ISPs, Officials Closely Monitoring FCC Fabric Challenge Process Before Initial Maps Release

ISPs, states and local officials said they're closely monitoring the FCC’s bulk challenge process for the broadband serviceable location fabric, before the initial map’s release later this fall. Few issues have been identified so far, though some ISPs raised concerns about potential challenges by states since the new maps will be used to allocate broadband-related Infrastructure Investment and Jobs Act funding.

The FCC’s broadband mapping effort “is not one and done,” Chairwoman Jessica Rosenworcel told reporters Thursday, confirming the commission expects the first iteration of the new maps to be released “mid-November.” Mapping every location through the broadband serviceable location fabric is a “complex process under the law,” Rosenworcel said, “but we’re committed to getting it done.”

“We should have started years ago,” Rosenworcel said: “That is a big effort" and “entails everything from property tax review to tax assessment documents, to reviews of satellite images, and a whole bunch of other things to make sure we get all those locations on the map.” The FCC opened the fabric, which identifies all locations where broadband may be installed, in order for governments, ISPs and other entities to file bulk challenge of those determinations starting September 12.

The FCC will open a challenge process once the initial maps are released, Rosenworcel said. Some raised concerns about the new maps' accuracy because NTIA will rely on them to allocate broadband, equity, access and development program funding. EducationSuperHighway met with the FCC's broadband data task force last week to raise concerns about the accuracy of accounting for multifamily dwelling units and how it may affect BEAD funding for some states.

States “cannot comply with the language in the BEAD if they rely solely on FCC maps to determine if a household is unserved or underserved in an apartment building,” the group said, per an ex parte filing in docket 19-195. It asked the FCC to establish a new challenge process for "high-priority" multidwelling units by requiring ISPs to prove a building is fully served if every unit is "simultaneously" capable of receiving speeds of 25/3 Mbps. "It is now crucially important to determine the level of service available to all units in the building," EducationSuperHighway said.

Some ISPs also expressed concern about the challenge process. Wireless ISPs “mostly recognize that creating the first broadband map will be a messy process,” emailed a Wireless ISP Association spokesperson, and are “especially concerned” about the state challenge processes because they will “be used to come up with the final iterations of the maps” for the FCC and NTIA’s broadband programs.

The National Association of Counties told FCC Consumer and Governmental Affairs Bureau Associate Chief Ed Bartholme it would like to see the "availability measures" before the maps are publicly released. It would "advance our partnership" and allow counties to "flag anything major," said NACo Chief Government Affairs Officer Mark Ritacco during an event Friday. "This process is essential" because the new maps will help determine the flow of over $42 billion in deployment funding," said NACo President Denise Winfrey.

Several NACo members asked whether the fabric CostQuest designed includes address-level location data through existing datasets for enhanced 911 because the company relied on a variety of data sources to produce the fabric. Bartholme noted the fabric is based on geolocations and "in future versions, they're working on incorporating even more variations on addresses," but "what we're really focused on is location matching to a [latitude and longitude], not so much the address."

Vermont got access to the fabric and plans a “deep dive” in October after it finishes updating its state maps, a process that starts each spring and wraps in the fall, said Clay Purvis, telecom and connectivity director for the Vermont’s Department of Public Service, in an interview. There were no problems opening or working with the fabric, but -- not unexpectedly -- the state already sees “discrepancies” between the fabric and what the state knows about its serviceable locations, he said. Purvis expects Vermont will file a bulk challenge in October or November once it finishes its analysis, he said.

Other states told us they’re reviewing the fabric. “With the assistance of the Rasmuson Foundation, the State of Alaska is acquiring building footprint location data from satellite imagery to run a comparison with the FCC Fabric Mapping,” said a joint statement by Alaska Broadband Office Director Thomas Lochner and Lisa Von Bargen, project manager for Commissioner Julie Sande of Alaska's Department of Commerce, Community and Economic Development. “The results of that comparison will be used to submit a challenge if necessary.”

The Virginia Department of Housing and Community Development “received access in August and is reviewing” the fabric, said a department spokesperson.