Impacting the FCC’s RDOF, A-CAM programs, PR Fund, and Connect USVI Fund
The FCC’s Wireline Competition Bureau (WCB) has officially adopted the Broadband Serviceable Location Fabric (Fabric) as the data foundation for verifying compliance with high-cost program deployment obligations and adjusting location counts for select high-cost support programs.
Effective April 4, 2025, this adoption aims to leverage CostQuest’s Broadband Fabric, the most up-to-date and comprehensive source for identifying Broadband Serviceable Locations (BSLs) nationwide, to enhance the accuracy and oversight of broadband deployment funded through high-cost support programs.
By leveraging a standardized and continually updated dataset across its funding programs, the Fabric data will ensure the efficient distribution of taxpayer dollars to deploy broadband services to eligible locations, monitor funding overlap, and reduce waste, fraud, and abuse.
With this adoption, CostQuest’s Broadband Fabric data is now being used by eight federal funding programs as the foundational location database to monitor and synchronize tracking of broadband deployment funding for:
- NTIA’s BEAD
- Enhanced ACAM (E-ACAM)
- Rural Digital Opportunity Fund (RDOF)
- Alternative Connect America Cost Model (A-CAM)
- Revised A-CAM I
- A-CAM II
- Bringing Puerto Rico Together Fund (PR Fund)
- Connect USVI Fund
*Before moving forward*
As a reminder, BSLs in the Fabric are locations where fixed broadband internet access service is or can be installed, as defined by the FCC.
It’s important to fully understand which locations are Broadband Serviceable Locations and which are not, especially with the new FCC adoption of using the Broadband Fabric to verify compliance with high-cost program deployment obligations and adjust location counts for select high-cost support programs.
The image above is an example of building structures that meet the FCC’s definition of a Broadband Serviceable Location (BSL). The structures in green meet the FCC’s BSL definition, and the remaining locations in red are secondary structures that do not qualify as FCC-defined BSLs.
Click here for more guidance on locations that do or do not meet the FCC’s BSL definition.
Programs affected by the FCC’s new Fabric adoption ruling
This new ruling impacts several programs, including:
- Rural Digital Opportunity Fund (RDOF)
- Alternative Connect America Cost Model (A-CAM)
- Revised A-CAM I
- A-CAM II
- Bringing Puerto Rico Together Fund (PR Fund)
- Connect USVI Fund
Main changes to be aware of
For RDOF
- The FCC will announce revised location totals for RDOF support recipients based on the December 2026 version of the Fabric.
- Once the Bureau has adopted revised location totals, the specific BSLs that are included in this total will be the locations that the RDOF carrier is required to serve.
- As a result, RDOF carriers will transition to reporting Location IDs (from the Fabric) in their HUBB filings to USAC.
- Support will be adjusted on a pro rata basis if there are significant deviations from the original location estimates.
- Per the FCC, “Because each RDOF carrier will be uniquely situated depending on the number of locations it will serve, the technologies it plans to use, the amount of support it has been authorized to receive, the terrain in its service area, and other factors that may impact the ability of a RDOF carrier to serve certain locations, the FCC concludes that it would be best to examine each situation on a case-by-case basis. Otherwise, the FCC could potentially strand locations without broadband that would be otherwise reasonable to serve based on the carrier’s individual circumstances, and/or if the carrier had conducted due diligence as required. Instead, a case-by-case approach will allow the Bureau to examine all relevant factors, including the enforceable buildout commitment preventing broadband funding for deployment by other Federal programs, and allow it to coordinate with other Federal, state, and local partners if the Bureau in fact does deem a location unreasonable to serve.”
For the PR Fund & Connect USVI Fund
- Similar adjustment processes will be implemented for the Bringing Puerto Rico Together Fund (PR Fund) and the Connect USVI Fund, with timelines aligned to ensure carriers have adequate time to adjust to any changes.
- The FCC will be generating a list of locations in the carriers’ service areas that they are required to serve—transitioning from an area-based obligation to a location-based obligation.
- As a result, PR Fund and Connect USVI Fund carriers will also transition to reporting Location IDs in their HUBB filings.
- The FCC will also account for the buffer when reconciling inconsistencies between all carriers’ HUBB reporting and data reported in the BDC.
For A-CAM, Revised A-CAM I, and A-CAM II
- A-CAM I, Revised A-CAM I, and A-CAM II carriers’ deployment obligations will remain area-based— i.e., they must serve a set number of locations within the eligible census blocks—the FCC will cross-reference the Fabric with the HUBB data.
- If an A-CAM carrier reports serving a location that is technically outside the eligible census block and it is accepted in the HUBB, that carrier can count that location towards the number of locations it is required to serve.
- For compliance reviews, the FCC will consider the 7.6-meter HUBB buffer, which permits carriers to include locations near—but not technically within—eligible blocks.
- Because A-CAM I, Revised A-CAM I, and A-CAM II are area-based, these nearby locations can be counted if accepted in HUBB, even if the Fabric places them just outside the eligible blocks.
General
- The FCC decided to exclude group quarters locations, which are currently BSLs in the Fabric, from the revised location totals to maintain consistency with previous guidance to exclude these locations from high-cost support location counts.
Compliance reviews
In the FCC’s February 2024 Public Notice, it was advised that high-cost support recipients compare their HUBB and BDC data filings and resolve any mismatches. The two filings should be consistent with one another.
The FCC plans to use the Fabric in compliance reviews to verify HUBB reporting and milestone claims.
If a support recipient identifies a mismatch between its two datasets, it can take one of the following steps to address the mismatch:
- Remove the location from its HUBB submission or modify the attributes of its HUBB submitted location(s) to better align with its BDC submissions.
- Submit a Fabric challenge through the National Broadband Map or the BDC system to the extent that a support recipient believes the Fabric is not accurate.
Data accuracy and Fabric challenge process
While some stakeholders expressed concerns about the accuracy of the Fabric and the challenge process, the FCC emphasized that the Fabric is the most accurate and granular dataset of Broadband Serviceable Locations (BSLs) currently available.
As outlined by Congress through the Broadband DATA Act, the Fabric is designed to improve iteratively through stakeholder participation in the challenge process, updates to underlying data sources, and improvements to the model used to generate the Fabric.
Per the FCC’s ruling, “No commenters suggested that any other dataset would be more comprehensive or up-to-date than the Fabric. Moreover, using a different data source could jeopardize the FCC’s efforts through interagency coordination to minimize duplicative Federal funding for broadband given that other agencies rely on Fabric data to identify potential overlaps in funding.”
The FCC’s Fabric Challenge Process plays a key role in improving the accuracy of the Fabric. Since its launch, the FCC stated they received 2 million challenges that aimed to add locations, however, the FCC said these 2 million locations hit the footprint of a Broadband Serviceable Location that was already in the Fabric. The FCC believes these challenges might have been intended to change an address or change another data attribute associated with a Broadband Serviceable Location.
It is critical to ensure challenges to the Fabric are filed under the correct challenge category. This is the MOST common reason for unsuccessful Fabric Challenges.
Fabric Challenge Help
If you would like more assistance on Fabric Challenges, join us for our “Best Practices for Filing Location Fabric Challenges” session at our Fabric User Conference in Seattle, WA, October 20-22, 2025.
CostQuest will also have other sessions covering best practices and technical uses of the Fabric, along with open office hours during which you can ask us your specific questions.
Explore these articles for more information on Fabric Challenge types and tips:
Preparing for the new Fabric adoption ruling
Review data:
The FCC encourages carriers to review the December 2024 and June 2025 versions of the Fabric and file challenges as soon as possible if there are potential inconsistencies, to ensure they are resolved before the FCC finalizes the version used for determining deployment obligations.
- Outstanding or pending challenges that were filed and not incorporated into the December 2025 Fabric will not be considered for determining the final deployment obligations.
Report changes:
When reporting to USAC’s HUBB, if a carrier discovers misidentified locations in the Fabric, the carrier should file a challenge to have those locations removed from the Fabric and should not report those locations in HUBB.
Per USAC’s Submit Data in the HUBB Guidance, “In some instances, the Fabric may include locations that are not actually broadband serviceable, such as a dilapidated structure or stack of haybales. If a carrier discovers misidentified locations in the Fabric, the carrier should file a challenge to have those locations removed from the Fabric and should not report those locations in HUBB. (Please see the FCC Guidance on Location Reporting for Carriers Receiving CAF Support for examples of locations not eligible for CAF support.)
- The FCC reminds carriers that the Fabric reflects each Broadband Serviceable Location as a single point or record defined by a set of geographic coordinates (latitude and longitude) that fall within the footprint of a building or structure.
- Each record in the Fabric also contains other attributes, such as primary address, unit count, and building type code.
- Apartment buildings appear as a single location with multiple units in the Fabric, and carriers should treat them as a single location with multiple units for BDC and HUBB reporting purposes.
- Similarly, a single residential parcel with two separate single-family homes may appear as a single location in the Fabric. If a carrier reports the two separate single-family homes as unique deployments in the HUBB, but filed an unsuccessful challenge to add the second home as a separate location to the Fabric, the carrier can file a challenge to adjust the unit count associated with that location in the Fabric to reflect the two units being served on the parcel.”
For further information
- Click here to read the FCC’s full ruling to adopt the Broadband Fabric as the foundation for high-cost funding oversight.
- For further information, the FCC stated to contact, Heidi Lankau, Attorney Advisor, Telecommunications Access Policy Division, Wireline Competition Bureau, at [email protected] or 202-418-7400.