Gavel with money behind it

C-Band Auction Results

The FCC’s C-Band Auction closed in January, but the full results weren’t released until earlier today. Here’s how I described the auction in a previous post:

In the C band auction, about 280 megahertz of spectrum in the 3.7-3.98GHz range was reallocated to cellular companies. Spectrum in this frequency range is particularly appealing to operators of cellular networks. The spectrum offers great characteristics, combining a potential for covering large areas with a potential for delivering fast speeds.

The C-Band Auction had fifty-seven qualified bidders. Twenty-one of the bidders won at least one spectrum license. Here’s a breakdown of the winners (note that Cellco Partnership is Verizon and Little Bear Wireless is Dish):

Bidder Gross Winning BidsLicenses Won
Cellco Partnership$45,454,843,197 3,511
AT&T Spectrum Frontiers LLC$23,406,860,839 1,621
T-Mobile License LLC$9,336,125,147 142
United States Cellular Corporation$1,282,641,542 254
NewLevel II, L.P.$1,277,395,688 10
Canopy Spectrum, LLC$197,021,760 84
Widespread Wireless, LLC$64,606,668 14
Cellular South Licenses, LLC$49,850,284 8
Pioneer Telephone Cooperative, Inc.$23,652,000 4
Carolina West Wireless, Inc.$18,565,480 7
Nex-Tech Wireless, L.L.C.$12,164,043 5
East Kentucky Network, LLC$8,675,753 1
Horry Telephone Cooperative, Inc.$7,638,336 3
Smith Bagley, Inc.$6,635,510 4
Nsight Spectrum, LLC$5,424,123 3
Agri-Valley Communications, Inc.$4,915,460 2
LICT Wireless Broadband Company, LLC$4,267,485 5
Union Telephone Company$3,123,600 2
Little Bear Wireless L.L.C.$2,510,020 1
Grand River Communications, Inc.$1,590,200 2
Granite Wireless LLC$170,510 1

Verizon spent a bit more than some analysts expected. Interestingly, Dish barely spent anything. While Comcast and Charter registered to participate jointly as C&C Wireless Holding Company, they did not win any licenses.

The full results can be explored in the FCC’s Public Reporting System.

FCC Politics & Media Bias

I’m a big believer in a free and open internet. I’m also wary of unchecked corporatism. Yesterday, many people who share my views were rejoicing as Ajit Pai, the FCC Chairman, stepped down. As Pai left his role, journalists published a bunch of hit pieces about Pai and the last several years of the FCC’s work. Despite having plenty of sympathies with the journalists, I was rubbed the wrong way.

Vice’s article was emblematic of what bothered me. The article’s title started with: “Gigantic Asshole Ajit Pai Is Officially Gone.” Vice went on to give a long list of everything it could construe as a failure of Pai’s FCC term. Not an ounce of effort was put into expressing anything positive.

I would love to see journalists shedding more light on the FCC’s actions. However, I’m concerned with how popular media outlets’ coverage of the FCC gets mixed up with broader political conflicts. We should keep what happened yesterday in mind if the same media outlets that published hit pieces yesterday are only willing to say positive things about the Biden-era FCC and the next FCC chairperson.

If you have suggestions for where to turn for nuanced commentary on the FCC, please chime in with a comment!

Spectrum Is Expensive

The FCC’s C band auction recently closed with a total of about 81 billion dollars in bids. This was by far the highest-grossing spectrum auction in U.S. history. Previously, the largest auction garnered about 45 billion dollars.1

In the C band auction, about 280 megahertz of spectrum in the 3.7-3.98GHz range was reallocated to cellular companies. Spectrum in this frequency range is particularly appealing to operators of cellular networks. The spectrum offers great characteristics, combining a potential for covering large areas with a potential for delivering fast speeds.

The amount of money committed in the recent auction drives home a point that I think most casual observers miss: spectrum is an enormous expense for cellular networks in the U.S. With the auction closing at about 81 billion dollars, U.S. networks are spending over $250 per person in the United States in a single auction.2

Farmer with tablet

Rural Digital Opportunity Fund (RDOF) Phase 1 Results

Today, the FCC announced the winners of the Rural Digital Opportunity Fund Phase 1 auction. In this reverse auction, the FCC had up to 16 billion dollars in funds available for compensating companies building out broadband networks in underserved areas.

The excerpt below comes from the FCC’s press release:

Auction results released today show that bidders won funding to deploy high-speed broadband to over 5.2 million unserved homes and businesses, almost 99% of the locations available in the auction. Moreover, 99.7% of these locations will be receiving broadband with speeds of at least 100/20 Mbps, with an overwhelming majority (over 85%) getting gigabit-speed broadband.

While up to 16 billion dollars was available in this phase, only 9.2 billion dollars were allocated. The leftover funds will be added to the pot of money available in the next RDOF phase.

Winning companies in this phase of the auction will have funding awarded over the next ten years (contingent on companies meeting certain milestones).

Results

Below, I share the full list of 180 winners sorted by the funding awarded.1

CompanyAmount
LTD Broadband LLC$1,320,920,718.60
CCO Holdings, LLC (Charter Communications)$1,222,613,870.10
Rural Electric Cooperative Consortium$1,104,395,953.00
Space Exploration Technologies Corp.$885,509,638.40
Windstream Services LLC, Debtor-In-Possession$522,888,779.80
AMG Technology Investment Group LLC$429,228,072.90
Frontier Communications Corporation, DIP$370,900,832.80
Resound Networks, LLC$310,681,608.90
Connect Everyone LLC$268,851,315.90
CenturyLink, Inc.$262,367,614.20
Etheric Communications LLC$248,634,963.10
California Internet, L.P. dba GeoLinks$234,889,665.70
Consortium of AEG and Heron Broadband I$194,378,552.00
NRTC Phase I RDOF Consortium$156,714,678.20
Segnem Egere Consortium$152,854,440.70
NexTier Consortium$126,287,693.30
RDOF USA Consortium$112,044,022.70
Prospero Broadband Consortium$100,366,008.80
Point Broadband Fiber Holding, LLC$78,414,413.10
Mercury Wireless, Inc.$68,310,842.00
Co-op Connections Consortium$61,485,589.50
Consolidated Communications, Inc.$58,873,337.50
Frontier Communications Northwest, LLC$57,202,650.80
Talkie Communications, Inc.$57,065,010.20
Citynet West Virginia, LLC$53,516,858.30
Consortium 2020$48,918,960.90
Computer 5, Inc. d/b/a LocalTel Communications$48,818,171.30
Wilkes Telephone Membership Corporation$46,055,343.40
Bay Springs Telephone Company, Inc.$41,871,850.10
Continental Divide Electric Cooperative$38,004,786.20
Cal.net, Inc.$29,169,982.60
Commnet Wireless, LLC$28,436,936.10
GigaBeam Networks, LLC$28,067,881.20
Cincinnati Bell Inc.$26,887,580.40
Aptitude Internet LLC$24,655,295.20
Armstrong Telephone Company – Northern Division$22,009,640.50
Grain Communications Opportunity Fund II, L.P.$19,172,673.60
Arrowhead Electric Cooperative, Inc.$18,462,273.10
RHMD, LLC$18,303,843.20
Paul Bunyan Rural Telephone Cooperative$16,307,892.10
Direct Communications Rockland, Inc.$15,745,252.70
Connecting Rural America$14,180,599.00
Blackfoot Telephone Cooperative, Inc.$12,703,077.60
Halstad Telephone Company$12,141,118.40
South Arkansas Telephone Company$11,387,245.50
Pine Belt Communications, Inc.$11,126,003.10
Centre WISP Venture Company, LLC$11,086,348.40
Micrologic Inc.$10,036,047.70
Emery Telephone dba Emery Telcom$9,822,853.00
Digital Connections Inc. dba PRODIGI$8,583,001.40
Rural American Broadband Consortium$8,471,858.10
Chariton Valley Communications Corporation$8,070,272.00
Northern Arapaho Tribal Industries$7,799,035.00
Hamilton County Telephone Co-op$7,796,825.30
St. John Telco$7,116,876.00
Cox Communications, Inc.$6,636,520.50
Reedsburg Utility Commission$6,439,594.10
Savage Communications$6,090,479.10
Hawaii Dialogix Telecom LLC$6,009,953.00
Tennessee Cooperative Group Consortium$5,981,516.90
Peoples Telecom, LLC$5,668,121.40
Cherry Capital Connection, LLC$5,620,840.40
Pioneer Wireless, Inc$5,543,142.00
Atlantic Broadband Finance, LLC$5,407,684.70
Hotwire Communications, Ltd$5,150,040.00
Shenandoah Cable Television, LLC$5,059,616.50
Wisper-CABO 904 Consortium$4,974,442.30
Midcontinent Communications$4,960,473.00
Visionary Communications, Inc.$4,450,264.40
DoCoMo Pacific, Inc.$3,706,235.00
Daviess-Martin County Rural Telephone Corporation$3,565,039.40
Rivers High Group$3,540,398.10
Great Plains Consortium$3,427,873.30
Cellular Services LLC.$3,294,968.60
City of Farmington$3,179,884.50
4-Corners Consortium$2,598,030.00
Pine Cellular Phones, Inc.$2,303,742.10
Mediacom Communications Corporation$2,254,655.00
Hankins Information Technology$2,171,844.50
BEK Communications Cooperative$2,157,719.00
TruVista Communications, Inc.$2,059,050.80
Minnesota Connections c/o Consolidated Tel Company$2,040,278.70
Horizon Communications, Inc.$2,033,292.00
Custer Telephone Cooperative, Inc.$1,954,488.00
American Heartland$1,821,520.00
FiberLight, LLC$1,772,705.80
Bandera Electric Cooperative, Inc.$1,689,601.50
LICT Corporation$1,675,826.80
NBVDS Investment, L.L.C.$1,655,443.40
Central Arkansas Telephone Cooperative, Inc.$1,629,930.50
ACT$1,622,136.00
Siuslaw Broadband, LLC dba Hyak Technologies$1,611,684.90
HomeTown Broadband, Inc.$1,424,229.00
Hughes Network Systems, LLC$1,273,784.00
Union Telephone Company$1,264,770.00
Roseau Electric Cooperative, Inc.$1,228,494.00
Safelink Internet LLC$1,197,661.50
Pembroke Telephone Company, Inc.$1,053,063.00
Fond du Lac Communications Inc.$1,046,123.00
Wikstrom Telephone Company$983,637.00
SLIC Network Solutions, Inc.$978,722.00
Altice USA, Inc.$849,880.00
DTC Cable, Inc.$834,597.00
Nova Cablevision, Inc.$785,400.00
Farmers Mutual Telephone Company$759,822.00
Scott County Telephone Cooperative, Inc.$755,841.60
Horry Telephone Cooperative, Inc.$729,554.50
Terral Telephone Company$716,381.20
Worldwide Technologies, Inc.$700,874.20
Somerset Telephone Co., Inc.$669,564.00
AB Indiana LLC$668,304.10
Albion Telephone Company, Inc.$599,795.70
Palmetto Telephone Communications, LLC$570,024.00
Federated Telephone Cooperative$537,399.00
Daktel Communications, LLC$531,894.00
Redzone Wireless, LLC$507,752.00
MEI Telecom, Inc.$479,789.10
Zito West Holding, LLC$457,596.00
Baraga Telephone Company$444,490.80
Lakeland Communications Group, LLC$408,952.00
Heart of the Catskills Comm. Inc., dba MTC Cable$398,574.00
LigTel Communications, Inc.$385,924.00
Citizens Vermont Acquisition Corporation$373,680.00
Allen’s T.V. Cable Service, Inc.$371,348.10
Plains Internet, LLC$345,624.00
Reservation Telephone Cooperative$337,080.00
Miles Communications LLC$316,641.00
Mountain View Telephone Company$298,572.00
RC Technologies$263,796.00
QCOL, Inc.$235,146.00
Socket Telecom, LLC$232,768.80
St Paul Cooperative Telephone Association$190,908.00
Easton Utilities Commission$189,047.60
Newport Utilities$159,492.00
Mountain West Technologies Corporation$141,801.20
One Ring Networks, Inc.$137,715.00
Hamilton Long Distance Company$128,560.30
Bruce Telephone Company, Inc.$113,745.00
Winnebago Cooperative Telecom Association$104,637.80
WC Fiber, LLC$98,189.50
Net Ops Communications, LLC$69,676.40
Enduring Internet$65,690.00
Gardonville Cooperative Telephone Association$63,903.00
Northeast Missouri Rural Telephone Company$60,126.00
Skywave Wireless, Inc.$57,660.00
MARQUETTE-ADAMS TELEPHONE COOPERATIVE, INC.$55,378.00
yondoo Broadband LLC$54,833.80
Pioneer Long Distance, Inc.$50,994.00
All West Communications, Inc.$46,648.00
XIT Telecommunication & Technology$43,254.50
Corn Belt Telephone$42,237.00
WTC Communications, Inc.$40,845.20
Consortium 904$40,470.00
MCC Network Services, LLC$36,204.00
Pinpoint Bidding Coalition$31,254.00
Wood County Telephone Company d/b/a Solarus$28,848.00
NMSURF, Inc.$26,964.00
KanOkla Telephone Association$26,538.00
Yucca Telecommunications Systems, Inc.$26,221.00
IdeaTek Telcom, LLC$23,590.60
Home Communications, Inc.$15,540.00
Barry Technology Services, LLC$14,502.00
LR Communications, Inc.$13,974.00
Farmers Mutual Cooperative Telephone Company$12,447.00
PVT NetWorks, Inc.$12,039.00
Baldwin Telecom, Inc.$11,370.00
H&B Communication’s, Inc.$11,301.60
NTS Communications, LLC$8,923.00
W. T. Services, Inc.$8,785.70
Computer Techniques, Inc. dba CTI Fiber$8,509.00
Sandhill Telephone Cooperative, Inc.$6,396.00
Taylor Telephone Coop., Inc. dba Taylor Telecom$5,466.00
Comcell Inc.$4,644.00
Peoples Communication, LLC.$4,140.00
Plateau Telecommunications, Inc.$3,150.00
Coleman County Telephone Cooperative, Inc.$3,142.80
Bloosurf, LLC$1,860.50
Wildstar$1,790.00
Unified Communications Inc.$1,604.00
Carolina West Wireless, Inc.$460.00

Thanks For Approving My Merger!

T-Mobile’s former CEO, John Legere, was extremely successful in branding himself as an advocate for consumers. While I admire Legere’s success, I don’t think he lived up to the persona he created.1

Today, Legere shared a tweet that reaffirmed my feelings:


While I think a lot of criticism of Ajit Pai has been unfair, “advocating for wireless competition” is quite the phrase. It feels particularly insincere coming from Legere who made the better part of $100 million from a bonus and other compensation tied to the closure of the merger between T-Mobile and Sprint. I’m on the record saying I expected the merger to be bad for consumers. Eight months later, I continue to stand by my view.

Verizon Hints At Plans For Tracfone Subscribers

Earlier this year, Verizon announced plans to acquire Tracfone and its roughly 20 million subscribers. While more than half of Tracfone’s subscribers already have service that runs over Verizon’s network, it has been unclear what might happen to the 8 to 9 million Tracfone subscribers on other networks.

In an investor event a few days ago, Ronan Dunne, a Verizon executive, hinted at how Verizon might handle those subscribers if the acquisition goes through:

Just for context, about 13 million of their [Tracfone’s] 21 million, 22 million customers ride on the Verizon network today, but there’s 8 million or 9 million thatride on competitor networks. And we have the opportunity to migrate those across to be on to Verizon.

I’m not sure how seriously I should take Dunne’s words. I still think Verizon may sell off Tracfone subscribers on other networks—selling off some subscribers may appease regulators who are reluctant to allow the acquisition.

FCC Hits T-Mobile With A $200 Million Fine For Sprint’s Abuse Of The Lifeline Program

The FCC fined T-Mobile $200 million for Sprint’s abuse of the Lifeline program. Under the Lifeline program, wireless carriers can get a nearly $10 subsidy for each eligible, low-income American they provide phone service to. Often, the Lifeline subsidy is large enough for carriers to offer basic service at no cost to eligible consumers.

According to the Lifeline program rules, carriers are only supposed to get subsidies for lines that are in active use. Lines that go unused are supposed to become ineligible for a subsidy. Here’s how the FCC explains the rationale for rules about usage:

The FCC developed this and other rules after investigations showed that companies were aggressively selling free Lifeline service, knowing that they would get paid each month even if consumers didn’t use their phones. Since there was no bill, consumers had no incentive to relinquish the subscription.

Before Sprint’s merger with T-Mobile, the carrier was receiving subsidies for almost a million lines that we’re in violation of the usage rules. Since T-Mobile now owns Sprint, T-Mobile is on the hook for the FCC’s $200 million fine. The FCC’s press release describes the fine as the “largest fixed-amount penalty to be paid in Commission history.”

In Hindsight: T-Mobile’s Network Outage

Yesterday, T-Mobile experienced a serious network outage beginning around 10am MT. The outage persisted through most of the day and primarily affected voice and text services.

Around 11pm MT, T-Mobile announced that outage was over:

These issues are now resolved. We again apologize for any inconvenience and thank you for your patience.

What caused the outage?

A lot of speculation was floating around yesterday. Some Twitter users, including a congressman, suggested there was a huge distributed denial-of-service attack causing trouble for U.S. networks. This story never made much sense.

Others speculated that a massive network failure was causing issues for all the major cellular operators. This idea was based on information from the website Downdetector, an entity that aggregates user complaints in real-time. Downdetector suggested that customer complaints about Verizon and AT&T were increasing at the same time that T-Mobile was experiencing issues.

Here’s how Downdectector describes its methodology:

Downdetector collects status reports from a series of sources, including Twitter and reports submitted on our websites and mobile apps. Our system validates and analyzes these reports in real-time, allowing us to automatically detect outages and service disruptions in their very early stages.

I expect the customer complaints about Verizon and AT&T were ultimately caused by T-Mobile’s network issues. Verizon and AT&T customers may have tried to call T-Mobile customers, then thought their own carriers (rather than T-Mobile) were at fault when calls failed.

Both AT&T and Verizon made statements suggesting that their networks were operating normally.

Updates from T-Mobile & the FCC

Yesterday evening, T-Mobile’s CEO, Mike Sievert, gave a vague explanation of what caused the outage:

T-Mobile has been experiencing a voice and text issue that has intermittently impacted customers in markets across the U.S…This is an IP traffic related issue that has created significant capacity issues in the network core throughout the day. Data services have been working throughout the day.

The outage was likely triggered as T-Mobile took steps to merge Sprint’s technology and/or customer base into the New T-Mobile. I haven’t heard any further information about the outage from a plausible-looking source, but details may come out soon. Ajit Pai, the FCC Chairman, shared the following tweet last night:

U.S. Telecom Companies Take The “Keep Americans Connected” Pledge

In response to coronavirus-related threats, the FCC recently asked a large number of U.S. broadband and telephone companies to take the Keep Americans Connected Pledge. Companies that take the pledge commit not to cut off subscribers who fail to pay their bills for reasons related to the coronavirus. Companies further pledge to waive late fees for subscribers that fail to pay.

From a document on the FCC’s website:

The Keep Americans Connected Pledge reads as follows:Given the coronavirus pandemic and its impact on American society, [[Company Name]] pledges for the next 60 days to:(1) not terminate service to any residential or small business customers because of their inability to pay their bills due to the disruptions caused by the coronavirus pandemic;(2) waive any late fees that any residential or small business customers incur because of their economic circumstances related to the coronavirus pandemic; and(3) open its Wi-Fi hotspots to any American who needs them.

In a very short period of time, a ton of American telecom companies took the pledge. Here’s an incomplete list of players in the wireless industry that have already pledged:

  • AlticeUSA
  • AT&T
  • Comcast
  • Sprint
  • T-Mobile
  • TracFone Wireless
  • US Cellular
  • Verizon

It will be interesting to see how these companies’ commitments play out.

FCC Reveals Misleading Coverage Claims

On Wednesday, the FCC released a fascinating report related to the Mobility Fund Phase II (MF-II). The MF-II is a planned program to provide federal funding for network build-outs in rural areas that are underserved by 4G coverage.

To determine which geographic areas were underserved, the FCC requested coverage maps and data from network operators. After reviewing the data and allowing outside entities to challenge the datas’ reliability, the FCC became concerned about the accuracy of the information shared by T-Mobile, U.S. Cellular, and Verizon. The FCC decided to conduct its own performance tests and compare the results of its tests to the information the network operators provided. Here’s what the agency found:1

Through the investigation, staff discovered that the MF-II coverage maps submitted by Verizon, U.S. Cellular, and T-Mobile likely overstated each provider’s actual coverage and did not reflect on-the-ground performance in many instances. Only 62.3% of staff drive tests achieved at least the minimum download speed predicted by the coverage maps—with U.S. Cellular achieving that speed in only 45.0% of such tests, T-Mobile in 63.2% of tests, and Verizon in 64.3% of tests…In addition, staff was unable to obtain any 4G LTE signal for 38% of drive tests on U.S. Cellular’s network, 21.3% of drive tests on T-Mobile’s network, and 16.2% of drive tests on Verizon’s network, despite each provider reporting coverage in the relevant area.

Incentives

When considering the accuracy of coverage maps, I try to think about the incentives network operators face. When advertising to consumers, network operators often have an incentive to overstate the extent of their coverage. However, incentives can run in the opposite direction in other situations. For example, when trying to get approval for a merger between Sprint and T-Mobile, Sprint had incentives to make its 4G coverage profile look limited and inferior to the coverage profiles of other nationwide networks.2

I’m not well-informed about the MF-II, so I don’t feel like I have a good grasp of all the incentives at play. That said, it’s not clear that all network operators would have an incentive to overstate their coverage. A network operator that claimed to offer coverage in an area it didn’t cover may limit competitors’ access to subsidies in that area. However, a network operator erroneously claiming to cover an area may prevent itself from receiving subsidies in that area.

Challenges

After network operators submitted coverage information to the FCC, a number of entities, including both governments and network operators, were allowed to challenge the validity of coverage information submitted by others. Here’s a bit more detail about the challenge process:3

After release of the map of presumptively eligible areas, mobile service providers, state, local, and Tribal government entities, and other interested parties granted a waiver were eligible to submit challenges in the challenge process via an online system operated by USAC. Challengers that requested access to the USAC MF-II Challenge Portal were able to access the provider-specific coverage maps, after agreeing to keep the coverage data confidential, and to file challenges to providers’ coverage claims by submitting speed test data. Challengers were required to conduct speed tests pursuant to a number of standard parameters using specific testing methods on the providers’ pre-approved handset models. The Commission adopted the requirement that challengers use one of the handsets specified by the provider primarily to avoid inaccurate measurements resulting from the use of an unsupported or outdated device—e.g., a device that does not support all of the spectrum bands for which the provider has deployed 4G LTE…During the eight-month challenge window, 106 entities were granted access to the MF-II Challenge Portal. Of the 106 entities granted access to the MF-II Challenge Portal, 38 were mobile service providers required to file Form 477 data, 19 were state government entities, 27 were local government entities, 16 were Tribal government entities, and six were other entities that filed petitions requesting, and were each granted, a waiver to participate.

About a fifth of the participating entities went on to submit challenges:4

21 challengers submitted 20.8 million speed tests across 37 states.

The challenge data often showed failed tests and lackluster speeds in areas where network operators claimed to offer coverage:5

During the challenge process, some parties entered specific concerns into the record. For example:6

Smith Bagley (d/b/a Cellular One) submitted maps of its service area in Arizona overlaid with Verizon’s publicly-stated 4G LTE coverage and the preliminary results of drive tests that Smith Bagley had conducted. Smith Bagley asserted that, for large stretches of road in areas where Verizon reported coverage, its drive testers recorded no 4G LTE signal on Verizon’s network. Smith Bagley argued that the ‘apparent scope of Verizon’s inaccurate data and overstated coverage claims is so extensive that, as a practical matter, the challenge process will not and cannot produce the necessary corrections.’
As part of a public report detailing its experience, Vermont published a map showing its speed test results which contradicted the coverage maps in Vermont of U.S. Cellular, T-Mobile, and Verizon, among others. This map included information on the approximately 187,000 speed tests submitted by Vermont, including download speed, latency, and signal strength. In the report, Vermont detailed that 96% of speed tests for U.S. Cellular, 77% for T-Mobile, and 55% for Verizon failed to receive download speeds of at least 5 Mbps.

After reviewing the challenges, the FCC requested additional information from the five largest network operators (AT&T, T-Mobile, Verizon, Sprint, and U.S. Cellular) to understand the assumptions involved in the networks’ coverage models.

FCC tests

Around the same time the FCC was requesting additional information from network operators, the agency also began its own testing of Verizon, U.S. Cellular, and T-Mobile’s networks. These speed tests took place in 12 states and primarily made use of a drive-testing methodology. As mentioned earlier, analyses of the FCC’s test data suggested that the on-the-ground experience with Verizon, T-Mobile, and U.S. Cellular’s network was much different than the experience that would be expected based on the information the networks provided to the FCC.

What happened?

A lot of the commentary and news articles I’ve seen in response to the FCC’s report seem to conclude that network operators are bullshitters that intentionally lied about the extent of their coverage. I have reservations about fully accepting that conclusion. Accurately modeling coverage is difficult. Lots of factors affect the on-the-ground experience of wireless subscribers. The FCC largely acknowledges this reality in its report:

Providers were afforded flexibility to use the parameters that they used in their normal course of business when parameters were not specified by the Commission. For example, the Commission did not specify fading statistics or clutter loss values, and providers were required to model these factors as they would in the normal course of business.7
Our speed testing, data analyses, and inquiries, however, suggest that some of these differences may be the result of some providers’ models: (1) using a cell edge RSRP value that was too low, (2) not adequately accounting for network infrastructure constraints, including backhaul type and capacity, or (3) not adequately modeling certain on-the-ground factors—such as the local clutter, terrain, and propagation characteristics by spectrum band for the areas claimed to be covered.8

Further supporting the idea that assessing coverage is difficult, the FCC didn’t just find that its tests contradicted the initial information submitted by network operators. The FCC data also contradicted the data submitted by those who challenged network operators’ data:

The causes of the large differences in measured download speed between staff and challenger speed tests taken within the same geographic areas, as well as the high percentage of tests with a download speed of zero in the challenger data, are difficult to determine. Discrepancies may be attributable to differences in test methodologies, network factors at the time of test, differences in how speed tet apps or drive test software process data, or other factors…Given the large differences between challenger and staff results however, we are not confident that individual challenger speed test results provide an accurate representation of the typical consumer on-the-ground experience.9

While the FCC found some of the information submitted by networks to be misleading about on-the-ground service quality, I don’t believe it ended up penalizing any network operators or accusing them of anything too serious.10 Still, the FCC did suggest that some of the network operators could have done better:

Staff engineers, however, found that AT&T’s adjustments to its model to meet the MF-II requirements may have resulted in a more realistic projection of where consumers could receive mobile broadband. This suggests that standardization of certain specifications across the largest providers could result in coverage maps with improved accuracy. Similarly, the fact that AT&T was able to submit coverage data that appear to more accurately reflect MF-II coverage requirements raises questions about why other providers did not do so. And while it is true that MF-II challengers submitted speed tests contesting AT&T’s coverage data, unlike for other major providers, no parties alleged in the record that AT&T’s MF-II coverage data were significantly overstated.11

FCC response

The FCC concluded that it should make some changes to its processes:12

First, the Commission should terminate the MF-II Challenge Process. The MF-II coverage maps submitted by several providers are not a sufficiently reliable or accurate basis upon which to complete the challenge process as it was designed.
Second, the Commission should release an Enforcement Advisory on broadband deployment data submissions, including a detailing of the penalties associated with filings that violate federal law, both for the continuing FCC Form 477 filings and the new Digital Opportunity Data Collection. Overstating mobile broadband coverage misleads the public and can misallocate our limited universal service funds.
Third, the Commission should analyze and verify the technical mapping data submitted in the most recent Form 477 filings of Verizon, U.S. Cellular, and T-Mobile to determine whether they meet the Form 477 requirements. Staff recommends that the Commission assemble a team with the requisite expertise and resources to audit the accuracy of mobile broadband coverage maps submitted to the Commission. The Commission should further consider seeking appropriations from Congress to carry out drive testing, as appropriate.
Fourth, the Commission should adopt policies, procedures, and standards in the Digital Opportunity Data Collection rulemaking and elsewhere that allow for submission, verification, and timely publication of mobile broadband coverage data. Mobile broadband coverage data specifications should include, among other parameters, minimum reference signal received power (RSRP) and/or minimum downlink and uplink speeds, standard cell loading factors and cell edge coverage probabilities, maximum terrain and clutter bin sizes, and standard fading statistics. Providers should be required to submit actual on-the-ground evidence of network performance (e.g., speed test measurement samplings, including targeted drive test and stationary test data) that validate the propagation model used to generate the coverage maps. The Commission should consider requiring that providers assume the minimum values for any additional parameters that would be necessary to accurately determine the area where a handset should achieve download and upload speeds no less than the minimum throughput requirement for any modeling that includes such a requirement.

Reflections

The FCC’s report illustrates how hard it is to assess network performance. Assumptions must be made in coverage models, and the assumptions analysts choose to make can have substantial effects on the outputs of their models. Similarly, on-the-ground performance tests don’t always give simple-to-interpret results. Two entities can run tests in the same area and find different results. Factors like the time of day a test was conducted or the type of device that was used in a test can have big consequences.

If we want consumers to have better information about the quality of service networks can offer, we need entities involved in modeling and testing coverage to be transparent about their methodologies.