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Missing Pieces: How the FCC's Broadband Map Misrepresents Public Libraries

February 2023

DOI:10.13140/RG.2.2.22239.53929

Authors:

Digital Equity Research Center

The Federal Communications Commission (FCC) recently released a "pre-production" draft of their National Broadband Map in an effort to provide more precise details about where internet service does and does not exist in individual locations across the U.S. While much attention has been paid to how the map represents broadband service for individual households, there is much less understanding among the general public with regards to how the map represents individual community anchor institutions, such as public schools, libraries, and hospitals. In an effort to address this gap in public understanding, and to help contribute to improving the FCC's Broadband Map overall, this paper presents findings from a study of 200 public libraries in 20 states across the U.S. to gain a better understanding of the following: (1) whether public libraries are classified as "broadband serviceable" or not; (2) whether public library buildings are classified as "residential" or not; and (3) the level of service that public library buildings receive in individual locations. The findings from this study raise important questions about whether the FCC's current process allows for public challenges to correct these mis-classifications. Recommendations are provided at the end of this report to help ensure that the map helps to address the broadband needs of community anchor institutions across the country. Methodology This section describes the overall approach and methods used for the study.

Public library location broadband "Status"

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Figures - uploaded by Colin Rhinesmith

Content may be subject to copyright.

Content uploaded by Colin Rhinesmith

Content may be subject to copyright.

Missing Pieces: How the FCC’s Broadband Map Misrepresents Public Libraries

By Colin Rhinesmith, Ph.D.1

Abstract

The Federal Communications Commission (FCC) recently released a “pre-production” draft of

their National Broadband Map in an effort to provide more precise details about where internet

service does and does not exist in individual locations across the U.S. While much attention has

been paid to how the map represents broadband service for individual households, there is

much less understanding among the general public with regards to how the map represents

individual community anchor institutions, such as public schools, libraries, and hospitals.

In an effort to address this gap in public understanding, and to help contribute to improving the

FCC’s Broadband Map overall, this paper presents findings from a study of 200 public libraries

in 20 states across the U.S. to gain a better understanding of the following: (1) whether public

libraries are classified as “broadband serviceable” or not; (2) whether public library buildings are

classified as “residential” or not; and (3) the level of service that public library buildings receive

in individual locations. The findings from this study raise important questions about whether the

FCC’s current process allows for public challenges to correct these mis-classifications.

Recommendations are provided at the end of this report to help ensure that the map helps to

address the broadband needs of community anchor institutions across the country.

Methodology

This section describes the overall approach and methods used for the study. This includes a

description of the public library sample used in the research, which is drawn from the Institute of

Museum and Library Services 2020 Public Library Survey (PLS) data, as well as how the FCC’s

Broadband Map was used in the research.

Library Sample

In deciding on a sample of libraries for the study, I downloaded the Institute of Museum and

Library Services (IMLS) 2020 Public Library Survey2data and randomly selected 20 states that

are included in this data set. As the IMLS website explains, “The data are collected from

approximately 9,000 public libraries with approximately 17,000 individual public library outlets

(main libraries, branches, and bookmobiles) in the 50 states, the District of Columbia, and

outlying territories.” 200 randomly selected public libraries from 20 states are included in this

data set. The states selected include: California, Connecticut, Colorado, Florida, Georgia,

Hawaii, Illinois, Jersey, Louisiana, Massachusetts, Michigan, Minnesota, New Mexico, Nevada,

North Carolina, Pennsylvania, Texas, Virginia, Washington, and West Virginia.

2https://www.imls.gov/research-evaluation/data-collection/public-libraries-survey

1Dr. Colin Rhinesmith is the Founder and Director of the Digital Equity Research Center at the

Metropolitan New York Library Council. https://dercenter.org/

After selecting these 20 states, I then used the IMLS data to select individual locations for 10

public libraries in each state for a total of 200 libraries that were included in this study. For the

library selection process, I randomly selected roughly every 10th library listed in the IMLS data

for each state, except for Hawaii, Nevada, and New Mexico. For these 3 states, I randomly

selected roughly every fifth library in the IMLS data set, because there were not as many public

library locations available in the data set as the other states.

Using the FCC Broadband Map Data

After compiling a list of 200 public libraries, which were randomly selected from the IMLS Public

Library Survey data, I began manually entering the addresses from the IMLS data into the

FCC’s Broadband Map. In looking at the results of each search, I was particularly interested in

collecting the following information for each public library:

● Broadband “status” (e.g., “served” or “not a serviceable location”)

● Broadband “type” (e.g., “Residential” or “Business”)

● Broadband “speed” (e.g., “25/3 Mbps or greater”)

● “Building type” (e.g., “Residential” or “Community Anchor Institution”)

● “Location ID” (i.e., as the FCC describes, “the unique identifier for the broadband

serviceable fabric location”).

In collecting data on the broadband “status” of individual public library building “types,” I paid

particular attention to the following color indicators as described by the FCC:

●“Green locations have internet services available to them, based on information reported

by an ISP.

●Red locations have no reported internet services available.

●Gray locations represent buildings or structures that are not likely to use the broadband

internet access services typically sold to homes and small businesses (they typically use

special commercial-grade broadband services).”3

In addition to collecting these data for each of the 200 public library locations, I also noted

whether buildings had more than one broadband “status” or building “type” at each location.

Appendix I includes a full list of the data used (IMLS) and gathered from the FCC’s Broadband

Map.

https://help.bdc.fcc.gov/hc/en-us/articles/10467446103579-How-to-Use-the-FCC-s-National-Broadband-M

Results

In this section, I describe three main areas of focus with regard to the findings of this study.

These include the following: (1) “broadband status” of individual public library locations on the

map; (2) “building type” indicated for each public library location on the map; and (3) several

additional problems that I discovered when searching for information about public libraries, as

community anchor institutions, using the FCC’s Broadband Map.

Public Library Location Broadband “Status”

This section provides an overview of how the FCC describes the “Status” of broadband service

at each of the 200 public library locations that were selected for the study.

Figure 1. Public library location broadband “Status”

Served. The FCC describes locations that are “Served,” or green-colored location points

on the map, as locations that “have internet services available to them, based on information

reported by an ISP.”4See Figure 2 below for an example of a public library that was classified as

“Served” and “Residential.”

https://help.bdc.fcc.gov/hc/en-us/articles/10467446103579-How-to-Use-the-FCC-s-National-Broadband-M

Figure 2. Example of a public library (Española Public Library) that is classified as “Served” and

“Residential”

Twenty-eight percent of public library locations, using the IMLS data for this study, were

classified as “Served” on the FCC’s Broadband Map. It appears these libraries have been

mis-classified as "residential," and it is unclear if they are "served" with the gigabit service called

for in the IIJA.5

Not Broadband Serviceable. The FCC describes locations that are “not broadband

serviceable,” or the gray-colored location points on the map, as locations that “represent

5https://www.congress.gov/bill/117th-congress/house-bill/3684/text

buildings or structures that are not likely to use the broadband internet access services typically

sold to homes and small businesses.”6See Figure 3 below as an example.

Figure 3. Example of a public library that is classified as “not broadband serviceable”

This category of broadband “status” was most prevalent for public library locations on the FCC’s

Broadband Map. 61% of public library locations used in this study were classified as “not

broadband serviceable.” These same building types were also described as “Community Anchor

Institutions” (which appeared after clicking on the “Mobile Broadband” tab and on a separate

pop-up window after clicking on the “Location Challenge” button).

https://help.bdc.fcc.gov/hc/en-us/articles/10467446103579-How-to-Use-the-FCC-s-National-Broadband-M

No Location Data. A much smaller percentage of public libraries (10%) had no location

data at all. In other words, there was simply no dot at the location where the public library was

located. I used Google Maps, as well as the public libraries’ websites, to confirm the address for

each public library location. Figure 4 provides an example of this type of classification for one of

several public libraries on the map, most notably in Hawaii.

Figure 4. Example of a public library location (Waipahu Public Library) where “no location data”

are available.

Not having any location data available is another case where the FCC’s Broadband Map

fails to represent public libraries as community anchor institutions. Unlike the previous problem,

the FCC challenge process does allow libraries to provide location data to update the map.

Whether or not all libraries will have the capability of filing these location challenges, however, is

unknown.

Not Broadband Serviceable + Served. The fourth category of public library location

broadband “Status” includes locations where the public library building is marked with both gray

(“Not a mass market location” or “Not broadband serviceable”) and green (“Coverage available”

or “Served”) dots on the map. Figure 5 shows an example of one of the 3 public library buildings

in this category that were discovered in this study’s small sample.

Figure 4. Example of a public library location (Memorial Hall Library) that is "not broadband

serviceable" and "served"

This category may represent buildings with two different types of public library broadband

connections, one that does not subscribe to a mass market service (i.e., not broadband

serviceable) and another that is mass market (i.e., served) internet service. The fact that these

two categories of service appeared on the map together raise important questions that may

require verification with the public library location.

Public Library Location “Building Type”

This section provides an overview of how the FCC describes the “Building Type” at each of the

200 public library locations that were selected for the study. Figure 5 shows each of these

building type classifications that appeared in the FCC’s Broadband Map search results using the

addresses from the IMLS Public Library Survey data.

Figure 5. Public library location “building types”

As Figure 5 indicates, 8 different “building types” were found for the 200 public library addresses

used for this study. The largest percentage (60%) of public libraries were classified as

Community Anchor Institutions or “CAI.” The next largest category of building types were

classified as “Residential” (14%) followed by “Business” (11%). 10% of all public library locations

on the FCC’s Broadband Map had no location data available at all, so their building type and

level of internet service are unknown.

The other four categories of building types were either classified as “Enterprise” (3%), both

“Community Anchor Institution” and “Business” (2%), both “Residential” and “Business” (2%),

and “Group Quarters” (.5%), which the FCC defines as “housing units.”7These were much

smaller numbers of libraries found in these last three categories.

Additional Problems

There were several other issues noted in the FCC's Broadband Map relative to public library

buildings, which are described below.

7https://docs.fcc.gov/public/attachments/FCC-21-20A1.pdf

Broadband Type. All of the locations marked as “Community Anchor Institutions” were

classified as either “Residential” or “Business” (e.g., see West Virginia’s public libraries) in the

selected location “Broadband Type.” This was not necessarily helpful for gaining a better

understanding of the actual broadband “Service”,“Technology”, and “Speeds” available at each

CAI location. The FCC map should add a “Community Anchor Institution” category to its initial

summary page without having to click on the “Location Challenge” or “Mobile Broadband”

button, which shows this “Building Type” for those classified as community anchor institutions.

Broadband Speed. While all public library building locations were classified as having

“25/3 Mbps or greater” speeds, it was much less clear what the maximum advertised speeds

were at each location, particularly for those marked as “not broadband serviceable.” In other

words, while it was positive to see that the majority (54%) of public libraries were classified as

“Community Anchor Institutions” on the FCC’s Broadband Map, “broadband data were

unavailable” for CAIs with regards to internet service provider and maximum advertised speed

at each location.

Location ID. Those interested in finding the location of public libraries on the FCC’s map

need to have the “Location ID” to get an accurate location on the map. Neither the building

location address nor name of the library were often sufficient enough to locate the exact location

of each public library building on the map. In other words, those interested in finding public

libraries on the FCC’s Map really need to have access to their Location IDs. This also means

that Location IDs all need to accurately represent the public library, or other community anchor

institution, building location.

Recommendations

Based on the findings from this study’s snapshot of 200 public libraries in 20 states across the

country, several recommendations are now offered to help improve the FCC’s Broadband Map.

● Provide evidence to support CAI “not broadband serviceable” category. The Map

should not classify CAIs as "not broadband serviceable" unless there is evidence that

they do in fact purchase “commercial service.” In other words, the Map should start with

the presumption that libraries and other anchors purchase mass market service and are

broadband serviceable unless there is evidence that they purchase custom-tailored

service.

● Add a “Served” category for CAIs. The Map should classify CAIs as "Served" only if

they have gigabit level service. As Title IV of the IIJA states, “ensure that the proposed

middle mile broadband network will be capable of providing broadband to an anchor

institution at a speed of not less than 1 gigabit per second for downloads; and 1 gigabit

per second for uploads to an anchor institution.” A “Served” category for CAIs on the

Map can help clarify where the middle mile network is serving the CAI and where these

networks still need to be addressed.

●Add broadband “Provider” data for all CAIs. One way to address the first

recommendation is to add a list of internet service providers to the map for each of the

“Community Anchor Institution” building types. Similar to the list of “Residential” and

“Business” locations that are served by internet service providers on the map,

“Community Anchor Institutions” should also be included in this list of locations served by

internet service “Providers,” and should include “Technology” type and maximum

advertised upload and download speeds.

●Fix “No Location Data” errors. As the examples in this study showed, there are

several cases where public libraries are not represented on the map. This is because

“No Location Data” exist for these community anchor institutions. As seen in the example

of the Waipahu Public Library and several others in Hawaii alone, these obvious errors

need to be fixed, not just challenged.

●Make “Location IDs” available for all CAI Buildings. Even in this small sample of 200

public library buildings, there were several discrepancies between the addresses of the

public library buildings and the location IDs associated with them. The FCC should make

Location IDs available for all community anchor institutions, and allow people to search

the map by location ID. The FCC can utilize the IMLS Public Library Survey dataset to

ensure the correct addresses and location ID are used for public libraries.8

●Add “Community Anchor Institution” to “Broadband Type.” The FCC should also

add a new category for “Community Anchor Institution” to the “Broadband Type” for each

“Selected Location” on the map. This would help update the type of service from

“Residential” or “Business,” which it currently reads to more accurately reflect the actual

type of broadband service provided at each CAI location.

8https://www.imls.gov/research-evaluation/data-collection/public-libraries-survey

APPENDIX I - PLS, FCC, and E-Ra

STABR LIBNAME ADDRESS CITY ZIP CNTY LOCALE FCC/BROADBAND STATUS FCC/BROADBAND TYPE FCC/SPEED FCC/BUILDING TYPE FCC/LOCATION ID

E-RATE

PARTICIPANT

(FY22)

USAC

LOCALE

Missing Pieces: How the FCC's Broadband Map Misrepresents Public Libraries

Abstract and Figures

Recommended publications

Household Demand for Broadband Internet Service

Public Libraries, Digital Equity Coalitions, and The Public Good

Digital Inclusion and Meaningful Broadband Adoption Initiatives

Federal Subsidies of Advanced Telecommunications for Schools, Libraries, and Health Care Providers