One can assess the population that is unserved by broadband, the residential housing units unserved by broadband, or with the new Federal Communication Commission maps, “broadband serviceable locations.” My analyses are based on census block-level housing unit projections for 2019 (based on the 2010 Census), published by the FCC. In April 2021, the Census published the 2020 decennial block-level housing unit counts, which updates the “ground truth,” and it’s worth examining how these numbers change the “Digital Divide”. However, when we looked at housing units unserved by broadband according to the June 2021 FCC Form 477 data, there are 19% fewer unserved housing units. To be clear, nothing changed because of inefficient mapping techniques from the FCC. The reason is that the datasets used by the FCC between the 2010 Census and the 2020 Census were not interchangeable. What’s likely happening is the same problem that beset Rural Digital Opportunity Fund (RDOF): in an effort to update projections for county-level population growth since 2010, somehow Census blocks that shouldn’t have population were given population. The 2020 Census corrects that back to zero. Considering how different the new FCC “broadband serviceable locations” maps will be from the existing Form 477 block-level data, and the grumbling about the maps which has already begun, the FCC and CostQuest need “ground truth” to compare against. It won’t work if there’s nothing to compare a “broadband serviceable location” against, and it won’t work if the comparison is apples-to-oranges. What will work, in my view, is a comparison of residential broadband serviceable locations as identified by the FCC and CostQuest against the 2020 Census housing unit counts.

Given the excess of $11 billion that the Federal Communications Commission currently has in the Rural Digital Opportunity Fund (RDOF), interested parties--particularly major broadband providers--have inquired whether the FCC will offer another round of award funding. However, for this to be feasible, the FCC would have to engage in a lot of internal review and restructuring of its reverse auction mechanism if it seeks to revitalize the RDOF. Specifically, the FCC would have to address several issues: who the funds are being allocated and why; how to engage state and local officials in the process; overcoming federal mapping and coverage incompetence; and how to properly utilize funds to support applicants based on demonstrated need and a viable business plan. To address these concerns, the simplest solution would be for the FCC to relinquish its efforts to coordinate and facilitate broadband planning, and to diffuse that responsibility to state broadband offices--who are becoming better-equipped thanks to Broadband Equity, Access, and Deployment (BEAD) program funding. Doing so would mitigate awards going to "cost-effective" but not "future-proof" broadband providers; overcome the disconnect between the FCC and local needs and accurate mapping, and ultimately allow broadband offices to leverage their own expertise to properly bridge their digital divides. 

Spectrum policy takes engineering and technical realities as inputs to a decision-making process that is driven by normative principles. While many competing principles have had their heyday, these five are enduring guides to making spectrum work in the public interest:

1. Spectrum’s value comes from how people use it, so spectrum policy should maximize productivity rather than maximizing auction revenue or minimizing interference.
2. Markets are the best way to drive spectrum to its most productive use, so spectrum policy should enable well-functioning markets for flexible licenses.
3. There are important federal missions that require spectrum, but policymakers should account for its value in the appropriations process.
4. Public and private research into new radio technologies is key to increasing the availability of spectrum through developments such as sharing systems and uses for higher frequencies.
5. Unlicensed spectrum contributes to productivity when combined with proper technical rules and limited propagation, but calls for more unlicensed spectrum deserve close scrutiny.

[Joe Kane is director of broadband and spectrum policy at the Information Technology and Innovation Foundation.]