Broadband Data and Mapping: Background
May 19, 2021
and Issues for the 117th Congress
Colby Leigh Rachfal
Access to high-speed internet service, also known as broadband, is increasingly important in the
Analyst in
21st century, as more aspects of everyday life, such as job applications, bank transactions, and
Telecommunications
homework assignments, are completed online. Broadband is provided by a variety of
Policy
technologies (e.g., cable, telephone wire, fiber, satellite, and mobile and fixed wireless) that give

users the ability to send and receive data at volumes and speeds that support data-intensive
activities such as voice communications, streaming audio and video, telemedicine, distance

education, and telework.
Broadband technologies are currently being deployed, primarily by the private sector, throughout the United States. Some
areas of the United States—particularly rural and tribal areas, but also some urban areas—have limited or no access to
broadband due to geographic and socio-economic factors. The gap between those who have access to broadband and those
who do not is referred to as the digital divide. Some policymakers, believing that disparities in broadband access across
American society could have adverse economic and social consequences on those left behind, assert that the federal
government should play a more active role to address the digital divide in broadband access, particularly in light of the
Coronavirus Disease 2019 (COVID-19) pandemic, which further revealed discrepancies in broadband availability and
accessibility.
Since 2018, the FCC has had the primary responsibility for developing a comprehensive map of broadband access in the
United States. The data available to determine where to invest resources may be incomplete or inaccurate. For example, the
FCC’s current methodology considers a census block served if at least one home or business in that census block has
broadband access. In addition, the data is self-reported by broadband service providers. Though the main responsibility for
mapping broadband availability lies with the FCC, Congress has provided funding to the National Telecommunications and
Information Administration (NTIA) to develop a National Broadband Availability Map to help augment the FCC’s mapping
data. As of May 11, 2021, the National Broadband Availability Map includes 36 states (data from June 2020).
There is sustained congressional interest in increasing the accuracy of broadband data and mapping. Accurate maps help
policymakers to make informed decisions about where federal funds should be directed and enable federal agencies to fulfill
certain statutory requirements, such as the FCC’s annual “reasonable and timely deployment” determination, as required by
the Telecommunications Act of 1996 (P.L. 104-104). In response to congressional interest, the FCC adopted a Report and
Order in August 2019 introducing a new process for collecting fixed broadband data, called the Digital Opportunity Data
Collection (DODC). On March 23, 2020, Congress enacted the Broadband Deployment Accuracy and Technological
Availability Act or the Broadband DATA Act (P.L. 116-130), which requires the FCC to change the way broadband data is
collected, verified, and reported, and codifies many components of the FCC’s DODC.
As the FCC implements the Broadband DATA Act, Congress has a wide variety of options for oversight and legislation. For
example, Congress may continue to consider issues such as the optimal level of data granularity and whether the
incorporation of additional variables into the map may be beneficial for policymakers. To assist with future federal action,
Congress may take into consideration state broadband mapping efforts, which could provide additional insight into models
that could be replicated on a national scale.
Congress may consider whether federal funding for broadband expansion should be withheld until new maps are established,
or whether to continue addressing the digital divide––especially in light of the COVID-19 pandemic—using current maps
while more accurate ones are being developed. Congress may also consider whether the FCC’s Fixed Broadband Deployment
Map should be updated more frequently than every six months so that data reflects continuing network changes and, if so,
whether that would impose a significant reporting burden on broadband service providers. As the new data collection efforts
progress, Congress may consider how much in additional appropriations might be required to establish the maps and sustain
the mapping efforts annually.
Bills addressing some of these broadband mapping issues have been introduced in the 117th Congress, including the
Broadband—Measuring Availability and Aligning Policies Task Force Act (H.R. 1044), introduced in the House on February
15, 2021, and the Data Mapping to Save Moms’ Lives Act (S. 198/H.R. 1218), introduced in the Senate on February 3, 2021,
and in the House on February 23, 2021.
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Broadband Data and Mapping: Background and Issues for the 117th Congress

Introduction
Mapping broadband availability,1 which means graphically displaying where broadband is and is
not available on a map, is complex and depends on data—with the accuracy of the map
depending on the accuracy of the data used to compose the map. Congress has an interest in
accurate broadband mapping data, because accurate data can help ensure that federal programs
that finance broadband deployment target areas of the country that are most in need of assistance.
The Telecommunications Act of 1996 (P.L. 104-104) requires the Federal Communications
Commission (FCC) to determine annually whether broadband is being deployed to all Americans
on a timely basis, and the FCC relies on broadband mapping data to make this determination.
Additionally, the FCC uses broadband mapping data to direct billions of dollars per year to
deploy broadband in unserved or underserved areas. Congress has also taken an interest in
broadband mapping due to concerns from constituents that certain areas, especially rural areas,
remain underserved or unserved.
Pinpointing where broadband is and is not available in the United States has been an ongoing
challenge. Current data on broadband availability is provided by private telecommunications
providers, collected by the FCC, and displayed on the FCC’s Fixed Broadband Deployment
Map.2 Difficulty in accurately mapping broadband availability has been attributed to a number of
factors, including the potential inadequacy of census block data, the lack of independent data
validation outside the FCC, and the absence of a challenge process for consumers and other
entities that believe the Fixed Broadband Deployment Map may overstate availability in their
areas. In early 2019, it came to the FCC’s attention that inaccuracies in the Fixed Broadband
Deployment Map’s data may cause broadband deployment to be overstated, possibly indicating
that areas have access to broadband when, in reality, they do not. Inaccurate data on broadband
deployment could lead to overbuilding in areas that currently have broadband while leaving other
areas underserved or unserved.
On March 23, 2020, the Broadband Deployment Accuracy and Technological Availability Act or
Broadband DATA Act (P.L. 116-130) was enacted, which requires the FCC to change the way
broadband data is collected, verified, and reported. Congress may consider oversight of FCC
efforts to implement the provisions of the Broadband DATA Act and whether additional
legislative actions related to broadband mapping might be necessary.
Broadband Defined
The term broadband commonly refers to high-speed internet access that is faster than dial-up
access. Broadband includes several high-speed transmission technologies, such as:
 digital subscriber line (DSL),
 cable modem,
 fiber,
 wireless,
 satellite, and

1 Broadband availability refers to whether or not broadband service is offered, while broadband adoption refers to the
extent to which American households actually subscribe to and use broadband.
2 Federal Communications Commission, Fixed Broadband Deployment, available at https://broadbandmap.fcc.gov/.
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 broadband over power lines (BPL).3
The internet became publicly available in the 1990s and has evolved since that time as more
information has become digital (e.g., many job applications and government forms have moved
online). However, not all Americans currently have access to broadband.
As methods to access the internet have evolved, so have speeds, with the FCC’s current
broadband benchmark speed set at 25 megabits per second (Mbps) download and 3 Mbps upload
(25/3). Table 1 shows how the FCC’s broadband definition has changed from what was initially
adopted in 1996 to its current definition, which was adopted in 2015.
Table 1. FCC Broadband Definitions over Time
Year Adopted
Minimum Download
Minimum Upload
1996
200 Kbps
200 Kbps
2010
4 Mbps
1 Mbps
2015
25 Mbps
3 Mbps
Source: Jameson Zimmer, “FCC Broadband Definition Has Changed Before and Wil Change Again,”
BroadbandNow, February 10, 2018, available at https://broadbandnow.com/report/fcc-broadband-definition/.
Notes: Mbps means megabits per second and Kbps means kilobits per second.
The Urban/Rural Digital Divide
The term digital divide refers to a gap between those Americans who use or have access to
telecommunications and information technologies and those who do not.4 While broadband
service providers continue to make progress in expanding high-speed broadband service,
according to the FCC the rate of broadband deployment in urban areas has outpaced deployment
in rural and tribal areas.5 Broadband is deployed primarily by the private sector. The
comparatively lower population density of rural and tribal areas and, in some cases, difficult
topography contributes to lower broadband penetration rates relative to more highly populated
urban and suburban areas. Particularly for wireline broadband technologies—such as cable
modem and fiber optic cable—greater geographical distance between customers in sparsely
populated areas results in the inability to spread infrastructure costs over a larger subscriber base.
Thus, there is often less incentive for companies to invest in broadband in rural areas than in
urban areas. The primary goal of broadband mapping is to identify areas without access to
broadband so that policymakers can make informed decisions on policies to address the
urban/rural digital divide.

3 DSL uses copper telephone wires. Cable modem uses coaxial cables—the same used for cable television. Fiber uses
pulses of light shot by lasers through thin strands of glass. Wireless uses a radio connection between the consumer and
the service provider’s terrestrial antennae. Satellite uses a radio connection to a space-based antenna. BPL uses power
lines to deliver broadband to consumers. For further information, see Federal Communications Commission, Types of
Broadband Connections, June 23, 2014, available at https://www.fcc.gov/general/types-broadband-connections.
4 For more information on the digital divide, see CRS Report R46613, The Digital Divide: What Is It, Where Is It, and
Federal Assistance Programs, by Colby Leigh Rachfal.
5 Federal Communications Commission, Fourteenth Broadband Deployment Report, January 19, 2021, p. 4, available
at https://docs.fcc.gov/public/attachments/FCC-21-18A1.pdf.
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Federal Agency Roles in Broadband Mapping
The major federal agencies involved in broadband mapping are the U.S. Department of
Agriculture (USDA), the National Telecommunications and Information Administration (NTIA)
in the Department of Commerce, and the FCC. Though the main responsibility for mapping
broadband availability lies with the FCC, Congress has provided funding to NTIA to help
augment the FCC’s data in identifying regions with insufficient broadband service. Additionally,
the USDA manages multiple maps that depict eligibility for their federal broadband programs to
help determine where to direct federal resources.
U.S. Department of Agriculture
USDA’s Rural Utilities Service (RUS) oversees federal programs that fund the deployment of
broadband infrastructure. To help determine where to direct federal resources, RUS manages
multiple maps that show data related to RUS broadband program eligibility. For example, RUS’
Broadband Program Mapping Tool is used by:
 existing borrowers or those interested in applying for funding under the
Infrastructure Loan Program, Broadband Access Loan and Loan Guarantee
Program, or Community Connect Grant Program, enabling them to draw existing
or proposed service area maps;
 RUS to post Public Notices of proposed funded service areas for pending loan
applications, as well as by existing service providers to submit information on
their service offerings;
 other entities that wish to upload an authenticated map of existing broadband
services.6
RUS’ other mapping tools show the locations of RUS-financed broadband projects.7 For example,
RUS developed the ReConnect Program Eligibility Area Map to assist in the determination of
service area eligibility for the ReConnect Program across the United States. Congress established
the ReConnect Program––which provides loan and grant funding to eligible entities to deploy
broadband internet service in eligible rural areas––under the Consolidated Appropriations Act,
2018 (P.L. 115-141).8 The ReConnect Program Eligibility Area Map displays categories of data
including the FCC’s Connect America Fund winners, nonrural areas, pending applications, and
protected broadband borrower service areas.9

6 U.S. Department of Agriculture, Broadband Program Mapping Tool, available at
https://broadbandsearch.sc.egov.usda.gov/.
7 See U.S. Department of Agriculture, Telecom Maps, available at https://www.rd.usda.gov/programs-services/all-
programs/telecommunications-programs/telecom-maps; U.S. Department of Agriculture, ReConnect Program
Eligibility Area Map, available at https://www.usda.gov/reconnect.
8 For more information on the ReConnect Program, see CRS In Focus IF11262, USDA’s ReConnect Broadband Pilot
Program, by Alyssa R. Casey.
9 Rural Utilities Service, Broadband Pilot (ReConnect) Program, 84 Federal Register 14911, April 12, 2019, available
at https://www.federalregister.gov/documents/2019/04/12/2019-07345/broadband-pilot-reconnect-program.
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National Telecommunications and Information Administration
The Broadband Data Improvement Act (P.L. 110-385), enacted on October 10, 2008, directed the
Department of Commerce to establish a state broadband data and development grant program.10
This program, known as the State Broadband Initiative (SBI), was administered by NTIA, an
agency in the Department of Commerce, and funded under the American Recovery and
Reinvestment Act of 2009 (P.L. 111-5). One of the purposes of the program was to assist states in
gathering data twice a year on the availability, speed, and location of broadband service as well as
on the broadband services used by community institutions, such as schools, libraries, and
hospitals. This data was used to establish the National Broadband Map, the first public,
searchable, nationwide map of broadband availability, which was launched in 2011.11
Through the SBI program, NTIA awarded a total of $293 million to 56 grantees—one from each
of the 50 states, five territories, and the District of Columbia. The grantees were required to use
the funds to promote broadband adoption and access tailored to their local needs and to collect
broadband-related data and provide it to NTIA. The SBI program collected its final data as of
June 30, 2014, and in 2015, the program ended.
In the Consolidated Appropriations Act of 2018 (P.L. 115-141), Congress provided $7.5 million to
NTIA to develop a National Broadband Availability Map. Specifically, Congress directed NTIA
to acquire and display available third-party data sets to augment data from the FCC, other federal
government agencies, state governments, and the private sector. The stated objective of this
funding was “to help identify regions with insufficient service, especially in rural areas.”12
In response, NTIA announced in February 2019 it had partnered with eight states—California,
Maine, Massachusetts, Minnesota, North Carolina, Tennessee, Utah, and West Virginia—for a
pilot to improve the FCC’s Fixed Broadband Deployment Map. The first phase of NTIA’s new
National Broadband Availability Map was published in October 2019. It is available only to state
and federal partners due to the inclusion of nonpublic data, which may be business sensitive or
have other restrictions that prevent public disclosure.13 As of May 11, 2021, the National
Broadband Availability Map includes 36 states.14

10 P.L. 110-385 directed, but did not authorize appropriations for, the establishment of a state broadband data and
development grant program.
11 National Telecommunications and Information Administration, State Broadband Initiative, available at
https://www2.ntia.doc.gov/SBDD.
12 “Joint Explanatory Statement,” Congressional Record, vol. 164, part 50—Book II (March 22, 2018), pp. H2084-
H2085.
13 National Telecommunications and Information Administration, National Broadband Availability Map, October 2,
2019, available at https://broadbandusa.ntia.doc.gov/map.
14 These states include Alaska, Arizona, California, Colorado, Connecticut, Florida, Georgia, Hawaii, Idaho, Illinois,
Kansas, Indiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska,
New Hampshire, New Mexico, New York, North Carolina, Oklahoma, Oregon, South Dakota, Tennessee, Utah,
Vermont, Virginia, Washington, West Virginia, Wisconsin, and Wyoming. For more information see BroadbandUSA,
NTIA’s NBAM Reaches 36 State Milestone, May 11, 2021, available at https://broadbandusa.ntia.doc.gov/node/7413.
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Federal Communications Commission
In 2000, the FCC established the Form 477 Data Program to collect from providers “data
regarding broadband services, local telephone service competition, and mobile telephony services
on a single form and in a standardized manner.”15
The FCC collects data on both fixed and mobile broadband availability through Form 477. It does
not combine the two sets of data into a single map; rather, it uses the fixed data to create the Fixed
Deployment Broadband Map, and it has used the mobile broadband data to determine which areas
were eligible for the Mobility Fund Phase II program (see “Directing Federal Assistance” below).
Form 477 Fixed Broadband Data Methodology
Every six months, all facilities-based providers16 of fixed broadband are required to submit a list
of all census blocks where they provide, or could provide, fixed broadband service to at least one
location. For each census block, the provider is required to submit data specifying the last-mile
technology used;17 whether the provider can or does offer consumer, mass market, or residential
service; the maximum advertised download and upload speeds for consumer service; and whether
the service is also available for business, enterprise, or government customers.18
In 2017, the FCC acknowledged some shortcomings of this methodology:
Facilities-based providers of fixed broadband must provide in their Form 477 submissions
a list of all census blocks where they make broadband connections available to end-user
premises, along with the last-mile technology or technologies used. These deployment data
represent the areas where a provider does, or could, without an extraordinary commitment
of resources, provide service. Thus, the meaning of “availability” in each listed census
block can be multifaceted, even within the data of a single filer. In a particular listed block,
the provider may have subscribers or it may not. At the same time, the provider may be
able to take on additional subscribers or it may not. The various combinations have varying
implications that make it difficult to understand availability. Specifically, if a block was
listed by a provider, it is impossible to tell whether residents of that block seeking service
could turn to that provider for service or whether the provider would be unable or unwilling
to take on additional subscribers. This may limit the value of these data to inform our
policymaking and as a tool for consumers and businesses to determine the universe of
potential broadband service providers at their location.19

15 Federal Communications Commission, In the Matter of Modernizing the FCC Form 477 Data Program, June 27,
2013, p. 3, available at https://docs.fcc.gov/public/attachments/FCC-13-87A1.doc.
16 A facilities-based provider is a provider that owns (as opposed to leases) networks used to provide
telecommunications services.
17 Last mile refers to the type of connection between a broadband service provider and the consumer (e.g., fiber or
cable).
18 For a more detailed list of the data elements required, see Federal Communications Commission, Explanation of
Broadband Deployment Data, May 1, 2019, available at https://www.fcc.gov/general/explanation-broadband-
deployment-data.
19 Federal Communications Commission, FCC Proposes Improvements to Broadband/Voice Services Data Collection,
pp. 11-12, available at https://www.fcc.gov/document/fcc-proposes-improvements-broadbandvoice-services-data-
collection-0.
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Form 477 Mobile Broadband Data Methodology
The collection of accurate and reliable mobile broadband data is particularly challenging because
a user’s mobile wireless experience varies and is affected by factors such as terrain, user location,
weather, network congestion, and the type of connected service. Under Form 477 filing rules,
facilities-based providers of mobile broadband service are required to submit and certify, for each
technology and frequency band employed, polygons in shapefiles20 that digitally represent the
geographic areas in which a customer could expect to receive at least the minimum speed the
provider advertises for that area. Additionally, mobile broadband providers must report the census
tracts in which their service is advertised and available to potential customers.21
Digital Opportunity Data Collection and the Broadband DATA Act
In August 2019, the FCC adopted a Report and Order introducing the Digital Opportunity Data
Collection (DODC), which is intended to address many of the issues that currently lead to
inaccurate broadband mapping data.22 On March 23, 2020, the Broadband Deployment Accuracy
and Technological Availability Act or Broadband DATA Act (P.L. 116-130) was enacted. This law
requires the FCC to change the way it collects, verifies, and reports broadband data. Specifically,
the act directs the FCC to:
 Collect and disseminate granular broadband service availability data from wired, fixed-
wireless, satellite, and mobile broadband providers. To do this, the FCC is required to
establish the Broadband Serviceable Location Fabric (a dataset of geocoded information
for all broadband service locations, atop which broadband maps are overlaid) as the
vehicle for reporting broadband service availability data.
 Put forth specified requirements for service availability data collected from broadband
providers, and create a process to enable the submission of independent data to challenge
the accuracy of FCC broadband maps.
 Conduct regular audits of information submitted by telecommunications providers, and
develop a process whereby entities or individuals may submit information about the
deployment and availability of broadband service to verify and supplement information
submitted by providers.
 Provide data collection and submission assistance to Indian tribes; small service
providers; consumers; and state, local, and tribal governments.
The Broadband DATA Act codifies many––but not all––aspects of the DODC. For example, the
DODC proposed to have the Universal Service Administrative Company (USAC)23 create and
manage a challenge portal that will allow individual consumers, as well as state, local, and tribal

20 Shapefiles are a data storage format for recording data associated with particular geographic locations. A polygon in
a shapefile indicates the boundaries of the geographical area to which a particular set of data applies. For more
information on how the FCC uses polygons in shapefiles for mobile broadband mapping, see Federal Communications
Commission, Mobile Broadband Deployment, June 23, 2014, available at https://transition.fcc.gov/form477/MBD/
definitions_mbd.pdf.
21 Federal Communications Commission, FCC Proposes Improvements to Broadband/Voice Services Data Collection,
August 4, 2017, p. 2, available at https://www.fcc.gov/document/fcc-proposes-improvements-broadbandvoice-services-
data-collection-0.
22 Federal Communications Commission, Digital Opportunity Data Collection (DODC), available at
https://www.fcc.gov/digital-opportunity-data-collection-dodc. See also “Broadband Mapping Challenges and
Criticisms” section in this report.
23 USAC is an independent not-for-profit designated by the FCC to administer the Universal Service Fund.
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government entities to submit input on the accuracy of the data on the public fixed broadband
availability map. The act prohibits the FCC from delegating mapping responsibilities to USAC.
In a July 16, 2020, statement, FCC Chairman Ajit Pai stated that funding from Congress is needed
to implement requirements in the Broadband DATA Act.24 On December 27, 2020, the
Consolidated Appropriations Act, 2021 (CAA 2021; P.L. 116-260), appropriated $98 million for
this purpose.
Implementation of the Broadband DATA Act
With the appropriation of funds in the CAA 2021, the FCC has moved forward with preliminary
initiatives to implement the provisions within the act. Some of these initiatives include:
 On January 13, 2021, the FCC adopted rules to specify which fixed and mobile
broadband service providers are required to report availability and/or coverage
data; requirements for reporting speed and latency for fixed technologies; and a
requirement for fixed broadband providers to report whether broadband services
are offered to residential and/or business customers.25
 On February 17, 2021, the FCC announced the establishment of a Broadband
Data Task Force dedicated to implementing improvements to the broadband data
and mapping tools.26
 On March 8, 2021, the FCC issued a Request for Information to start the
contracting process for the creation of the Broadband Serviceable Location
Fabric.27
 On March 22, 2021, the FCC announced a new outreach effort to collect
consumer broadband availability experiences.28
In the FCC February 2021 Open Commission Meeting, the FCC indicated the new broadband
maps may not be ready until 2022.29
Why Broadband Mapping Accuracy Matters
Accurate broadband data and mapping helps policymakers to make informed decisions about
where federal funding should be directed––such as with Phase II of the FCC’s Rural Digital
Opportunity Fund and 5G for Rural America Fund––and enables federal agencies to fulfill certain

24 Federal Communications Commission, Pai Statement: FCC Improves Broadband Data and Maps to Bridge the
Digital Divide, press release, July 16, 2020, available at https://www.fcc.gov/document/fcc-improves-broadband-data-
and-maps-bridge-digital-divide/pai-statement.
25 Federal Communications Commission, FCC Takes Next Step to Collect More Precise Broadband Mapping Data,
January 19, 2021, available at https://www.fcc.gov/document/fcc-takes-next-step-collect-more-precise-broadband-
mapping-data.
26 Federal Communications Commission, Rosenworcel Establishes Broadband Data Task Force, February 17, 2021,
available at https://www.fcc.gov/document/rosenworcel-establishes-broadband-data-task-force.
27 Federal Communications Commission, A Running Start on New Broadband Maps, March 16, 2021, available at
https://www.fcc.gov/news-events/notes/2021/03/16/running-start-new-broadband-maps.
28 Federal Communications Commission, FCC Announces New Outreach To Collect Consumer Broadband Availability
Experiences, March 22, 2021, available at https://docs.fcc.gov/public/attachments/DOC-370978A1.pdf.
29 Federal Communications Commission, February 2021 Open Commission Meeting, February 17, 2021, available at
https://www.fcc.gov/news-events/events/2021/02/february-2021-open-commission-meeting.
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statutory requirements, such as the FCC’s annual “reasonable and timely deployment”
determination.
Directing Federal Assistance
Accurate maps are important in federal funding decisions designed to target areas where
broadband is needed the most. Without accurate data, maps may not be reliable indicators of
need, and federal assistance may be provided to areas that already have adequate broadband
services. This may result in overbuild in some areas and neglect of other areas, further widening
the disparities between areas that are served and those that are not.
Whether the current FCC broadband map was granular enough to direct federal assistance was an
issue of disagreement between FCC Commissioners for the FCC’s Rural Digital Opportunity
Fund (RDOF).30 Through RDOF, the FCC plans to commit $20.4 billion to bring high-speed
fixed broadband service to rural homes and small businesses in two phases. For Phase I, the FCC
used its current, less granular broadband map data to determine the wholly unserved areas eligible
for the auction.31 In the January 30, 2020, RDOF Report and Order, former FCC Commissioner
and current FCC Acting Chairwoman Jessica Rosenworcel stated,
We need maps before money and data before deployment. With today’s decision we
commit the vast majority of universal service funds—$16 billion!—for the next ten years
without first doing anything to improve our maps, survey service accurately, or fix the data
disaster we have about the state of service today. That means if your home is marked as
served by the FCC’s maps today and it is not, then for the next decade you are on your
own. Good luck. It means millions of Americans will slip deeper into the digital divide.32
Upon adoption of new rules for the DODC on July 16, 2020, FCC Commissioner Brendan Carr
stated
On the bright side, our Form 477 data are good at identifying areas that are completely
unserved. And that’s why I am glad the FCC is moving ahead with Phase I of the Rural
Digital Opportunity Fund, which can ensure that Americans living in those unserved areas
need not wait any longer than necessary to receive high-speed service.33
The Phase I auction began on October 29, 2020, and the FCC announced the results on December
7, 2020—180 bidders won $9.2 billion to deploy high-speed broadband to over 5.2 million
unserved homes and businesses.34 On May 6, 2021, the advocacy group Competitive Carriers
Association (CCA) submitted a letter to the FCC regarding an analysis CCA conducted that found
RDOF awards may go to areas that already have broadband service. CAA stated,
The premise of RDOF Phase I was to target areas that the Commission “knew with
certainty” were “currently unserved,” so the proceeding therefore did not need to await a

30 For more information on RDOF see CRS Report R46501, Rural Digital Opportunity Fund: Requirements and
Selected Policy Issues, by Colby Leigh Rachfal.
31 For Phase II of RDOF, the FCC plans to use broadband mapping data from the maps required to be established under
the Broadband Deployment Accuracy and Technological Availability Act (P.L. 116-130).
32 Federal Communications Commission, Statement of Commissioner Jessica Rosenworcel, January 30, 2020, p. 2,
available at https://docs.fcc.gov/public/attachments/FCC-20-5A5.pdf.
33 Federal Communications Commission, Statement of Commissioner Brendan Carr, Re: Establishing the Digital
Opportunity Data Collection, available at https://docs.fcc.gov/public/attachments/FCC-20-94A4.pdf.
34 Federal Communications Commission, Successful Rural Digital Opportunity Fund Auction To Expand Broadband
To Over 10 Million Rural Americans, December 7, 2020, available at https://docs.fcc.gov/public/attachments/DOC-
368588A1.pdf.
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new data collection process to produce updated broadband maps. But the premise is
incorrect; deficient mapping means that instead of supporting areas that lack service, the
Commission’s RDOF program will subsidize broadband deployment in areas that
obviously are served—including some of the nation’s wealthiest, most densely populated
areas.35
An example of how inaccurate data has affected eligibility for federal assistance occurred in the
FCC’s Mobility Fund II (MF-II) program, which would have made up to $4.53 billion in support
available over 10 years to primarily rural areas that lacked unsubsidized 4G Long Term Evolution
(LTE) service. The FCC published initial eligibility maps for MF-II in August 2018 and in
December 2018, the FCC announced it would launch an investigation into whether one or more
major carriers violated the Mobility Fund reverse auction’s mapping rules and submitted incorrect
coverage maps.36 In December 2019, the FCC released MF-II Coverage Maps Investigation Staff
Report, which found that the coverage data submitted by three providers likely overstated actual
coverage in many instances.37 The FCC proposed to both terminate the MF-II challenge process
and replace MF-II with the 5G Fund for Rural America, which plans to distribute $9 billion over
the next decade to bring 5G wireless broadband connectivity to rural America. The 5G Fund will
use improved mobile broadband coverage data gathered in the FCC’s Digital Opportunity Data
Collection proceeding.38
Reasonable and Timely Deployment Determination
The Telecommunications Act of 1996 (P.L. 104-104) requires the FCC to “initiate a notice of
inquiry concerning the availability of advanced telecommunications capability to all Americans.”
In conducting this inquiry, the FCC must “determine whether advanced telecommunications
capability is being deployed to all Americans in a reasonable and timely fashion.” If that
determination is negative, the commission “shall take immediate action to accelerate deployment
of such capability by removing barriers to infrastructure investment and by promoting
competition in the telecommunications market.”39
Using data from Form 477, the FCC develops an annual Broadband Deployment Report, also
referred to as the Section 706 Report, in which the FCC evaluates the availability of fixed and
mobile broadband services. In its 2021 analysis, the FCC made a Section 706 finding that
advanced telecommunications capability is being deployed to all Americans in a reasonable and
timely fashion. This finding was supported by Commissioner Brendan Carr, with Commissioners
Jessica Rosenworcel and Geoffrey Starks dissenting.40 The 2021 report noted, “While some ...

35 Competitive Carriers Association, Re: Establishing the Digital Opportunity Data Collection, WC Docket No. 19-195;
Modernizing the FCC Form 477 Data Program, WC Docket No. 11-10; Rural Digital Opportunity Fund (Auction 904),
AU Docket No. 20- 34; Rural Digital Opportunity Fund, WC Docket No. 19-126; Connect America Fund, WC Docket
No. 10-90; Telecommunications Carriers Eligible to Receive Universal Service Support, WC Docket No. 09-197, May
6, 2021, p. 1, available at https://irp.cdn-website.com/cd1ed710/files/uploaded/6%20May%202021%20CCA%20Ex
%20Parte%20%26%20White%20Paper.pdf.
36 Tina Pelkey, FCC Launches Investigation into Potential Violations of Mobility Fund Phase II Mapping Rules,
December 7, 2018, available at https://docs.fcc.gov/public/attachments/DOC-355447A1.pdf.
37 Federal Communications Commission, Mobility Fund Phase II (MF-II), May 18, 2020, available at
https://www.fcc.gov/mobility-fund-phase-ii-mf-ii.
38 Federal Communications Commission, FCC Establishes 5G Fund for Rural America, October 27, 2020, available at
https://docs.fcc.gov/public/attachments/DOC-367778A1.pdf.
39 47 U.S.C. §1302(b).
40 FCC, Fourteenth Broadband Deployment Report, January 19, 2021, pp. 288-290, available at https://docs.fcc.gov/
public/attachments/FCC-21-18A1.pdf.
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have criticized the FCC Form 477 data for overstating deployment ... the degree of overstatement
is proportionately inconsequential to the broader conclusions and trends.”41
Broadband Mapping Challenges and Criticisms
The FCC’s difficulty mapping broadband availability has been attributed to a number of factors,
including data granularity, overstated availability, lack of a validation and challenge process, and
the difficulty of keeping up with real-time deployments.
Data Granularity
The FCC requires each broadband service provider to submit information on the services it offers
at the census block level. Census blocks are the smallest unit of geography defined by the Census
Bureau and are “statistical areas bounded by visible features, such as streets, roads, streams, and
railroad tracks, and by nonvisible boundaries, such as selected property lines and city, township,
school district, and county limits and short line-of-sight extensions and roads.”42 Census blocks
vary in size and population, and their geographical area can be especially large in some parts of
the United States. For example, according to the U.S. Census Bureau, in remote areas, census
blocks may encompass hundreds of square miles.43
For the purposes of Form 477, the FCC considers a census block served if even one house or
business in the block is served. Since some rural census blocks may encompass hundreds of
square miles and include geographically dispersed communities or individual residences, the
availability of service in one part of the census block is less likely to indicate general broadband
availability across the block than in smaller, more densely-populated census blocks.
With the use of census blocks, areas within a large block that might otherwise be eligible for
federal assistance may not be considered eligible. The Utah Governor’s Office of Economic
Development told the NTIA:
Basing data collection, planning efforts, and funding decisions on census blocks is
problematic, particularly in blocks which are large, remote, and include terrain that makes
it difficult to install infrastructure. For example, in Utah, the largest populated census block
is 947 square miles. Under the current Form 477 submission process, any census block that
is partially covered would be ineligible for all federal broadband programs, even if only a
small percentage of households or census block area is covered.44
Overstated Availability
Although staff examine FCC Form 477 data for quality and consistency, the FCC acknowledges
that the data may understate or overstate deployment of services to the extent that broadband

41 Ibid., p. 55.
42 Federal Communications Commission, More About Census Blocks, March 26, 2015, available at
https://transition.fcc.gov/form477/Geo/more_about_census_blocks.pdf.
43 U.S. Census Bureau, Glossary, September 16, 2019, available at https://www.census.gov/programs-surveys/
geography/about/glossary.html.
44 Kelleigh Cole, “Comments on (NTIA) Docket No. 180427421‐8421‐01, Improving the Quality and Accuracy of
Broadband Availability Data, Utah Governor’s Office of Economic Development, June 18, 2016, pp. 1-2, available at
https://www.ntia.doc.gov/files/ntia/publications/2018_ntia_mapping_comments_utah.pdf.
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providers misreport or fail to report.45 As an example, on September 2, 2020, the FCC proposed a
$163,912 fine against broadband service provider Barrier Communications Corporation for
reporting inaccurate information that significantly inflated its broadband subscription numbers,
failing to file required deployment data, making false statements to Commission investigators,
and failing to respond to other inquiries.46
In April 2019, Microsoft asserted that the percentage of Americans without broadband access is
much higher than the figures reported by the FCC. Microsoft claimed that although the FCC
indicates that 24.7 million people do not have broadband available, Microsoft’s own data
indicates that 162.8 million people do not use the internet at broadband speeds of 25 Mbps or
more.47 Microsoft released a map showing differences between the FCC’s claimed broadband
access and actual usage of broadband. NCTA—The Internet and Television Association—
criticized this analysis, saying that it “conflates availability and usage” and, as a result, draws “a
number of unsupportable conclusions.”48
Lack of Validation and Challenge Process
Broadband service providers self-report information on Form 477. Although the FCC reviews the
data, it is not verified independently outside of the agency. There is also no challenge process in
place if a consumer, provider, or other entity identifies any of the data as potentially inaccurate.
Stakeholders who testified at an April 2019 hearing before the Senate Committee on Commerce,
Science, and Transportation asserted that a challenge process is needed, citing the problems with
the FCC’s mobility fund auction and how it was difficult for wireless carriers to challenge mobile
broadband availability data that the FCC had intended to use as a basis for awarding funding.49
Real-Time Deployments
The telecommunications industry is fluid––broadband service providers are constantly changing
(e.g., through mergers and acquisitions), building new networks, or revising older networks. The
FCC currently updates the Fixed Broadband Deployment Map twice a year, but the map reflects
data that is approximately a year or more behind the current date––this is likely due to the time it
may take for the FCC to process the data it receives from broadband service providers. For
example, as of May 2021, the map reflects June 2020 data.

45 Federal Communications Commission, 2019 Broadband Deployment Report, May 8, 2019, p. 12, available at
https://docs.fcc.gov/public/attachments/FCC-19-44A1.pdf.
46 Federal Communications Commission, FCC Proposes to Fine Broadband Provider for Reporting Overstated Service
Data to Commission, press release, September 2, 2020, p. 1, available at https://docs.fcc.gov/public/attachments/DOC-
366634A1.pdf.
47 John Kahan, It’s Time for a New Approach for Mapping Broadband Data to Better Serve Americans, Microsoft,
April 8, 2019, available at https://blogs.microsoft.com/on-the-issues/2019/04/08/its-time-for-a-new-approach-for-
mapping-broadband-data-to-better-serve-americans/.
48 Victor Reklaitis, It’s Microsoft vs. Comcast in Infrastructure Push to Expand Rural Broadband, Market Watch, May
20, 2019, available at https://www.marketwatch.com/story/its-microsoft-vs-comcast-in-infrastructure-push-to-expand-
rural-broadband-2019-05-06.
49 U.S. Congress, Senate Committee on Commerce, Science, and Transportation, Broadband Mapping: Challenges and
Solutions, testimony of Tim Donovan, SVP, Legislative Affairs, Competitive Carriers Association, 116th Cong., April
10, 2019, available at https://www.commerce.senate.gov/public/_cache/files/335dcd54-07d6-4140-a286-0b59f6527f6b/
C2717D2DE1A24F364CAC37068A0EF5CE.04-10-19donovan-testimony.pdf.
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For the Digital Opportunity Data Collection, the Broadband DATA Act requires the FCC to
update the broadband maps at least every six months,50 as well as with any updates or corrections,
to meet the Broadband DATA Act’s requirement to use the most recent data collected from
providers. To achieve this, the FCC is to direct its Office of Economics and Analytics to update
the maps as quickly as possible after the filing deadlines of March 1 and September 1 each year
and to update the maps continually based on the outcomes of challenges, investigations, and
inquiries, including those informed by crowdsourced data as that information becomes
available.51 Using the most recent data available and updating the maps as quickly as possible
may help to address the issue of older data being displayed on the map. However, the map will
likely not reflect real-time broadband deployments, and the data may not be as accurate as
possible, since broadband service could have been deployed or improved since the most recent
data was submitted and mapped.
Policy Issues for Congress
As Congress continues to contemplate broadband mapping, it may consider:
 the optimal level of data granularity and potential inclusion of additional data
variables;
 whether to withhold federal funding for broadband until the new maps are
released;
 funding for sustainability of the Broadband DATA Act; and
 frequency of updates.
Granularity and Inclusion of Additional Data Variables
The Broadband DATA Act addresses the issue of granularity and requires the development and
use of a Broadband Serviceable Location Fabric, which would include precise coordinates of all
structures that have broadband. There are, however, additional questions Congress may consider
to ensure that broadband maps are regularly produced at the appropriate granularity and include
information that best inform policy decisions. Collecting and including additional data
variables—for example, data on broadband adoption or broadband subscription pricing––could
further assist policymakers in addressing the digital divide. As an example, the Data Mapping to
Save Moms’ Lives Act (S. 198/H.R. 1218 ), introduced in the Senate on February 3, 2021, and in
the House on February 23, 2021, would require the Federal Communications Commission to
incorporate data on maternal health outcomes into its broadband health maps. Some state
broadband offices collect and include variables in their maps that are not in the FCC’s Fixed
Broadband Deployment Map that could serve as models for federal mapping efforts. For
example:
 Kansas’ map shows service availability at the street level for broadband across
the state.52

50 The FCC’s Second Report and Order and Third Further Notice of Proposed Rulemaking states, “we establish a
biannual schedule for collection of broadband Internet access service availability and quality of service data. For this
purpose, we establish filing deadlines of March 1 and September 1 each year.”
51 Federal Communications Commission, Second Report and Order and Third Further Notice of Proposed Rulemaking,
July 16, 2020, p. 34, available at https://docs.fcc.gov/public/attachments/FCC-20-94A1.pdf.
52 ArcGIS, The Kansas Broadband Map, published July 31, 2019, available at https://www.arcgis.com/apps/
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 North Carolina has developed multiple broadband maps; among them is a map to
identify areas that are eligible for various grant programs aimed at expanding
broadband access across the state.53
 Hawaii’s map is populated with consumer-reported information on a home’s
wired (i.e., cable, DSL, fiber) internet speeds.54
Should Congress consider the inclusion of additional variables in the FCC’s Fixed Broadband
Deployment Map, the potential benefits and burdens of gathering and providing additional data
could be assessed through a targeted pilot program.
Withholding Federal Funds Until New Maps Are Released
As the FCC’s RDOF and MF-II demonstrated, there is a possibility federal funding may be
misallocated to areas that already meet the 25/3 Mbps broadband service minimum using current
maps, potentially limiting the ability to provide broadband to unserved and underserved
communities. Using the current FCC maps may potentially limit the effectiveness of new federal
broadband programs focused on addressing the digital divide that were enacted in CAA 2021
(P.L. 116-260) and the American Rescue Plan Act of 2021 (P.L. 117-2).
For example, Section 905 of CAA 2021 provided $300 million to the National
Telecommunications and Information Administration for grants to support broadband
infrastructure deployment to areas lacking broadband, especially rural areas.55 Section 905 of
CAA 2021 states,
The term “eligible service area” means a census block in which broadband service is not
available at 1 or more households or businesses in the census block, as determined by the
Assistant Secretary on the basis of—(A) the maps created under section 802(c)(1) of the
Communications Act of 1934 (47 U.S.C. 642(c)(1));56 or (B) if the maps described in
subparagraph (A) are not available, the most recent information available to the Assistant
Secretary, including information provided by the Commission.
If the broadband maps required under the Broadband DATA Act are not available by the time
NTIA administers this grant program, CAA 2021 directs the NTIA to use the most recent
available information, including information provided by the FCC. While NTIA anticipates
accepting grant applications for this program in summer 2021,57 the FCC has indicated new maps
may not be available until 2022. This may lead the NTIA to have to rely on the FCC’s current
broadband mapping data to make funding decisions. A consideration for Congress is whether the
need for more granular and accurate data justifies withholding federal broadband funding until
better maps are available or whether the goal of closing the digital divide is so pressing that
funding should proceed using currently available maps.

webappviewer/index.html?id=72ab65f4ac2c4207abd1e575fa148cb4.
53 North Carolina Broadband Infrastructure Office, Identification of Grant Eligible Locations, available at
https://nconemap.maps.arcgis.com/apps/webappviewer/index.html?id=72f01e944bde425ca07523d06a59c232.
54 Department of Commerce and Consumer Affairs, Hawaii Internet Speed Map, available at https://cca.hawaii.gov/
broadband/speedmap/.
55 BroadbandUSA, Overview of Consolidated Appropriations Act, 2021, available at https://broadbandusa.ntia.doc.gov/
resources/grant-programs.
56 47 U.S.C. 642(c)(1) refers to the broadband maps that are required to be created under the Broadband DATA Act.
57 BroadbandUSA, NTIA Grant Program: Broadband Infrastructure Webinar, Session 1, available at
https://broadbandusa.ntia.doc.gov/node/7411.
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Funding for Sustainability of Broadband Mapping
The Broadband DATA Act contains specific timelines for the FCC to carry out the requirements
of the act. The act requires the FCC to adopt final new mapping rules no later than September
2020––a deadline the FCC missed––which may have been due to lack of resources. Since the
passage of the Broadband DATA Act, the FCC has highlighted the need for funding from
Congress in order to implement the provisions within the act. According to then-FCC Chairman
Ajit Pai:
At this point, it is vital for Congress to provide the FCC as soon as possible with the
appropriations necessary to implement the Act. Right now, the FCC does not have the
funding to carry out the Act, as we have warned for some time. And given the Act’s
prohibition on the Universal Service Administrative Company performing this mapping
work, if Congress does not act soon, this well-intentioned legislation will have the
unfortunate effect of delaying rather than expediting the development of better broadband
maps.58
The Consolidated Appropriations Act, 2021, P.L. 116-260, provided $98 million to implement the
Broadband DATA Act. Congress may consider how much in additional appropriations might be
required to establish the maps and sustain the mapping efforts annually. Additionally, Congress
may debate whether to leave this task to the FCC, such as in the Broadband—Measuring
Availability and Aligning Policies Task Force Act (H.R. 1044), introduced on February 15, 2021,
which would require the FCC to establish a task force that oversees implementation and use
of the broadband maps, including providing cost estimates for maintaining the maps.
Frequency of Updates
The FCC collects data from broadband service providers every six months through Form 477, and
updates the Fixed Broadband Deployment Map twice a year. However, the Fixed Broadband
Deployment Map’s data lags approximately a year and a half behind. (See the report section
“Real-Time Deployments”). The Broadband DATA Act requires the Broadband Serviceable
Location Fabric to be updated, at a minimum, every six months. A consideration for Congress
may be whether the Fixed Broadband Deployment Map could be updated more frequently (e.g.,
data could be collected every month) to reflect continuing network changes and, if so, whether
that would impose a significant burden on broadband service providers.
Concluding Observations
Broadband mapping has garnered congressional interest since the creation of the SBI under the
Broadband Data Improvement Act (P.L. 110-385) and introduction of the NTIA’s National
Broadband Map. Congressional interest in mapping accuracy remains high due to the potential
misallocation of federal assistance funds using current FCC maps.
The enactment of the Broadband DATA Act is a step forward in obtaining more granular and
accurate broadband mapping data. As the new collection effort unfolds, Congress may take an
interest in monitoring:
 whether the FCC broadband data collection effort appears sufficient to alleviate the
current broadband mapping issues,

58 Federal Communications Commission, Chairman Pai Statement on the Broadband DATA Act, March 24, 2020,
available https://docs.fcc.gov/public/attachments/DOC-363267A1.pdf.
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 the balance between waiting on distribution of federal funding (e.g., new federal
broadband programs established within CAA 2021 or ARPA) until the map is determined
accurate versus the continuing need to address the digital divide, and
 whether additional legislative action should be taken to incorporate other variables into
the data collection and mapping efforts.

Author Information

Colby Leigh Rachfal

Analyst in Telecommunications Policy

Disclaimer
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Congressional Research Service
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