New York Governor Kathy Hochul's administration needs to "ensure that future state-funded projects are based on accurate broadband availability data," and that it should fund technologies that actually do provide high-speed, reliable internet service, because it hasn't been doing so despite millions of dollars in funding.That's according to a little-noted <a href="https://www.osc.state.ny.us/state-agencies/audits/2022/07/01/new-ny-broadband-program" target="_blank" rel="noopener noreferrer">audit </a>published earlier this month by New York State Comptroller Thomas P. DiNapoli.&nbsp;“The New NY Broadband Program did not meet its goal to close the internet gap because of poor planning and execution,” DiNapoli said in a press release. “As my office’s audit found, the program took years longer than promised and supplied many communities with slow, satellite-based internet that is inadequate for today’s needs. The state is now embarking on another effort to provide all New Yorkers with broadband access called ConnectALL and it is my hope it learns from the issues we found in this audit so they are not repeated.”DiNapoli’s audit recommended that ESD and BPO:<ul><li>Work with ISPs to complete outstanding projects as soon as possible;</li><li>Use a disclaimer when reporting the percentage of broadband availability in the state to reflect limitations in the data’s accuracy; and</li><li>Ensure that future state-funded projects are based on accurate broadband availability data; and that technologies that provide high-speed, reliable internet are used.</li></ul>National Public Radio affiliate WBFO recently <a href="https://www.wbfo.org/2022-07-18/new-yorks-broadband-program-to-provide-service-across-the-state-is-behind-schedule-uses-an-inaccurate-tool-to-monitor-how-well-its-doing-and-is-getting-another-billion-dollars?utm_source=sendgrid&amp;utm_medium=email&amp;utm_campaign=Newsletters&amp;mc_cid=4a875cd440&amp;mc_eid=f63cc288fd" target="_blank" rel="noopener noreferrer">highlighted</a> the report and spoke with two county leaders whose geographies have been impacted by the faulty data and technology decisions. Those are Orleans County and Chautauqua counties.&nbsp;<blockquote>Chautauqua County Executive P.J. Wendel has a particularly choice words for the FCC's Form 477 data: “You gotta get sick and tired of fighting those, 'Yeah, well these are our numbers and we stand by them'" Wendel said. "Yeah, you can balance an elephant on a quarter, too, but that doesn't necessarily mean it could happen. Physics can tell you that.”</blockquote>Hochul's administration disagreed with DiNapoli's characterizations of its funding program so far. Felisa Hochheiser, New York's Director of Compliance for its economic development authority Empire State Development, said that satellite tech was only funded in areas where fiber deployment was prohibitively high and couldn't be provided at an affordable rate.&nbsp;And Empire State Development's Broadband Program Office has established a new broadband mapping and data collection program and is investing significant new resources in wireline rural broadband deployment, she wrote <a href="https://www.osc.state.ny.us/files/state-agencies/audits/pdf/sga-2022-20s19.pdf" target="_blank" rel="noopener noreferrer">in a response</a> included in the audit. The BPO realized that the Federal Communications Commission's Form 477 data is faulty, she wrote.&nbsp;The comptroller's findings are concerning because Hochul announced that the state is putting another billion dollars into broadband funding this year under its <a href="https://www.governor.ny.gov/news/governor-hochul-announces-new-1-billion-connectall-initiative-bring-affordable-broadband" target="_blank" rel="noopener noreferrer">ConnectALL initiative</a>. Her administration has come under fire for violating the Governor's promise for more transparency than her predecessor Governor Andrew Cuomo, who first announced a $500 million broadband initiative several years ago. Projects from that initiative are way behind and remain unfinished, DiNapoli's report noted.Broadband.money <a href="https://broadband.money/state-broadband-offices/new-york" target="_blank" rel="noopener noreferrer">projects </a>that New York State could receive another $672.8 to $756.4 million from the Bipartisan Infrastructure Law's BEAD program.Perhaps ESD's BPO (or even the counties) should look into using <a href="https://broadband.money/state-broadband-map/new-york" target="_blank" rel="noopener noreferrer">Broadband.money's New York State broadband coverage map</a>, which use Ookla and MLab speed data and compares it with the FCC's form 477 data to illustrate where areas are <a href="https://broadband.money/broadband-grant-terms/unserved-location" target="_blank" rel="noopener noreferrer">unserved</a> and <a href="https://broadband.money/broadband-grant-terms/underserved-location" target="_blank" rel="noopener noreferrer">underserved</a> as defined by IIJA's BEAD broadband grant program.&nbsp;<figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Orleans_County_New_York_min_d4915a14fb.png"></figure>The map above, for example, shows this data comparison within a census block within Orleans, one of the counties named within the NPR affiliate story. It's also worth noting here that the IIJA's BEAD program <a href="https://broadband.money/ntia-bead-nofo/program-description" target="_blank" rel="noopener noreferrer">allows local entities</a> to challenge a state's planned funding allocations if they use their own verified data.&nbsp;

New York State needs to improve the way it administers broadband grants, according to a new audit from the state comptroller's office. 

New York State needs better broadband data, says comptroller

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2022 will be the year that America begins the collective —and complex — process of rolling out ubiquitous broadband networks. Congress has thrown a lot of money at the problem most recently through the <a href="https://discuss.broadband.money/c/broadband-grant-resources/broadband-grant-guide">Infrastructure, Investment and Jobs Act</a>, <a href="https://discuss.broadband.money/c/broadband-grant-resources/broadband-grant-guide">the American Rescue Plan</a>, and the <a href="https://discuss.broadband.money/c/broadband-grant-resources/broadband-grant-guide">Consolidated Appropriations Act</a>, each with their own sets of deadlines. For now, I’ll focus on the IIJA — at the request of one of the <a href="https://broadband.money/">Broadband.money</a>‘s community members. These are notes that I made for a year-in-review Broadband Breakfast panel discussion that took place earlier this week. They largely came from <a href="https://www.benton.org/blog/when-do-we-get-our-broadband">Benton</a> and a few other documents. But the text of the law is available <a href="https://www.govtrack.us/congress/bills/117/hr3684/text">here</a>. A fuller on-site explanation/backgrounder to the IIJA is available <a href="https://discuss.broadband.money/c/broadband-grant-resources/broadband-grant-guide">here</a>.&nbsp;<h2>Key IIJA deadlines and milestones:&nbsp;</h2><ul><li>The National Telecommunications and Information Administration has to issue Notices of Funding Opportunities to states by May 2022.&nbsp;</li><li>However this process is complicated by the fact that NTIA can’t allocate the bulk of the infrastructure funding until the Federal Communications Commission issues updated broadband deployment <a href="https://www.costquest.com/products/broadbandfabric/">maps</a>. A bid protest over the FCC’s choice of a vendor has stopped the agency’s progress. The GAO has 100 days to decide whether the protest is valid. <a href="https://ecfsapi.fcc.gov/file/1217077327468/21-633.pdf">Only when this issue is resolved</a> can the FCC start working with a vendor to create its <a href="https://www.gao.gov/products/gao-21-104447">Broadband Serviceable Location Fabric</a>. So rather than commencing construction activities, 2022 might more likely be the great Year of Broadband Measurement Crowdsourcing and Inventorying as the <a href="https://www.fcc.gov/document/fcc-encourages-public-use-its-speed-test-app">FCC</a> and <a href="https://www.wyobbmap.org/pages/bb-speedtest">state</a> and <a href="https://www.recordcourier.com/news/2021/nov/08/internet-speed-test-launched-better-connect-people/">local governments</a> around the country <a href="https://ag.ny.gov/SpeedTest">ask the public to report</a> on their Internet connections and <a href="https://www.duluthnewstribune.com/business/technology/7275178-Minnesota-residents-asked-to-take-broadband-speed-test">complete speed tests online</a>, among other things. Every government body is trying to figure out and verify where broadband networks really are and aren’t located, and what speeds and prices they’re really offering their users. Think of it like <a href="https://www.birdcount.org/participate/">The Great Backyard Bird Count</a>. This will be the Great National Broadband Count. (<a href="https://broadband.money/">Broadband.money</a> parent <a href="https://ready.net/">Ready.net offers its own speed test you can take here</a>.)&nbsp;</li><li>GAO has to <a href="https://www.benton.org/blog/how-infrastructure-investment-and-jobs-act-will-make-broadband-more-affordable">issue a report</a> on Internet speeds within a year: On how the FCC assesses speed; whether FCC should consider whether its requirements have an impact on the proliferation of broadband-based businesses, like small businesses, working from home, video conferencing, distance learning; whether it should issue/revise/update its rules on Internet speeds.&nbsp;</li><li>“Reforming” the <a href="https://www.fcc.gov/general/universal-service-fund">Universal Service Fund</a>. The FCC <a href="https://www.benton.org/blog/your-chance-weigh-future-universal-service-fund">launched a proceeding Dec. 15</a> to evaluate how it approaches its goal of ensuring universal access to the Internet in light of the IIJA. A report is due Aug. 22, 2022.&nbsp;</li><li>Transition from <a href="https://www.fcc.gov/broadbandbenefit">Emergency Broadband Benefit</a> to <a href="https://www.fcc.gov/acp">Affordable Connectivity Program</a> begins December 2021 and must be complete by March 2022. What does this process involve? It involves the Agriculture, Health and Human Services and Education Departments to share data in mid-January so that <a href="https://www.usac.org/">Universal Service Administration Company</a> can verify that people/end-users are eligible for the $30 a month broadband service discount. They use data from programs like Medicaid, SNAP, Public Housing Assistance, free and reduced lunch program to verify that individuals are eligible for the benefit. (If you’re an ISP that wants to get involved in offering Affordable Connectivity Program to your subscribers, you can enroll in <a href="https://broadband.money/">broadband.money</a> for tools you can use to easily sign up and track with EBB/ACP-participating subscribers.)</li></ul>&nbsp;<h2>Workforce:&nbsp;</h2>FCC needs to work with the Secretary of Labor to form an interagency taskforce on state training and safety standards for the telecommunications industry. They have a deadline of January 2023 to submit recommendations to Congress.&nbsp;<ul><li>By mid-May 2022, the Interagency Taskforce and the GAO need to submit a report to Congress the number of telecommunications workers needed to maintain 5G wireless and broadband infrastructure in rural areas.</li><li>October 1, 2022: NTIA will begin awarding planning grants to states for State Digital Equity Plans. NTIA has $60 million each fiscal year.</li><li>November 15, 2022: The FCC must issue rules on <a href="https://docs.fcc.gov/public/attachments/DOC-338708A1.pdf">broadband labels</a> including information on introductory v. long-term rates for consumers. (This is an idea that was introduced at the FCC several years ago and then repealed under the previous chairman’s tenure.) The FCC is to use the information on labels for Affordable Connectivity Program reporting. The FCC also has to issue final rules concerning the annual collection of pricing and subscription data of participating providers under the ACP. The FCC has six months to amend rules and verify that data and correct it. They have to make it public.&nbsp;</li><li>May 15, 2023 FCC must create the Broadband Deployment Locations Map, an overview map of deployments of federally-funded broadband maps. The FCC is to update this map every six months.</li><li>November 15, 2023 The FCC must promulgate rules against “digital discrimination.” The IIJA instructs the FCC to enact rules within two years to ensure that all Americans have equal opportunities to subscribe to high speed Internet access regardless of income level, race, ethnicity, color, religion, place of national origin. The law also instructs the commission and the attorney general to ensure that deployments don’t discriminate based on “an income level of an area,” or the race or ethnicity composition of an area, or based upon “other factors the commission determines to be relevant based on the findings in the record developed from the rulemaking.” And the FCC has come come up with model rules and best practices that states and localities can emulate to prohibit discrimination. Lastly, the law instructs the FCC to revise its complaint process to accept complaints about discrimination. - Bear in mind that each state and its broadband office will also issue their own deadlines for grant applications.</li></ul>

2022 will be the year that America begins the collective --and complex -- process of rolling out ubiquitous broadband networks.

2021-2022: Looking Backwards, Looking Ahead

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Missouri's first Office of Broadband Development Director Tim Arbeiter announced Thursday that he's joined infrastructure engineering company Finley Engineering, headquartered in Lamar, Missouri.<h2>Arbeiter's New Title</h2>His new title is Director, Broadband Consulting. A company statement says that "he will identify and support the long-term growth of Finley clients. This includes defining programs and measurable objectives, strategic planning, feasibility studies analysis, and other initiatives."Per The Missouri Times, "Arbeiter has steered the office since its establishment in 2018, leading the state through its first broadband grants and an influx of federal funds amid the COVID-19 pandemic. He worked with state, federal, and local leaders to collect data, increase awareness, and accelerate broadband efforts across the state."Arbeiter has spent his career in economic and community development.Finley Engineering conducts feasibility studies, consults for local governments, provides engineering services and funding analyses. Broadband clients in the past couple of years have included the city of Worthington, Minn., Blue Earth County, Minn., and Davis, Ca.An announcement on Arbeiter's successor is expected next week when Missouri Governor postgres Parson delivers his state of the state address.

Missouri's first broadband officer joins engineering firm. Meanwhile the state still doesn't have a leader.

Missouri Broadband Leader Joins Private Sector Firm Finley Engineering

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State officials need to prioritize planning for the deployment of federal broadband funds and not discount wireless solutions in the process, said Jonathan Adelstein, president and CEO of the Wireless Infrastructure Association.“People need to get moving pretty fast on this thing, given the level of funding coming,” Adelstein said in an interview with Broadband.money.&nbsp;“They have got to have the legal and administrative framework — if they don’t already have something developed under ARPA [the American Rescue Plan Act,] they’ve got to get moving,” he said.Adelstein is a former Federal Communications Commissioner and Administrator of the U.S. Department of Agriculture’s Rural Utilities Service.A analysis conducted for the WIA by the infrastructure company Tilson found that many states and territories haven’t created specific programs or offices to allocate ARPA funding or funding from the Infrastructure, Investment and Jobs Act.The report was published late last year. Since then, some governors and legislatures that haven't established programs have discussed the need for some organizational principles, but others state offices simply link to federal Treasury guidelines to provide local governments and Internet Service Provider grant applicants guidance.The states that Tilson identified as in “pre-planning” stages of development include: Alaska, American Samoa, Mississippi, New Jersey, North Dakota, Puerto Rico, U.S. Virgin Islands and Washington, D.C.Broadband.money estimates show that these states and territories may not be prepared to efficiently funnel the hundreds of millions of dollars of funds coming their way, or be in a position to help local governments make the most of the money by providing training, planning and engineering consulting resources.For example:<ul><li>Alaska will receive $185 million in federal funds from the IIJA, using the law’s allocation formula. It's anticipated to receive $112 million from ARPA’s Capital Projects Fund (CFP).</li><li>Mississippi is estimated to receive $548 million from IIJA and is anticipated to receive $163 million from the CFP. (Mississippi’s House of Representatives in February approved House Bill 1029. It establishes a broadband commission. It would coordinate all broadband expansion efforts in the state and administer all federal broadband expansion programs.&nbsp;The commission would be comprised of seven members: three appointed by the Governor and four appointed by the Lieutenant Governor, two of which would be recommended by the Speaker of the House).</li><li>New Jersey is estimated to receive just over $778 million from the IIJA and is anticipated to receive $195 million from the CFP.</li><li>North Dakota is estimated to receive just over $195 million from the IIJA and is anticipated to receive $113 million from the CFP.</li><li>Puerto Rico is estimated to receive $518 million from the IIJA and is anticipated to receive $158 million from the CFP.</li><li>Washington, D.C. is estimated to receive just over $150 million from the IIJA and is anticipated to receive $106 million from the CFP.</li></ul>President Joe Biden signed ARPA into law in March 11, 2021. The legislation provides $350 billion in state and local recovery funds. It includes $10 billion in Capital Projects Fund state block grants.Some states like Missouri and Louisiana, and local governments have been working around the clock to use the money to build broadband networks for unserved or underserved areas as defined under a combination of Treasury rules and state law.These activities also include creating state mapping initiatives so that they can get a jump on which areas need to get funded most urgently — and so they can fight for as much funding from the federal government as is necessary.Other state offices have waited because they weren’t clear about Treasury’s rules.&nbsp;Other states — Alaska being a prime example — don’t have a point person or program for the billions coming their way.More specifically, states and tribal territories have $65 billion coming their way in the form of infrastructure and digital equity grants.&nbsp;The legislation allocates $42.5 billion for broadband infrastructure rollout and $14.2 billion to subsidize low income households' monthly broadband and subscriptions. The rest is targeted to initiatives focused on digital inclusion, tribal connectivity, middle mile infrastructure and the United States Department of Agriculture (USDA)’s ReConnect Loan and Grant Program.When Tilson and other groups talk about states being “ready” for federal funding, they mean that state level governments have an organizational and legal structure in place to funnel and manage funds efficiently.&nbsp;States such as Illinois, Maine, Minnesota, North Carolina, Tennessee and Virginia are the furthest along. Some of these states also have extensive webinar programs to help local officials to understand broadband technologies and grant application processes.States need staff to examine grant applications and a system for <a href="https://broadband.money/blog/8-ideas-to-power-your-scoring-criteria-for-grants" target="_blank" rel="noopener noreferrer">scoring the grants</a> in order to decide which projects should get the funding under the IIJA.They need <a href="https://broadband.money/blog/way-cleared-for-fcc-s-quest-for-a-better-national-broadband-map" target="_blank" rel="noopener noreferrer">accurate maps and data</a> to figure out what households really do and don’t have access to broadband, and at what price levels.They need to develop programs to spread digital literacy. They need to communicate with other departments across state and local governments to streamline permitting processes.All of the states are at various stages of getting ready. California’s vast bureaucracy, for example, is already engaged in the process of rulemaking to decide how to disburse IIJA funding for example.And Governor Newsom has already announced the state’s $6 billion middle mile projects.Meanwhile, the Missouri General Assembly’s special committee on broadband development has synthesized months of work and research into a comprehensive list of recommendations to Governor postgres Parson’s administration. The list is, in effect, a to-do list for state broadband deployment as it gets ready to send out $400 million in ARPA funding.The full list of recommendations is available <a href="https://house.mo.gov/billtracking/bills221/commit/rpt2721/BroadbandReport.pdf" target="_blank" rel="noopener noreferrer">here</a>.Meanwhile, Alaska also has a to-do list from a task force report. But unlike Missouri and 47 other states with some point person and/or broadband office, Alaska has yet to create such an office, or to implement its task force’s recommendations — even though the state has a large population that are on the wrong side of the digital divide and need the most help.Adelstein and others say these states need to act quickly — yet thoughtfully — to put the administrative staff in place to be able to make full use of the money.And they need to have flexible enough rules to enable a wide range of grant applicants to participate — or state residents will remain unconnected despite Congress’ best efforts.“Congress cannot assume that if it provides funding with narrow strictures that its vision can be achieved – even if funding levels are very large as to appear sufficient,” Adelstein told the Senate Commerce Committee last June. “I am concerned that if Congress does not provide implementing agencies with needed flexibility, it will find that for many areas, no qualified applications will come in the door and areas will remain unserved.”

The federal government is working to allocate billions for broadband expansion, but some states and territories aren't ready. 

State Officials Need to Hustle To Deploy Hundreds of Millions For Broadband

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State administrators are scrambling to hire staff to manage the influx of billions in broadband funding.&nbsp; They’re are gearing up for billions of dollars coming their way as a result of federal funding initiatives, such as the Infrastructure, Investment and Jobs Act.The IIJA, which allocates $42.5 billion to states to disburse to Internet Service Providers and local communities to build out broadband networks to unserved and underserved areas, mandates that the National Telecommunications and Information Administration must issue a Notice of Funding Opportunity six months after the law’s passage. That would be May 16th.States then have to formulate their applications. Many states already have experience, resources and staff to do this — but not on the scale that is being proposed by the federal legislation.&nbsp; Virginia, which opened its broadband office in its Department of Housing and Community Development in 2019, is on the hunt for four additional members of project management staff. The hires will bring the state’s Office of Broadband staffing level to 12. Together, they will be managing more than $2 billion in state and federal grants and other leveraged funds. &nbsp; Broadband.money estimates that Virginia will receive $958,917,185 for broadband grants from the Infrastructure, Investment and Jobs Act, and $219,812,354 from the Treasury Department’s Capital Projects Fund, which comes from the American Rescue Plan Act (ARPA.) The four new members of staff will be project managers. One of them will manage Virginia’s $16 million line extension program. That’s a program that subsidizes broadband companies’ buildouts to homes that are currently located a little beyond the reach of their lines. (Though houses may only be 1,000 feet from the end of the line, telecom companies often want to charge residents as much as $20,000 to extend their lines, says &nbsp;Dr. Tamarah Holmes, Virginia’s broadband office director.)&nbsp; Holmes’ office is filled with grant managers, planners, engineers, policy analysts and compliance staff.&nbsp; “We’re going to hire someone because we have to build a dashboard, a public facing dashboard on the progress of the project that they’re building out from ARPA funding. So we have someone to be able to collect all that data,” Holmes tells Broadband.money in an interview.&nbsp; <a href="https://broadband.money/state-broadband-offices/virginia" target="_blank" rel="noopener noreferrer">Virginia </a>is just one example of what’s happening across the rest of the country.&nbsp;<a href="https://discuss.broadband.money/c/get-broadband-grant-alerts-news/texas-looking-for-broadband-program-coordinator" target="_blank" rel="noopener noreferrer">Texas</a> was looking for a Broadband Program Coordinator in early February. <a href="https://discuss.broadband.money/c/get-broadband-grant-alerts-news/maryland-looking-for-a-program-manager" target="_blank" rel="noopener noreferrer">Maryland</a> was looking for a senior program manager for broadband infrastructure around the same time. That person will be overseeing the allocation of $300 million. <a href="https://discuss.broadband.money/c/get-broadband-grant-alerts-news/new-york-state-looking-for-director-of-program-design" target="_blank" rel="noopener noreferrer">New York</a> was also looking for a director of program design. That team would be overseeing the disbursement of $1 billion, according to a tweet by Scott Rasmussen, acting director for New York State’s <a href="https://www.governor.ny.gov/news/governor-hochul-announces-new-1-billion-connectall-initiative-bring-affordable-broadband" target="_blank" rel="noopener noreferrer">ConnectALL</a> office.&nbsp;<a href="https://discuss.broadband.money/c/discuss-colorado-broadband-grants/brandy-reitter-joins-colorado-broadband-office-as-executive-director" target="_blank" rel="noopener noreferrer">Colorado</a> and Connecticut recently went through hiring processes for broadband directors. Washington State is currently <a href="https://www.governmentjobs.com/careers/washington/jobs/3300470/director-office-of-broadband-civil-service-exempt-13068" target="_blank" rel="noopener noreferrer">looking for </a>one. Colorado hired Brandy Reitter in February. Connecticut hired Kevin Pisacich.&nbsp;Broadband offices coordinate broadband expansion efforts. They create scoring criteria and issue grants to ISPs and local entities to reach areas neglected by commercial interests in the underserved and unserved communities. They also co-ordinate by creating maps of broadband availability, helping local governments with technical issues and training and increasing public awareness on broadband access issues.State broadband offices will need to manage all the planning, logistics and coordination for a smooth, streamlined and successful rollout of incoming infrastructure funds, as well as oversee matching of local, federal and private funds.States will be applying to the NTIA for funding based on formulas outlined in federal legislation – formulas that depend on Federal Communications Commission-produced maps of broadband network access which identify underserved and unserved areas such as low-income neighborhoods and rural communities.Based on these formulas, states will give grants to internet service providers, who will use them to build broadband infrastructure in the underserved and unserved areas.Anna Read, senior officer of The Pew Charitable Trusts’ Broadband Access Initiative, says that a state broadband staff is critical to implementing broadband policies. “While their structures vary, these programs share many similarities, including working with local officials and other stakeholders to close gaps in service, managing data on broadband access, and administering grant programs” said Read. Read says that Pew is aware of “a dedicated office or agency working to expand broadband access” in 49 states. The offices are central to determining how much of broadband funds are allocated to each state. Read says they are “well positioned” to lead mapping and creation of broadband plans. “In many states, like these examples from&nbsp;<a href="https://www.revisor.mn.gov/statutes/cite/116J.39" target="_blank" rel="noopener noreferrer">Minnesota</a>,&nbsp;<a href="https://oregon.public.law/statutes/ors_285a.166" target="_blank" rel="noopener noreferrer">Oregon</a>, and&nbsp;<a href="https://app.leg.wa.gov/RCW/default.aspx?cite=43.330.534" target="_blank" rel="noopener noreferrer">Washington</a>; the legislation that created broadband offices directly tasks those offices with mapping and planning activities,” she said. Planning activities by offices involve:<ul><li>Cultivating stakeholder buy-in.</li><li>Identifying existing assets.</li><li>Conducting surveys or other demand research, such as on economies of scale.</li><li>Reaching out to internet service providers.</li><li>Examining potential models for deployment.</li><li>Network design.</li><li>Business planning.</li></ul><a href="https://discuss.broadband.money/c/broadband-grant-events/ask-me-anything-with-peggy-schaffer-director-connect-maine" target="_blank" rel="noopener noreferrer">Peggy Schaffer</a>, executive director of <a href="https://www.maine.gov/connectme/home" target="_blank" rel="noopener noreferrer">ConnectMaine</a>, says she is somewhat concerned by staffing issues in state broadband offices, but that at the same time offices are rapidly expanding their staff. The <a href="https://www.maineconnectivity.org/" target="_blank" rel="noopener noreferrer">Maine Connectivity Authority</a>, a sister agency, is adding 10 members of staff to its extant staff of two.&nbsp; “I know state agency broadband leaders, we're all little nervous because it's a lot of money, right?” said Schaffer, “And a lot of responsibility. And most of our offices have very few people.” “States are staffing up quick. They're stepping up quick. They're hiring people, and they're looking for specific skills. They're looking for finance people to make sure we spend the money right. They're looking for, for grants management, they're looking for community people,” she said. &nbsp;

States need staff to ensure they will get their fair share of billions in broadband funding. 

States In Hiring Race As Feds Work to Meet Infrastructure Law Deadlines 

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It’s time for every American to get involved and actively push for better broadband connections.Having access to basic, affordable internet became a matter of survival during the pandemic — and<a href="https://www.washingtonpost.com/technology/2020/03/16/schools-internet-inequality-coronavirus/"> </a><a href="https://www.vox.com/recode/2020/9/10/21426810/internet-access-covid-19-chattanooga-municipal-broadband-fcc">not everyone got by</a>.That’s why everyone, including state, local and national media, local internet service providers, and government officials, should tune in and pay close attention to what NTIA Administrator<a href="https://www.commerce.gov/about/leadership/alan-davidson"> Alan Davidson</a> has to share with us when he comes to speak at the<a href="https://discuss.broadband.money/c/broadband-grant-events/alan-davidson-keynote-mountain-connect"> Mountain Connect 2022</a> conference on Tuesday, May 24th.You can check out the <a href="https://discuss.broadband.money/c/broadband-grant-events/alan-davidson-keynote-mountain-connect">details of the event here</a>.&nbsp;Alan will explain what comes next after the<a href="https://broadbandusa.ntia.doc.gov/"> National Telecommunications and Information Administration</a> fires off its starting gun in the national race to make internet access ubiquitous, reliable, and affordable for all.The<a href="https://mountainconnect.org"> Mountain Connect 2022</a> conference will be one of the first<a href="https://mountainconnect.org/venue/"> places</a> where you can get a front row seat to talk with the man with a plan to deploy nearly $50 billion of new broadband grants aimed at ending America’s digital canyon once and for all, as Broadband Money Co-Founder Jase Wilson puts it.&nbsp;As he writes:&nbsp;&nbsp;<blockquote>NTIA’s programs will unleash more broadband funding over the next few years than all prior U.S. broadband funding programs combined. In the right hands, such resources could kick off nothing short of a new chapter in American dynamism. NTIA’s historic announcement is the “starting gun” for states, local governments, and network builders.&nbsp;&nbsp;</blockquote>It’s crucial that we get it right this time, after<a href="https://www.eff.org/deeplinks/2020/04/frontiers-bankruptcy-reveals-cynical-choice-deny-profitable-fiber-millions"> decades</a><a href="https://www.politico.com/news/2021/11/29/fcc-broadband-maps-biden-523425"> of</a><a href="https://conexon.us/conexon-blog/sunk-costs-a-cautionary-tale/"> failure</a>. It's why Congress gave this job to the NTIA and came up with this new way of distributing broadband funding in the first place.&nbsp;Otherwise,<a href="https://www.techdirt.com/2022/04/28/big-telecom-convinces-missouri-lawmakers-to-block-funding-for-broadband-competition/"> bills like this might become law</a>.As writer and digital activist Cory Doctorow<a href="https://doctorow.medium.com/all-broadband-politics-are-local-e103967a0f0c"> says</a>: "We need to counter that pressure.<a href="https://www.eff.org/deeplinks/2021/12/every-state-has-chance-deliver-fiber-all-broadband-future-2021-review"> Residents of every state</a> need to call their state legislators and demand participation in this universal broadband."The right providers, under the <a href="https://broadband.money/annotated-resources/annotated-guide-to-iija-broadband-programs">Infrastructure, Investment and Jobs Act</a>, includes local ISPs working in concert with local anchor institutions, government agencies and other local members of the community. Specifically, the law mentions that “cooperatives, nonprofit organizations, public-private partnerships, private companies, public or private utilities, public utility districts, or local governments” cannot be excluded from being awarded the money.&nbsp;Come and join us to set a new agenda. Learn about how the IIJA works, and how Alan wants to work with you to put it into action. Come to meet the many local government officials and infrastructure professionals working hard to build this future.&nbsp;As Cory says in his own piece, "this is one of those rare moments where individual action can make a huge, lasting difference. All the pieces are coming together for a new broadband future for the nation, one where public provision and management ends decades of gouging, underinvestment and naked contempt from the universally loathed (and loathesome) telecoms sector."Find out how these pieces are coming together, how funding works, and how Broadband Money and its grant application, ISP management and mapping tools can help you -- whether you're a government official, regional ISP or other kind of entity looking to improve access.&nbsp;And then get active and participate in the process of making sure that all this money goes to the highest and best uses.So come and be a change-maker, learn how to land the funds, and get organized. Come join us at <a href="https://mountainconnect.org/">Mountain Connect</a>!

Come and be a change-maker, learn how to land the funds, and get organized. Come join us at Mountain Connect!

Join us at MountainConnect 2022, and learn what local ISPs must do now to bring affordable internet access to everyone

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The Biden administration is going to work “in deep partnership" with states, territories' and local governments across the country to construct broadband plans for the $42.5 billion in broadband infrastructure funding "in a radically transparent way,” promised Evan Feinman, the National Telecommunications and Information Administration's Broadband Equity, Access, and Deployment Program director.&nbsp;Feinman urged ISPs to stay in constant contact with their state broadband directors and the NTIA so that they could work closely to achieve the goals of the Infrastructure Investment and Jobs Act's BEAD program.&nbsp;“Please, please, please take advantage of the opportunities to get this dialogue with your state broadband office and with your NTIA Program Officer,” Feinman told a ballroom-sized audience of rural telephone companies and ISPs attending the <a href="https://www.ntca.org/events-education/events/fall-conference/agenda" target="_blank" rel="noopener noreferrer">NTCA Fall conference</a> in San Francisco on Monday morning. “We have to hear from you to know what we're doing right and wrong. And don't be shy about sharing. We need to hear from you. We're going to be standing up a lot of different public meetings, really soliciting input a lot of different times in ways."Feinman also said that the NTIA is going to be creating state level broadband coalitions “in every single state of the union.” “And when that opportunity comes, please join that coalition. Lend your voice to this to this group, this chorus that is calling out for state support and local electoral support to make sure that we get this project done. Simple availability of funds on the NTIA level will not ensure program success. We have to see a whole society ever to make this happen. And you all are critical partners.”Feinman said that the NTIA has all of its regional directors in place and that it has hired three quarters of its state directors.&nbsp;“So every single community here, every single person sitting in this room is going to hear from their state broadband office and my staff person in your state. Or you don't, let me know right now, and I'll get right on that. But that's critically necessary. What we have to do to get this right is literally go down to the grassroots level. My team is going to …[go to] every project that's proposed and go to every single county in which there's a project to be constructed across the entire country, all 50 states and six territories. We're gonna throw that map up on an easel, and we're gonna invite the citizens to come and say: “Y'all, this is what we're building. Does this get this done for you?”"&nbsp;He added: “Every single state must have a plan that persuasively argues that it is reaching universal coverage. They must, in the context of that, have engaged all of these new stakeholders, not just once, not just a notice and comment – even if a state has the best notice and comment period in the history of humanity, that's an ‘F Minus’ and they get $0. There must be ongoing continuous collaboration with the folks in this room with community leaders to make sure that we're getting the job done.”&nbsp;He added that the NTIA is still receiving a lot of questions about the BEAD program, such as the need to prove that grant applicants' have the financial wherewithal to complete projects, for example, and how the NTIA will coordinate funding with other broadband programs from other parts of the administration. He said that the NTIA is working hard to address these questions.Feinman made the remarks on Monday morning during a discussion with NTCA's Executive Vice President postgres Romano and the Federal Communication Commission's Wireline Competition Bureau Chief Trent Harkrader.&nbsp;Feinman added during the discussion: “You know, it's a significant undertaking, and that's why we're gonna get all the way down to that community level, that community meeting that I described --down to a couple of locations on a piece of poster board. You know, that's, that's the level of granularity we're gonna have to reach. If we're gonna get internet for every single American.”The panelists also discussed the FCC's mapping efforts. NTCA's CEO Shirley Bloomfield alluded to some of the frustrations providers are experiencing with the process earlier on in the morning during a speech in which she referenced providers who were seeing things like boulders being referenced in the FCC's Fabric map as “broadband serviceable locations.”Congress has charged the FCC with creating more accurate, accountable broadband maps that can be verified by parties other than the current self-reporting process from ISPs. The first version is due to be published sometime in November. The NTIA needs these maps in order to allocate BEAD funding.&nbsp;The panelists acknowledged that the FCC's Fabric map is an iterative project. Giving a sense of scale of information gathering effort, Harkrader said that the NTIA used its outreach specialists to contact more than 3,000 providers to get them to file the required information with the FCC on time.&nbsp;Feinman, for his part, said that the NTIA is going to wait until the FCC's map's quality improves before the agency makes any allocations. The ultimate decision on when to start allocating money will be up to his boss, NTIA Administrator Alan Davidson.&nbsp; &nbsp;

The BEAD program director emphasized the NTIA's focus on working with local communities.

NTIA is creating state level coalitions to push for state support for broadband rollout. BEAD program director emphasizes local coordination

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During a recent<a href="https://www.youtube.com/watch?v=_9oSq09WeXo"> online discussion</a>, Shayna Englin, Director of the <a href="https://www.calfund.org/digital-equity-initiative/" target="_blank" rel="noopener noreferrer">California Community Foundation’s Digital Equity Initiative</a>, recounted how low income and immigrant neighborhoods in Los Angeles haven't, for a longtime, been able to subscribe to broadband internet plans.&nbsp;Non-profit organizations offering services in the area realized that their residents needed better broadband in order to take advantage of the basic healthcare and education services. Whenever clients tried to get the local large commercial broadband provider to provide affordable services, the response always was: “You have service.”&nbsp;The leaders of the neighborhood development project <a href="https://destinationcrenshaw.la" target="_blank" rel="noopener noreferrer">Destination Crenshaw</a> took action to address this problem. They compiled a report with data gathered through a painstaking, organized community effort, and realized that specific areas were being<a href="https://www.governing.com/community/the-nuances-of-digital-redlining-explained"> digitally red-lined</a>.&nbsp;<a href="https://thecounty.me/2022/09/15/news/business-news/county-partners-launch-broadband-survey/">Local entities</a> around the nation are conducting what effectively amount to what we are calling<a href="https://broadband.money/broadband-grant-terms/broadband-audit"> broadband audits</a>. To prevent every locality from having to reinvent the wheel, and in an effort to ensure industry-standard best practices, Broadband.money is making a free <a href="https://toolkit.broadband.money/">broadband community kit</a> available so that you can generate your own broadband feasibility study.&nbsp;You’ll get best practices recommendations for browser-based speed test surveys, and the speed test result portion of the surveys will be fed back into our<a href="https://broadband.money/state-broadband-grant-portals"> broadband grant maps</a>.&nbsp;In Los Angeles' case, the report is likely to generate significant interest because the Infrastructure Investment and Jobs Act<a href="https://www.jdsupra.com/legalnews/the-crackdown-on-digital-redlining-9090788/"> instructs</a> the Federal Communications Commission to create rules to end digital redlining.The data is likely to draw regulators' attention to focus on how digital redlining works, and how they can end the practice.&nbsp;It could also show local and state communities around the nation how to document the practice for themselves.&nbsp;“What we saw is that in higher poverty communities of color, communities with a high immigrant population, [they] were really consistently charged a lot more for the same service tiers as their neighbors in whiter, wealthier communities, which doesn't make a ton of sense from a business perspective,” Englin said. After asking around, the authors of the study were told that the service provider was likely engaging in the practice to disincentivize subscriptions to a service in an area with outdated cable technology that doesn't have the bandwidth to handle large volumes of traffic and subscribers, Englin said.&nbsp;The community survey also revealed that many low-income households weren’t taking advantage of the Federal Communications Commission’s Affordable Connectivity Program (ACP) internet subsidy program because the large commercial internet service provider’s salespeople didn’t know what it is and how to enroll people for it, Englin said.&nbsp;The study also found that many of these low-income households didn’t understand their telecommunications bills, or that they had options to pick from a menu of services, and they didn't have to subscribe to an entire telecommunications package.&nbsp;The result is that these households don’t subscribe to broadband.&nbsp;“And so the actual availability is not there,”&nbsp; Englin said during a<a href="https://www.youtube.com/watch?v=_9oSq09WeXo"> Benton Society panel discussion</a> on broadband mapping on Monday.&nbsp;“That's an example of where the infrastructure availability question, and the pricing and adoption questions really do intersect, and you can’t really contemplate that without those — the speed test data and the pricing data laid against availability data over and above what the ISP says."&nbsp;That's why it's so important to think in a holistic way about data gathering, and why speed tests are important when it comes to broadband mapping, Englin said.&nbsp;A study<a href="https://www.lightreading.com/digital-divide/study-highlights-impact-of-digital-redlining/d/d-id/779933"> published this August</a> from the University of Pennsylvania also showed how Philadelphia suffers from digital redlining.&nbsp;Yet the much-anticipated new national broadband map that the Federal Communications Commission has been charged with compiling will show that these neighborhoods do have broadband service.&nbsp;That’s because the maps will only reflect whether an ISP's advertised service is actually available for purchase, not anything else.&nbsp;“I want to make sure people understand and are clear that what we are collecting is availability data,” said Eduard Bartholme, the FCC’s Broadband Data Task Force’s senior outreach director, during the Monday discussion. “So while adoption, affordability and quality of delivered services are very important, they’re outside of the scope of what the FCC was tasked with under the Broadband Data Act back in 2020.”&nbsp;“I think another thing that’s really important for everyone to be aware of is that what we are collecting is the maximum speed that is offered for purchase at a location,” he elaborated. “So for example, our maps will show that a provider may offer 200 [Mbps] down over five … that’s what they’re offering for sale. That’s not the performance the consumer may find when they run speed tests at that location … but what the maps [reflect] is what’s available for purchase.”&nbsp;Local governments and other ISPs can challenge the claims of service providers’ coverage claims, and the FCC will ultimately adjudicate those claims, Bartholme said. He urged the public to go through the FCC’s relevant reports and orders to understand the adjudication process.&nbsp;Dustin Loup, the<a href="https://www.marconisociety.org/magazine/meet-dustin-loup-national-broadband-mapping-coalition-program-manager/"> Marconi Society’s National Broadband Mapping Coalition Program Manager</a>, moderated the discussion.In answer to Loup's question about whether challenge information would be published online, Bartholme said that the FCC's maps would reflect areas that were being challenged and that:&nbsp;“There is an adjudication process that the commission would undertake to ultimately determine the outcome of a challenge if there’s no ability for the person filing the challenge and the provider involved in the challenge to come together and reach an outcome by working with each other.”The FCC will also later allow consumers to “fact-check” ISPs’ offerings in their area. But it’s still unclear what the FCC will do with the information. ISPs will not be obligated to respond to the complaints.&nbsp;&nbsp;Sarah Morris, a senior advisor at the National Telecommunications and Information Administration, said that the NTIA had written its BEAD Notice of Funding Opportunity (NOFO) hoping to incentivize service providers to upgrade their networks.“This is certainly a tension that we are aware of, and one that we tried to thread the needle very carefully to address in our NOFO,” she said. “We do see the need to incentivize where possible, or financially viable, future-proof builds, and that's what we are hoping to do.”The IIJA directs states to come up with their own challenge programs to enable local communities to challenge incorrect or incomplete information state authorities might have about local broadband needs.&nbsp;That process enables local governments, nonprofit organizations, or providers to challenge state and territories’ determinations of local areas’ connectivity and grant funding needs – as defined by the number of locations that are unserved and underserved in their IIJA BEAD grant funding application to the NTIA.&nbsp;The worry is that states may undercount the number of locations needing grant funding because of exaggerated coverage claims by monopoly incumbent providers, or because of other faulty data.&nbsp;&nbsp;The IIJA determines that locations are unserved if they have connections that can only manage speeds of less than 25/3 Mbps upload/download. Underserved areas are those locations that have connections that offer speeds of less than 100/20 Mbps.At least<a href="https://muninetworks.org/content/united-states-broadband"> 12 states have created their own</a> broadband maps. The NTIA is<a href="https://broadband.money/blog/NTIA-is-creating-state-level-coalitions-to-push-for-state-support-for-broadband-rollout"> mandating that states vigorously engage with local communities</a> to discover their broadband needs.&nbsp;That's why Broadband.money<a href="https://broadband.money/blog/mayors-broadband-grants-for-cities"> urges local government leaders</a>, community leaders, local broadband champions and action teams to conduct<a href="https://broadband.money/broadband-grant-terms/broadband-audit"> broadband audits</a> with our free<a href="https://toolkit.broadband.money/"> broadband community kit</a>.

The gulf between theory and reality became apparent during a broadband mapping discussion between a grassroots non-profit and a Federal Communications Commission staffer 

Investigation in urban Los Angeles reveals need for broadband audits

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Back in November 2021 when President Biden signed the Bipartisan Infrastructure Law, he promised: “This law is going to make high-speed Internet affordable and available everywhere — everywhere in America — urban suburban, rural — and create jobs laying down those broadband lines.No parent should have to sit in a parking lot at a fast-food restaurant again just so their child can use the Internet to do their homework. That’s over.”But almost a year after he signed the law, questions are swirling about the way the Federal Communications Commission is carrying out a key component of the goal, which is the implementation of a more accountable mapping system that shows which areas of the country most need subsidized and grant-funded broadband networks. The map is being managed by CostQuest, a private-sector contractor.“There is a really important role for communities to play in building this information from the ground up and getting some some ground truth,” said Dustin Loup, the Marconi Society’s <a href="https://www.marconisociety.org/programs-services/broadband-mapping/" target="_blank" rel="noopener noreferrer">National Broadband Mapping Coalition</a>’s project manager in a recent discussion on broadband mapping with Broadband Breakfast. “Designing a transparent evidence-based streamlined challenge process for the [Broadband, Equity, Access and Deployment] program that allows communities to use that ground truth to make the case for the funding that they need is an opportunity to mobilize those communities in a way that helps them advocate for themselves, but also builds a better state level database and hopefully that translates into a better national database.”The “ground truth” Loup is referring to is the ability for local communities to conduct Internet speed tests to verify that Internet service providers are actually providing the level of service that they say they are providing, among other things.&nbsp;(Broadband.money is providing local communities with a <a href="https://broadband.money/broadband-grant-terms/broadband-audit">broadband community kit </a>where they can conduct multiple speed tests simultaneously using best practice methodology and instructions, and it will also include a comprehensive qualitative survey so local communities can determine their exact needs.) It's called a <a href="https://broadband.money/broadband-grant-terms/broadband-audit" target="_blank" rel="noopener noreferrer">broadband audit</a>.&nbsp;But the FCC has recently<a href="https://www.fcc.gov/document/specs-available-bulk-broadband-data-collection-fixed-challenges"> said </a>that it’s not, for the most part, going to accept third-party speed tests as a form of verification, and even when it does, it will only do so in an amorphous auditing capacity. ISPs won’t have to respond to crowdsourced speed test data. And the FCC is also limiting initial access to its new mapping system. Anyone accessing the publicly-funded $45 million mapping system must obtain a license through CostQuest that limits their access to specific portions of the map and not share access with anyone else.&nbsp;&nbsp;This poses a problem for local and regional organizations preparing to apply for federal funding to deploy new networks to unserved and underserved communities, and which have used speed tests to map out broadband service in their areas.&nbsp;The idea behind the new federal map is better accuracy. The FCC’s current broadband coverage map is based on ISPs’ self-reported availability data, which is prone to exaggeration and is <a href="https://www.politico.com/news/2021/11/29/fcc-broadband-maps-biden-523425">famous </a>for its <a href="https://arstechnica.com/tech-policy/2019/08/the-fccs-horrible-broadband-mapping-system-is-finally-getting-an-upgrade/">inaccuracies </a>and a resulting misallocation of billions of dollars of broadband grants.&nbsp;&nbsp;The goal of the current push (mandated by the <a href="https://www.congress.gov/bill/116th-congress/senate-bill/1822">Broadband DATA Act) </a>is to figure out the areas of demand that telecom companies have deemed not worth serving financially, but under the current self-reported mapping system are reported as served. Communities often use speed tests, as well as other methods, to determine what level of service is available.&nbsp;State broadband offices need to work with local communities and create a database to share with the National Telecommunications and Information Administration (NTIA) to determine the grant allocations they should receive under the BEAD grant funding program. Under BEAD, Internet speeds less than 25 Mbps download and 3 Mbps upload (hence the reference to 25/3 Mbps) are considered unserved and Internet speeds less than 100/20 Mbps are considered underserved. NTIA is the agency administering the $42.5 billion in broadband funding from the IIJA.&nbsp;When asked whether his organization would challenge the FCC map when it’s expected to be published in November, Ohio’s <a href="https://buckeyehills.org/">Buckeye Hills Regional Council</a>’s Broadband Coordinator Ryan Collins said: “Our maps are based on speed tests and speed tests aren’t allowed to be used to challenge the map.”&nbsp;Asked how his organization then plans on challenging discrepancies it sees on the FCC’s map, he said: “That’s the question we’re all asking: ‘How are community organizations supposed to – in a reasonable amount of time, and within a reasonable amount of resources, challenge it?”&nbsp;The Council along with other partners, has created a <a href="https://connectingappalachia.org/" target="_blank" rel="noopener noreferrer">web site </a>with county-level broadband availability maps and the associated costs of getting connected. It used speed tests results provided by Ookla to create the maps.&nbsp;&nbsp;The Buckeye Regional Council represents the eight counties of Athens, Hocking, Meigs, Monroe, Morgan, Noble, Perry, and Washington in Southeastern Ohio in the Appalachian region. Key members include local elected officials and representatives from the educational, healthcare, forestry and farming communities and local mayors.&nbsp;Ultimately, Collins said, the council hopes to work with the state to inform the FCC’s map. Allowable forms of challenges to the FCC’s map include knowledge of infrastructure, information collected from consumers about whether advertised services are available or not available to them, and “other.”&nbsp;Collins’ organization isn’t the only one that’s frustrated. Loup has been leading the <a href="https://broadbandmappingcoalition.org/">Broadband Mapping Coalition</a> for several months and meeting with the FCC’s Task Force. Members of the coalition include Google, Broadband.money (us) the Institute for Local Self-Reliance, the Internet Society, MLab, XLab and Next Century Cities, among others.&nbsp;Members of the coalition have complained that the FCC is effectively sticking to its “trust and don’t verify” regulatory approach to broadband mapping, and have asked repeatedly how the FCC will verify ISP’s coverage claims effectively if it doesn’t have a public process to adjudicate potentially thousands of disputes. And members also worry about the public’s limited ability to access the mapping data such as location IDs without a license provided by CostQuest. That could hobble third party efforts to integrate the data with “the ground truth” data that Loup was talking about to easily check the FCC’s Fabric map.&nbsp;All this has members looking to work with states to make sure state broadband offices have accurate information informed by empirical data, i.e., speed tests, instead of the FCC. The goal is now to create an industry “best practices” standard of speed test data that states could use as they create their own evidence-based challenge processes required by the NTIA for BEAD grants.Speed tests have long stirred debates in the telecom industry because of the many different elements that have to be in place to make sure that they are actually measuring what they say they are measuring. But a <a href="https://deliverypdf.ssrn.com/delivery.php?ID=759099099100077018029018075018090025023080034035049002106083111067071082022110094005019106107032112124109125126093112005019002061037071049081096017071025072105070068085019023112065064115107125100110004022119026078010110096122066067013071015000115006&amp;EXT=pdf&amp;INDEX=TRUE">draft analysis</a> on MLab’s NDT test from MIT initially reports that: “We found that there were enough data points in one month, [in] one state, to give what seems to be a representative characterization of performance. The fact that the data is crowd-sourced does not prevent us from drawing justifiable conclusions, provided those conclusions are crafted with care, carefully stated and qualified.”In a recent newsletter article, Jonathan Chambers, a<a href="https://broadband.money/events/ask-me-anything-with-jonathan-chambers"> recent AMA guest,</a> partner at <a href="https://conexon.us/" target="_blank" rel="noopener noreferrer">Conexon </a>and the FCC’s former Chief of the Office of Strategic Planning and Policy Analysis, requested that the NTIA establish clear guidelines and provide technical assistance for the state mandated challenge process under BEAD. He noted that the FCC has “published <a href="https://www.usac.org/high-cost/annual-requirements/performance-measures-testing/">speed test protocols </a>for every ISP that receives federal funding for rural areas. Those are the same protocols that should be used by challengers. It is a simple matter for state broadband offices to verify the validity of speed tests that follow the FCC’s [already established] protocols.”

The FCC's new Fabric map is meant to more accurately target broadband grant awards, but will it?  

Will the FCC’s Fabric Map Really Enable Communities To See Their Broadband Realities?

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Biden administration officials recently gathered with state and local government stakeholders from around the country to discuss the Federal Communications Commission's Fabric map and broadband funding allocations.&nbsp;The two successive mapping workshops took place last week at the <a href="https://www.shlb.org/" target="_blank" rel="noopener noreferrer">Schools, Health &amp; Libraries Broadband Coalition</a>'s <a href="https://broadband.money/blog/join-broadband-mapping-experts-and-broadband-money-wednesday-afternoon-to-learn-from-the-best" target="_blank" rel="noopener noreferrer">10th annual AnchorNETS conference</a> in Crystal City, Virginia.&nbsp;Below are 8 top takeaways we came away with.&nbsp;<ol style="list-style-type:decimal;"><li>Local governments must take an active role in determining the quality of the Federal Communications Commission’s Fabric map.&nbsp; The <a href="https://broadband.money/annotated-resources/annotated-guide-to-iija-broadband-programs" target="_blank" rel="noopener noreferrer">Infrastructure Investment and Jobs Act </a>creates a formula for allocating the $42.5 billion in broadband grant funding. Every state and territory will receive at least $100 million.&nbsp; But the rest will be determined &nbsp;according to the ratio of state’s unserved locations to all unserved locations nationwide. These calculations will rely on the FCC’s <a href="https://broadband.money/blog/will-the-fcc-s-fabric-map-really-enable-communities-to-see-their-broadband-realities" target="_blank" rel="noopener noreferrer">Fabric map</a> for its data on locations that are considered served or unserved. &nbsp;  The Fabric initially relies on ISPs telling the FCC where they provide service. ISPs report the maximum advertised speeds of service to the FCC. This information is not independently verified by speed tests. &nbsp; &nbsp; The <a href="https://www.govinfo.gov/app/details/PLAW-116publ130" target="_blank" rel="noopener noreferrer">Broadband DATA Act</a>, the law that requires the FCC to build the fabric and establishes a challenge process, uses those challenges as a correction mechanism for the initial reporting.&nbsp; “State, local, and Tribal governments, service providers, and other entities can begin to file bulk challenges to data in the Broadband Serviceable Location Fabric (Fabric), which serves as the foundation for the Broadband Data Collection (BDC) fixed availability maps,” <a href="https://www.fcc.gov/news-events/events/2022/09/broadband-serviceable-location-fabric-bulk-challenge-process-webinar" target="_blank" rel="noopener noreferrer">according to </a>the FCC. &nbsp; This means that resource-strapped local governments will need all the help they can get within the next four months before the FCC publishes its maps and the Commerce Department's National Telecommunications and Information Administration (NTIA) starts using it to calculate its BEAD grant allocations.&nbsp; &nbsp; &nbsp; “The accuracy of the information in these maps will determine how much money states are going to receive and that is huge — especially for unserved and underserved areas -- the same areas that have been neglected and left behind in the past because they have had the fewest resources to actually make sure that the accuracy of this information is where it needs to be,” declared Ovidu Viorica, broadband program manager for <a href="https://broadband.money/state-broadband-offices/new-mexico" target="_blank" rel="noopener noreferrer">New Mexico</a>’s public schools during the workshop. &nbsp;  Added Kevin Sievert, program director of broadband deployment for <a href="https://broadband.money/state-broadband-offices/north-dakota" target="_blank" rel="noopener noreferrer">North Dakota</a>: “At the state level, we don't have the vision down to every local locality. So there really needs to be a kind of a groundswell of challenges and validation of this data in order for us to make it as accurate as possible.” &nbsp; That’s why Broadband.money created the <a href="https://broadband.money/community-broadband-kit" target="_blank" rel="noopener noreferrer">Community Broadband Kit</a>. Local governments can use this free resource to create their <a href="https://broadband.money/broadband-audits" target="_blank" rel="noopener noreferrer">broadband audit</a>.&nbsp; &nbsp;</li><li>There’s still time for local governments to advocate for themselves, and to frame the terms of discussion over the best ways to get their communities broadband access. &nbsp;  “A lot of the responses from the NTIA and the FCC indicated that there are a lot of things still in the works,” noted Stephanie Jane Edwards, the North Carolina Broadband Infrastructure Office’s broadband mapping and data lead. “And that means that we still have a great amount of opportunity for advocacy on what we want to see, and more specific answers about timelines and granularities.” &nbsp; Many state and local officials (and others) had peppered the two administration officials at the panel with questions about the nature of the FCC’s fabric, what kinds of challenges are allowed, the differences between a challenge and a crowdsourced report from a consumer, the openness of Fabric data, and the role of community anchor institutions, among other things.&nbsp; Nick Alexander, a senior NTIA telecommunications policy analyst, and Kirk Burgee, the FCC’s wireline competition bureau chief, were not able to answer several of the questions immediately. &nbsp;</li><li>Nobody really understands the terms on which the FCC’s Fabric data can be used.&nbsp; This leads to the next big takeaway from SHLB’s AnchorNETs 2022 mapping workshop: Nobody really understands the terms on which the FCC’s Fabric data can be used because the Fabric is governed by a secret procurement contract. &nbsp; &nbsp; Both Alexander and Burgee were repeatedly asked questions about how state and local governments and the public can use Fabric data, and the terms on which it can be accessed. The answers they gave all boiled down to: “It’s complicated.”&nbsp; At one point, Alexander said: “There's a complicated kind of partnership chain that is a function of the license agreements.” &nbsp;  This hobbles local governments because they need to navigate a bureaucratic system to even access basic information they need to conduct analyses of their own communities’ needs. &nbsp; Dustin Loup, the Marconi Society’s National Broadband Mapping Coalition Program Manager, told workshop participants that he has submitted a Freedom of Information Act (FOIA) request for the the FCC’s contract with mapping vendor CostQuest.&nbsp; He was told that the terms of the contract would be redacted. &nbsp; “Because of the restriction on [allowable] uses [of the data] and the restricted access, it's very difficult to provide support at the local level,” he said. “It also makes it difficult to do things that should be done in the coordination process, like a local governments should be able to check some of the broadband serviceable locations against the public utility information, and say: ‘Oh, what they're all these residential electric connections?’”&nbsp; That kind of analysis could enable a local government to challenge the accuracy of the Fabric. “But they're not allowed to share it this way, because it's so restricted,” Loup said. “And all of this ties back to the fact that this is a proprietary locked down dataset that we're kind of forced to help build, and ISPs are forced to submit to it.” &nbsp;  Kelleigh Cole, Utah’s former broadband outreach director, threw out this hypothetical during the mapping workshop: “So say that I take my state map, I've seen the Fabric, I make adjustments to my state, not addresses but maybe I adjust polygons or I make some change [and] trim a state map because of whatever I've seen on the Fabric. Am I violating the license? Is that okay to do? " There is no clear answer.&nbsp; Cole is currently director of strategic initiatives at the Utah Education and Telehealth Network. &nbsp;</li><li>The FCC’s Fabric will only reflect very limited information about broadband availability and will not reflect the digital divide&nbsp;&nbsp; “On the fixed side, we're not accepting speed tests to show that service is not provisioned at a location,” the FCC’s Burgee said during the mapping workshop.&nbsp; &nbsp; The IIJA focusses funding on unserved, underserved, and high cost areas, which require broadband grantors to understand the performance of networks in order to properly direct funding. &nbsp; But the Fabric will only reflect advertised availability, not verified performance levels. Recent <a href="https://static1.squarespace.com/static/6165cb6ecbf6d70401a212f6/t/6345ca9c147af0682276fb3d/1665518251184/Broadband+Pricing+Disparities+Report+-+Oct+2022.pdf" target="_blank" rel="noopener noreferrer">investigations </a>by the <a href="https://static1.squarespace.com/static/6165cb6ecbf6d70401a212f6/t/6345ca9c147af0682276fb3d/1665518251184/Broadband+Pricing+Disparities+Report+-+Oct+2022.pdf" target="_blank" rel="noopener noreferrer">California Community Foundation</a> and the non-profit investigative newsroom <a href="https://themarkup.org/still-loading/2022/10/19/dollars-to-megabits-you-may-be-paying-400-times-as-much-as-your-neighbor-for-internet-service" target="_blank" rel="noopener noreferrer">The Markup </a>have shown the importance of the role that socio-economic data and speed test information is in trying to determine where to focus resources to improve access to under-resourced areas. &nbsp; <a href="https://broadband.money/state-broadband-grant-portals" target="_blank" rel="noopener noreferrer">Broadband.money’s broadband grant maps </a>are designed to provide communities with this information. &nbsp;  For his part, Burgee acknowledged the utility of additional information that’s necessary to figure out whether low-income populations are able to get reasonable terms of access to broadband, but said that it wasn’t something that would be incorporated into current FCC maps. &nbsp; When asked at the mapping workshop whether the FCC would include affordability and reliability factors in the Fabric, Burgee said: “In a perfect world, we would have all that data. It's it adds a layer of significant complexity to do that. We weren't tasked with it with the broadband data. It's not to say it couldn't become a part of the collection or different collections in the future.”  That echoes what another FCC spokesperson said recently: &nbsp;“I want to make sure people understand and are clear that what we are collecting is availability data,” Eduard Bartholme, the FCC’s Broadband Data Task Force’s senior outreach director, said during a recent Webinar. “So while adoption, affordability and quality of delivered services are very important, they’re outside of the scope of what the FCC was tasked with under the Broadband Data Act back in 2020.”&nbsp; &nbsp;</li><li>It will be up to ISPs to resolve consumer challenges that report broadband availability inaccuracies in the Fabric.&nbsp; &nbsp; Here’s how the consumer challenge process will work, as described by Burgee:&nbsp; “A consumer submits a challenge to give us evidence that the service is not consistent with what's been filed. That information is transmitted to the provider (that is relevant to that provider,) which has 60 days to admit the accuracy of the challenge, or they can dispute it. If they dispute it, there's a 60-day period that commences, during which the provider is required to work with the challenger to clarify any misunderstandings to make sure that everybody has the full facts. And hopefully that will resolve a lot of challenges.” &nbsp;</li><li>The FCC will publish a broadband funding map by March 2023 so that broadband grant-making entities can co-ordinate funding between different programs and agencies. “It basically is intended to reflect areas where there has been firm commitments from funding agencies,” Burgee said.&nbsp; &nbsp;</li><li>Challengers are encouraged to submit challenges to the accuracy of a reported “broadband serviceable location” if even just one unit of an apartment building can’t get the level of service reported by a provider.  “Generally, a multi tenant dwelling is a structure that will be considered as a broadband serviceable location, and we identify the number of units. That number can be challenged. If a resident of a unit within that structure is not able to get the service as reported, that would be a legitimate challenge and we could potentially call into question the reporting for the entire structure,” Burgee said.&nbsp; &nbsp;</li><li>Schools, health facilities and libraries — basically any community anchor institution, should make sure that they understand what kind of broadband service their institution subscribes to, and make sure that they communicate with the FCC about it, or they will be omitted from the Fabric by default.&nbsp;&nbsp; The Broadband DATA Act — the law behind the creation of the FCC’s Fabric – specifies that the FCC collect information only for “mass market” broadband service, and not “enterprise” subscriptions that many institutions subscribe to, Burgee said.&nbsp; Therefore many CAIs are not included in the Fabric. But as New Mexico’s schools Broadband Program Manager Viorica pointed out, many small CAIs might subscribe to retail or mass market kind of internet services. &nbsp; “That's something that can be brought to our attention, as part of the challenge process. If the evidence is compelling, we would change that categorization,” Burgee said.&nbsp; That change would mean that the Fabric would include that CAI as a broadband serviceable location that’s eligible for broadband funding.&nbsp;</li></ol>

The FCC's secret procurement contract puts local governments in an unfair "hurry up and wait" position as they work to land funding to close the digital divide.

​​Broadband.money’s Top 8 Takeaways from AnchorNETS' 2022 Mapping Panel

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Setting up your Community’s Broadband Kit is simple. You’ll need to spend a few minutes filling out a few forms, decide what colors and logos you want associated with your pages, and then we’ll help you establish a Web address.We recommend that you read through this entire set of instructions so that you’ll be fully prepared to answer the questions in the set-up process.<h2>Step 1: Log into <a href="http://broadband.money/" target="_blank" rel="noopener noreferrer"><code>Broadband.money</code></a>. Then click on the “Begin” button.</h2><figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/CBK_Step_1_ST_b799ecb2a4/CBK_Step_1_ST_b799ecb2a4.png"></figure>It would be helpful if you briefly consult a Web designer, or use an online graphics service, such as Canva, to edit images. You can always re-configure your choices, although re-configuring web address information requires a little more legwork, so try to settle on a name and stick with it. &nbsp;<h2>Step 2: Make key decisions before you set up the kit.</h2>You and your community broadband action team leaders need to prepare before setting up your community broadband kit. The below image is a template that you can customize with your territory’s logo, colors, instructions and call-to-action to take an internet speed test.<figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_31_at_9_19_21_AM_83997d1056/Screen_Shot_2022_10_31_at_9_19_21_AM_83997d1056.png"></figure><ul><li>You will need a site logo — such as a logo for your city, county, or other geographic area where you want to create a geographic representation of internet speed tests that show which addresses that are served, unserved, or underserved. See what the city of Detroit used, for example.</li><li>You’ll also be able to customize the color themes on your community broadband kit. The image below shows some of the choices you’ll be offered.</li></ul><figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_28_at_9_01_41_AM_1_adbb9f6dca/Screen_Shot_2022_10_28_at_9_01_41_AM_1_adbb9f6dca.png"></figure><ul><li>Decide what to name the community broadband kit web site address where residents will go to take the test (see the image below.)&nbsp; We recommend using the name of your city, or county, parish or other geographic unit for a subdomain, and something easy to remember.&nbsp; For example, a city named Hogwarts might use <a href="https://speed.hogwarts.gov">https://speed.hogwarts.gov</a> for the address of its community broadband kit. Its subdomain would be <a href="https://hogwarts.broadband.money">https://hogwarts.broadband.money</a>. We recommend using a government web site so that broadband community kit test-takers don’t get confused.</li><li>Decide whether you will require test takers to list the address associated with their speed test. We recommend that you do. Otherwise, the end result (in the form of a map) won’t precisely reflect speed test information. The address information is stored in the community broadband kit testing database and is not used for any other purpose. You could provide an informational to test-takers to re-assure them about your privacy policies and what is done with the information, and how it is stored.</li></ul><figure class="image image-style-align-center"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_28_at_9_01_53_AM_1_1e765fadaf/Screen_Shot_2022_10_28_at_9_01_53_AM_1_1e765fadaf.png"></figure><h2>Step 3: Upload a logo of your city, town, county or other geographic unit.</h2>We recommend a logo with the dimensions of 100 to 200 px in a <a href="https://blog.hubspot.com/website/what-is-an-svg-file" target="_blank" rel="noopener noreferrer"><code>SVG format</code></a>. You can see how Detroit created the front page of its community broadband kit <a href="https://detroitspeed.broadband.money/" target="_blank" rel="noopener noreferrer"><code>here</code></a>.<figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_28_at_9_02_08_AM_1_bb2e16e9e2/Screen_Shot_2022_10_28_at_9_02_08_AM_1_bb2e16e9e2.png"></figure><h2>Step 4: Upload an additional image to urge the community to take the broadband kit speed test in social media.</h2>You will also want to share the kit widely to encourage as many people (within your geographic region applying for a broadband grant) to take the test as possible. So use an image that represents your regional broadband community kit. This is called the “Open Graph Image.” The recommended image size is 1200 px x 627 px.Enter a call to action headline, such as: “Get Better Broadband! Take Hogwarts’ speed test now!”After that, you want a sentence or two underneath the headline explaining what action you want your audience to take.<figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_28_at_9_03_08_AM_1_3c3ddf9f39/Screen_Shot_2022_10_28_at_9_03_08_AM_1_3c3ddf9f39.png"></figure><h2>Step 5: Create a favicon for your broadband kit.</h2>Your community broadband kit is a web page and will need what’s called a “<a href="https://en.wikipedia.org/wiki/Favicon" target="_blank" rel="noopener noreferrer"><code>favicon.</code></a>” That’s the tiny image that appears in the tab of your browser. Like the logo of your city/town/county/parish, it represents the web page of your area. You’ll need to pick one to upload so that your community broadband kit can be represented properly in a browser tab. You will be able to preview the favicon right after you’ve uploaded it. You can use free sites such as <a href="http://favicon.io/" target="_blank" rel="noopener noreferrer"><code>Favicon.io</code></a> to create one.<figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_28_at_9_03_38_AM_1_f76de27764/Screen_Shot_2022_10_28_at_9_03_38_AM_1_f76de27764.png"></figure><h2>Step 6: Enter a call to action like “take the test” on the test button to urge community members to click to take the test.</h2>Once test-takers click on the button, the broadband kit will present them with a series of survey questions to provide broadband grant applicants and planners with more information that will help you gain more insights into local connectivity needs. These results will be aggregated in graphical format at the end of the process (see bottom panel.)<figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/kit_test_progress_96153af2c1/kit_test_progress_96153af2c1.png"></figure><h2>Enter links to your community’s social media pages.</h2><figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_28_at_9_03_51_AM_1_ad7f4e3d61/Screen_Shot_2022_10_28_at_9_03_51_AM_1_ad7f4e3d61.png"></figure><h2>Step 7: Enter a “from:” email address, from which you’d like to send messages to residents and community anchor institutions about the Community Broadband Kit and speed tests.</h2><figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_28_at_9_04_02_AM_1_32e1f29525/Screen_Shot_2022_10_28_at_9_04_02_AM_1_32e1f29525.png"></figure>&nbsp;<h2>Step 8: Enter a meta title for your community’s broadband toolkit.</h2><figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Detroit_Community_Kit_Search_Results_b58717e5a7/Detroit_Community_Kit_Search_Results_b58717e5a7.png"></figure>The “meta title” is the headline that appears in search results. A “meta description” is the text that describes the Community Broadband Kit's purpose and function. See above.<h2> Step 9: Next, you’ll be presented with instructions on how to upload your community shape file.</h2>Once you’ve completed those steps, you’ll see the boundaries of your community within which the test results will appear.<figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_28_at_9_04_19_AM_1_c9756e64ff/Screen_Shot_2022_10_28_at_9_04_19_AM_1_c9756e64ff.png"></figure><h2>Step 10: Let us complete some behind-the-scene settings.</h2>We’ll notify you when we’ve completed the necessary the behind-the-scenes’ finishing touches. &nbsp;<h2>Step 11: Launch your in-person and online campaign.</h2>Encourage as many community members as possible to take the broadband kit speed tests. The test itself takes a minute. Test results can be viewed immediately, and in multiple ways. For example, you can view them geographically within the boundaries you’ve established, or in a table, or represented on a graph.&nbsp;<figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_31_at_9_08_29_AM_967fbe6922/Screen_Shot_2022_10_31_at_9_08_29_AM_967fbe6922.png"></figure>The results will show the address at which tests were taken (if the test taker provided the information,) the number of tests taken, and the provider name.The Community Broadband Kit administers three different varieties of tests simultaneously. The results of all three tests, run by MLab, Ookla and WIFI.WTF, will be consolidated and displayed. The measurements displayed are download and upload speeds, latency and jitter.The system will then generate a summary infographic that shows you what percentage of the test-taker residents would be considered unserved and underserved, as defined by BEAD, among other things (see below.)<figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_31_at_9_10_28_AM_ac73f28f02/Screen_Shot_2022_10_31_at_9_10_28_AM_ac73f28f02.png"></figure>You will also be able to see more detailed statistical analyses of all of the aggregated information about the tests in charts on a dashboard.&nbsp;In addition, you’ll be able to view graphical representations of the quantitative aggregation of accompanying survey results.<figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_31_at_9_12_33_AM_6588c92342/Screen_Shot_2022_10_31_at_9_12_33_AM_6588c92342.png"></figure><figure class="image"><img src="https://storage.googleapis.com/bbm-public-bucket/Screen_Shot_2022_10_31_at_9_14_55_AM_09b5de5d66/Screen_Shot_2022_10_31_at_9_14_55_AM_09b5de5d66.png"></figure>

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