Clarity on the BDC Challenge Process and Definition of Broadband Serviceable Locations

*Updated December 5th, 2022

The Broadband Data Collection (BDC) Challenge Process is officially underway, for service providers, government entities, and other parties to file bulk and individual challenges to the locations within the FCC Broadband Serviceable Location Fabric and National Broadband Map. With the release of the FCC’s first draft of the National Broadband Map, the individual challenges to the Fabric locations and ISP’s service availability data are now open and can be submitted directly in the National Broadband Map interface.

If you’re looking to participate in the BDC Challenge process, below is some information to provide clarity as to what a Broadband Serviceable Location is, what challenges can be made, and why you should participate in the BDC Challenge Process as soon as possible.

What is a Broadband Serviceable Location?

A Broadband Serviceable Location (BSL) is defined by the FCC. A BSL is a residential or business location where fixed broadband internet access service is or can be installed, as determined by the Commission. 

  • A residential BSL is a residential structure, including structures that are (or contain) housing units or group quarters (as those terms are defined by the United States Census Bureau). 
  • A business BSL includes “all non-residential (business, government, non-profit, etc.) structures that are on the property without residential locations and that would expect to demand Internet access service.”
  • The Broadband Serviceable Locations in the Fabric will “reflect each location as a single point defined by a set of geographic coordinates that fall within the footprint of a building.”
  • BSLs are NOT units or addresses. They are structures needing services. (Ex: A multi-dwelling unit such as an apartment building may have multiple addresses, however, the building structure is the BSL and will have the main address for that location.)
  • Further defined as Mass-Market Broadband Connections (i.e. not enterprises, universities, prisons, or institutions).
  • An easy rule of thumb is that BSLs are location structures where people live and work.
An example of Broadband Serviceable Location Fabric data in a Geographic Information System (GIS). The green dots represent Broadband Serviceable Locations.

What types of challenges can ISPs and government entities, and other parties file?

BULK CHALLENGES TO THE BROADBAND SERVICEABLE LOCATIONS IN THE FABRIC

Per the FCC’s BDC Challenge Process Overview, Fabric challenges dispute the accuracy of the location data included in the Fabric. These challenges can include:

  • A location that meets the Commission’s definition of a Broadband Serviceable Location is missing in the Fabric.
  • A location’s broadband serviceability is incorrectly identified.
  • Information about a location is incorrect in the Fabric (e.g., the address or unit count for the location is incorrect).
  • The location’s placement (i.e., geographic coordinates) is incorrect.

INDIVIDUAL FIXED & MOBILE AVAILABILITY DATA CHALLENGES

On, November 18th, 2022, the FCC released their first draft of the National Broadband Map, which now allows individuals and other key stakeholders to submit individual challenges on the FCC Fabric locations and ISP’s availability data directly in the National Broadband Map interface.

The FCC stated in their November 10th release that the “broadband availability data will be based on data submitted by providers during the initial Broadband Data Collection filing window and will reflect services available as of June 30, 2022.  When published, the draft maps will display location-level information on broadband availability throughout the country and will allow people to search for their address, and review and dispute the services reported by providers at their location.

“The FCC will also accept bulk challenges to the reported availability data from state and Tribal governments and other entities. As a result, this map will continually improve and refine the broadband availability data relied upon by the FCC, other government agencies, and the public.  The pre-production draft map release is an important first step forward in building more accurate, more granular broadband maps, which are long overdue and mandated by Congress. “

Key Information about the Availability Data in the National Broadband Map:

Fixed Availability Data: This data is “granular, location-by-location broadband availability data from approximately 2,500 providers of fixed broadband service and standardized mobile broadband availability data.”

Mobile Availability: “Challengers may dispute the availability of mobile broadband service using on-the-ground speed test data. An updated version of the FCC’s Speed Test app will collect mobile availability challenge data submitted by users.”

What can be challenged in the Fixed and Mobile Availability Challenge Process?

  • Challengers may dispute the availability of fixed broadband service at a particular location or set of locations, including the network technology and maximum advertised download and upload speed reported by the provider.
  • The reported service is not offered or is the reported speed not available for purchase.
  • The provider denied a request for service or demanded connection charges that exceed its standard installation charge.
  • The provider failed to schedule or perform an installation within 10 business days of a request.

Ways to challenge

Bulk: “Challenges to the availability data or Fabric information for multiple locations. These will be filed directly into the BDC system and must meet the format of the applicable data specifications. Bulk Fabric challenges will begin in September 2022 and bulk availability challenges will begin after maps are released in November 2022.”

Individual: “Challenges can be made to ISP’s availability data or Fabric information for a single location. These challenges can now be accepted directly through the map interface.” Here is the link to the National Broadband Map to submit individual challenges.

When should I submit my challenges?

As soon as possible. NTIA stated in their recent press release, that between November 18th, 2022, and January 13th, 2023, is thebest opportunity for entities to submit challenges in time for the FCC to include corrections in the final version of the map that will be used to allocate Internet for All (which includes the BEAD program) funding in the summer of 2023.”

Why should you participate in the BDC Challenge Process?

Simply put, the distribution of billions of dollars is riding on the FCC Fabric and the broadband service availability data submitted by ISPs in the FCC National Broadband Map, and it’s critical to not leave valuable funding dollars on the table that can be used to help close the digital divide. The Challenge Process is a time for feedback. The quality of the FCC Fabric and FCC National Broadband Map is vastly improved when more stakeholders provide input to ensure funding is allocated appropriately for the general benefit of all Americans.

To put the importance of the quality of the FCC Location Fabric and ISPs service availability data into perspective, for example, if we assume that there are 10 million unserved locations in the country. Each location will drive around $4,000 of funding. As such, if 1000 unserved locations are missed in your neighborhood, county, or state, $4M of BEAD funding will go to other areas. So, from the perspective of making sure, your community receives adequate funding for broadband buildout, good quality Fabric, and service availability data are vital to helping bring underserved and unserved communities online. The FCC Fabric and service availability data submitted by ISPs will benefit all parties involved (organizations and consumers) by being improved over time.

It’s important to note, the development of an accurate Fabric of Broadband Serviceable Locations, as defined by the FCC, relies upon various components and processes that take time to create better data for better maps. Artificial Intelligence, machine learning, national data sets, and internal visual verification are critical to developing a granular and accurate data set, however, feedback from ISPs, state entities, and the public will work to ensure the Fabric and service availability data from ISPS are reflecting the on the ground reality of where adequate broadband is and isn’t across the US States and Territories.

The CostQuest team is working diligently in our role in this BDC process, to develop and deliver the FCC Fabric, and with your participation in the challenge processes, we can all help ensure the information necessary to close the digital divide is collected for the general benefit of all. 

More information & sources

Have questions?

To submit your questions, go to the BDC Help Center.

Link to BDC Filing System

Disclaimer

The Federal Communications Commission (FCC) is not responsible for the information or views in this communication and is not responsible for the accuracy, completeness, or timeliness of such information or views.

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