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Prices 'Highly Dynamic'

How Much Data Collection Too Much in FCC Broadband Mapping Debated

Pursue granularity and accuracy of broadband mapping data so consumers aren't trapped in broadband deserts when government funding is unavailable in areas deemed served, NTCA replied on FCC digital opportunity data collection (see 1909240005). Commenters differed on a latency-reporting obligation and most opposed collecting prices. DODC replies posted through Tuesday in docket 19-195.

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USTelecom opposes including latency and pricing information: "Neither is relevant to reporting broadband availability." The group recognizes the FCC requires some latency tests as part of Connect America Fund auctions, saying it would be inappropriate to require this as an unfunded mandate for all ISPs.

"A latency reporting obligation is particularly unwarranted with respect to fixed wireline broadband providers because there is no evidence of latency problems" with them, said NCTA. Broadband services "are highly dynamic and prices tend to change rapidly and fall quickly," Alaska Communications said. The FCC should focus on improving data on broadband availability and not expand the mapping program into an "omnibus data collection," CTIA said.

NTCA urged the FCC to consider "standard assumptions" on how broadband delivery varies for fixed wireless and satellite providers, and "incorporate oversubscription assumptions so that the effects of any shared capacity and its influence on the ability to serve each and every serviceable location within a coverage area are taken into account." Wireless providers using a particular band should claim availability within a coverage polygon only if it can access enough spectrum to serve every customer within that, the group suggested. NTCA said a DSL provider shouldn't claim to serve an entire polygon while it has "certain lengths of copper" still in its distribution plant.

Wireless ISP Association members use Form 477, which lacks granularity because it treats an entire census block as served even if service is available to only a portion, WISPA said. The group doesn't support a new voluntary category for providers to state where service is feasible but not currently available.

Data collection "must be focused on where service is available, not where it might be," Next Century Cities said. If it does include the voluntary category, the FCC could require wireless and satellite providers to flag locations where service is available but no connections are reported, the group said.

Requiring telecom providers to collect latency measurements for every location they report in a broadband mapping program is too burdensome and shouldn't be included in DODC rules, said Hughes Network Systems. "Those favoring latency data collection have no practical suggestions on how such data could be collected" or why it's needed. NTCA said latency affects consumer's experiences with live sports streaming and VoIP.

There's "broad agreement that it is not yet time to require reporting on 5G coverage," AT&T said.

America's Communications Association supports plans for an updated mapping program. ACA asked the FCC to "proceed deliberately before adopting any geolocation data collection" in light of unanswered questions.