Industry Urges Caution in FCC Broadband Fabric High-Cost Proposal

Industry encouraged the FCC to reconsider a proposal that mandates using broadband serviceable location fabric data to verify compliance with deployment obligations in high-cost USF programs (see 2402130058). Some welcomed using the fabric data later, warning that premature use could disrupt deployment obligations for support recipients of ongoing programs. WTA welcomed the proposal. Reply comments were posted Tuesday in docket 10-90.

The record "does not support tying compliance with high-cost support deployment obligations to the fabric at this time," said NTCA. The fabric "is not yet in a settled place where it can be relied upon as an authoritative source for tracking deployment compliance," the group said, especially for programs that began "before the fabric was anything more than a conceptual aim."

NTCA asked the FCC to limit use of the fabric to verify compliance with programs launched after the fabric's creation, noting the enhanced alternative connect America cost model (ACAM) program's buildout obligations are "unique in that they alone were specifically determined by reference to the national broadband map in the first instance." WTA welcomed voluntary use of the fabric's data but raised concerns about the impact of requiring its use for ACAM I and Alaska Plan support recipients.

"Mandating that fabric data be used at this late date to adjust or verify" compliance with ACAM I and Alaska Plan buildout obligations would "force participating [rural] LECs to engage in eleventh hour reviews that are likely to cause disruptive delays and needs to modify locations and routes that will adversely impact the completion of ongoing deployment projects," WTA said.

GCI Communication agreed but noted the fabric "may have a role to play in improving the commission's available data for mobile service providers participating in the Alaska Plan." In addition, GCI said one short-term benefit of doing so is that it may "better pinpoint" where the population lives than the Alaska population-distribution mode. "In other areas, however, it is premature to incorporate the Fabric into the Model due to the Fabric’s known inaccuracies in remote Alaska," the company said.

The National Rural Electric Cooperative Association (NRECA) backed the commission's efforts to eventually rely on the fabric to verify compliance with deployment obligations, but "the fabric is not ready" to do so. "Stated simply, there appears to be a significant disconnect between the fabric and the real world," NRECA said. The group asked the FCC to encourage more corrections to fabric data, saying the fabric's location challenge process "at this stage is proving to be far too onerous."

The Wireless ISP Association backed using the fabric to verify deployment obligations for high-cost support programs. It also encouraged the FCC to continue using 2010 census block data to determine compliance with high-cost program location counts. Reconfiguring census block boundaries "could result in recipients removing facilities from areas constructed under the 2010 boundaries and relocating them to areas within the 2020 boundaries," WISPA said, creating "an outcome that would unnecessarily waste high-cost support."