 2020 for more news on the 5G Fund.
- That's 47 CFR § 1.17(a)(1) if you're scoring at home.
- Standardization should be implemented as appropriate for the purposes of the coverage data collection, taking into account relevant variations, for example in terrain.
- Public Interest Groups Urge Congress to Hold the FCC Accountable for America’s Degrading Telephone Network (Public Knowledge)
- Senators' year-end push on privacy (Axios)
- Sprint Overcounted Low-Income Customers for Years (WSJ)
- FCC Office of Engineering and Technology Chief Julius Knapp Announces Retirement (FCC)
- Gigi Sohn one of thought leaders laying the groundwork for future policy change (National Journal)
Weekend Reads (resist tl;dr)
- Report and Order on Deployment of Wi-Fi in Schools and Libraries (FCC)
- How Peoples Rural Telephone Cooperative is Connecting Rural Kentucky (The New Yorker)
- 2020 Democratic candidates on technology (Vox)
- Justice Department Issues Business Review Letter to the GSMA Related to Innovative eSIMs Standard for Mobile Devices (DoJ press release)
- FCC General Counsel Tom Johnson Remarks at TaxWatch 40th Anniversary (FCC)
ICYMI from Benton
- Too Big to be Left Unnoticed: America's Uncompetitive Broadband Market (Jonathan Sallet)
- The Not So Good, Very Bad and Really Weird Merger of T-Mobile and Sprint (Gigi Sohn)
- Imperial County: Closing the Homework Gap in a California Desert Community (Jonathan Sallet)
- On the Road to Better Broadband Maps? (Kevin Taglang)
Dec 11: Consumer Advisory Committee Meeting (FCC)
Dec 11: Closing the Digital Health Divide: Ensuring Access in 2020 and Beyond (Connected Health Initiative)
Dec 11: Spreading Tech Hubs to More of America: A Proposal (Information Technology & Innovation Foundation)
Dec 12: December 2019 Open FCC Meeting (FCC)
Dec 17: Exploring the Intersection: Online Hate and Privacy (The Lawyers' Committee for Civil Rights Under Law)
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