Fast, affordable Internet access for all.
A Challenge A Day Will Make BEAD Go Our Way - Episode 562 of the Community Broadband Bits Podcast
This week on the podcast, Christopher is joined by Christine Parker (Senior GIS Analyst at ILSR), and Meghan Grabill (Geospatial Analyst at the Maine Connectivity Authority) to talk about the recently announced NTIA location challenge process for the upcoming BEAD program. They talk about the handful of states that have been moving fast and already submitted (or will soon) their initial proposals, including Virginia and Louisiana and Maine, before tackling the recently released challenge process. Meghan and Christine run through the process by which states are allowed to set up different criteria for eligible BEAD locations, including everything from adjusting eligible technologies to location types, and how households can submit data and challenges.
Worthwhile revisions we like to see in the process include some shifting of the burden of proof to the IPSs (the largest one which have a long history of over-reporting service territory), the allowance of more flexible speed test data, and the ability to add community anchor institutions to grant-eligible maps.
We want your feedback and suggestions for the show-please e-mail us or leave a comment below.
Listen to other episodes here or view all episodes in our index. See other podcasts from the Institute for Local Self-Reliance here.
Thanks to Arne Huseby for the music. The song is Warm Duck Shuffle and is licensed under a Creative Commons Attribution (3.0) license.
Meghan Grabill (00:07):
The individual choices that each of the states are gonna make to best fit the needs of their state are gonna make it kind of impossible to have a one size fits all.
Christopher Mitchell (00:16):
Welcome to another episode of the Community Broadband Bits podcast. I'm Christopher Mitchell at the Institute for Local Self-Reliance in St. Paul, Minnesota. And if I am a little distracted today, it's 'cause I'm going camping and I'm really excited to get away from my computer <laugh>. So, but I'm even more excited to have a relevant show because I'll tell you the truth, we ran the risk of of picking a rerun to run for next week until Christine Parker was telling me about what we know about the challenge process and how that's updated. And so Christine at the last second volunteered to come on the show to update us from what we talked about a bit in episode 5, 5 5 with Alexis Truby. So welcome Christine Senior g i s and analyst on the Community Broadband Networks team. Thanks Chris. And then you somehow convinced Megan on minutes notice Megan Grable the geospatial analyst for the main connectivity authority to join us as well. So thank you so much, Megan. Thank
Meghan Grabill (01:18):
You for having me.
Christopher Mitchell (01:20):
I am excited to learn more about exactly what's going on now that we have, I think, a more definitive understanding of what N T I A plans to do. Although I understand that there's still a lot of unanswered questions. Before we jump into that though, I did wanna note, as I was doing my, my customary five minutes of preparation leading up to this, I was reading an article in State Scoop which is one of the few that has written about the N Tia's challenge process in the, in the past week or so. Not a lot of coverage out there from what I could tell. You know, I was checking out Benton headlines and others, and they, if people had written about it, I feel like they would've found it. And I noted in that an article on State Scoop, it said that some states, and it listed Hawaii, Louisiana, Maine, Utah, and Virginia have already published their first volumes for public feedback which is part of that process that they have to do take public comment on their plans before they submit their initial proposal to N T I A.
And that suggests to me that many of us thought in talking to a few state broadband folks, that it would be really December before we saw states submitting their plans. Now I would say that it does seem like it's clear that some states are gonna be aggressive and trying to get their initial proposals in very early much earlier than we thought might be likely. So just a little update there from what you know, I'm seeing out there. I don't know if if Megan, if you have anything, you know, if you have any perspective on that from what you've seen of, of Maine or other states, or Christine, if you've seen anything along those lines.
Meghan Grabill (02:57):
So for Maine, we yep. Got our broadband action plan out. We had our public comment period and we've gotten it back and we're doing our revising right now. We plan to submit that August 1st and then the digital equity plan we released that at the same time for public comment, but we're holding that until September 1st for submission, is kind of our plan right now. And so then that's setting us up for initial proposal volume one in December
Christopher Mitchell (03:24):
To submit it in December.
Meghan Grabill (03:26):
Christopher Mitchell (03:27):
Okay. So that's why I'm confused, I guess if you already have it up for public comment. 'cause I had seen some comment where I thought Louisiana was trying to get theirs in well early, but it's such a, I know that is a very complex process, but do you think some states will be able to get it in much earlier than December 1st?
Meghan Grabill (03:46):
Well, it's two separate things, right? You have the broadband action plan, and then you have the initial proposal,
Christopher Mitchell (03:50):
The broadband action plan that, is that the five-year plan or is that separate? Yes. Okay. Okay. That's
Meghan Grabill (03:55):
The five-year plan. Thank you. Yep. Yeah, so that one's first and then the initial proposal, however, Virginia, I believe, released both at the same time for public comment. And so their public comment period is over as far as I understand, and they are ready to submit. I haven't heard that they actually submitted yet, and I think Louisiana, yep. Same. Trying to hit a really aggressive timeline. We've heard from some of our other state partners that they are taking a slower approach to it. Right. Because once you submit your initial proposal and you get approval on volumes one and two, that starts the clock ticking for when you have to submit your final proposal mm-hmm. <Affirmative>, which is when you have to have all of your sub-grantees selected. And that is a very giant lift that everybody <laugh> wants to be very prepared for and very Right. Ready to be able to execute on that process. 'cause 365 days is short
Christopher Mitchell (04:53):
<Laugh> here. Again, I did not do close enough reading of the nofo perhaps, but are you, so one year after you get your initial proposal approved at that point you have one year to do your final proposal. Are you saying that you have to know everyone you're granting money to before you get 80% of the dollars
Meghan Grabill (05:13):
Yes. In the final proposal? Yep. All the sub-grantees have to be tentatively selected. Wow.
Christopher Mitchell (05:19):
That's crazy. I mean like, 'cause I, I guess, I mean, it makes sense from a perspective. I just trying to get money out there as fast as possible, but it does not make a lot of sense from a perspective of being able to adjust over the years based on how sub-grantees are doing or allowing the, some of the smaller ones to be able to spend that money and then come back for more and things like that. I guess learn something new every day. So <laugh>, I, I, I really decided that I was not gonna turn this into a show where Chris is complaining all the time about frustrations with this process and how I, I I, I feel it's perhaps not ideal for the sub-grantees that are envisioned by the people who are the rules. But but any rate, we want to talk about the challenge process. And so let me turn to you, Christine, to ask you to tell us roughly how it works. Like N T I A is trying to make it easy on states I, I gather. And so what is N T I A providing to states so that they can develop a successful challenge process and tell us what a challenge process is, I guess?
Christine Parker (06:21):
Yeah, so the, the challenge process is somewhat like the fccs federal, like their federal challenge process where folks were asked to look at the, the national broadband map and make sure that their address information was correct, make sure that their, the provider service availability at their address was correct. And so it's kind of a similar process, but this is just gonna be based on a map that the state is sharing. And so in this process, the state is able to accept some different or adapt some different modules they're calling them that would allow them to alter the designation or classification of locations prior to this state level challenge process. For example, one is A D S L module where any location with that is considered, like served by D S L would be then considered I think unserved or underserved. There are these different modules that states can adopt depending on their circumstances and, and needs to influence how the challenge process is going to work and what locations, what the classification of locations will be in that final list that is presented to residents.
Christopher Mitchell (07:41):
So if I understand correctly, then basically it's up to the state, for instance, whether or not they want to say per se no D S L is considered served N T I A. Is it true that N T I A is saying basically, but if you want to do that, here's how you have to do it. Like here's a bucket of rules that go along with that. If you wanna say this, we're not saying you have to say this, but if you do say this, here's how you do it.
Christine Parker (08:03):
Yeah. And there, you know, in some of these instances, there's still some question on the details of it. So that's something that like folks in the National Broadband Mapping Coalition have been talking about is maybe coming up with some additional suggestions or maybe an, an option, an additional module. To tack onto this, to kind of further refine what, what we would recommend states do as we move forward.
Christopher Mitchell (08:32):
About how many modules are we talking about?
Meghan Grabill (08:34):
I think currently there's only three modules.
Christopher Mitchell (08:38):
Okay. So it's not like there's 20. I was, I was just trying to get a sense of ballpark <laugh>, no.
Meghan Grabill (08:43):
Yeah. the D S L one, the speed test one, and then they grouped the area and they M D U one together now into a module.
Christopher Mitchell (08:54):
Okay. So let's go through them. What is the M D U module that is now you say area module, also what, explain what that is, if you don't mind, Megan.
Meghan Grabill (09:02):
If there are more than six challenges in a census block group that would trigger the entire all BSLs in that group as challenged. And then that puts the burden of proof on the provider that was challenged with those six challenges that they have to prove it for the entire census block group that they're showing in the national broadband map is correct.
Christopher Mitchell (09:27):
Okay. And we're gonna come back and talk more about that toward the second half of the show. What is the M D U module?
Meghan Grabill (09:34):
So the M D U is for the multi-dwelling units,
Christopher Mitchell (09:38):
Meghan Grabill (09:39):
Correct? Yep. The fabric, they're one point but they might have multiple, well, they do have multiple units in each one. And so if at least three units or 10% of the unit count is challenged in an M D U, then the entire M D U is challenged at that point.
Christopher Mitchell (09:59):
Okay. And then what was the last module that we haven't talked about yet? Speed test module. Just conceptually what is that?
Meghan Grabill (10:07):
Speech test module is where a consumer has taken three speed tests on so many consecutive days and found that I think it was like 80% <laugh>. Their scores are 80% below what is shown on the national broadband map for speed. And if the median of those three scores is below that 80%, then that's a sufficient challenge which is a cool add since speed testing isn't part right. Of the fccs version other than as like a crowdsource challenge, which isn't our direct availability challenges.
Christopher Mitchell (10:48):
This sounds like actually like figure skating where <laugh>, you know, you, you do, I mean, if they, if they made 'em do the routine three times, I guess it's not quite, it's not a, it's not a perfect analogy, but you drop the high score, you drop the low score, and is it within 80% of the advertised on the national broadband map? And I mean that's, that's actually at least understandable, I think if you get away from the lingo. <Laugh>
Meghan Grabill (11:09):
<Laugh>, that's right. Yep. Take three speed tests see what happens
Christopher Mitchell (11:14):
<Laugh> within the right, within the right timeframe. Actually
Christine Parker (11:16):
The, the timeframe, they removed the timeframe for residents for the submission part portion. But I believe they tacked that onto the I S P side of things. So that is when they are going to be doing their testing.
Christopher Mitchell (11:32):
Right. And that makes sense because it's in the interest of the homeowner or the, the, the user, I'm, I'm just struggling not to say consumer, I hate that word when it comes to the Internet. When it comes to the, the subscriber has an interest in doing the speed test at the time when the link is the most congested. They are supposed to still be getting those speeds during that time, but if you're not getting those speeds at 3:00 AM well then you also have an even bigger problem, probably <laugh>. So
Christine Parker (11:58):
<Laugh>. Right. And I think also in the interest of just getting people to be able to do this in consecutive days, like it's a hard, it's a hard lift. Not everybody is gonna remember to do that mm-hmm. <Affirmative>. so I think that was a good change.
Meghan Grabill (12:11):
The timeframe before was kind of like evening hours, right? Like six to 11:00 PM or something, which also as we're having our partners help and interact, you know, six to 11:00 PM isn't really the time that they're necessarily doing business. So it's also helpful to have that window opened up for assistance.
Christopher Mitchell (12:30):
Yes. Although for, for people's inter if people are interested, the, typically the highest peak time for networks for residential networks is Sunday night and Monday night for some reason. That's when, I don't know the most streaming happens and things like that, the most consecutive people are using the network. So that's my understanding when I talk to different ISPs. Interesting
Meghan Grabill (12:54):
Christopher Mitchell (12:55):
Yeah. <laugh>. Maybe that will be future trivia. We'll see. The so let's talk about the timing of this then. When we talked before about this, if my memory serves, the challenge process will be something that comes into play likely in I would say like, you know, second quarter of 2024, perhaps in Virginia in the first quarter of 2024, after states have a sense that there are nearly gonna get the money they need to go through the challenge process. And the timing of it is important because they don't want the challenge process to delay handing out the money. I'm guessing one other thing that I wanted to include for sure that people knew is that and to make sure I got this right this is not about locations anymore. We're done with locations. Like everything we're talking about here cannot change whether or not a location is on the map. The states cannot add locations or subtract locations through this process,
Christine Parker (13:47):
Christopher Mitchell (13:48):
Right. It's just about
Christine Parker (13:49):
Whether they have service most not this process. Oh, come
Christopher Mitchell (13:50):
On Megan, you're gonna kill me here. <Laugh>, <laugh>, there's an exception.
Meghan Grabill (13:53):
So we are being encouraged, right? To use the most UpToDate version of the map. And so if you challenge in the F C C map and it gets added from one version to the next, right? Mm-Hmm. Then you are getting new locations.
Christopher Mitchell (14:08):
Okay? So that would be a reason to get challenges, get those challenges in early to make sure the F C C has a chance. But from the purpose of this challenge process, as these rules are written states are not supposed to be using this to add or remove BSLs broadband serviceable locations from the map in terms of whether they exist. It's just about the level of service that is at those locations,
Christine Parker (14:31):
Right? Yep. Okay. Yeah. So people won't have the option to say, actually, my house isn't showing up on here, or it's incorrect, or something like that,
Christopher Mitchell (14:38):
Right? And people will say that and they'll be correct about that, but we're sorry. There's a whole different process to deal with that <laugh>. It's gonna
Christine Parker (14:44):
Take some time. Go to the national broadband map for that <laugh>.
Christopher Mitchell (14:47):
Yes. Okay. So what is the timing then of dealing with our fight over whether or not a given location has the service that is being advertised to, to it?
Christine Parker (14:57):
So the whole process from starting the in initial, like starting the challenge process and opening that window to sending that final list of challenge locations to N T A and having those submitted 120 days three months. So pretty
Christopher Mitchell (15:16):
Short four months. Mm-Hmm. <affirmative> three months, four months, four months. I can do math even in the morning. <Laugh>, <laugh> you have four months basically.
Christine Parker (15:25):
Yep. Within the challenge process itself, there's a, like a couple, like minimum of 14 days, so challenges have to be submitted for a minimum of 14 days. And then rebuttals also have to be allowed for about 14 days.
Christopher Mitchell (15:41):
So let's talk about it in terms of how it starts. What's the, what's the opening salvo of the challenge process likely to be? Megan?
Meghan Grabill (15:48):
So state broadband offices have to publish their determination on what are the eligible locations. So the unserved, underserved unserved brought to create <laugh> that list of eligible locations, the states have to go through all of the steps. So there is the deduplication,
Christopher Mitchell (16:09):
And this is before the window starts, the 120 days,
Meghan Grabill (16:10):
This is before the window starts, right? Yep. So we announced whatever version of the map that we're going to be using from the national broadband map, and then so deduplication, so you have to identify where there's been any funding awarded in the past. So R D O F locations or the broadband infrastructure program, those ones come off, and those ones are no longer eligible. States have to get together their list of cais community anchor institutions, and what they're including in that list we're given I think six or seven bullet points for definitions of what's included as a C A I. However, states can add additional ones. And then we have to assess at each of those locations whether they have gigabit speeds or not because those are right eligible for BEAD funding if they don't have the proper speed.
Christopher Mitchell (17:11):
Okay? So there's a series of steps that are prepar preparatory to, to making sure you're ready. And then the state says publicly, we got three buckets. Here's all the unserved locations, here's all the locations that are underserved, meaning they have more than 25, 3 megabits per second down and up. And then they have less than 120 megabits you know, down and up. And then and then the locations that we consider to be fully served, those locations that probably have either a very high quality wireless product or a licensed wireless product, I suppose, or a or a fiber or cable connection most likely. And then that kicks off the wrangling about whether or not those three buckets have the right addresses in them. And so some people will be wanting to fix that. Now, I don't know if this breaks apart the timeline issue, but Christine, you were mentioning yesterday that it's not like an individual homeowner is able to just reclassify, right? Like to say, oh, you got me wrong, and the state doesn't have to deal with individual people which I think is helpful from the state's point of view, but adds another real challenge to, to actual people who are paying attention on their own.
Christine Parker (18:25):
Yeah. There's kind of like this little sidestep in the challenge process wherein states are not, states are not receiving the individual challenges. It is going to be government small, like smaller local governments and nonprofit organizations that are collecting the challenge data through some portal of some kind that is yet, yet to be determined. It sounds like states are generally unsure yet how, how that's going to occur, but and then those organizations submit the data to the state. Yeah, it sounds like, from what I was hearing yesterday, there are some states that are considering, you know, they have a portal already set up so that heavy lift is done and they will collect the data, then give it to the nonprofits or whatever organizations they're collaborating with have them package it and send it back.
Christopher Mitchell (19:24):
That seems like the only way it would work. I just can't imagine what nonprofits are out there ready to step in and do this. I mean, like, we're one that in theory would be one, and I have no idea how we'd even go about doing it <laugh>.
Christine Parker (19:34):
Right. And then I also heard yesterday the nonprofit has to be registered in this state that it is,
Christopher Mitchell (19:40):
Christine Parker (19:41):
Better setting challenge data for. So even though we are a national nonprofit, I,
Christopher Mitchell (19:46):
You could do it in DC where we're registered, that's where we were born 50 years ago, <laugh>, so
Christine Parker (19:51):
Yeah. Yeah, <laugh>, it's just gonna be, I, I'm not sure how that part is going to work. I know I, I have some friends that are really interested in working with states on, you know, like putting together a, a portal. But I think because each state is going to have different needs and different modules that they're adopting, there's not going to be any single, like, single solution for that portal option. So it'll be interesting to see how states handle that.
Christopher Mitchell (20:19):
Was this a, was this a surprise to you, Megan, like, or did you sort of see this coming and do you have, do you have this main connectivity authority, have a plan for how to go about dealing with it?
Meghan Grabill (20:29):
Yeah, so we've been in the works developing a more robust analytics system and this, and the whole BEAD process has definitely been a driving factor behind needing to do that. At one point, really early on last year, there was maybe a hint that N T I A was going to have some sort of portal that states could use. But once the challenge came out, they definitely said, no, that's, it's not happening. Even knowing they were, they could've may have created it, I don't think Maine would've used it. It just seems like the individual choices that each of the states are gonna make to best fit the needs of their state are gonna make it kind of impossible to have a one size fits all. However, I, there's quite a few g i s companies out there that are standing up platforms to help do this. So if you are a state that doesn't have resources like Christine and myself <laugh> to be pushing the <laugh>, pushing in a more data-driven direction there's definitely a solution out there that you can purchase and make work for you. This is, this is a great g i s based cloud problem, <laugh> that there are many mapping people that we've been waiting years for a great activity like this to do. Yes. So
Christine Parker (21:57):
This is our time to
Meghan Grabill (21:58):
Shine. That's right. <Laugh>
Christopher Mitchell (22:01):
This reminds me of a conversation I had with Tamara Holmes who runs the Virginia office. And she, it was episode five 30, it was back in November of 2022. And when I'd asked her about advice for other offices she said, hire a G I Ss data person, like at least one. And and I think that that's important for people who might think, oh, I wish we had done that, but now it's not so important. No, it will be important moving forward as well. Like this is something that will continue to be an issue where it is, I have a expansive imagination in some sense, and a very limited imagination in other sense. So when I say it is unimaginable to me that the F C C anytime soon will have accurate data that states can use I could be wrong, but I think I, we could also be here 10 years saying, you know what, like the FCC is just never gonna have good data on where high quality Internet accesses. And so states need to take this seriously and not feel like, oh, we can get by without it. No, you need someone that can is, is comfortable like collecting this data and figuring out how to use it properly and things like that. So that's just my quick pitch <laugh> for every state to have someone that has the kind of skills that the both of you have in their broadband office focused on this work.
Christine Parker (23:22):
We use the analogy of highways and roads when we talk about inter network networks and the Department of Transportation, they have plenty of g i s people on hand, so it just makes sense that broadband offices would have g i s folks as well.
Christopher Mitchell (23:37):
Yeah. That's because states take roads seriously because states are essential for commerce <laugh>, and they recognize that networks are essential for commerce, but they do not take them seriously. <Laugh> at this point. Oh,
Meghan Grabill (23:48):
Now's the time to change <laugh>. Yeah, <laugh> plenty of reasons. Now, <laugh>
Christopher Mitchell (23:53):
And, and Megan, you were describing how states could go different ways, and so that's to say that this challenge process in Maine could look very different than New Hampshire or other states that are in New England. You know, we're gonna see a lot of different approaches and some of those different approaches may involve a different approach to speed test data, for instance. I'm guessing, I don't even know really what that might look like, but I don't know if you have a sense if, if either Christine or Megan, you can tell me how you could imagine two different states incorporating speed tests in different ways in order to, again, to get back to people haven't lost the thread to make sure that the, the addresses are correctly classified as having service or being underserved or unserved
Meghan Grabill (24:35):
States, I guess kind of have three options, speed tests or any of the modules in the challenge process. One is that you don't accept the module, and so you have no speed testing whatsoever in your challenge process. Two is that you accept the module wholesale and put that into your process and you do it exactly the way that it's written. The third option, and maybe the risky option is to alter it and come up with your own methodology for how they would be included when you submit your volume one proposal. N T I A has the discretion to approve or ask for changes in it. And so if you don't follow exactly as they have written, you're running the risk that they will not like it, right? <Laugh> and either ask for changes or say, no, you absolutely can't do it that way.
And so then that's slowing down your process because yeah, it'll just take more time for them to do. So if you've got a timeline and you're committed to sticking to that timeline, it's kind of a strategy, right? Trade off. Like thankfully we have our federal program officers and Maine has a great one. And so we work with her quite a bit on some of these questions so that it wouldn't be like such a great surprise like we can float some of these ideas mm-hmm. <Affirmative> and kind of get a little feedback before we get to that point. So it's not just like you cross your fingers, <laugh>, you submit it to the black box, and then you see what happens. Like we are really well supported <laugh>.
Christopher Mitchell (26:08):
One of the things I could imagine I cannot imagine happening, I hope but with an illustration of this, I think would be like, if a state was to say, we're gonna use Joe's speed test. Like we, we met this guy named Joe, and he seems like he's a good guy. He's outta work, he has some time on his hands, he's developed a speed test for us, and he's, you know, hosting it somewhere in in the Arctic. And we're gonna use that speed test. <LAUGH> and N T I A would say no, that's, that's unreasonable, right? <Laugh>? Yeah. You have to use a, a speed test that ha we have some sense is accurate <laugh>.
Meghan Grabill (26:41):
Yeah, I think there's rigorous or robust or there's some word in there that yeah, your speed test has to meet the requirements mm-hmm.
Christopher Mitchell (26:50):
<Affirmative>. Now, the other question I'm wondering about is because it's 120 days, I mean that's a fairly long time. It's in everyone's interest. Is it from a process point of view possible that a state could say to N T I A, you know, kind of forecasting this is what we're gonna, well, let me put it differently. If you just accept the module rules that N T I A lays out, then in theory you're not gonna be arguing with them about it because that's already been approved. Does that mean you could start your challenge process before your initial plan was approved in order to be moving forward? Or are there other reasons that you have to wait to do your speed tests or to do your challenge process until after the initial process plan has been approved?
Meghan Grabill (27:34):
You have to wait for volumes one and volume two to be approved by the N T I A before you're allowed to start.
Christopher Mitchell (27:40):
So there is no way to hand out money within 120 days of receiving the 20% that comes after your initial plan is approved because you have 120 days in which you have to go through this challenge process.
Meghan Grabill (27:54):
Not all states are going to ask for that initial 20%.
Christopher Mitchell (27:58):
Meghan Grabill (27:59):
That's an option too. Some states are just in way
Christopher Mitchell (28:03):
Sound of my head exploding. <Laugh>, <laugh>
Meghan Grabill (28:08):
Yeah, some states are just going to get through the process and then get their full chunk of money with the final proposal,
Christopher Mitchell (28:17):
Huh? Main is Maine gonna do the 20% option?
Meghan Grabill (28:21):
We were chatting about this yesterday, <laugh>
Christine Parker (28:24):
Meghan Grabill (28:26):
I, yeah, I'm not sure where we're landing yet. There's a lot of questions that we're still kind mulling around.
Christopher Mitchell (28:33):
Okay. All right. This is revelatory. Alright, so one of the things we wanted to make sure we covered is how to be strategic. And this is where we'll talk a little bit more about the area challenges and why that is relevant. Perhaps it would be easiest, Christine, if I asked you how not to be strategic, like what would be a bad way to go about doing the challenge process and to use your resources ineffectively?
Christine Parker (28:59):
I would say to not use any of the modules and just accept a default list of locations and move forward that way. Is, you know, not ideal.
Christopher Mitchell (29:11):
That's a good point. So if you, if, if a state does that, does it really have a challenge process? Like, I mean, what mechanism would people have to challenge if there was, would that just be ISPs would be arguing with each other about it? Or how would that work?
Christine Parker (29:24):
It would probably be more along the lines of like service availability. Like if, if they had a bill demonstrating that they were, that they were receiving some level of service and, and they weren't, like, I, I think it's gonna be a less factual form of a challenge mm-hmm. <Affirmative> because they wouldn't have like a speed test option to be able to support that. They do have a whole list of like forms of evidence that you can use to support challenges like that. I I don't think it would be as valuable as having these additional modules involved.
Christopher Mitchell (29:59):
Right. I think, I feel like it would be one thing you'd be sort of focused then on getting a letter from the I S P that says we cannot serve that location or something like that, right? Mm-Hmm. <affirmative>. Yeah. As opposed to arguing about the level of service being insufficient.
Christine Parker (30:12):
Right. I think the, the modules are nice because they do put more the, the burden proof is more on the ISPs rather than individuals.
Christopher Mitchell (30:21):
What's your recommendation for being strategic?
Christine Parker (30:23):
So something I've been talking with folks lately about is focusing on these area challenges and working with, if you have historical, like relatively recent, but historical speed test data, using that to target areas that you could shift from served to un underserved or underserved to unserved. So areas where you would be able to make a difference and target your outreach for speed tests in those areas rather than just trying to blanket approach outreach and get everybody in the state to participate because we know surveys are not going to be really effective in that way. You know, people are either not going to participate or they can't participate because they don't have Internet at home and they don't wanna have to drive somewhere to like submit whatever forms. And so targeting on the areas where people need to participate, but also keeping in mind the area challenge you only need to get six locations. So if you can focus on areas and get those six locations, you can get a whole census block group thrown into a challenge rather than just like a piecemeal individual challenge situation. And so that's one way to I think approach this process and get larger swaths of area challenged and put that burden of proof on ISPs. If
Christopher Mitchell (31:47):
A state hasn't been collecting speed tests, the M lab open data would be a place where one could look and try to find concentrations where you would be sort of having good fishing, you know, <laugh>. Exactly. grid hunting. Yep.
Christine Parker (32:01):
Absolutely. Megan had a good point earlier when we were talking about more rural areas. You might have only six locations in a whole census block group, and so that strategy may be different.
Meghan Grabill (32:13):
I guess one of our questions would be, does it have to be a census block group? Could it be based on density, larger areas for less dense areas, and write it into our challenge process like that? Those are the types of things that we're going to be investigating, kind of pressure testing with our F P O to see if, if that sort of thing would be considered to make sure that Maine does the best challenge process for Maine.
Christopher Mitchell (32:37):
Christine, where is the best place for people to go to have more strategic conversations that may not be broadcast on open podcasts that anyone can listen to? <Laugh>.
Christine Parker (32:48):
I have a Discord channel that has quite a few people in it now. It's called broadband and Digital Equity Research. We don't always talk about research. A lot of times we're talking about this <laugh> challenge process or the state of the maps. There's some venting in there if you just need to go and hear that other people are frustrated in the same ways that you are. But we do talk a lot about like the changing policy dynamics and it's a really good place to, to get up to speed pretty quickly.
Christopher Mitchell (33:18):
And remind us about the Marconi organization. The, the network,
Christine Parker (33:21):
Also the National Broadband Mapping Coalition. We have monthly meetings. Dustin Loop is our leader, and that's another really great meeting place to hear from experts in a variety of fields from consultants to state mapping folks to nonprofit mapping folks like myself.
Christopher Mitchell (33:41):
Wonderful. Any last thoughts, Megan?
Meghan Grabill (33:43):
I wouldn't mention that our strategy includes a lot of work that we've been doing in building up our partners around the state. So we have the main broadband coalition as well as our regional and tribal broadband partners. People who can, or groups that can participate do include tribal government along with local government and the nonprofits. So we've really been boosting up those groups of people so that as we get to the state challenge process and they're the groups that can participate, they have the resources that they need to be able to enhance our challenge process.
Christopher Mitchell (34:15):
Excellent. And yeah, Maine has been doing just tremendous work from the, the great organizations of your state, the, the Broadband Coalition. Over the years it's been a real model state that I feel like it'd be nice to see a case study of in the future for how a small state just really organized itself effectively to, to be well connected. So thank you for joining us and and I really appreciate your insights today.
Meghan Grabill (34:39):
Absolutely. Thank you again for having me.
Christopher Mitchell (34:41):
Absolutely. And Christine, thanks for making this happen.
Christine Parker (34:44):
Ry Marcattilio (34:44):
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