How the FCC Got to 100/20

Benton Institute for Broadband & Society

Thursday, March 14, 2024

Digital Beat

How the FCC Got to 100/20

In its 2024 Broadband Deployment Report, the Federal Communications Commission raised its fixed speed benchmark for broadband to 100 megabits per second (Mbps) download and 20 Mbps upload. The FCC last updated these benchmark speeds in 2015 when it set the speeds at 25/3 Mbps.1

There is an obvious, short answer to how the FCC reached its 100/20 determination: Congress. In the 2021 Infrastructure Investment and Jobs Act, Congress determined that locations without access to networks that can deliver 25/3 Mbps service are "unserved" and locations without access to 100/20 Mbps service are "underserved." Obviously, the FCC could not continue to set standards for broadband internet access service that Congress considered inadequate. 

But the FCC did not rely solely on the Infrastructure Investment and Jobs Act to reset the broadband standard. The longer answer to today's question is that the FCC applied a five-step examination to come to 100/20. And the FCC showed its math in the report adopted on March 14. Below, we look at the FCC's reasoning, which is important not for this decision, but in this annual process of determining what the correct benchmark should be going forward.

I. Recent Congressional Action

We start with the FCC's acknowledgment that Congress has established a new standard for broadband. "We find that Congress’s determination that areas receiving broadband speeds of less than 100/20 Mbps are not adequately served necessitates that the Commission raise its fixed speed benchmark accordingly," the report reads. 

Although this may be the most important development in broadband policy impacting this decision about benchmark speeds, Congress is not likely to return to this in the coming years.

II. What Broadband Providers are Deploying to American Households

In its examination, the FCC found that deployment of infrastructure capable of delivering service of at least 100/20 Mbps is widespread and the speeds marketed by many internet service providers (ISPs) generally substantially exceed 25/3 Mbps.


Data from the FCC's Broadband Data Collection show widespread deployment of download speeds faster than 25 Mbps, and that deployment of at least 100/20 Mbps is the norm.  Deployment trends suggest an overwhelming majority of providers are already offering speeds of at least 100 Mbps download:  approximately 93 percent of Americans had access to a terrestrial fixed broadband service with download speeds of at least 100 Mbps in December 2022. In fact, FCC deployment data indicate that since 2018, more than 90 percent of the population has had access to terrestrial fixed broadband service with download speeds of at least 100 Mbps.


Most of the nation’s largest providers focus their marketing efforts on fixed broadband speeds of at least 100 Mbps download, making slower offerings increasingly irrelevant. For example:

  • Charter markets 300 Mbps as its slowest internet speed.
  • Verizon appears to market three tiers of fixed service with discounts for low-income customers, with the slowest tier being 300 Mbps.
  • Google Fiber appears to market only 1, 2, 5, and 8 Gbps service.

III. Speeds Required for Common Applications

As the New York Public Service Commission told the FCC, “[U]se of the current 25/3 Mbps simply out of step with a typical customer’s broadband needs.”

The FCC finds that the requirements for high-quality applications necessitating higher speeds have dramatically increased since 2015 and appear to trend towards requiring more bandwidth over time.

A combination of remote applications, streaming, and other needs play a role in household broadband use.  Services such as video and music streaming applications necessitate access to higher speeds. For example, as 4K video increases in popularity, individual households may have an increasing number of 25 Mbps video streams serving applications such as video conferencing, telehealth, and remote learning, in addition to streaming of video entertainment and gaming. Fast speeds are vital to enable remote applications to work properly. Graphics-intensive telework, alone, can require 45 Mbps or more.

The FCC believes that broad consumer demand for 100/20 Mbps service alone sufficiently demonstrates that the practical reality of consumer broadband usage often requires speeds of at least 100/20 Mbps, regardless of whether the FCC has delineated a specific “use case.” 

First, occasional downloads of very large files can be bandwidth-intensive. Second, it is important to account for larger households—as of 2023, approximately 21 percent of all U.S. households had four or more people. Households of all sizes must have sufficient bandwidth to satisfy their needs. In addition, the number of connected devices per household continues to grow. Taking these factors into account suggests that fixed broadband download/upload needs could easily exceed 100/20 Mbps.

IV. Consumer Choice

The FCC examined data regarding consumer choice and found that consumers are adopting higher speeds where they are available.

Almost 68 percent of households have subscribed to services meeting a 100 Mbps download speed threshold where it is available.

The number of American households subscribing to services meeting a 100 Mbps download speed threshold increased from approximately 57.4 million in December 2018 to approximately 89.4 million in December 2022. As of December 2022, the mean download speed for all residential fixed broadband subscriptions was 439 Mbps while the median residential download speed was 300 Mbps. Nearly 79 percent of all residential subscriptions had a download speed of at least 100 Mbps.

Consumers are not only subscribing to faster speeds, but also using more bandwidth. According to OpenVault, average U.S. household bandwidth consumption increased by approximately 86 percent between the end of 2019 and the end of 2023.2 OpenVault has previously observed that such a dramatic increase in bandwidth consumption “confirms the linkage between significant growth trajectories in both bandwidth consumption and faster speed adoption."

In addition, many ISPs upgraded the speed provided to customers to accommodate their consumers’ need for higher bandwidth services. Current consumer broadband usage involves an increasing number of streams serving applications ranging from telehealth, remote learning, streaming video and gaming, and video conferencing/telework. For example:

  • Telehealth has become an established method of providing and receiving healthcare; one poll of medical group leaders found that 72 percent of medical groups expect patient demand for telehealth to stay the same or increase in 2023.3
  • With regard to telework, a Bureau of Labor Statistics survey conducted in the third quarter of 2022 of private-sector establishments found that over 27 percent have some or all of their employees teleworking some or all of the time (with over 11 percent of respondents reporting that all of their employees teleworked all of the time). Over 95 percent expect current levels of telework to stay the same over the next six months.4 
  • Increased levels of online learning are likely here to stay beyond the COVID-19 pandemic. For example, virtual school enrollment across ten states increased 176 percent in the 2021-22 school year, as compared to the 2019-20 school year.  And even students who are attending school in person still rely on home connectivity for schoolwork outside of school hours.

With approximately 21 percent of U.S. households having four or more people and an increasing number of homebuyers seeking multigenerational housing, this can lead to substantial household bandwidth demand.  In addition, the number of connected devices per U.S. household continues to grow, from an average of 13 in 2021 to an average of 17 in 2023.  Households increasingly have multiple people demanding bandwidth at the same time and need higher speeds. In multiple-person households, multiple people make use of applications simultaneously, which requires extra capacity. 

The FCC does not anticipate usage decreasing, and accordingly must recognize that households of all sizes must have sufficient bandwidth to satisfy their needs.

V. Other Relevant Broadband Programs

The FCC, the Department of Agriculture's Rural Utilities Service, the Department of Commerce's National Telecommunications Administration (NTIA), and the Department of Treasury all administer federal broadband deployment programs. The FCC examined the requirements in these various programs to inform its decision on benchmark speeds. 

A number of programs and initiatives at the federal, state, local, and Tribal levels already require speeds at or above 100/20 Mbps.

At the federal level, the NTIA's Broadband Equity, Access, and Deployment (BEAD), Treasury's Capital Projects Fund (CPF), and RUS's ReConnect Program all require supported networks to be capable of offering service at 100/20 Mbps or better. 

In 2021, the FCC's Task Force for Reviewing the Connectivity and Technology Needs of Agriculture in the United States recommended that the FCC increase the benchmark speed to 100/20 Mbps. The Task Force determined that 25/3 Mbps is insufficient to enable innovation and utilization of precision agriculture and for transferring large amounts of data from field or farm to the cloud for storage.

Already at the FCC, the Enhanced Alternative Connect America Cost Model (Enhanced ACAM) program, the Bringing Puerto Rico Together (Uniendo a Puerto Rico) Fund, the Connect US Virgin Islands Fund, and the Rural Digital Opportunity Fund are all supporting deployment of networks meeting or exceeding the 100/20 Mbps benchmark. 

Many states have already adopted broadband standards that meet or exceed 100/20 Mbps including:


In its broadband deployment report, the FCC explains its reasoning behind the decision to raise the fixed speed benchmark. Trends in deployment, marketing, applications, and consumer choice—as well as Congressional action and standards adopted in various federal and state broadband programs—all play a role in determining the benchmarks. And the FCC notes that it intends to continue to examine evidence and the record similarly in the future, including the use of new and improved data sources to the extent they become available.

Understanding the FCC's process can help stakeholders ensure that the FCC sets realistic speed benchmarks and accurately reflects the availability of broadband services nationwide.


  1. Prior to that, the benchmark speeds were 4/1 Mbps.
  2. See OpenVault, Broadband Insights Report (OVBI) 4Q23, at 4 (2024),
  3. MGMA Stat, Telehealth Utilization and Patient Demand in 2023: Best Guesses and Best Practices (Nov. 3, 2022), See also Tanya Albert Henry, Millions of Medicare Patients Kept Telehealth Habit Post-Vaccines, AMA (Feb. 6, 2023), (finding that about 4 million Medicare patients received medical care through telehealth in each of the first two quarters in 2022); Jiang Li, Telemedicine And Telehealth In 2023 And Beyond: From Leveling Out To Leveling Up (Dec 27, 2022),; FAIR Health, Monthly Telehealth Regional Tracker,
  4. See Bureau of Labor Statistics 3Q2022 Survey. See also Jennifer Liu, More Americans are Now Working Fully Remote than 3 Months Ago, Despite Fewer WFH Job Openings, CNBC (Feb. 13, 2023) (noting that 46% of respondents in a January 2023 LinkedIn survey are working a hybrid or remote schedule); Kim Parker, About a Third of U.S. Workers Who Can Work From Home Now Do So All the Time, Pew Research Center (Mar. 30, 2023) (finding that 59% of hybrid workers work from home three or more days in a typical week).

The Benton Institute for Broadband & Society is a non-profit organization dedicated to ensuring that all people in the U.S. have access to competitive, High-Performance Broadband regardless of where they live or who they are. We believe communication policy - rooted in the values of access, equity, and diversity - has the power to deliver new opportunities and strengthen communities.

© Benton Institute for Broadband & Society 2023. Redistribution of this email publication - both internally and externally - is encouraged if it includes this copyright statement.

For subscribe/unsubscribe info, please email headlinesATbentonDOTorg

Kevin Taglang

Kevin Taglang
Executive Editor, Communications-related Headlines
Benton Institute
for Broadband & Society
1041 Ridge Rd, Unit 214
Wilmette, IL 60091
headlines AT benton DOT org

Share this edition:

Benton Institute for Broadband & Society Benton Institute for Broadband & Society Benton Institute for Broadband & Society

Benton Institute for Broadband & Society

Broadband Delivers Opportunities and Strengthens Communities

By Kevin Taglang.