Details Debated on FCC Plans to Update Broadband Mapping Reporting Requirements

Better broadband maps can greatly assist rural LECs and other providers in deciding whether to participate in competitive bidding for FCC funding in high-cost areas, WTA said, "and potentially remove the risk of the provider realizing after the fact that it is obliged to serve a significantly larger number of 'locations' than actually exist, and that it is subject to a loss of high-cost support even though it built a broadband network capable of serving the entire area at issue."

Polygon Shapefiles and Location Fabric

Cable and telephone interests back different broadband mapping technology updates. NCTA supports having providers report their broadband deployment data in a polygon shapefile format, while USTelecom said such data could be overlayed onto comprehensive location fabrics that more precisely identify unserved locations. NCTA said "far more information is needed" before the FCC should consider taking a location tool nationwide. The FCC "does not need to wait for the development of any new tools before distributing additional support to promote deployment in unserved areas," NCTA said. It wants the agency to focus on "technological compatibility of the data that is submitted, not the specific details of how companies create that data." Verizon, too, supports flexible standards for broadband reporting.

Establish an education and compliance regime for providers and permit them to file polygons in different file formats, said America's Communications Association. AT&T said the FCC shouldn't prescribe how providers create their broadband maps but should clearly define what the maps must represent and require transparency on how they're generated.

USTelecom and its partners in a broadband mapping coalition recently completed a pilot in two states to demonstrate how the location fabric works (see 1908200055). Pilot results "show that a nationwide fabric is scalable and will improve the accuracy and granularity of broadband reporting," USTelecom said in joint comments with ITTA and the Wireless ISP Association. USTelecom recommends the FCC follow its lead in creating a location fabric that identifies the primary structure on individual parcels of land "as the initial broadband serviceable location until such time as information about secondary structures can be understood and public policy decisions necessitate including them." Some larger properties, such as farms, may require multiple broadband connections to a single customer, for example.

Don't Forget the Farmlands

"Incorporate agricultural lands into the definition of broadband serviceable locations," Deere said. It wants the FCC to include mobile broadband coverage on its maps to help spur the use of precision agriculture (see 1908150057). It thinks secondary structures on farms should be mapped: "By not including agricultural structures and lands into the definition of broadband serviceable locations, the commission will not be able to accurately assess broadband access on agricultural lands."

NCTA asked the FCC to clarify that providers won't be expected to submit proprietary customer addresses to the Universal Service Administrative Co. or its contractors if and when they move forward with a broadband location fabric tool. It also wants to limit the use of a location fabric tool to rural areas.

New York City wants the agency to "define location using latitude, longitude, and altitude in multi-tenant, multistory buildings," noting that with mobile broadband, service deployment in one part of a building doesn't necessarily indicate coverage is available throughout. The city also wants the FCC to establish technical standards of broadband data reporting specific to the various broadband technologies, including terrestrial wireless and satellite.

Alaska Communications wants safe harbor technical standards for reporting fixed wireless because its broadband performance can vary widely through factors beyond its control, it said, such as maturing foliage in the fall.

Expand the maps to allow providers to separately identify areas they're willing to serve based on demand, several interest groups said in comments led by Next Century Cities. The groups also want the FCC to collect information on the maximum capacity subscriber numbers in a given area for technologies that may have spectrum-related limits. It requests the FCC collect pricing data so that stakeholders can evaluate whether efforts "are successfully bridging the digital divide."

Commenters agree better data is needed on where broadband is and isn't deployed, but there's less consensus about reporting and verification of details including top performance speeds, latency and pricing. There's room for crowdsourced data to challenge provider data, but "providers should be given a reasonable opportunity to respond to the challenge," said NCTA. Allowing public input will result in a more accurate depiction of coverage because it ensures the data provided by service providers is aligned with reality, said the National Rural Electric Cooperative Association.

Crowdsourced reports of areas unserved by broadband or not performing at the levels advertised by providers could lead to false positives and should be used for informational purposes only, WTA said. Do a pilot program to evaluate the utility of crowdsourced speed tests for mobile broadband services, CTIA advocated. The pilot could assess whether other tools could be used to validate provider data, it added.

Incorporate a more robust validation process to ensure the accuracy of FCC broadband mapping data before it's used in funding or policy decisions, the NTCA said. It suggested local and state policymakers could play a role in the validation process.

FCC mapping reports on mobile broadband coverage compiled from Form 477 data don't match "consumers' on-the-ground experience," said the Competitive Carriers Association. It wants new standards for data collection, including signal strength, cell edge probability, cell loading, and clutter factors.