When the Federal Communications Commission (FCC) released their new broadband map in November 2022, many hoped the chronic inaccuracies of past FCC maps would be resolved. Previous maps of high-speed broadband access in the United States painted inaccurate pictures partly because the definitions of things like “access” and “high-speed” were, frankly, wrong. Furthermore, the maps were based on data self-reported by internet service providers, which have every interest in claiming better service than they actually provide. The new maps have all the problems of the old maps, with the new issue that they are the basis for how $42 billion in broadband infrastructure grants will be spent.

The problems have also been raised by states, local government, and community organizations, who have filed challenges to the FCC over these inaccuracies. It is now up to the FCC and NTIA to fix the map, and time is of the essence: the Biden administration is set to confirm how the money will be spent by the summer as part of its Broadband Equity, Access, and Deployment (BEAD) program.

Overreliance on internet service providers (ISPs) to report service locations and service availability is a recurring problem. ISPs have no incentive to accurately report, and in fact, have every incentive to overreport, because misinforming the government has never carried a heavy penalty. These same ISPs then use these faulty broadband maps - which are built on their bad data - to challenge and try to prevent would-be competitors from building infrastructure into areas that are underserved or unserved.

The FCC, recognizing this concern, created a challenge process through which government entities as well as individuals are able to challenge the ISPs over their service location and service availability. Setting aside the issues with the challenge process and the obvious discrepancy that is pitting an average consumer or small government agencies against well-resourced ISPs, these challenges only allow a glimpse of the true scope of the map’s inaccuracies. 

For example, in Nevada, the Nevada State Office of Science, Innovation, and Technology found over 20,000 purported broadband-serviceable locations that they believe overstate coverage. They also found incorrect information on quality of service available as well as missing serviceable location.

In Vermont, the maps show 100% coverage, with only 3% of residents lacking speeds greater than the FCC’s definition of high speed internet of "25/3" (25 megabits per second download and three megabits per second upload). The Vermont Department of Public Service found that the maps omitted 22% of the addresses in the state’s own database: over 60,000 locations. Their Community Broadband Board further estimates that 18.6% of residents, not the map’s stated 3%, lack access to speeds greater than 25/3. It was so bad, the Community Broadband Board released a call to action “urging Vermonters to challenge wrong FCC map data.”

It is not just single-family residences that were omitted but also public and multifamily housing units, where a single omitted location could mean hundreds of people being uncounted, as well as centers of community life like schools, churches, and libraries. A letter signed by 110 organizations representing housing, education, healthcare, library, and state and local government interests finds that nationwide, 20-25% of unconnected households reside in public and multifamily units. The undercounting of schools, churches, and libraries omits crucial places of community and gathering where improving service would have an outsized impact in connecting otherwise unserved rural communities. For these to go uncounted  omits some of the most vulnerable populations and ignores precisely those areas that this initiative is meant to assist. 

The NTIA, and subsequently state governments, must rely on these inaccurate maps to disburse $42 billion in taxpayer dollars to build out internet infrastructure. An undercounting of a cumulative hundreds of thousands if not millions of underserved and unserved locations and their residents severely hinders how these funds will address existing inequities.

Take for example Los Angeles County, in California: according to the data ISPs have submitted to the FCC, LA County is 100% served. What we know from community organizations in LA County is that this is simply not true.

Unfortunately, the danger of these inaccuracies has extended to the California Public Utilities Commission’s (CPUC), which recently issued its own priority areas map. The priority areas map marks areas the CPUC sees as priorities for investment, using the same underlying data as the FCC’s inaccurate broadband maps. By failing to correctly reflect the deep inequities that exist in LA County when it comes to internet access, the CPUC map would also fail to prioritize those areas for much needed investment. Of the 100 census tracts in LA County that are least connected - those with the lowest percentage of population with fixed broadband at home - only 5 are in a CPUC priority area. Of the 500 least connected census tracts, only 14 are in a CPUC priority area. Conversely, of the 100 best connected census tracts - those with the highest percentage of population with fixed high speed broadband at home - 19 are in priority areas, and of the 500 most connected census tracts, 80 are in priority areas. If funds are disbursed based on the current data, LA County’s best connected are set to receive more investments in more places than the county’s least connected.

The obvious solution is to require better data and penalize intentional over-reporting of coverage. Looking beyond the map, the NTIA should not distribute the full $42 billion using the current available data given what appears to be systemic inaccuracies that disproportionately harm low-income people in cities. Furthermore, the FCC needs to do more than just count on less resourced entities to correct the false ISP data. They should proactively ensure everyone receives their fair share of federal support from the infrastructure law and root out bad faith efforts by ISPs.

Community organizations and state and local governments can only do so much by flagging the flagrant inaccuracies. These inaccurate maps put at risk the once-in-a-lifetime opportunity to build future-proof internet infrastructure that benefits all Americans for generations to come.