Why Not Force Incumbents To Show Which Areas Are Served?

One of the most troubling aspects of the NTIA/RUS NOFA is its requirements for unserved vs. underserved.

Not only do the definitions limit subsidies to the most rural areas cutting out viable urban and suburban projects, but the data applicants need to gather to prove an area is un- or underserved is expensive and time-consuming to gather, plus the rules seem to prioritize protectionism over progress by giving incumbents 30 days to respond to and refute any application that touches upon their service territory.

But at the same time, the data needed to determine un- and underserved doesn't necessarily have to be recaptured as it's already readily available in the hands of incumbent carriers. Additionally, we know the incumbents are very interested in preventing government subsidies from going towards project that will introduce significant new competition to their legacy networks.

Now combining these two threads together, I'd like to propose an alternative solution: why not force incumbents to show which areas are already served by threatening to consider all areas unserved that they don't produce verifiable data for showing that they offer service there?

By doing this we'll save applicants from wasting a lot of time and money collecting data that already exists, plus we'll also enable them to know if the area they're putting together a project for qualifies for subsidies before submitting their application. Additionally we'll be able to take this data and use it to inform the broadband maps we're charged with creating.

On the carrier side, we give them a clear reason for why they should give up their data on the availability of their services so as to insure we're not subsidizing duplicative investment. And at the same time we can remove any appearance of prioritizing the protection of private service provider interests over making real progress in the deployment of broadband.

So there you have it, a simple way to improve how the un/underserved dynamic works in the NOFA: consider all areas unserved until an incumbent carrier provides the verifiable data needed to prove otherwise, either that an area's already fully served or merely underserved.