How accurate is the map?

The biggest story you know nothing about is taking place at the Federal Communications Commission in Washington, where regulators are trying to figure out what to do with $185 million in leftover broadband expansion funds Internet Service Providers either could not qualify for or did not want. The FCC is on the verge of making a decision, one that will rely on broadband map data that service providers are now calling grossly inaccurate.

During the first phase of the Connect America program to fund broadband expansion in rural areas, the Commission offered up to $300 million to providers willing to wire consumers and businesses deemed too unprofitable to serve.

The rules largely favored phone companies, and although some including Frontier Communications gratefully accepted the funding to expand their DSL service, both of America’s largest phone companies expressed little interest. Many others, including CenturyLink and Windstream, petitioned to change the rules.

In the end, less than half of the available funding — $115 million — was actually spent, none in areas served by AT&T and Verizon.

The initial guidelines for participation were not exactly a high bar to cross. Under the program’s original rules, providers are required to deploy broadband within three years to certain locations that receive less than 768kbps downstream and 200kbps upstream (or no service at all). That “means test” set the bar far below the minimum speed providers can even call “broadband” under the FCC’s own current definition: 4/1Mbps.

Anyone served by 1-3Mbps DSL “broadband” was instantly ineligible because the FCC effectively deemed those speeds ‘good enough for now.’ The FCC argued it wanted to first target funds to those without any service at all, not those who had inadequate service.

Participating carriers receive compensation up to $775 per home to defray connection costs, bringing expenses closer to the Return on Investment-test that decides whether your rural home will have broadband service or not. Large phone companies complained the subsidy was not nearly enough and did not bother applying. Some others said even with the subsidy, it was still too unprofitable to wire rural homes in their service areas.

This not-so-auspicious start of the Connect America project has driven the FCC to propose modifying the rules to increase participation by disinterested providers. In an opaque “Further Notice of Proposed Rulemaking,” the Commission proposes new rules that will “further accelerate the deployment of broadband facilities to consumers who lack access to robust broadband.”

Under the new guidelines, providers could be able to apply for funding if the areas they propose to serve are not already getting at least 4/1Mbps service. But in a surprising footnote, the FCC announced they will “use 3Mbps downstream and 768kbps upstream as a proxy for 4/1Mbps service.” In other words, the FCC is ignoring its own standard definition of broadband and settling for something less. That will leave customers waiting for something better than 3Mbps service up the creek, excluded from Connect America funding.

The U.S. Telecom Association is a lobbying group dominated by AT&T, Verizon and other phone companies.

The U.S. Telecom Association (USTA), which represents phone companies, was appalled, suggesting this footnote will block funding from approximately one million rural households that receive what most of us would consider substandard broadband.

“This is particularly true for rural areas served by DSL which in most cases has been engineered to provide an upstream speed of 768 Kbps,” the USTA wrote in comments to the FCC. “In such cases, significant and costly network upgrades would be necessary to provide broadband service meeting the 4/1Mbps  benchmark. Therefore, rather than relying on evidence of 3/768 service to exclude areas from eligibility, the Commission should use the next speed tier—6/1.5Mbps as a proxy for 4/1 service.”

Windstream, in its own comments, was reduced to educating the FCC about the basic technical facts of DSL:

One Mbps upload speeds are not necessarily available to all customers served by standard ADSL 2+ architecture over a 24 AWG copper pair of 12,000 feet. Rather, delivery of reliable upload speeds of 1 Mbps would require an upgrade, such as two-pair bonded ADSL 2+. Two-pair bonded ADSL2+ essentially doubles last mile deployment cost since the end user modem is two to three times the cost of a normal single pair modem, two cable pairs are used instead of one, and two ADSL2+ ports are required at the DSLAM. Moreover, to achieve 1 Mbps of customer payload throughput would require an upload connection speed of more than 1.2 Mbps, while an upload connection speed of 1 Mbps would produce an actual throughput of about 820 Kbps.

Even where the loop length from the DSLAM to the customer is less than 12,000 feet, a service provider can only deliver service meeting the 4/1 requirement—or more precisely, service at speeds of 6/1.5Mbps, the next-fastest standard service tier—if the DSLAM is ADSL2+ capable and fiber-fed.

Windstream provides a primer on DSL to the FCC.

The resource that will determine who qualifies for broadband funding and who does not is the National Broadband Map, which seeks to describe the broadband options available at hundreds of millions of American addresses. If the map shows an area unserved, it qualifies for funding. If the map shows there is no broadband inadequacy, no funding will be offered.

Unsurprisingly, providers of all kinds are hurrying in comments that declare often considerable inaccuracies in the FCC’s map. This is ironic since much of the collected data on which the map is based was voluntarily supplied by those providers.

In various submissions filed with the FCC, several ISPs suggest the national map is not to be trusted. Some complain the updated service areas they earlier submitted have never been incorporated into the map, others are discovering inaccuracies for the first time because they can make the difference between winning or not qualifying for rural broadband funding (either for themselves or a competitor). Among other complaints: providers are overestimating their coverage and fibbing about actual speeds, the map’s census tract granularity ends up declaring an area served if even one household manages to get DSL service while others cannot, and providers only serving business customers are treated as if they serve everyone.

Mississippi Gov. Phil Bryant is asking the FCC to clean up the inaccuracies in the Mississippi portion of the National Broadband Map.

The state of Mississippi is the poster child for inaccuracies in the National Broadband Map. All that was required to disqualify most of the state from rural broadband funding was a boastful and inaccurate submission from one cable broadband reseller that claimed they served virtually all of Mississippi. Nobody bothered to question the veracity of their submission or verify it. Now the governor’s office is involved in efforts to scrub the inaccurate broadband map they consider more a fantasy than reality on the ground.

With the FCC preparing to launch the second phase of the Connect America Fund with up to $1.8 billion of available funding per year over five years, the money sharks are in the water circling one another.

Cable operators and wireless ISPs are asking the FCC not to hand out money to their competitors and phone companies are returning fire claiming those providers are lying about their coverage areas and have restrictions on service.

Companies ranging from Comcast to small, independent cable operators working with the American Cable Association are filing objections to the existing map. Wireless ISPs, often family-owned, are even more worried what will happen if phone companies like Windstream get federal dollars to upgrade their DSL service while unsubsidized WISPs are left to compete on their own.

In fact, the Competitive Carriers Association argues wireless providers are best positioned to make use of the unspent funds to deploy rural wireless broadband immediately.

“Wireless carriers offer the best opportunity to bring much needed broadband services to unserved and underserved areas, and it only makes sense for the FCC to consider proposals from wireless carriers,” said CCA president Steven K. Berry. “Many of our members are ready and willing to build out these networks, but depend on [financial] support in order to do so.  Wireless remains underfunded, and this could be an opportunity for the FCC to provide significant support for the services consumers want most.”

Not if the USTA and Windstream have anything to say about it. Both are on the attack in comments filed with the FCC:

WISPs: “Coverage should be independently verified before such areas are considered ineligible for Connect America funding. Like satellite providers, WISPs often have capacity caps and service quality issues, including unpredictable degradation from third-party interference from common devices such as cordless phones, garage door openers and microwave ovens when WISPs use unlicensed spectrum. The sustained speeds WISPs offer, particularly during busy times, also tend to be slower than those offered by [phone company broadband], and certainly slower than the 4Mbps downstream standard required of future recipients of federal funding.” — U.S. Telecom Association

The USTA also attacks WISPs for their usage caps, which they claim should disqualify them from serious consideration because their networks are technically and realistically inadequate to service today’s broadband consumer.

Cable “Competitors”: Windstream claims the bare existence of a cable operator alone should not disqualify the phone company from funding. Windstream suggests cable companies in its service areas may only serve one or two customers in a census tract, not really offer service at all, or provide sub-standard broadband that is so bad, nobody will do business with them.

Windstream proposes its own competition test: “In many areas […] with an alleged presence of an unsubsidized competitor, Windstream has received no requests in the past two years from customers for telephone number ports that are accompanied by cancellation of the customer’s Windstream broadband service. In other words, despite the alleged presence of a competitor providing service at speeds of at least 3/768 in areas where Windstream itself does not provide service exceeding 3/768, Windstream has not received a single request in two years in an entire area to port a phone number to a competitor and cancel the associated Windstream broadband service. Windstream submits that the lack of such porting requests throughout an entire area over a reasonable historical period is strong evidence that there is no competitor providing 3/768 or better service in that area.”

The independent phone company proposes that alleged unsubsidized competitors offer proof they are actually providing service before the FCC excludes an area from funding consideration.

“Here is our view.” — Phillip Dampier

Consumers are free to share their own views with the FCC on these matters by filing their own comments here. The Proceeding Number you will need is 10-90. It is generally easier to create a .PDF, standard .txt file, or Microsoft Word document and attach it to the submission form. Your comments will be publicly visible and posted to the FCC website.

Stop the Cap! feels the FCC should not renege on its commitment to fund rural providers that will guarantee customers will receive at least 4/1Mbps service. This barely adequate minimum will require phone companies to upgrade their facilities to next generation DSL technology that can support future speed upgrades. Compromising on lower speeds gives phone companies the option to deploy outdated early generation DSL that cannot be upgraded easily. In a positive development, many phone companies seem willing to commit to these upgrades with some financial assistance.

Funding should also be available to the provider that can deliver the best broadband service at the lowest cost. As urban and suburban customers have learned, that service often does not come from the phone company. Cable operators willing to commit to rural broadband upgrades should not be disqualified from funding, nor should community-owned providers who want to build their own networks.

We have also repeatedly complained about broadband mapping that lacks a formal mechanism to clearly verify coverage and speeds independent of the ISP supplying the data. Providers have an incentive to artificially boost or reduce coverage, particularly if it means the difference between qualifying for federal broadband expansion funding or disqualifying a competitor because the provider can falsely claim they already offer the service.

Our thanks to Cassandra Heyne, who dubbed the current situation an FCC ‘maptastrophe.’

Despite making revenue growth the top priority at Frontier Communications, the company still managed to lose 3% in year over year revenue as another 51,800 customers pulled the plug on their Frontier landline and slow DSL service.

Frontier’s latest quarterly earnings showed a net income rise to $67 million, a major improvement over $20.4 million earned during the same quarter last year. The earnings improvement comes from reduced operating expenses, down 12 percent to $977.3 million and rate increases for certain Frontier markets in less-competitive areas.

Frontier CEO Maggie Wilderotter told investors the company has been reviewing accounts obtained from Verizon Communications, scrutinizing for “unnecessary credits, adjustments, and discounts, ” and systematically eliminating them.

“We’ve got a number of [ex-Verizon] customers that have been with us at a very, very, very low price point; they’ve been on promotions,” said Donald Shassian, Frontier’s chief financial officer. “They’ve been in existence for years and never got curtailed. And once we converted [those customers] onto [Frontier’s billing system], we identified those.”

Frontier’s plan for future growth is a temporary transition away from expanding broadband service into unserved areas, instead focusing on speed upgrades and service improvements where Frontier already serves.

Frontier: Speed upgrades “help dispel the myth that DSL technology cannot keep up with customer demand.” Faster speeds support IPTV as well.

Frontier has targeted investment on improving speeds and network capacity for customers currently stuck with 1-3Mbps traditional DSL service. Frontier is using its fiber-based middle mile network and more advanced forms of DSL to dramatically increase broadband speeds. According to company officials, 64% of Frontier’s exchanges are now equipped with VDSL2, with speeds up to 40Mbps. At least 73% have equipment capable of bonded ADSL2+ with speeds up to 20Mbps. The target for Frontier’s fastest speeds are commercial customers. By the end of this year, 71% of Frontier’s exchanges will support carrier Ethernet service up to 1Gbps for business accounts.

Most Frontier residential customers will see more modest speed improvements. During the third quarter, Frontier expanded its higher speed offerings with more to come:

• 20Mbps service is now for sale in 34% of its national service territory. By year end, 40% will have access and 52% by 2013;
• 12Mbps service is now available to 48% of its network footprint. By the end of the year, 51% of homes will have access and 60% in 2013;
• 6Mbps is now available to 67% of Frontier-served homes, with 74% expected by year end and 80% by 2013.

“We’re seeing 100Mbps delivery in vendor labs and that should be a reality in the next 12 months in our markets,” Wilderotter said. “This should help dispel the myth that DSL technology cannot keep up with customer demand.”

Wilderotter noted that the latest network upgrades might eventually support television service.

“We think we have the opportunity to offer an IPTV-type service in many of our markets, to many of our customers,” said Wilderotter. “In our labs, we’re doing some experimentation on the DSL platform with certain types of technologies that compress the data stream, so we could actually offer a very good video experience at 6Mbps or above. We’ll be doing some experimentation with that in 2013.”

New Products, More Simplified Pricing, Bigger Promotions

To better compete with cable, Frontier has simplified many of their broadband packages, eliminating the modem rental fee and other hidden surcharges for customers. Wilderotter noted the cable industry has recently started to “nickle and dime” customers with modem rental fees and surcharges, something Frontier has also charged customers in the past.

Frontier is now staking a position in simplified pricing.

“So when a customer gets a quote of $39.99 for broadband, it includes the modem, it includes surcharges, it includes everything,” Wilderotter explained. “So they’re not surprised when they get their bill. And we think that’s a huge value selling point for our product set.”

But simple pricing is not always lower pricing.

Increases in broadband service pricing, a hike in the Subscriber Line Charge, and other surcharges introduced for departing customers helped add to the company’s bottom line. But Frontier insists it adjusts rates only after considering the competitive environment.

“You don’t necessarily see us do price increases on broadband across the board,” explained Shassian. “We also believe that the price increases should be associated with increased value to the customer, too. So in some cases, it’s incremental speeds and capability.”

In an effort to upsell current customers, and even more importantly “win back” those who left, Frontier has introduced an aggressive new promotion that will reward subscribers with up to a $450 Apple gift card when committing to a new two-year contract. The value of the gift card ranges depending on how many services a customer chooses.

Stop the Cap! found Frontier pitching a triple play promotion in Tennessee for $87.99 a month with a $450 Apple gift card for new or returning Frontier customers. The bundle includes 6Mbps DSL, Frontier residential phone service with features and long distance service, and DISH Networks’ America’s Top 120 satellite service.

But there is fine print, including a two year service agreement with a $400 early termination fee for phone and broadband service, a DISH cancellation fee of $17.50 for each month remaining in a two year contract, at least $85 in “setup fees,” a $9.99 “broadband processing fee” if a customer disconnects service, and an online bonus credit a customer has to remember to request within 45 days of service activation.

Other Frontier Developments This Quarter

• Frontier began deploying the FCC Connect America Fund proceeds during the quarter to bring broadband to 92,877 new Frontier homes;
• A wireless partnership trial with AT&T began on October 8 in Washington and Minnesota. The discounted package bundle is only available to customers who also maintain Frontier broadband service;
• Over 203,000 Frontier customers signed up with legacy partner DirecTV saw their satellite service unbundled from their Frontier bills this quarter. Frontier chose DISH Networks as its satellite partner back in 2011, and the company has encouraged its old DirecTV customers to consider switching to DISH;
• Business customers constitute 52% of Frontier customer revenues. Frontier expects more than 66% of total customer revenue to come from broadband service;
• Frontier’s Simply Broadband, a broadband-only product, used to include a free landline. Not anymore;
• Frontier will begin accelerating promotions for its Apple Store gift card starting this week;
• Hughes Net Satellite service was integrated into Frontier’s systems and is pitched to customers as Frontier Satellite Broadband. It will be targeted to 750,000 households that cannot access wired broadband service from Frontier.

PC Magazine has declared fiber to the home service America’s fastest broadband technology, and among larger providers, Verizon’s FiOS once again took top honors for delivering the fastest and most consistent broadband speeds.

Over the past nine months, the magazine’s readers have been conducting regular speed tests using their personal broadband connections. The magazine found fiber optics remains the best current technology for delivering cutting-edge broadband service, with an average speed rating for FiOS reaching 29.4/16.7Mbps. Since PC Magazine readers were subscribed to various speed tiers while conducting the tests, the magazine’s ratings do not measure the fastest possible speeds on offer from different providers. Verizon’s most-popular service bundle includes 15/5Mbps service, heavily weighting Verizon’s speed rating which is capable of even faster speeds with their 50-300Mbps premium service tiers. But on average, consistently fast speeds kept them in the top spot.

Cable broadband technology was the second-best choice, depending on how cable operators implement it. Cable companies depend on a singl, shared broadband pipeline in each neighborhood. DOCSIS 3 upgrades allow a cable operator to vastly expand that pipeline by “bonding” several channels together to increase the maximum bandwidth. Cable operators that combine the latest technology with the smallest number of customers sharing a connection do the best.

Midcontinent Communications (better known by customers as Midco), achieved first place nationwide. The company, which serves customers in Minnesota, the Dakotas, and Wisconsin, took top honors with an average speed of 24.7/4.4Mbps — the best of any cable operator.

Ratings sometimes show the level of investment made by cable operators in their network. A sudden boost in average speeds is a sure sign a cable operator is rolling out network upgrades. A speed decline can expose a cable company trying to oversell an already constrained network. Charter Cable, which has routinely gotten poor ratings in Consumer Reports’ rankings, showed dramatic improvement in PC Magazine’s ratings, achieving third place with an average speed increase from 15Mbps to 18.5Mbps. But while the added speed is nice, the company’s usage caps are not. Conversely, WOW!, which achieved top scores in Consumer Reports’ ratings, scored towards the bottom of PC Magazine’s tests.

Comcast, which last year trumpeted its high rankings in controversial ads claiming to deliver the fastest broadband in the nation has now been overrun by both Midco and Charter. Comcast Xfinity is now in sixth place, hardly the fodder for any future ad campaign.

Cox Cable actually lost ground since last year, with average speed now down to 14.8Mbps. The bottom four: Time Warner Cable, Mediacom, WOW!, and Suddenlink — are all hampered by slow upload speeds and more anemic “take-rates” on higher speed broadband plans with the speeds on offer. With fewer premium speed customers, average speed ratings take a hit from the larger proportion of customers sticking with standard service.

Phone companies barely appeared in the magazine’s top ratings. AT&T’s U-verse could not even make the top-15. While 25Mbps was adequate when U-verse was first deployed, the broadband speed race has quickly overshadowed the company’s fiber to the neighborhood service, which still relies on home phone lines and antiquated copper infrastructure in the immediate neighborhood.

Phone companies still offering traditional ADSL on almost all-copper networks turned in even more dismal results — most too low to rate. Only Frontier’s adopted FiOS network kept them in the rankings in the overall broadband “slow zone” in the Pacific Northwest, along with CenturyLink’s acquired ADSL2+ and bonded DSL networks built by Qwest.

ISPs that perform poorly typically criticize the methodology of voluntary speed tests as the basis for speed and performance ranking. Most criticize the apparent lack of consistency, random sampling, the possibility rankings may be weighted in certain geographic areas, and may mix a disproportionate number of customers with standard or premium level speeds to unfairly boost or diminish average speed rankings. But overall, PC Magazine’s rankings show some technologies superior to others. If a customer has a choice, finding a fiber to the home provider is likely to provide an improvement over what the cable company offers, but the differences between phone company DSL and cable broadband are even starker.

The FCC speed test program, conducted by SamKnows, takes more regular snapshots of broadband quality from volunteer panelists. Your editor’s home broadband connection from Time Warner Cable is profiled above, showing results from January-September 2012

Frontier’s headquarters in Rochester, N.Y.

Frontier Communications has boosted speeds for some customers in 28 communities in Appalachian Ohio, but Stop the Cap! readers report actually qualifying to get faster broadband can be hit or miss.

Frontier has deployed ADSL2+ bonding technology in several exchanges throughout the region, which means customers can potentially double their current broadband speeds. The company says it will now sell residential customers up to 12/2Mbps and business customers up to 15/2Mbps DSL.

“With Frontier’s recent deployment of the latest broadband technology, residential customers can get the speeds they need to stream high-definition videos, run multiple devices, do online gaming and surf the net without lag,” said Dave Davidson, senior vice president and general manager for Frontier’s Ohio operations. “The ADSL 2+ Bonding technology also allows us to offer business customers super-fast speed that’s perfect for sending large files and for videoconferencing.”

The communities where Frontier recently deployed technology for increased broadband speeds in Appalachian Ohio include:

• Central Ohio — Logan
• Eastern Ohio — Bowerston, Byesville, Cambridge, Cooperdale, Flushing, Freeport, Knoxville, Lowell, Lower Salem, North Georgetown, New Philadelphia
• Southern Ohio — Albany, Athens, Portsmouth, Guysville, Wellston, Idaho, Jackson, Lucasville, New Marshfield, Otway, Pomeroy, Shade, Piketon, Wellston
• Southwest Ohio — Felicity, Manchester

But several Stop the Cap! readers in Ohio told us even though their communities are on Frontier’s upgrade list, they still don’t qualify for anything above 3-5Mbps service.

Frontier Communications has confirmed a Stop the Cap! exclusive report that the company has shown an interest in a licensing arrangement with AT&T to deliver U-verse to Frontier customers in larger markets.

Maggie Wilderotter, CEO of Frontier Communications today told investors on a morning conference call that the company likes the U-verse product and is considering deploying it.

“We’ve been evaluating a lot of other alternatives of which U-verse is one of the alternatives,” Wilderotter said. “We think it’s a product that can work, not just on fiber, but it also works on copper as well. So it’s a lot more forgiving in the market.”

Wilderotter claimed the company has no immediate plans to introduce the technology, but Stop the Cap! has obtained documentation that shows the company now refers specifically to “U-verse” in internal communications, is hiring new leadership to oversee the company’s IPTV plans, and has plans to dramatically expand VDSL technology, a prerequisite for deploying AT&T’s fiber to the neighborhood platform.

Wilderotter

Frontier Communications has had a difficult time supporting its Verizon-inherited FiOS fiber-to-the-home networks in the Pacific Northwest and Indiana.  The company has found itself unable to compete effectively in the video business because it negotiates programming contracts independently, which locks Frontier out of the volume discounts that other independent providers routinely receive from participating in programming purchasing co-ops.  Frontier lost 4,800 FiOS video customers in the last quarter alone.

Wilderotter said as a result of programming costs, Frontier has no plans to pursue any additional fiber expansion to deliver video programming.

However, a licensing arrangement with AT&T U-verse could open the door to Frontier receiving the same volume discount prices for programming that AT&T already receives as part of its own operations. Because Frontier would have to significantly upgrade its existing, primarily middle-mile fiber network to reduce the amount of copper wiring in its network, the company faces significant capital investment costs wherever it chooses to deploy the more advanced broadband network.

Wilderotter hinted Frontier’s plans for the enhanced technology would be limited to a handful of cities.

“It doesn’t make sense in all of our markets,” she said. “It’s only a handful of markets other than where we have FiOS today. So there’s more to come on that over time. Video is very important. We think over the top video is probably more important than anything else.”

The most likely target for any IPTV expansion would be Frontier’s western New York operation in and around Rochester, where the company currently competes against Time Warner Cable with a mediocre DSL product that can no longer compete with the cable operator’s superior speeds and pricing promotions.  Frontier is steadily losing market share in most of its more-populated service areas.

Other likely targets for expanded broadband include larger cities in Pennsylvania, Illinois, West Virginia, and California.

Frontier's Broadband Customers (as of 12/31/11)

Chief Operating Officer Daniel McCarthy added Frontier also has plans to improve broadband speeds in most of its service areas.

“We’ve been working pretty steadily to improve the core network around the country,” McCarthy said. “You’ll see us aggressively move forward with sort of VDSL and bonded ADSL2 copper.”

Currently, Frontier only informally offers bonded service to residential customers in very limited areas, notably in parts of the Genesee Valley in western New York.  The company has been marketing an extra line of traditional ADSL service to customers elsewhere who want more broadband capacity, but that requires a second broadband modem and delivers no speed improvements.

Frontier’s time frame to deploy enhanced speeds in within 12-24 months, according the company officials.

In other developments, Frontier Communications customers formerly served by Verizon will likely find themselves choosing new service plans as Frontier prepares to migrate customers away from legacy Verizon service packages.

Wilderotter telegraphed that affected Frontier customers will see some rate increases when the new plans become effective.

“We do think that there is a pretty substantial revenue upside,” Wilderotter said. “We think the net-net is we’ll get customers on the right portfolio of products that will also be revenue enhancing for the company and we’re going to surround the products with the right kind of service experience, both online and off-line. We’re redesigning all of our online product sets for a better customer experience so they can manage their own broadband usage and actually upgrading or changing what they do with broadband themselves, if in fact, they want to do that.”