Mapping, BEAD, and the Future of Broadband - Episode 516 of the Community Broadband Bits Podcast

This week on the podcast, Christopher is joined by Jon Chambers, industry veteran and partner at Conexon. The two begin by talking about the work electric cooperatives are doing in rural areas to convert subscribers from DSL connections reluctantly maintained by monopoly providers to member-owned fiber connections.

Then, they address what Jon calls the next frontier in broadband policy and funding with BEAD, initiated by the inherent shortcomings of the new Broadband Data Collection Fabric and which underscore the FCC's continued inability to act decisively to figure out where and which types of connections are available at the address level. This includes the fraught and complicated consequences when the federal government sets too low a definition of broadband, the challenge process, the delay in funding until a complete list of Broadband Serviceable Locations is complete, the lack of transparency in the new data sets, and more.

This show is 47 minutes long and can be played on this page or via Apple Podcasts or the tool of your choice using this feed

Transcript below. 

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.


Jon Chambers (00:07):

There are approximately the same number of unserved and underserved households today, as there were 10 years ago. The reason does not have to do with lack of investment in the telecommunications industry. It has to do with lack of foresight.

Christopher Mitchell (00:22):

Welcome to another episode of the Community Broadband Bits podcast. I'm Christopher Mitchell at the Institute for Local Self-Reliance, and I'm wearing a headset for the first time in years, rather than recording this on a proper mic. So I'm kind of curious how it's gonna turn out. but I have here one of my, one of, one of our favorite all-time guests, Jon Chambers. welcome back. Jon is a one of the partners in connection and a person whose voice is very well known through this industry as bringing a I think a, a persistent and cold logic to some of these discussions. Welcome, Jon.

Jon Chambers (01:00):

Thanks, Christopher. Good to hear you. You're coming across loud and clear.

Christopher Mitchell (01:05):

Yeah, usually I'm loud, not always so clear. <laugh> so connects on for people who haven't listened. First of all, go back and, and listen to some of those past episodes cuz our conversations with Jon tend to be some of the best ones but connects on, focuses entirely on working with rural electric cooperatives and in those kinds of environments. how is life working with the rural electrics?

Jon Chambers (01:26):

Well, I got a text this morning. It was the first thing I saw when I woke up from one of our great friends in Oklahoma. And the text just said 30,000

Christopher Mitchell (01:38):

<laugh>. I remember, was it two years ago? You said they were building at the fastest rate? You'd seen anyone do it, I think, and then they're sir holding onto that.

Jon Chambers (01:45):

This is Oklahoma Electric co-op OEC. Fiber is their broadband subsidiary name, 30,000 for a, a co-op that's maybe 40 some thousand members. And they have built into a couple of towns. So 30,000 in a few years. they're killing it. And it is, to me, another example of this is a, you know, local company in the community. For 85 years, they decided to get into this business with a lot of, of hesitation, a lot of thought reluctance initially. and 30,000 new broadband subscribers in the last few years isn't gonna sound like a lot to AT&T or Comcast, but where they operate, it's the whole community. And, and it is to me, one of the clear examples of the right way to approach rural broadband, any type of broadband, I suppose. But, you know, we are just in rural areas, which is an electric co-op is a pure manifestation of a community led business that has sustained that community first with electricity now with broadband.


And that's 30,000 subscribers who, you know, used to get D S L service from at and t once upon a time. So that, that is a nice thing to wake up to this morning. it, it is the, there's a lot of frustrations in everybody's field. I mean, you know, it, it, it doesn't matter what you do for a living, whether you're checking out groceries or whether you're digging trenches or you, there's always frustration. It's nice to have things that remind you, you know, why you wake up in the morning. and, and that email, I'll give a shout out again to the fellow who sent it, David. Good speed. that text rather that he sent me was a, was a great wake up this morning.

Christopher Mitchell (04:12):

I just I just had to outta curiosity, I had to go and remind myself what their pricing was. And it's a hundred megabit is their intro offer. $55 a month. it's a heck of a deal. And people that want to gigabit $85 a month I'm gonna go ahead and guess that those are the actual prices that show up on people's bills as opposed to <laugh>. You know, what we see with the more revenue focused providers where it's a little bit ambiguous as to what you'll actually pay at the end of the month,

Jon Chambers (04:39):

That is, that has been their pricing since they launched. they've never changed their pricing. We, that is Conexon, co-ops we work with and, and our subsidiary, our Internet service business, which is called Conexon Connect. Last year we introduced a two gigabit tier for $99. And I remember less than a decade ago when people made fun of Google for launching gigabit service in Kansas City. And when my business partner Randy Clint, launched gigabit service in rural Missouri, people questioned the need, why, why would you introduce gigabit service? How are you gonna use it? Are you gonna stream 20, 30 movies all at the same time? Like there is no need for it.

Christopher Mitchell (05:30):

I still don't understand why we have highways that have multiple lanes, and then when all cars are only one lane wide

Jon Chambers (05:35):

<laugh>. That's right. And I, like, I expected when we launched symmetrical, two gigabit service, true speeds that people would have that same question. And I anticipated our take rate on two gig service would be in the two to 5% range of our customers.

Christopher Mitchell (05:53):

That sounds even ambitious. I would've guessed less than 1%, honestly.

Jon Chambers (05:56):

Yeah. So we have three tiers of service, a hundred meg gigabit, two gigabit. The split is almost even wherever we offer service of about a third, a third and a third of our customers take a hundred meg gig and two gig service. And the two gig service a third of our customers tells me, not only, you know, was my projection way off, but it tells me people will continue to get high quality service when you make it available at an affordable price. And when I ask people who have taken two gig service, why oftentimes they simply say, well, I was paying that much for 10 megabit service, so why not?

Christopher Mitchell (06:40):

I'm excited about it. I still haven't taken full advantage of the Comcast speeds where I am because the Soho gear you know, like my, my network equipment in my house is kind of maxes out at a, at a gigabit a second. but I'm, I'm hoping we'll see a new line of that popping out because when I'm transferring my big files around my home, it's pretty annoying to only be getting, you know, a hundred some megabits a second or megabytes a second when you're measuring the file transfer. And you know, I, I could see the use for it. And I'll tell you right now, like, I mean, I'm, I'm moving stuff up to the cloud moving my office, I got a hundred megabits symmetrical connection, and if I had two gigabytes I would be spending less time going back and forth in my office to make sure I've got the Dropbox syncs working and stuff like that, because I have to wait so long for that volume.

Jon Chambers (07:25):

So you, you have just incidentally touched on what I think is going to be a huge fight in the next couple, few years, having to do with the funding, the, the bead funding in particular for rural broadband or unserved areas and underserved areas. And that has to do with the upload speeds. So if you're working here, if you're uploading files, the upload speeds for cable and the notice of inquiry that the FCC launched, whether broadband should be defined as a hundred down 20 up the, the bead program, which takes as its directive, the statutory language of the infrastructure Act, which says that underserved are areas that lack a hundred down 20 up to me, what the fight is going to be about over where to fund for bead funding is not gonna be what lacks 25 3, because three quarters of those places will already be receiving funding, ardo funding or ARPA funding, maybe a higher percentage of that. So what will be left are areas that lack a hundred down, 20 up and areas of lack, a hundred down, 20 up, it's, it's all gonna come down. The way I think of it to one major fight is cable broadband really broadband. And, and I, as one who came up in the industry through the cable industries, I worked for Comcast and Cox and TCI, and Charter and a bunch of others, I would always have said that cable broadband is broadband, in fact is the only broadband

Christopher Mitchell (09:09):

Prior to fiber,

Jon Chambers (09:10):

Prior to fiber. Now, if the question is, is broadband reliable, broadband is the term used in the, in the ACT and the term used by N T I A reliable broadband, some consistent delivery of broadband that gets, you forget the download speed, you can get downloads of a hundred meg down by lots of transmission media. Can you get 20 megs? And and that is not a question that will be answered by the fccs maps, right? And this is to me, the, the one of, although there are a series of mistakes the FCC has made that is in gathering data that doesn't answer the core question that they've been asked. The core question they've been asked is, where in the country do locations lack 25 3 and where do they lack a hundred down 20 up? Tell us where with specificity, if you don't collect the data to answer that question, folks are gonna receive these maps some point next year for the first time.


And what will be revealed is that the FCC didn't collect the necessary data to answer that question, and then we're gonna be into this massive challenge process that will occupy time, energy, money, and won't leads to the very reason that Congress appropriated tens of billions of dollars, that is to spend the money in rural areas that black service today so that they can get service. All will be doing is churning, churning paper between the FCC and, and applicants between the FCC and those that have submitted data. The FCC between the FCC and N T I A will be churning and churning and churning <laugh>, you know? Yeah. For years. Unless somebody steps in and says, you're on the wrong path, it's time for a course correction. Now, before we discover in six months time that you've been on the wrong path for the last three years,

Christopher Mitchell (11:28):

You know, for people who might be a little bit newer, I want to jump back in time to explore what you were just saying, because for me, it seems like yesterday that it was 2012 and the cable networks were so oversold that nobody ever saw the speeds that were advertised, right? Because like each neighborhood was exceeding the technical amount that the cable company could make available. And in the 2013, 2014 environment, they, the cable companies largely like, especially the better ones like Comcast implemented DOCSIS 3.0. And at that point, my neighborhood started seeing, I was regularly getting what was advertised to me because they had enough capacity to meet neighborhood demand. And at that time they also improved the upload speed. And what we saw was that they could deliver the uploads too, in part because not a lot of people were using it. And the question now is, as people are using more and more, are we gonna see that where the download speed, there's plenty of space in the system, but the cable company can only deliver me 20 megabits the second of upload, as long as most of my neighbors aren't using it.


And we're gonna see a lot more congestion there for several years until his doxy four doxy symmetrical gets rolled out. And, and I guess I would cap that off by saying, in my mind, this is the ultimate failure of the fcc. I've been, I've been very disappointed and disillusioned with the fcc, which you're intimately familiar with having worked there as well. and when I look back at the fact that we have an expert agency and the whole point of an expert agency is that they're not supposed to be surface level, right? They're supposed to really get down and, and to make good policy. And the fact that they just keep basically saying, well, as long as a house can get 25 3 or can get a hundred by 20, well, what does that really mean? Because like, I, like, as, you know, you could deliver a gigabit symmetrical over wireless to a house, but to try to do it to all of their neighboring houses is almost impossible. And so, like, what does it actually mean if a house could get it? I, I, I don't, and there's no technical like approach that actually makes sense for trying to deal with that paradox.

Jon Chambers (13:32):

So the other related parts to what you've just said is that the digital divide can clearly be explained as the difference between services available in urban areas and services available in rural areas, unserved areas. That's

Christopher Mitchell (13:50):

The majority of it. Divide. There's a few people right now who are heads are exploding because there are some unserved areas in urban areas, but you understand that. But the vast majority of the issue, is that what you just described?

Jon Chambers (13:58):

Yeah. So in the statute it just says urban and rural high cost. But if, you know, we can ignore the statute and say there are other digital divides. Sure, there's a low income portion of the statute two, the statute I'm talking about is a communications act. So, but simply the digital divide is the divide between one thing and another thing. The difference between those two things. So as I've just explained to you about what we offer as service, and that's in rural areas, but what we offer, we don't offer a hundred down 20 up. That's too slow. We don't offer anything that slow nothing. And yet the FCC has put out an n o i that's a notice, which can't take years. I expect they're putting that out so that they come up with their answer next February when they issue their next broadband report.


But they're just asking the question, teasing out this question as to whether the broadband definition should be changed from 25 down three up to a hundred, down 20 up. That is, they're at the initial part of asking whether something which is already slower than the thing, the speed that's available in urban areas today and is available all across the country today. Whether that should be the new definition by the time they decide it is, it's already no longer broadband according to the marketplace. So we will spend money, the, the, the reason we as a public will spend money through government agencies on things that will be out of date before the money gets spent. And the digital divide will persist in perpetuity until the FCC and N T I A decide to spend money not on yesterday's technology, but on tomorrow's technology. And, and there's a reason that the, there are, there are approximately the same number of unserved and underserved households today as there were 10 years ago.


The reason does not have to do with lack of investment in the telecommunications industry. It has to do with <laugh>, lack of foresight. Not even a lot of foresight. Like, you know, looking down just at your shoes about the next step you're gonna take. All you have to do is say, why should I invest in something that is no longer the speed that's available today for something that should last for 10 years? If we take that approach in 10 years time, we'll have the same number of unserved and underserved locations. I, I've never understood that complete focus on speed. And I recognize the FCC has other categories they look at, they look at speed, they look at latency, they look at affordability, but usually people look at speed. And usually when they look at speed, they just talk about the download. And the upload is more and more important in an environment where people work increasingly from home.


And where there's more and more video, more and more video uplinks, as well as streaming video down to your various devices. So the Congress discussed, there were early versions of this infrastructure act, early iterations introduced by Clyburn, introduced by others. That would've set as a symmetrical level the speeds. It's still the right answer, and any state could still do it that way. Any state could still say, you know, the speed has to be. And then we're gonna take a measure as to what's available today and what's available today. If you ask, not me, not Jonathan Chambers running around rural America with our little two gigabit service. You can ask at and t and you can ask for Verizon, and you can ask all of the large telecommunications companies that invest, and you ask them, what do you invest in and what services do you offer? An at and t would boast that they offer five gigabits per second symmetrical speeds. Why do we continue to invest in lesser things? Is it stupidity? no, there's smart people working on this at the FCC and N T I a

Christopher Mitchell (18:33):

Smart people can be stupid in my experience, but I take your point. Go ahead.

Jon Chambers (18:37):

Ah, is it corruption? Is it avarice? Is it you know, the old politics of compromise? Is it any of those? It's a sort of laziness,

Christopher Mitchell (18:50):

A capture. I mean, I, I do think a part of it is a capture and that

Jon Chambers (18:53):


Christopher Mitchell (18:53):

Yeah. I mean, which is, which is to say a kind of like innocent corruption <laugh>. I mean, depending on how one used the word corruption always implies intent when in fact, you know, I think of corruption the way our, our founding fathers use that term, which basically means, you know, whether or not it's perverted is the system perverted towards some or not. And and I, and I think a lot at the fcc, there's sort of this issue of which I hear from the fixed wireless folks regularly, which is, why are you so worried about upload Chris? You know, no one's really using their upload. We monitor our, our, our network bandwidth and we give people upload and, and they don't use it very much. So, you know, why should we increase our upload speeds if, if, if it's just a waste of of time and capacity?

Jon Chambers (19:36):

You know the answer.

Christopher Mitchell (19:38):

No. Yeah.

Jon Chambers (19:39):

That's why I to you the answer <laugh>, because this is the essence of, of what you've been doing since I first met you longer than that. The answer is the very first thing that I mentioned in our conversation, which is the answer are community-based organizations. For me, it's electric co-ops that have lots and lots of assets that make it work better than other community organizations. electric co-ops, the, the, the, the one I mentioned at the outset, Oklahoma Electric Fiber, you wanna see what works. Go to Oklahoma City, visit the folks in Norman, visit David Good Speed and Patrick Grace visit them. You'll see what works, what works at a local level without large amounts of federal funding and subsidies. You'll see what works. And this isn't one of those, if it works there, it can work anywhere. It takes hard work, it takes dedication, it takes, it takes a, a commitment to mission to serve community, but it's all the right things that it takes that makes that work.


And you'll see the same thing. Now. We started working with O E C in 2017, I guess it's now working in lots and lots of places. And we work in more than half the states. We build today more than a thousand miles of fiber optic cable each and every week. You can see a path from where we've come from. We as a country, we, the electric co-ops, you can see a path from where we've come from a decade ago to where this can go. And it is possible to build a fiber optic cable to every single rural home in the country. And there is enough money to do so. And as sure as you know, we're talking, we won't do it as a country, but we can get, we can get a lot closer in the next few years than, than we ever than at least I thought we could have sitting in a different place 10 years ago looking at these same issues.

Christopher Mitchell (21:53):

Let me ask you a question about that, because I recently saw a a system, it was a municipal system that I believe is mostly centralized, like a fiber middle mile kind of stuff with a few customers here or there. But it was mainly for you know, connecting large institutions and things like that. And they were preparing to privatize it, not because they wanted to, but because they couldn't find the a person that wanted to move there and could work at the right salary to run it. Are you seeing that at all with, with electric co-ops that are trying to, cuz I mean they have great talent within them already, but a lot of times they're gonna wanna bring in someone that's had decades of experience in the industry. You know? Is there any concern with like, finding the right people to run these systems at this point?

Jon Chambers (22:36):

Not where we work and we work in the most remote parts of the country in the poorest parts of the country. We work a lot in persistent poverty counties.

Christopher Mitchell (22:46):

Yeah, I mean, you're down there in the Mississippi, Delta and Louisiana. Just so people have a sense. You're, you're in a lot of places. Those are two that just stick outta mind in mind for being, having a lot of poverty. And we're just looking at, some of those counties have 50% of people between 50 and 75% of people live below 200% of the poverty line.

Jon Chambers (23:03):

If I could be back in one of my old jobs and, and help direct some of the funding I would direct funding some of that Amer affordable connectivity program funding. I would direct more of it to persistent poverty counties and make their lives easier. Yes, we work a lot in Florida, Georgia Mississippi, Arkansas, Oklahoma, Missouri, Louisiana. I mean that part of Texas, you know, we, we work a lot in the southeast and the southwest. We, we also work in the Midwest. We work in about half the country, but where we work, this is to your question, you can either attract people or if you're saying some folks say, well there nobody will come and live here and work here. It's just training. People will work hard anywhere. And I heard the same thing years ago. Sometimes from electric co-ops, we don't know that we could attract the right people to do the to do the support, to do the operations work, to do the engineering to, but I haven't found it in practice that as I haven't found that missing piece.


These are good jobs. Like if you work in a place where it's a persistent poverty county and you're offering a good job, you'll find somebody to take that job. You can train them. What I thought you were gonna say since you described that project as a Middle Mile project <laugh> Yeah. Where they were connecting anchor institutions. Nah, that's a different problem. Those Middle Mile projects, they never work. That's like looking for car keys beneath the street light when you lost them in the alley, you know, you're looking there cuz that's where the light is. The old joke a money over the decade has gone to Middle Mile largely because that's what was easy for governments to spend their money on

Christopher Mitchell (24:57):

Because it was less political. There was less political opposition.

Jon Chambers (25:01):

Exactly. Less political opposition to the so-called over-building argument. The concept was well, we'll build Middle Mile then others will come. Yeah. The

Christopher Mitchell (25:10):

Mythical others

Jon Chambers (25:11):

Now it doesn't work.

Christopher Mitchell (25:11):

It's only 20. We actually 25 years of experience now with Middle Mile networks and not seeing that happen. I mean, I can point to five edge cases, maybe I can point to three edge cases. I don't know if I could do five. but it almost never happened.

Jon Chambers (25:23):

The only place I would spend Middle Mile on now and I know there's a billion dollar n t middle mount program and since NT i's other programs aren't up and running, they're gonna be flooded with with requests for that middle mile, which we'll just convince them that, you know, I guess we need more middle mile when really it is. Well that's the program that you've got running. That's why people are applying for, the only place I've put in Middle Mile are places where there is more or less just one provider, a monopoly provider where somebody is charging rates that are higher than than average. If you can find those places, that's how I'd review that program. That is, if, if I were reviewing applicants, I'd wanna know what, what do you spend for d I u what do you spend for direct internet access today?


What does it cost you to get a a 10 gig or a and or a hundred gig circuit back to an internet exchange point back to Atlanta, back to Kansas City? What does that cost you? If you're paying more than the average, then there's a case. If you're paying a lot more than the average of the median, then there would be a case for building Middle Mile there. Have you been refused? We have. We've been refused. middle mile that is leasing circuits back to internet exchange points from Windstream for example. Cuz Windstream views us as a competitor. So where you're being refused access for competitive reasons where the prices are higher as they are, for example, in New Hampshire, because they only have one provider up there who took government money there, you should spend some money on Middle Mile. But, but the reason you'll get a lot of Middle Mile applications right now <laugh> is because the bead program, the only thing they're gonna have to be moving is, is the Middle Mile program.


That 42 and a half billion, it's stuck behind this slow moving train that has to do with the mapping of unserved and underserved locations in the country. And that train that that's not pulling into the station for another year. Yeah. People will chase the money just because that's the only programs available. The freeing up the bead program, there's a way to do it. I haven't heard a single useful word out of N T I A about how they could get things going. There is a need to change direction and I I I don't see it happening. The direction we're going on is the bulk of the money appropriated last November. The bulk of that money is still a year away. And, and, and there's, there's no reason for

Christopher Mitchell (28:06):

It. Well I think the beginning of that money is the year away. The bulk of the money must be two or three years away if you're gonna use to term the bulk.

Jon Chambers (28:12):

I I mean the bulk, the 42 and a half billion of the 60 billion or so. That was part of the

Christopher Mitchell (28:16):

Right, no, that's, that's what I'm saying. I mean like I think in a year we might see the beginning of that 20% amount. Right?

Jon Chambers (28:22):

Exactly right.

Christopher Mitchell (28:23):


Jon Chambers (28:24):

We are we are a year away from the beginning. That is from the states getting their application turning get, getting their, their allocation after which they have to make their application. They have to get their applications approved. They have to start their state programs, which often takes six months to a year then to operate. We are two years away from any money flowing. That would be not my best guess. I'd be willing to bet money on it. You won't see money flowing to end user applicants. Those that are building networks for two more years unless we change course. Now this isn't hard to figure out. Like the one thing that we have on our side as a country policy makers looking at this is we got decades of history to point to. You can see what works and what doesn't work. This doesn't require for any more experimentation.


It's pretty clear. And what's also clear is that the, the location fabric, the, the overlay of the location fabric, which is self-reported advertised speed availability data from ISPs, that challenge process, which for the first time is gonna be challenges to locations, challenges both as to the physical attribute is something there, is there a structure there or isn't there something there and to the speed reported by an I S P of all different types and reported in a combination of shape files and and and C S V lists, which will list the location fabric data, all with a new articulation of how, how speeds are to be calculated. Distant calcula distance calculations between d slams and end users propagation characteristics of of the spectrum of for the fixed wireless guys calculations of distance for the hfc, the fiber coax systems, cable systems, all of that is gonna be something brand new run through the mill. And then they're gonna be challenges to that. Challenges that will number in the millions and possibly in the tens of millions, which must be adjudicated by a handful of individuals at a regulatory agency, one by one Perhaps that's why we're years away.

Christopher Mitchell (30:55):

Yes. And one of the things that I find frustrating and I don't fully understand this yet, but is that I don't understand how we're putting all this money into developing that location fabric. You have access to it because you're an is p but I don't, because I'm a non-profit organization. Like this is super secret and you know, I look at the work that Free Press had done in identifying a lot of the problems with rdo. It's not clearly they'd be able to do that with this new location fabric cuz they're not supposed to see it because it's a big secret unless you're an isp, I guess, and I don't, I don't understand the value or the why we would allow this to be a big secret in terms of what that fabric is.

Jon Chambers (31:37):

Well that's right. We compared it with wit what we won an art off and you know, we've won more money than any company in the country. So we have a lot of data. You

Christopher Mitchell (31:47):

Mean as dispersed or you mean an aggregate?

Jon Chambers (31:50):

Wow. As <laugh> as dispersed. So we had a lot of locations that we looked at, the free press data was crap, but it was taken up by the current F C C for political reasons. Wanted to show that the last FCC had made mistakes, the anecdotal evidence that there were, you know, parking lots or international airports. And I said you had to look at the specific data and I we could have shown you where it was right and where it was wrong. But what you're talking about now, yeah. Do you have access to the, to the fabric? You do not. we do. We've looked at it. We've compared it with where we're building. Look, I think the guys at cost quests are, are brilliant. I've known 'em for years. They do really good work. I told them as recently as today that they have taken on an impossible task. I've taken on difficult tasks in my life, but I, like, I I, you know, I try to stay away from impossible.

Christopher Mitchell (32:50):

That's wise.

Jon Chambers (32:51):

I don't mind thing. So let

Christopher Mitchell (32:52):

Me, lemme just change the

Jon Chambers (32:53):

Subject. People don't think

Christopher Mitchell (32:54):

Is possible. So, so let's

Jon Chambers (32:56):

impossible. No, and I, what they're trying to do,

Christopher Mitchell (32:58):

I agree with you. I feel like when you and I have talked before, the ideal situation is one in which we have a public fabric that is transparent that actually has estimated costs to connect as part of it that states could use, that others could challenge. That is the ideal. And I'm not blaming CostQuest for this. Like I feel like this is a failure of the fcc. It doesn't seem like we're heading in that direction and I feel like we're heading less in that direction than I thought we were

Jon Chambers (33:26):

Comparing the data fabric, the location, fabric of serviceable locations. It shouldn't surprise anyone that there are lots and lots of errors because you'd missed things the first time through the, you're trying to, here's, here's what they're trying to do. Identify broadband, serviceable locations for every single location in the country, whatever that number really is. 130, 140 million things, structures and having to make decisions that are on an individual basis as to whether, well, is this a serviceable location or not? Sometimes looking at imagery, you can, there's a great eye would commend to anybody listening to an interview with Jim Stegman, the, the president, C e o of CostQuest that he gave to light reading, I think. And he describes what they have to do in order to identify, sometimes they're looking at satellite imagery, sometimes they're gonna get it wrong because anybody would, it's a, a good faith effort that they're undertaking and over the course of several years, they likely will have a, a really good dataset.


But on the policy part N T I A is interpreting misinterpreting, I would say the mandate by Congress to wait for the publication of the Full Data Act maps by the FCC before they can do an allocation. I agree with you. I say misinterpreting because there's no need for that. There's no need even reading the statutory language. You don't need to know the specific identity of every single location in the country that could take broadband before you can come up with an allocation that's just a formula based on a ratio of A to B, a being unserved in your state, b being unserved in the nation. That's it. That's all you have to do to come up with an allocation. Yep. It's simple algebraic, you could do lots and lots of things that will come up with answers that are within a couple of percent of the other answers that are close to the number of locations.


And you don't have to have the exact number before you begin a allocating money or approving plans to spend money cuz you're not gonna spend all the money in the first year or the first two years of the first three years. Therefore you really do have two or three years to get the location fabric right and start approving plans and spending the money without the risk that you got the exact number wrong. Cuz you can true up the number in two or three or four years, right? When you need to spend the remaining five or 10% of the money,

Christopher Mitchell (36:11):

You know that everyone is getting more than a hundred million. So you can start there.

Jon Chambers (36:17):

Absolutely. You could start with a hundred million or a state like Texas, you know, Texas is gonna get several billion. You could start in, you could start with 50% of the calculated amount for everybody and not worry about missing it. Yes.

Christopher Mitchell (36:32):


Jon Chambers (36:33):

You don't have to worry that, oh, I I was off by 3% because I used what I used census blocks instead of specific locations because I used, you know, rooftops because I used, there's lots and lots of things you could use that would get you a close enough population and you could use lots of things. You don't have to wait for the maps and yet they choose to wait for the maps. This is a choice. This isn't statutory on how to read statutes. These used to write statutes for a living. So that cost quest so that guys that cost quest can get the maps correct because we looking at this in years to come have a lot at stake at getting this right. I know there are other consultants that write maps for states, but those state maps are not better than this cost quests data and, and FCC data collection.


They're not better. We, I, we have access to this kind of data. In fact, our data is g i s data of electric meter locations for the co-ops we work at and we have data for on about 20% of the geography of the country. We have lots and lots of data. It's not just sta statistically significant. It's, it's like uber accurate. It's the best data you could possibly have. And we have compared that data with everybody else's maps. And when I say it's, it's like super accurate, really key data. What I mean is we design networks off of the g i s data that electric co-ops have as to the meter, locations, poles, the spans we design, we design two electric meters. And so to, in my world, a broadband serviceable location, that's the term used in the act B S L A, broadband serviceable location is most often an electric meter.


The spot, exact spot of an electric meter. Why? Because we design a fiber network to reach electric meters. Anything that has power, access to electricity, access to power, likely will take fiber. That's our experience in working in this field for a long, long time. So if I look at my data, my my client's data, I see stuff that would inform true accuracy in a mapping project as the underlying layer. And I think we could get there over that is with the fccs mapping process over the course of the next couple of years, I don't think we get there by September 1st, the data in which all of this data is supposed to be submitted to the fcc, we could separate out the rush to get the data true and accurate from the allocation that N T I A has to make. So the states can start getting some money to solve their broadband problems.


We can then better inform CostQuest and the data collection process. And all of this is getting to a point before you get to the speeds that are reported by ISPs as to whether something is served or unserved. But you can do all that work first. The thing that's driving the mistake is the interpretation of the act that, that that folks need the maps to be made public before N T I A can take out its little calculator and figure out how much the state of New Hampshire, the state of, of Texas or the state of Oregon should get. We've published our calculation, our calculation, I will tell you we published a year ago. It's going to be within 10%, certainly probably be within 5% of the final number. And as I keep saying, you don't need to be that accurate if all you are going to allocate initially is the first 25 to 50%.

Christopher Mitchell (40:45):

I agree with, with that. I will say that I wonder if I'm sitting back if N T I A did all that, if it would make that much of a difference because I don't know how many states are actually ready. Like some states will be ready right. To start taking in this money. But a number of the states need this time anyway to get their act together.

Jon Chambers (41:05):

Not where I work. Yeah. I have a home in Colorado. I was talking to the head of the, the new head of the broadband office there some months back. She said she had been told that they should expect an allocation of between two and 500 million. That's a big range. And, and she was engaged in a planning effort that is writing their broadband plan based on what she's being told their allocation might be. Their allocation's gonna be like 1.2 billion. You come up with a different plan if you think your allocation is 1.2 billion than if you think your allocation is 200 billion, you'll come up with a different plan, right? Sure, sure. So I, I hear this all the time. It by state broadband offices, they are writing plans, but they should know how much money to expect. Does it help even to tell people here's that how much money you could expect?


Give or take some percentage. Absolutely. It helps 'em in the planning process as far as whether they're ready to spend money. Georgia just just committed 400 million through one of the ARPA plans. Louisiana just announced 130 something million. They're all spending money, man. So whether they're ready or not, people are looking for action and some of the states are already moving forward. So you ought to know what your budget is gonna be in order to come up with a plan and come up with something logical. And, and yeah, there are states that are ready and, and the ones that aren't ready, the state of New Hampshire has a 50 million R F P out for, for that second phase of the ARPA money. What are you gonna do a year from now if you're still waiting for that other money? This is something that N T I A has, this is a failure on their part.


Just the first of many so far. And it makes a real difference if you're planning say a five to 10 year plan that you know what you're working with. This is all of the money that's going to be spent in the next decade. This is it. I agree with you that there's a lot more than just telling people how much money there are other things that N T I A should be doing to facilitate state broadband plans rather than layering on additional obligations. There are other things they could be doing to make the the rules clear and clean to provide support. Cuz this, this to me is the biggest problem. States will have and N T I A could help. Most state broadband offices I visit with, they have a handful of people there in the office. I mean, that's it. Their office is staffed with two or four people.


They don't have a thousand engineers. You have to design a spending plan with somewhere between a hundred million and two 3 billion depending on the size of your state. You have to design it with the resources that you have to implement it. Not for purposes of design of the plan, but for purpose, purpose of, of reviewing applications and implementing the plan. And when you only have a couple, few people <laugh> you, you better figure out a way that you can review the billions of dollars worth of applications that come through the door in a way that lets you with some confidence, spend the public's money right. On what will solve the problem. What N T I A could be doing is providing not just examples of places where this has worked, but tools they could use, whether it's software tools, review tools, methods that they've found that work better than others. And I mean, that's the key to all of this because when you, when you do finally get to the point where you're allocating the funding based on the broadband plan, that's when you get this rush of applications for money, for pent up demand for funding. And biggest shortcoming I've seen in state offices is they don't have the resource. Right. And you wouldn't expect them to have the resources for, for this sort of thing. And N T I A could be helping with that, but they're not giving them the tools.

Christopher Mitchell (45:28):

Well, Jon, we're running out of time. This is what always happens. We never run out of topics. We only run out of time <laugh>. So I don't like cutting it off there. but we are going to, and I really wanna thank you for your time today. Thank you for your work doing all this.

Jon Chambers (45:44):

Cool. Thanks Christopher. Good to talk to you as always.

Ry (45:47):

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