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Mike Conlow: There Really Is Enough Money to Reach Most of the Unserved and Underserved

Estimating how far the money will go does not require advanced math.

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The author of this Expert Opinion is Mike Conlow, a longtime broadband data and Internet policy analyst.

Last week a wireless company published a study about the cost to reach all the Unserved and Underserved. They estimated we need $307 billion to reach everyone. Similar reports have come out before. Generally they make a case that BEAD will run out of money, so the federal government should settle — for wireless technology, or FCC subsidy programs outside the scope of BEAD.

Like previous versions, this one too doesn’t represent the real situation. We have almost enough money to reach all the Unserved and Underserved, except for states that are particularly high cost.

Estimating how far the money will go does not require advanced math. We need an average cost to reach a location, and the total number of locations. There are 12.8 million Unserved and Underserved locations nationally. Instead of using the FCC data, the wireless study estimates this number from Census data, then adds 10% assuming growth from challenges to arrive at 16 million locations. That’s one difference.

The study breaks down these locations by the density of their Census tract. That’s a reasonable approach. Density is the primary driver of cost to serve a location, and is a decent proxy for other important things like terrain. When we break down the 12.8 million location Digital Divide by density, the peak is between 20-50 housing units per square mile. There are 2.7 million locations in that density range. There are about 1.5 million locations each in the least dense bucket 0-5 housing units/sq mile and the bucket between 5-10 hu/sq mi.

Now turning to the price per location at each of these intervals. I use the reserve prices from the RDOF reverse auction to estimate cost per location served by fiber. The reserve prices are not the winning bid from the RDOF auction. Instead, they are the price below which the FCC was willing to fund a project. If you add up all the RDOF reserve prices, it was $26.5 billion for 5.3 million eligible locations, or $5,000 per location. These prices are very clearly derived from the FCC’s cost model (built by CostQuest) and may be the cost model itself. Regardless, they certainly order locations correctly — more rural locations have a higher reserve price than urban locations.

As I’ve done previously, here I’m inflating the RDOF reserve price by 25% to capture changes since the RDOF auction like inflation, supply chain issues, and other things. When you plot these prices against the density of the Census block groups they cover, you see the expected hockey stick-like increase in cost. At less than 5 housing units per sq. mile the cost per location is $13,243 per location. It drops quickly: between 5-10 hu/sq mi the cost is $9,154, and when it reaches the mode at 20-50 hu/sq mi the cost is $6,015. In the most dense areas, the cost per location is $1,150. The overall average is $5,266 per location.

(As an aside, there are 373,000 BDC Unserved and Underserved locations in Census block groups with zero density. How does that happen? The Census counts housing units, not businesses. A Census block that is entirely businesses has 0 housing units and thus 0 density according to this metric using Census data. )

If you add up all these costs — the number of locations in each group times its average cost — you get $64.5 billion to reach all of them with fiber. That number includes the private capital match of at least 25%. The tab to BEAD alone is $50.6 billion. Remember also that this rough estimate doesn’t factor in the significant RDOF commitment to fund locations, nor ARPA, nor some locations which will be Extremely High Cost and therefor they won’t get fiber. Even if you inflate the RDOF cost by 50% it only brings the total to $81 billion, without any deductions for RDOF, private capital match, etc. I see no way to get $307 billion as this study did.

Below is the summary of how the wireless study reaches the conclusion about needing $307 billion in investment. The distribution of locations by density is not all that different. They have 6 million locations below 20 housing units/sq mile. I have 4.9 million. However, according to the BDC data there are over 1 million locations in blocks with density above 750 hu/sq mi which have a very low cost and is not reflected in this study.

Probably the biggest difference is the cost per location applied to that lowest density group. They appear to give a cost of $18,100 for every location under 20 hu/sq mi. I don’t disagree that the cost curve bends upwards for the lowest density areas, but I think the bend starts happening at 10 housing units / sq mile or even lower. There probably are locations that cost $18,000 to reach them, but it isn’t fair to apply that average across every location below 20 hu/sq mile. I can’t replicate how they get $191 billion to serve that lowest density group. Six million locations times $18,100 per location is $108.6 billion, not $191. That’s a big difference. Maybe there’s some methodological aspect I’m not following.

About the same time that this study was published, Cost Quest put up a blog post about cost curves. Using a state which they don’t name, they provide a cost curve chart by percentile for Unserved locations. The average cost per location in this state is $5,589, in line with the estimates I use for average cost per location nationally. Their cost curve starts to increase significantly for the last 10% most expensive locations in the state. It really hockey sticks for the hardest to reach 5% of locations.

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If we apply this logic to the national distribution of Unserved and Underserved locations by density, it means costs start to rise for least dense 10% of locations — 1.3 million locations. And really hockey sticks for the last 650,000 locations. While it is interesting to consider these locations, no state is going to try to build fiber to them. NTIA created the Extremely High Cost Location threshold for exactly this purpose. According to NTIA, the EHCL threshold is a price above which a state “may decline to select a proposal if the use of an alternative technology meeting the BEAD Program’s technical requirements would be less expensive.” How high the cost curve reaches doesn’t matter. They’ll be EHCLs and won’t get fiber.

Implicit in my contention that there’s [almost] enough money to reach all the Underserved and Unserved nationally is that BEAD grants are awarded competitively and close to the true cost to serve the location. Consider the example Cost Quest state above. They have a statewide average of $5,589 per location. But about 62% of locations are below that average. Some of these locations are on the “network edge” — an ISP provides service on the block, or next door. Some of them are dense towns served by DSL now. It is critical that this state generates competition for these areas and finds a proposal close to the true cost to serve the location. If they fund all these locations at the statewide average of $5,589 they could waste $2,000 or more per location.

We know private capital is willing to bring most of the capital for these low-cost locations because that’s exactly what happened in RDOF. Private capital brought more than 90% of the necessary funding in 20% of the locations that were won by providers planning to offer gigabit service. As a reminder, these location were unserved and relatively high cost. If private capital can bring most of the funding during RDOF, let’s find a way to bring the same level of private capital to state-administered grant programs.

There’s an important practical takeaway from all this: a public cost curve for every state is critical. States need it to set a reasonable Extremely High Cost Location threshold. But more importantly, states and the public need it to evaluate grant proposals. If states don’t have the cost curve data and the ability to run a grant program that optimizes on it, BEAD will run out of funding for sure, and it doesn’t matter whose numbers we use for estimation now.

Takeaways:

  • NTIA should procure a national cost model that represents the unique contours of every state.
  • NTIA should give that cost model to every state, and make it public.
  • NTIA should provide guidance to states on how to set the Extremely High Cost Location threshold based on their individual cost curve.
  • NTIA should provide guidance, and only accept plans from states, that encourage competition between ISPs, and that fund locations based on the underlying costs to reach those locations.

Mike Conlow is a longtime broadband data and Internet policy analyst. Prior to being involved in Internet policy he was in political technology, and was on both of President Obama’s campaigns, in 2012 as the Deputy CTO. This piece was originally published on Mike Conlow’s substack on April 25, 2023, and is reprinted with permission.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

Broadband Breakfast is a decade-old news organization based in Washington that is building a community of interest around broadband policy and internet technology, with a particular focus on better broadband infrastructure, the politics of privacy and the regulation of social media. Learn more about Broadband Breakfast.

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Bruce Kushnick: Look Overseas, America’s Prices for Broadband are Out of Control

America’s prices are 5–10 times higher than comparable data from other countries.

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The author of this Expert Opinion is Bruce Kushnick, New Networks Institute Executive Director.

This chart, taken from the European Union Report on Broadband, shows that a triple play — phone, cable TV, broadband-Internet, can cost about 36 Euros for a service with 30–100 Mbps speeds, and 21 Euros for a stand alone service.

The average U.S. triple play is about $220.00 a month, and with an exchange rate of 1 Euro=$1.09 Dollars, the overcharging, which we documented, is $150+ a month — or more.

The Digital Divide was created, in large part, because prices are unaffordable, and America is now paying for over 20 million low-income families to have broadband — up to $30. a month allowance.

America’s prices are out of control, yet where are the investigations and audits to explain how overseas prices are a fraction of what we are paying in the U.S.? And why are we giving billions to the companies that helped to create the Digital Divide in the first place?

We assembled our previous research with new findings in this new series, using both 3rd party expert analysis as well as actual examples from December 2023, comparing and detailing the out of control US prices vs the services of free Telecom in France and Spectrum-Charter in New York City.

America’s broken promises and the state 5-year broken broadband plans

America’s prices for broadband have made high speed internet unaffordable for many households, Moreover, the pandemic revealed a major Digital Divide where whole areas of the U.S. were never upgraded to fiber optic networks, much less high speed services even over the copper wires. Thus, no competition to lower rates.

And every state now has plans to ‘bridge the Digital Divide’, but in all of the state broadband plans, none have addressed how the Divide started in their state or about the massive financial price divide between America and the EU or Asian countries that charge a fraction of the prices charged in the US.

Over $150 billion is being given out in state and federal government subsidies over the next few years, and much of It going to the companies that helped to create the Digital Divide.

The states must investigate the core issues as they impact almost every FCC, NTIA, FTC, Congressional and state current and future actions.

The opening chart tells the tale of how the European countries did not allow for massive multiple additional made up fees, such as the Broadcast-Sports fee ($27.90 on a Spectrum Triple Play). Moreover, the services do not charge ridiculous prices for equipment, such as set top box, that is required to use the service. Also, because there is competition, customers have choices and prices have not skyrocketed, but are actually going down.

America’s prices are 5–10 times higher than comparable data from other countries

How can America’s prices for the stand-alone, double and triple play — (phone, cable TV and ISP-broadband) be 5–10 times more when comparing data from other countries, as highlighted in the European Union Commission’s report, published July 2022 for the year 2021. And, as the report details, even basic stand-alone high speed broadband prices overseas are a fraction of what we’re paying in the U.S.

  • America’s “Double play” — high speed broadband and phone service — is being overcharged, on average, almost $75 a month — a whopping $900 a year.
  • The “Triple play” is being overcharged by $180 a month on average; this comes to overcharged, over $2,200 for the triple play.

The current triple play in America, after the promotional prices end, is now around $220.00 a month, yet overseas, the average was around $40 a month, but the prices overseas are in decline. However, in some countries, it can be as low as $23.00 for 200 Mbps or more; only $15 for the double play.

According to the EU report, we’ve even been beaten out by Bulgaria, Romania and let’s not forget Slovakia:

  • “Overall, Lithuania and Romania have the most attractive prices for broadband internet in the EU. All the offers in these countries belong to the cluster of the least expensive countries in their respective baskets. Bulgaria, Latvia and Slovakia follow. Poland, Hungary, France and Spain have low prices especially for Triple Play.”

But when the EU report says prices are “attractive”, we are talking $10–12 bucks a month for stand-alone broadband and $20–23 for the triple play, with speed of 200 Mbps or more.

By the way, Bulgaria does get Netflix and their Top 10 shows are close to America’s viewing.

How is it possible that America’s Triple Play is $150-$200 a month over what is being charged overseas? That’s over $2,200.00 a year ‘extra’ being charged to families — including low-income families and fixed income seniors. This is on top of the fact that there could be only one or no providers of high-speed services in the rural regions or in low-income neighborhoods of cities.

It would be one thing if it was a small differential between the overseas EU group and others price of service, but this is a difference that is too large to be ignored.

What are the underlying issues?

No Serious Competition to keep market forces and rate increases at bay. First, AT&T et al. failed to show up with high-speed competition to keep the cable companies, the other group of providers that use a wired connection, in check. For example, in CA, AT&T-Pac Bell had obligations to bring fiber optic broadband throughout the state and our maps showed that much of AT&T’s entire Los Angeles county region had been left to deteriorate and not upgraded as promised with fiber optic infrastructure.

Made-up Fees and surcharges are out of control. One of the sleaziest practices in the US has become the addition of made-up taxes, fees and surcharges that are not mandated or government sanctioned. This is being done so that the companies can quote a price that is missing 20–40% of the total costs,

Made-Up Taxes include:

  • Broadcast and Sports surcharge: $15–24.00 a month
  • Cost Recovery Fee: $1.99–2.99
  • Admin Fees: $1.49-$2.99 per month
  • Pass-through taxes, Gross receipts tax, telecom taxes

The largest and most egregious added fee is now the Sports and Broadcast surcharge, which is really 2 separate charges that have been merged in many cases:

Made-up, Broadcast-Sports Fees Up 820%; Overcharging $250+ a Year — then Quintuple-Taxed, Fee’d and Surcharged.” This article was written in December 2021, and along the way there have been increases bringing the total charge on the Spectrum NY June 2022 bill to $23.70 a month. This one fee on the Spectrum NY Triple play bill is more than the entire charges for a triple play in many overseas EU countries.

This charge went up to $27.90 a month extra in 2023. That is an overall increase of 1,140%.

  • Quadruple Taxed, Fee’d and Surcharged. — If the increases to this one fee is not enough, there are made-up taxes, fees and surcharges being applied to this fee as it is considered ‘revenue’ to the company and is taxed as such. And some of these surcharges are actually tax pass-throughs where the company gets to have the customer pay the company’s taxes.
  • It is impossible to calculate the exact tax assessment as there is no ‘Rosetta Stone’ to be able to unravel how each tax, fee and surcharge is applied.

But, considering that basic telecom taxes can be 12–20% depending on the city and state, if a 15% tax is applied, that would add an additional $3.55 more per month.

  • Not included in the advertised price: To add irony to obfuscation, this fee is never included in the advertised rates, nor is it added completely in the promotional price, making the increases after the promotion even more egregious.
  • Not included in the EU statistics for the U.S. Triple Play: Ironically, the EU informed us that they do not include the extra charges and fees in the US because — well, the other countries only have a VAT (Value Added Tax), and not the made-up fees.
  • No Oversight, No Audits; Regulators Failed U.S.: The idea that a state-franchised cable service or the Holding Companies that control the state telecommunications public utility can just make up fees and add them to bills with no one asking for a cost analysis or some other justification to raise this make-believe charge, should have the peanut gallery screaming.
  • Public has Amnesia: No one knows who these local telecom companies are or what they’ve been able to get away with. And virtually no one could answer basic questions about who the companies are or the services they offer.
  • Let’s give government subsidies to keep America in a perpetual state of “Please Sir May I have another?” Currently there are subsidies being given to low-income families to go online, which are then handed over to the same companies that have caused this Divide in the first place; i.e.; a new flavor of Corporate Welfare. We will address these issues in an upcoming story.

The telecom holding companies that control the critical infrastructure wires, towers and antennas created the Digital Divide. They also control the pricing of all services, wireline, wireless, broadband, internet and even cable, and as we will discuss, they also were able to manipulate the accounting formulas to have the state telecom utility act as a cash machine to fund, illegally, the other lines of business.

America must go after these cooked books and must clean up the mess. There is plenty of money to get America upgraded, and it must be seen as the first step in LA County to clean up the mess and decades of public policy and regulatory issues.

Government subsidies, both state and federal, to companies who have created the Digital Divide and can control the prices and profits over the public utility wires needs immediate investigations — not more gifts of largesse.

Bruce Kushnick is Executive Director of New Networks Institute and a founding member of the Irregulators. He has been a telecom analyst for 40 years, and playing the piano for 65 years. A version of this piece originally appeared on Medium on January 9, 2024, and is reprinted with permission.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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Broadband Measurement Summit Announced for March 7

With state broadband challenges underway, Broadband Measurement Summit brings BEAD into dialogue with FCC nutrition labels.

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WASHINGTON, January 9, 2024 – Broadband Breakfast is pleased to announce the Broadband Measurement Summit on Thursday, March 7, in Washington, D.C.

This new one-day event will run from 8:30 a.m. to 3:30 p.m. and brings together the top stakeholders in understanding broadband speeds, prices, availability, reliability and competition. The Summit is in-person, but with a webcast component.

The Early Bird price of $195 available until Friday, February 9, 2024. Existing Breakfast Club Members take an additional $100 off the in-person event.

Sign up for the Broadband Measurement Summit, and visit the event page for updated information about panelists, keynotes and sponsors.

PANEL 1: THE CHALLENGE PROCESS FOR STATE BROADBAND OFFICES

Many state broadband offices are about to begin their broadband mapping challenges under the Broadband Equity, Access and Deployment grant program. This is a process for states to verify locations that are unserved (i.e., they lack access to 25 Megabits per second (Mbps) * 3 Mbps broadband), and locations that are underserved (i.e., they lack access to 100 Mbps * 20 Mbps broadband). A few advanced states have already begun, or have already completed the process. What have they learned? What “challenges” are they facing? What’s next for broadband mapping?

PANEL 2: THE VALUE OF MAPPING ASSETS BEYOND BEAD

Besides current broadband challenges, what geospatial, demographic, and operational information is important for BEAD implementation? In particular, what geospatial information do investors and operators of broadband networks need to better deploy broadband? This session will consider why mapping assets is valuable well beyond the BEAD program.

PANEL 3: THE FCC’S BROADBAND NUTRITION LABELS

As if the National Telecommunications and Information Administration’s BEAD program wasn’t enough, the Broadband Measurement Summit will consider the current status of the Federal Communications Commission’s broadband “nutrition” labels. By April 10, 2024, larger ISPs must display these new Broadband Consumer Labels at the point of sale. They must use clear, easy-to-understand, and accurate information about the cost and performance of broadband services. Internet service providers with 100,000 or fewer subscriber lines must do so by October 10, 2024. How is the FCC’s nutrition labels process going?

PANEL 4: MEASURING AND TRACKING BROADBAND PRICING

The Biden Administration’s “Internet for All” program emphasizes the important role of affordable broadband. That’s one reason that the Affordable Connectivity Program has loomed so large in discussions of America’s broadband buildout. What does the evidence show about the price of broadband in the United States versus other Western nations? How does it vary by location? As part of the more detailed and granular broadband mapping and data now being collected, is broadband pricing data being left out?

SPONSORED BY

BroadbandNow is a data aggregation company helping millions of consumers find and compare local internet options. BroadbandNow’s database of providers, the largest in the U.S., delivers the highest-value guides consisting of comprehensive plans, prices and ratings for thousands of internet service providers. BroadbandNow relentlessly collects and analyzes internet providers’ coverage and availability to provide the most accurate zip code search for consumers.

Broadband Measurement Summit Program

 


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NTIA Endorses FCC’s Proposed Increase of Broadband Speed Benchmark

The FCC sought comment on upping the definition to 100 * 20 Mbps.

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Graphic by Richard Patterson.

WASHINGTON, January 3, 2024 – The National Telecommunications and Information Administration is backing the Federal Communications Commission’s proposal to alter the definition of broadband to increase the speed benchmark. 

The current definition, set in 2015, requires a speed of 25 Megabits per second download and 3 Mbps upload for internet service to be considered broadband, or high-speed internet. The commission sought comment in November on a proposal to increase that threshold to 100 * 20 Mbps, in addition to using more data sources in its assessment of broadband availability in the U.S.

NTIA officials met with commission staff on December 21 to express support for the move, according to an ex parte letter the agency filed last week. 

“We support the Commission’s proposal to raise the speed threshold for fixed broadband to 100 Mbps downstream and 20 Mbps upstream,” the agency wrote, saying a higher benchmark would better reflect user needs and bring the standard in line with the Infrastructure Act’s Broadband Equity, Access and Deployment program, which the NTIA is tasked with managing.

That $42.5-billion broadband expansion effort already has a 100 * 20 Mbps benchmark, meaning infrastructure funded by the program will be required to provide at least that speed, and areas currently receiving slower internet will be eligible to be served with BEAD funded infrastructure. Homes and businesses receiving less than the current FCC benchmark of 25 * 3 Mbps are given special priority.

The commission is required by section 706 of the Telecommunications Act of 1996 to conduct annual assessments of the “availability of advanced telecommunications capability to all Americans.” In the same November notice of inquiry, the FCC proposed adding a number of new data points to that assessment, including latency, affordability, adoption, and equitable access among minority groups. That will partly be facilitated by the commission’s new Broadband Data Collection database, which has more precise information from internet providers.

The NTIA endorsed all of that as well, writing: “The Section 706 inquiry has the potential to serve as an important indicator of our nation’s progress toward achieving digital equity, and it will be best equipped to do so if it examines the available data on a wide range of challenges in this field.”

The agency added that it is working on a project with the Census Bureau to estimate broadband adoption in small geographic areas.

Industry response

In comments to the commission, broadband industry groups expressed broad support for the 100 * 20 Mbps benchmark, but some disagreed on the commission’s proposed long-term goal of 1 Gbps * 500 Mbps – something the NTIA did not touch on.

CTIA, a trade group representing wireless providers, wrote that while the commission noted some situations in which users require more than 100 * 20 Mbps, “none of these justifies a fixed broadband benchmark above 100 * 20 Mbps, even as a long-term goal.” That’s a view shared by WISPA, an association of wireless broadband providers.

NTCA, which represents small and rural broadband providers, advocated for an even higher long-term goal, but did not specify an exact number. Trade group INCOMPAS pushed for setting the download benchmark to 1 Gbps now, rather than in the future.

USTelecom, another broadband industry group, said the long-term 1 Gbps * 500 Mbps goal would be impractical, as the only technology capable of providing those speeds is fiber-optic cable.

“There are locations where deployment of fiber is not practical now and may never be,” the group wrote in comments to the Commission.

CTIA also opposed adding non-deployment metrics like adoption and affordability to the 706 inquiry, arguing that reporting requirements for existing Universal Service Fund programs are a better venue for assessing them.

This story was updated to reflect the current definition of broadband, 25 * 3 Mbps.

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