FCC Releases Information On Bulk Challenges To Broadband Serviceable Location Fabric Data & Clarifies How The Fabric Identifies Serviceable Locations In Certain Situations

July 1, 2022 – The FCC’s Broadband Data Task Force has released a Public Notice with information on the requirements for filing bulk challenges to broadband serviceable location (BSL) data in the Broadband Serviceable Location Fabric (Fabric).[1]

The Broadband Data Task Force also has clarified how the Fabric will determine BSLs in certain situations, such as when a single parcel of land contains multiple structures, multiple housing units, or multiple businesses. With this is the clarification that community anchor institutions and other high-density or high-demand locations are included in the Fabric but are not classified as BSLs.

A standalone document – Data Specifications for Bulk Fabric Challenge Data – with specific details on uploading bulk challenge files to the Broadband Data Collection (BDC) system also has been released. Broadband providers, governmental entities, and interested parties can access the document online at: https://us-fcc.box.com/v/bdc-bulk-fabric-challenge-spec.

Bulk Fabric Challenges

The Fabric is a common dataset of all locations (business or residential) in the U.S. where fixed mass-market broadband internet access service can be installed, and is the foundation for the data collected and maps to be created by the BDC. On June 23, 2022, the FCC released the production version of the Fabric to BDC filers and state, local and Tribal government entities. The BDC filing window opened on June 30, 2022 and closes on September 1, 2022.

There will be a challenge process for the Fabric, but the FCC has not set a date for the filing window. Broadband providers, governmental entities, and other stakeholders will be allowed to submit challenges and proposed corrections to location data in the Fabric. Entities may file multiple challenges at the same time, but these “bulk” challenges must conform to the Data Specifications for Bulk Fabric Challenge Data.

Bulk challenges must be submitted via a file uploaded to the online BDC system. They must include the following: entity name; entity contact information, locations subject to challenge, category of challenge for each location, and evidence to support the challenge.[2] Further, bulk Fabric challenge data files must include records for each location being challenged in a Comma Separated Value (CSV) format, all fields must be included in the file upload, and all values must conform to the descriptions, codes, or formats identified for each field in the Data Specifications for Bulk Fabric Challenge Data document.[3]

Further Clarification Of How The Fabric Will Determine Existence Of Broadband Serviceable Locations

In the Public Notice, the Broadband Data Task Force also addresses “additional characteristics of BSLs for purposes of the Fabric so that challengers will be able to align their data with the Fabric to determine when BSLs may be missing or mischaracterized.” This information is separated into three topics: (1) residential parcels; (2) non- residential parcels; and (3) differentiating between mass-market broadband locations and non-mass market broadband locations.

As mentioned, a BSL – broadband serviceable location – is a residential or business location at which fixed mass-market broadband internet access service is, or can be, installed. In the Fabric, each BSL is “a single point defined by a set of geographic coordinates that fall within the footprint of a structure, and each such location has been assigned a unique FCC-issued Location ID.”[4]

First off, the Broadband Data Task Force notes that the amount and quality of location data used to create the Fabric varies across the country. As a result, the Fabric’s determinations as to broadband serviceability are only accurate to the extent such determinations can be made given the data available. This means the challenge process is crucial because in many areas stakeholders on the ground will have better information on whether a location should be classified as a BSL.

Residential Parcels

The Broadband Data Task Force has provided the following clarification details on BSLs on residential parcels:

For a single residential parcel with one single-family home, the structure of the single-family home will be identified as one BSL in the Fabric. Similarly, an individual town home or row house that is on its own parcel will be identified as one BSL.

In situations where there is one residential structure, but more than one housing unit on the parcel (for example, a duplex, a triplex, an apartment building, or a home with a basement apartment), the Fabric identifies the structure as one BSL, but includes the number of separate housing units at the location in the Unit Count field, to the extent such data are readily available (e.g., where unit counts are included as part of public land records).

A single residential parcel that is identified as a single family residence but has multiple, identifiable single-family, or other single-unit structures (for example, a main home and a separate garage or some other auxiliary standalone dwelling unit) also is identified in the Fabric as a single BSL. The production version of the Fabric accords BSL status to the primary residential structure on a parcel, but not to other structures on the same parcel. While some such additional structures may be classified as broadband serviceable in later versions of the Fabric, currently, the available data do not allow us to determine reliably whether they are owned and/or occupied as a distinct household or are otherwise suitable for a distinct broadband connection.[5]

In cases where a residential parcel contains more than one multiple-dwelling-unit structure or other residential MTE structure not identified as a single-family-home, each structure is counted as a distinct BSL in the Fabric, with its own unique FCC identifier, and includes the number of separate housing units in the Unit Count field, if such data are readily available. For example, in the case of multiple condominium or apartment buildings on a single residential parcel, each building will be counted as a distinct BSL.

Non-Residential Parcels

The Broadband Data Task Force has provided the following clarification details on BSLs on non-residential parcels:

Generally, the Fabric reflects one representative BSL on a non-residential parcel (including multi-structure parcels) when any of the following circumstances exist: (1) all of the structures on the parcel are commonly owned and/or occupied by a single tenant; (2) there are multiple structures that the available data indicate would be expected to subscribe to mass-market broadband service (for example, libraries, religious centers, or houses of worship); (3) the parcel contains multiple group quarters structures (e.g., dormitories, prisons, or nursing homes); or (4) a recreational area such as a complex, resort, RV park, or marina contains multiple structures.[6]

In some limited circumstances, each structure on a parcel identified as commercial, office, or industrial is counted as a separate BSL in the Fabric that the data indicate have distinct occupants or tenants. (In contrast, a single structure with multiple office units on a non-residential parcel is designated as a single BSL in the Fabric.)

Differentiating Between Mass-Market Broadband Locations and Non-Mass Market Broadband Locations (Community Anchor Institutions & Other High-Density/High-Demand Locations)

The production version of the Fabric includes community anchor institutions and other high-density or high-demand locations. However, the production version of the Fabric does not identify them as BSLs because these types of locations “most commonly subscribe to enterprise/business data broadband services, which are not included in the BDC.”[7] Examples of high-density/high-demand locations include office buildings with demand for enterprise-level broadband service. Examples of community anchor institutions are schools; hospitals, including Veteran’s Administration facilities; state government buildings and courthouses; executive mansions and state legislative buildings; fire/EMS stations; and Red Cross facilities. Also, the Task Force “assume[s] that local government buildings in jurisdictions with a population of at least 500,000 are more likely to rely on enterprise or self-provisioned broadband service and will not be identified as BSLs.”[8]

The Task Force concedes that these locations “may subscribe to mass-market services in some instances,” but says it currently lacks data “to make reliable determinations of when this is the case.”[9]

However, if the FCC or CostQuest “obtain[s] information, through a challenge or otherwise, and determines that a building originally identified in the Fabric as taking enterprise broadband services instead takes mass-market broadband Internet access services, then that building will be identified in a future version of the Fabric as a BSL.”[10] 

**********

[1] Broadband Data Task Force Publishes Data Specification For Bulk Challenges Of Broadband Serviceable Location Fabric Data And Provides Further Details On Fabric Locations Data, WC Docket Nos. 19-195 and 11-10, Public Notice, DA 22-705 (July 1, 2022) (Public Notice), https://docs.fcc.gov/public/attachments/DA-22-705A1.pdf.

[2] Public Notice at pp. 1-2.

[3] Public Notice at p. 2.

[4] Public Notice at p. 3. A residential BSL includes all residential structures, including structures that are (or contain) housing units or group quarters (as those terms are defined by the United States Census Bureau). A business BSL includes “all non-residential (business, government, non-profit, etc.) structures that are on property without residential locations and that would expect to demand broadband Internet access service. Public Notice at pp. 2-3.

[5] Public Notice at p. 4. “In contrast, on a residential parcel identified as a mobile home park, each mobile home will be considered a distinct, individual BSL because the available data allow us to determine reliably that each individual structure is inhabited by a separate family or entity requiring a distinct broadband connection.” Id.

[6] Public Notice at p. 5.

[7] Id.

[8] Public Notice at pp. 5-6.

[9] Public Notice at p. 5.

[10] Public Notice at p. 6.