BDC (DODC) Background
Ever fond of acronyms, earlier this year the FCC released the Third Report and Order for the Broadband Data Collection (BDC), formally referred to as the Digital Opportunity Data Collection (DODC). Initially adopted in August 2019, BDC (DODC) is meant to improve the granularity of the collective view of broadband availability in the U.S. by having providers submit more detailed information about where they do and can provide broadband service. The hope is that BDC (DODC) would be the program to improve or replace the FCC’s Form 477. In March 2020, Congress passed the Broadband DATA Act (more on that in a separate article), which added layers of data and accountability that all hope would lead to more accurate broadband maps. With the Third Report and Order’s adoption, the final BDC (DODC) rules are now set, and a Public Notice will go out at least 6 months before the first BDC (DODC) filing deadline. Let’s dig into what providers have in store for them.
What this article will cover: Standards and obligations for fixed wireless providers for BDC (DODC) filing. Other technology types will be covered in future posts.
Other critical elements of the Broadband DATA Act (future posts): Broadband Location Fabric, challenge process, crowdsourcing process, and implementation of coverage maps.
BDC General Requirements
Before digging into requirements specific to fixed wireless providers, here’s a quick overview of what will apply to all filers.
Who Has to File?
Facilities-based providers will need to make semiannual fillings and are defined by the FCC as supplying service using any of the five types of facilities:
- Physical facilities that the entity owns and that terminate at the end-user premises
- Facilities that the entity has obtained the right to use from other entities, such as dark fiber or satellite transponder capacity as part of its own network, or has obtained from other entities
- Unbundled network element (UNE) loops, special access lines, or other leased facilities that the entity uses to complete terminations to the end-user premises
- Wireless spectrum for which the entity holds a license or that the entity manages or has obtained the right to use via a spectrum leasing arrangement or comparable arrangement under subpart X of Part 1 of our Rules (47 CFR SS 1.9001-1.9080)
- Unlicensed spectrum
What Will Be Included in BDC Filings?
The intent here is for all providers to include data relating to the availability and quality of broadband internet service (and voice service, where applicable) in their respective areas. The BDC (DODC) requirements will allow for submissions to generally take the form of a polygon shapefile, a list of addresses, or locations, with some nuances specific to technology type.
Generally speaking, all providers needing to make filings should assume they will need to provide speed, latency, an explanation of methodology with each shapefile or list provided, and certification(s) from a corporate office and professional engineer. This information will be made publicly available unless otherwise indicated or granted.
*There may be additional clarity provided on providers excluded from BDC (DODC) filings based on subscriber count.
BDC Requirements for Fixed Wireless Providers
In addition to the polygon shapefile or list of addresses or list of locations, fixed wireless providers will need to submit propagation maps, model details, and some additional information to round out their filing. We’ve summarized the requirements below:
Filing Format for Fixed Wireless Providers
Providers have the option to submit their information as a polygon shapefile, list of addresses, or list of locations detailing where service is available.
- Any option will need to include an explanation of the provider’s methodology in generating this data
- (Awaiting clarification from the FCC) Propagation maps and model details reflecting the speeds and latency of its service that document:
- Areas where the provider has actually built network infrastructure
- Areas where the provider is capable of performing a standard broadband installation
- Propagation maps and model standards:
- Cell edge probability not less than 75% receiving max advertised download and upload speeds
- Cell loading factor not less than 50%
- Receiver heights within range of 4-7 meters
Filing Details Required for Fixed Wireless Providers
Within BDC (DODC) fillings, fixed wireless providers will need to provide detail about the service offered, base stations used, terrain, and radio network planning tool(s) used.
Speed detail to be included for each propagation map or list of addresses or locations:
- 200 kbps – 10/1 Mbps (Download/Upload)
- 10/1 Mbps – 25/3 Mbps
- Max advertised download and upload
The intention here was to combine the lower speeds into two tiers to simplify and to focus the specificity on maximum speeds exceeding 25/3.
Latency will be reported for each max speed combination, indicating whether the network round-trip latency is less than or equal to 100 milliseconds (ms), based on the 95th percentile of measurements.
Providers must also indicate whether service is available to residential and/or business customers at each speed combination.
Information about base stations is required to give the FCC the opportunity to perform further due diligence to verify the feasibility of maps and models submitted. The base station detail required is as follows:
- Frequency band(s) used in each mapped area
- Carrier aggregation information
- Radio technologies used on each band (ex. 802.11 ac-derived OFDM, proprietary OFDM, LTE)
- Elevation for each base station
- Geographic coordinates (latitude/longitude) of each base station used to provide terrestrial fixed wireless
- NOTE: These coordinates will be presumptively confidential and NOT made publicly available
Information about terrain and clutter will also need to be included, but will be limited to the following:
- Name and vintage of the datasets used
- Resolution of clutter data
- List of clutter categories used with a description of each
- Link budget and a description of the other parameters used in the propagation model, including predicted signal strength
- Radio network planning tool(s) used, including:
- A version of the planning tool
- Name of tool’s developer
- The granularity of the model (ex. 3-arc second square points)
- Affirmation that coverage model has been validated and calibrated at least one time using the ground testing and/or other real-world measurements completed by the provider or its vendor
- Information on the height and power values used for receivers/CPE antennas in modeling (height must be within the range of 4-7m)
Certifications Needed for Filings
All providers submitting a filing will need to include certifications from two people (which can be performed by the same person, where appropriate): a corporate officer and a qualified engineer.
The certification from a corporate officer is meant to indicate a stamp of approval that, to the best of the officer’s knowledge, all information contained in the submission is true.
Going one step further, the engineering certification must indicate that he or she can attest that the network design and engineering elements of the submission are factually accurate. This must be performed by a certified professional engineer or corporate engineering officer who the provider employs and “has direct knowledge of, or responsibility for, the generation of the provider’s Broadband Data Collection (Digital Opportunity Data Collection) filing.”
How Fixed Wireless Providers Can Prepare for BDC
BDC (DODC) filings are a potential step in the right direction to create a more granular, shared understanding of where broadband service is available in the U.S. If executed properly, this is undoubtedly a good thing. However, as you can see, these filings will be robust, and there’s a tremendous amount of data that will need to be trued up across technology types, on top of the Broadband Locations Fabric, and against the feedback from the challenge process. Additionally, Form 477 filings will likely still be required for at least one filing period when BDC (DODC) is implemented so that resource planning will be critical. Ultimately, BDC (DODC) submissions will be overlaid on top of a baseline of all serviceable structures in the U.S., referred to in the Broadband DATA Act as the Broadband Locations Fabric. So, providers looking to prepare should keep in mind that their filings will need to mesh well compared to a database of locations.
While we don’t yet have an official timetable for implementing these rules (we’ll update you as there is one), we don’t want to get caught flat-footed when the FCC releases a Public Notice making it official. Consider these 5 steps to prepare your team for these filings:
- Read the Third Report and Order – It’s long and dry, especially if you’re not used to reading these documents, but they provide additional color around the rules adopted.
- Take inventory of any gaps – As you review these requirements, note any information you don’t normally document or don’t have a process to obtain routinely. Do you have all the coordinates of your base stations? Who on your team will be making these filings – are they up to speed?
- Figure out your format – Polygons, addresses, or locations? What will be your methodology to create the coverage polygons or lists of addresses or locations? Can you create these uniformly across your footprint?
- Locations, locations, locations – Since your filing will ultimately be compared to the Broadband Locations Fabric, consider building your methodologies with locations at the core. That could be generating polygons based on locations or using the raw list of locations themselves. Just be sure to focus on cleaning up the baseline for locations that are serviceable for broadband.
- Ask for help – Ask peers, your go-to trade association, or us for any specific items you need help on.