Industry Seeks Additional Refinements to FCC’s BDC Challenge Process
Industry groups are backing calls that would refine the FCC's challenge processes for the national broadband map and broadband serviceable location fabric, they said in reply comments posted Wednesday in docket 19-195 (see 2402200073). Many seek changes that would improve the challenge process for mobile service and increase transparency in how disputes are adjudicated within the commission.
CTIA echoed its request that the FCC make "targeted changes" to its challenge processes and broadband serviceable location fabric. Providers "agree that a lack of transparency and consistency in the adjudication of challenges has been a common experience, and there are simple steps the commission can take to enhance the transparency and consistency of the challenge processes," CTIA said. It sought a process for providers to request that CostQuest, the fabric's architect, add broadband serviceable locations. "This simple solution would greatly enhance the accuracy of the fabric," CTIA said.
"Challenges are a vital part of the mapping process to ensure data is accurate and up-to-date," said the Competitive Carriers Association. CCA raised concerns about the "lack of cognizable challenges" for mobile service, noting the commission "received less than 190,000 mobile-on-the-ground speed tests that resulted in 35 cognizable challenges to the mobile wireless coverage data" on the national broadband map. The number of challenges is "alarmingly low" compared with fixed broadband challenges. The FCC should "address any deficiencies in the bulk challenge system to ensure that data diligently collected is duly considered," the group said.
It's "apparent that the lack of mobile challenges being submitted using the Speed Test app is evidence of a flawed process," said rural wireless carriers Carolina West Wireless, C Spire, Appalachian Wireless, Viaero Wireless, Nex-Tech Wireless, CellularOne, Union Wireless, UScellular and United Wireless Communications. The coalition suggested "liberalizing the challenge criteria for using the Speed Test app, accepting bulk data sets that contain anonymized data, and accepting commercial data sets that do not include all of the data fields currently required of the challenge process." Ookla agreed, saying the FCC can "maximize and better leverage the available crowdsourced data by loosening the excessive data collection and disclosure requirements for speed test apps that currently discourage users from submitting this data." The company backed allowing speed test data to be used for availability challenges.
Require that bulk challengers "disclose the vintage of their information and submit prima facie justification for blanket challenges," the Wireless ISP Association said, echoing concerns that some challengers aren't acting in good faith to resolve disputes. The group also sought "more clarity and transparency on how challenges are adjudicated."
"A major inaccuracy in the broadband map lies in the locations where fixed wireless services report certain speeds that are, in reality, unavailable for purchase at that location," said the Accurate Broadband Data Alliance, representing more than two dozen small providers. The group asked the FCC to clarify that "affidavits are an acceptable methodology to support bulk challenges to reported coverage of fixed wireless providers."
NTCA noted the challenge process for fixed service is "not properly calibrated to produce a more accurate" national broadband map. The group also backed calls for greater transparency in the challenge adjudication process, saying it would "ultimately improve the speed with which the commission can adjudicate challenges and order corrections" to the national broadband map.