FCC National Broadband Map

The broadband availability data that mobile and fixed wireless providers report to the FCC is flawed, according to several rural broadband organizations. The organizations offered this view in comments filed with the FCC about the commission’s broadband data collection (BDC) challenge process.

The commission recently invited feedback on that process.

It’s an important issue because eligibility for broadband funding in many rural areas depends on the accuracy of the FCC data, which is used to produce the National Broadband Map.

The Comments

According to NTCA – The Rural Broadband Association, “factors critical to assessing fixed wireless providers’ ability to meet claimed service levels are often not available for Commission or challenger review under current BDC filing specifications.”

According to NTCA’s reading of the rules, only the fixed wireless providers who submit coverage maps (shapefiles) to the Commission are required to include other data, such as propagation models and base station locations and heights. Other fixed wireless providers have only been submitting addresses to the “fabric,” the FCC’s database of broadband availability locations. Challengers often do not have the resources to research propagation information in fabric challenges, NTCA noted.

NTCA suggests that the Commission standardize the data reporting specifications to all fixed wireless submissions, whether made via shapefiles or via lists of broadband serviceable locations.

NRECA, in its comments, noted that it has assisted its members in filing challenges to more than 266,000 locations. Like NTCA, it sees inaccuracies in coverage data creeping in because of flaws in wireless ISP reporting. Many large national mobile carriers, it said, have been reporting mobile 5G coverage as “fixed wireless.”

“For a variety of reasons, mobile 5G is not equivalent to fixed wireless service. Fixed wireless service provides a more reliable connection, with more consistent speeds than mobile service,” NRECA said.

According to NRECA, fixed services use multiple input, multiple output (MIMO) antennas and beamforming to improve throughput to specific subscribers. FWA providers also are less likely than mobile carriers to impose monthly data caps, NRECA said.

NRECA called on the Commission to prohibit mobile carriers from reporting mobile 5G as fixed wireless “with appropriate enforcement mechanisms [including penalties] for noncompliant entities.”

Meanwhile, the Coalition of Rural Wireless Carriers (CRWC) focused its comments on how the broadband data collection process measures mobile speeds and how that affects the 5G Fund, a universal service program intended to expand mobile network coverage. The FCC, CRWC claims, is not receiving enough challenge data to accurately report rural mobile coverage on the National Broadband Map.

Companies in CRWC include Carolina West Wireless, C Spire, Appalachian Wireless, NE Colorado Celllular, Viaero Wireless, Nex-Tech Wireless, CellularOne, Union Wireless, UScellular, and United Wireless
Communications.

As CRWC noted, the FCC analyzes mobile coverage challenges using data from its online speed test. Between November 2022 and August 2023, the commission received data from 190,000 challenge speed tests resulting in 35 separate challenges and 18 revisions to the map.

“We note that Ookla’s app, one of many commercial speed test apps, has been downloaded over 100 million times on Android devices alone and processes over 5 million unique mobile tests each day,” said the coalition. The FCC’s mobile speed test data is statistically insignificant, it said.

CRWC proposed an extensive change to the Commission’s geographic testing threshold to solve the problem.

WISPA Weighs In

In its comment filing with the FCC, the Wireless Internet Service Providers Association (WISPA) offered a rebuttal to the suggestion that the commission require propagation models for FWA coverage submitted in address form.

“The commission should preserve the status quo given the significantly increased amount of work that would be required for providers to submit propagation model details, base station information and link budget parameters for potentially hundreds of thousands of locations,” WISPA said.

“That increased work would not be confined to providers but also to [FCC} staff.”

According to WISPA, the FCC “appropriately chose to rely more heavily on challengers, the dispute resolution process and the verification process on the back end to determine service availability for those providers electing to submit locations.”

It’s worth noting that NRECA’s concerns about mobile coverage being reported as FWA applies to large mobile providers, not WISPA members.

Joan Engebretson contributed to this report

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