The recent emphasis on the expansion of broadband access across the country, coupled with the requirements of the Infrastructure Investment and Jobs Act and Broadband Equity and Deployment program, has prompted the Federal Communications Commission to review and update its collection of data. Accurate data pinpointing where broadband service is – and is not – available is critically important. Broadband maps are used by Internet Service Providers and governments to identify locations that need service, as well as how to fund broadband expansion.
The FCC has recently established an important initiative called the Broadband Data Collection Program to ensure the collection of accurate, vital broadband availability data, implementing new requirements. Among other requirements of the BDC, ISPs must submit their serviceable location data and align that data with the FCC’s serviceable location fabric, which will require new methodologies from ISPs, resulting in additional hours spent and more resources allocated to address this upcoming task.
At Michael Baker International, our team is at the forefront of data collection and broadband expansion services. This article provides details on the requirement and filing process for ISPs.
Recognizing the challenges
The BDC filing process may be unfamiliar and challenging to some service providers due to the novelty of the program and the list of requirements it encompasses. Moreover, ISPs may be delayed in the processing and submission of their data, either due to limited resources or bandwidth to support these new tasks and responsibilities or experience to immediately and effectively tackle and complete this complex data collection/submittal process. With the extent of the data expected to be collected and submitted, which involves technical elements and resources, proceeding may seem daunting. Sifting through newly published materials and resources takes away valuable time and issues can arise before or after submittal with incomplete data or the ability to process the data into the appropriate standards, recently specified for fabric comparison by the FCC.
Getting started according to the timeline
To begin the BDC Filing process, ISPs should first become familiar with the timeline, federal regulations and data requirements surrounding the submission period.
Due to be submitted for the first time on September 1, 2022, and semi-annually going forward, specific data must be provided by all facilities-based providers of fixed and mobile broadband internet access who had one or more end user connections in service on June 30, 2022. Each filing will be based on the same schedule as the Form 477 filings (June 30th through September 1st and December 31st through March 1st).
Fulfilling the prerequisites ad the data requirements
As prerequisite to filing data in the BDC portal, the FCC requires ISPs or government entities to first complete the registration process within the FCC’s Commission Registrations System (CORES). Users will be assigned a 10-digit FCC Registration Number that will be used for verification purposes by the FCC. Additionally, filers are also required by the FCC to show proof that they are indeed an organization that is responsible for tracking broadband coverage. Each filer must provide documentation from the highest-ranking executive within their company confirming that the organization tracks broadband data.
Each BDC filing must include detailed information about the filer, broadband availability data (including supporting data) and Form 477 broadband subscription data. In addition, specific requirements are mandated for various ISPs:
- Fixed wireline and satellite broadband service providers: Submit either polygon shapefiles or a list of locations constituting the provider’s service area.
- Fixed wireless broadband service providers: Submit either propagation maps and propagation model details or a list of locations constituting the provider’s service area.
- Mobile wireless broadband service providers: Submit propagation maps and propagation model details for each network technology, as well as for both outdoor stationary and in-vehicle mobile network coverage. Additionally, these ISPs must submit data for their signal strength heat map.
Finalizing for submission
Finally, ISPs must gain access to the serviceable location fabric, format the data to requirements for accurate comparison against the fabric and identify the addresses that meet requirements of serviceable areas. When the necessary data has been compiled and reviewed, the filing entity must navigate to the BDC system and submit its data onward to the FCC. The FCC gives the option to file submit data as an upload/web-based file or alternatively submit using an Application Programming Interface.
Partnering with a broadband expert
It is recommended that ISPs looking to both save time and ensure accuracy throughout the submission process partner with broadband experts that will ensure that all BDC requirements are met before submitting any data. Michael Baker International has thoroughly researched the BDC requirements and created a streamlined solution. ISPs simply provide the initial information, and our team then determines the appropriate data to be submitted, along with our translation of that data into the proper format. Once ISPs receive the data, they need only create a login and finally, upload the submission data.
Today, there is increased focus on an existing but growing need to close gaps in the digital divide. The new FCC requirements in the BDC program are an important part of ensuring the nation’s connectivity goals are met by collecting accurate data that will be necessary to provide services where they are most needed.
Jeremy Jurick is Michael Baker’s National Broadband Services Director and oversees Michael Baker International’s broadband planning, mapping and program management initiatives. His broadband experience includes roadmap development, planning, data collection and analysis, stakeholder engagement, broadband provider engagement, branding, multimedia design, GIS services, and software design, and he has provided testimony during several government hearings to inform policymakers on broadband policy and expansion, including advocating for high speed thresholds for the definition of broadband and allowing government entities to be eligible subgrantees for broadband funding.
Paul Schneid is a program manager at Michael Baker with nearly a decade of experience in broadband wireless equipment operation, customer service, and process improvement. Most recently, Schneid interfaced with vendors and clients to manage all implementation project phases from inception to completion across a citywide wireless broadband expansion in New York City. This piece is exclusive to Broadband Breakfast.
Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to firstname.lastname@example.org. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.
Garland McCoy: How Your State Can Defend Its Broadband Maps for Maximum Funds
Crowdsourced and bulk data are subject to a challenge process that has successfully eliminated crowdsourced data in the past.
On September 15, 2022, the Federal Communications Commission’s Broadband Data Task Force issued a public notice on “Specifications for Bulk Fixed Availability Challenge and Crowdsource Data.”
The notice provided guidance for filing bulk challenges, and bulk crowdsource data, to fixed broadband availability data that will be published later this year by the FCC as part of its new Broadband Data Collection. According to the notice, “individuals and entities, including consumers, state, local, and Tribal governmental entities, and service providers,” can submit challenges to the BDC fixed broadband availability data for single locations, as well as “bulk” challenges with respect to multiple locations.
Historically, Internet Service Providers have effectively used the FCC’s challenge process to disqualify the vast majority of disputes brought forward by states, counties, and other complainants regarding FCC’s broadband maps. And frankly, this will be the case again unless states take a new tack to validate their own data in such a way that will stand up to ISP challenges. Given the enormity of the federal broadband funds available to states this time around, the stakes could not be higher; that is, a single state could forgo hundreds of millions of dollars of federal broadband funds due to insufficient preparation to challenge-proof its data.
Here are two observations to start: 1) The ISPs are correct in challenging the data if the data is corrupted or incapable of being validated, and therefore should be disqualified. 2) the FCC and the ISPs must now be seen as embracing the new “crowdsourcing” challenge process since the Broadband Data Act of 2020 was very specific in requiring that the FCC’s new data gathering methodology include third-party crowdsourced data. That said, third-party “crowdsourced” and “bulk” data are subject to the same challenge process that has successfully eliminated individual and crowdsourced data in the past.
Three ways ISPs successfully challenge and disqualify third-party data
Alone, or in combination, the following three scenarios have succeeded year after year in ensuring that third-party data, crowdsourced or otherwise, has not made it past the challenge process and onto the FCC’s approved maps.
- Was the speed test launched from a device wirelessly? Modern modems set up a Wireless Area Network around the premises over the one or two Wi-Fi channels allocated. Almost all devices are now connected wirelessly to the modem. A wireless launch of a speed test, e.g., from your laptop or smart phone, therefore affects/corrupts the network speed test and disqualifies the data.
- Was the on-premises modem “still” when the speed test was taken? By “still” the ISP is referring to the modem’s management of data coming from any device remotely or over cable, ethernet connection, during the time of the test. For example, if a family member is working on their laptop, e.g., doing homework, the modem’s management of the data from the laptop will affect a speed test taken during that time. This will disqualify the speed test data.
- Was the crowdsourced and or bulk data drawn exclusively from the ISP’s premium service customers? The FCC stipulates that the speed testing data must be drawn from an ISP’s customers who have purchased the service provider’s best available service package. A customer might not need or be able to afford FCC’s “broadband” minimum service of 25/3 mbps, and thus would purchase a less expensive, slower service package offered by the ISP. For purposes of accurate speed testing, the ISP should not be penalized for offering true broadband-speed service that is passed over by a customer seeking a cheaper service.
PAgCASA, the Precision Ag Connectivity & Accuracy Stakeholder Alliance, is a non-profit organization whose sole purpose is to ensure broadband map accuracy, connectivity, and rural prosperity, stands ready to help states get their full share of federal broadband funds and successfully defend against challenges.
PAgCASA’s on-premises, cybersecure, network monitoring methodology – which deploys the same network monitoring devices the major ISPs use, on wired/ethernet-connected customer modems, from a volunteer pool of an ISP’s premium service customers selected using standardized random sampling methods – will, in fact, address all the challenge issues above and generate data ready for potential litigation.
As noted in another recent article on Broadband Breakfast, states like Georgia and North Carolina are finding significantly fewer served locations based on their latest state broadband data compared to FCC’s most recent Form 477 data. We expect to see similar differences across the country as states and the FCC bring forward their latest respective data.
Consider this: a ten percent delta between the FCC and state maps translates into a staggering $4 billion based on an overall federal broadband infrastructure spend of $40 billion – needed funds that will not make their way to genuinely unserved or underserved communities across the country.
Our nation can and must do better.
Garland T. McCoy, Co-Founder and Executive Director of Precision Ag Connectivity and Accuracy Stakeholder Alliance, is a long-time non-profit veteran in the fields of technology and telecommunication policy having served as Founder and CEO of the Technology Education Institute & Technology Policy Institute. Garland was recently an adjunct professor at Syracuse University’s iSchool, teaching information policy and decision making. He can be reached at email@example.com
Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to firstname.lastname@example.org. The views reflected in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.
State Broadband Maps Show Significantly Fewer Served Locations than Does FCC’s Map
There is a ‘massive difference’ between federal Form 477 data and state maps in Georgia and North Carolina
WASHINGTON, September 30, 2022 – State broadband maps from North Carolina and Georgia show significantly fewer served locations than do the Federal Communications Commission’s existing data, said a panel at a Fiber Broadband Association web event Wednesday.
For us there is “a massive difference” between Form 477 data and Georgia’s data, said Eric McRae associate director of the Carl Vinson Institute of Government at the University of Georgia. McRae said the number of Georgians the FCC identifies as unserved is “miniscule,” while the state’s estimate is between 1 and 1.2 million unserved.
North Carolina also found the federal data lacking: “There are thousands of people that are technically in FCC considered served blocks that typed in their address and said they had no access or came in with 1 megabit or horrible speeds,” said Ray Zeisz, senior director of the Technology Infrastructure Lab at North Carolina State University’s Friday Institute. “We verified, certainly, that the data was overstated.”
With the two state-mapping leaders, J. Randolph Luening, founder and CEO of Signals Analytics, presented the findings of his recent report, which compares data from Georgia and North Carolina’s maps to the FCC’s Form 477 data.
Luening’s report outlines the contrasting methods employed by North Carolina and Georgia. North Carolina collected – and published – the results of 109,000 speed tests, measuring download and upload speeds, latency, and jitter. The Tar Heel State also gathered information on technology type, service provider, and other relevant factors.
Georgia’s process is more like the FCC’s current map-making process: It created a fabric dataset and solicited coverage data from providers on an iterative basis. The Peach State published its data in block-by-block form.
Unlike the maps generated from Form 477 data, Georgia’s maps show the percentage of served locations in each census block. “We’ve been able to get a very accurate count of the number of unserved locations that we have in the state of Georgia,” McRae said.
Imprecisions and inaccuracies in Form 477 data were largely responsible for the inception of the FCC’s current location-by-location mapping project. The Commission is still constructing this map and will accept challenges to the accuracy of its fabric dataset on a rolling basis. The map will be used to apportion among the states $42.45 billion from the Broadband Equity, Access, and Deployment program.
McRae and Zeisz agreed a state must launch its own mapping initiative to check the accuracy of federal maps and ensure receipt of its fair share of BEAD funding.
FCC Broadband Data Task Force Emphasizes Need for Precision in Mapping Challenges
Officials on the panel said there was significant confusion among challengers regarding categories of challenges.
WASHINGTON, September 28, 2022 – Challenges that do not strictly adhere to the Federal Communications Commission’s fabric-challenge guidelines will be thrown out, FCC broadband mapping officials warned in a webinar Wednesday.
The FCC’s fabric, a dataset of buildings that are or could be reached by fixed broadband service, will be the basis for the agency’s new national broadband map and the National Telecommunications and Information Administration’s division among the states of $42.45 billion from the Broadband Equity, Access, and Deployment program.
Although the fabric’s data is not publicly available due to licensing agreements with contractor CostQuest, the FCC released a preliminary version to state governments, service providers, and other stakeholders. Those individuals may challenge the data contained in the fabric. The FCC and other experts have said the challenge process is indispensable to the accuracy of the agency’s forthcoming broadband map.
The panel of individuals on the webinar from the FCC’s Broadband Data Task Force identified seven challenge categories. The panel included Senior Counsel Sean Spivey, Senior Implementation Officer Chelsea Fallon, and officials John Emmett and Steven Rosenberg.
Each of the seven challenge pertains to a specific type of data correction. These include adding a serviceable location to the fabric, correcting an incorrect or missing address, or moving the marked serviceable location to another structure on the same parcel of land.
Officials on the panel said there is significant confusion among challengers regarding these categories. The panel highlighted a case in which the challenger mistakenly tried to add a new serviceable location instead of altering a listed address.
The panel also discouraged challengers from adding multiple serviceable locations to a single building. An apartment complex, for instance, is a single location, but can be marked as containing several sub-units. Even a building with multiple owners or addresses – like some duplexes – is considered a single serviceable location. Challenges to change the number of units or addresses associated with a location should not be confused with a challenge to add a location, the panel said.
To successfully add a serviceable location, a challenger must accurately mark the appropriate building to which it corresponds. Many challengers, however, marked proposed locations far from any building, often in the middle of a street.
The panel recommended the use of third-party software by challengers to ensure that their challenges are completed properly.
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