<RULE>
FEDERAL COMMUNICATIONS COMMISSION
<CFR>47 CFR Part 54</CFR>
<DEPDOC>[Connect America Fund et al.; WC Docket Nos. 10-90, 18-143, 19-126; AU Docket No. 20-34; DA 25-32; FR ID 280111]</DEPDOC>
<SUBJECT>Broadband Serviceable Location Fabric</SUBJECT>
<HD SOURCE="HED">AGENCY:</HD>
Federal Communications Commission.
<HD SOURCE="HED">ACTION:</HD>
Final action.
<SUM>
<HD SOURCE="HED">SUMMARY:</HD>
The Wireline Competition Bureau (WCB or the Bureau) adopts the Broadband Serviceable Location Fabric (Fabric), the most up-to-date and comprehensive source for identifying broadband serviceable locations (BSLs), as the basis it will rely on for generally verifying compliance with high-cost program deployment obligations and for adjusting the location obligations for certain high-cost support mechanisms.
</SUM>
<EFFDATE>
<HD SOURCE="HED">DATES:</HD>
Effective April 4, 2025.
</EFFDATE>
<FURINF>
<HD SOURCE="HED">FOR FURTHER INFORMATION CONTACT:</HD>
For further information, please contact, Heidi Lankau, Attorney Advisor, Telecommunications Access Policy Division, Wireline Competition Bureau, at
<E T="03">Heidi.Lankau@fcc.gov</E>
or 202-418-7400.
</FURINF>
<SUPLINF>
<HD SOURCE="HED">SUPPLEMENTARY INFORMATION:</HD>
This is a summary of the Bureau's Order (
<E T="03">Order</E>
) in WC Docket Nos. 10-90, 18-143, 19-126 and AU Docket No. 20-34; DA 25-32, adopted and released on January 10, 2025. The full text of this document is available at the following internet address:
<E T="03">https://www.fcc.gov/document/wcb-adopts-use-fabric-update-and-verify-high-cost-obligations.</E>
<HD SOURCE="HD1">Synopsis</HD>
The Bureau adopts its proposal to use the Fabric as the data source to verify compliance with deployment obligations for high-cost support mechanisms when the Bureau conducts compliance reviews. The Bureau also adopts specific procedures related to location total adjustments for the Rural Digital Opportunity Fund (RDOF), Alternative Connect America Cost Model (A-CAM) I, Revised A-CAM I, A-CAM II, the Bringing Puerto Rico Together (PR) Fund, and the Connect USVI Fund. The Bureau adopts processes and policies for implementing the RDOF location readjustment process prior to the six-year RDOF service milestone that will maximize the number of consumers served through RDOF support, and also leverage existing Federal Communications Commission (FCC or Commission) processes to implement streamlined location adjustment procedures for the PR Fund, the Connect USVI Fund, A-CAM I, Revised A-CAM I, and A-CAM II carriers. The Bureau's decision to rely on the Fabric for these purposes is an important step towards improving accuracy, oversight, and accountability for the Bureau's high-cost support mechanisms.
<E T="03">Use of the Fabric.</E>
The Bureau adopts its proposal to use the Fabric to identify the actual number of residential and small business units in each relevant high-cost support recipient's service area,
<E T="03">i.e.,</E>
the number of high cost-eligible locations. Many commenters supported using the Fabric to revise and verify deployment obligations. However, some commenters suggested that the accuracy of and process for challenging the Fabric should be improved before the Commission relies on the Fabric for verifying compliance with high-cost obligations. The Bureau disagrees. The Fabric is the most accurate and granular dataset of BSLs the Bureau has available to date. Moreover, as Congress intended in the Broadband DATA Act, the Fabric is an iterative dataset that will continue to improve through stakeholder participation in the challenge process, updates to the underlying sources of data, and improvements to the model used to generate the Fabric. No commenters suggested that any other dataset would be more comprehensive or up-to-date than the Fabric. Moreover, using a different data source could jeopardize the Bureau's efforts through interagency coordination to minimize duplicative Federal funding for broadband given that other agencies rely on Fabric data to identify potential overlaps in funding.
The Commission continues its work to balance the stability of the Fabric with the need to make updates that account for new inputs and improvements in the quality of the data. First, the Fabric remains stable and has become increasingly more stable with each release. Overall, 108 million BSLs from the original (June 2022) Fabric—or over 95% of the original BSLs—remain in the June 2024 Fabric version. The Fabric remains the most accurate picture of BSLs the Bureau has available to date. Delaying the Bureau's alignment of high-cost funding support with Fabric locations is not in the public interest because it would risk delaying deployments, leaving locations unconnected, and increase the potential for duplicative funding.
The challenge process is a critical part of ensuring the Fabric provides an accurate dataset of BSLs. Since the first version of the Fabric, the Commission has received a number of high-quality challenges that have improved the accuracy of the Fabric. For example, the Bureau has received over 2 million challenges to add a new location that hits the footprint of a BSL that was already in the Fabric. These challenges might have been intended to change an address or make some other change to the data associated with a BSL, but the challenges filed indicated that the Bureau should add a new BSL. The Commission is committed to ensuring that providers and challengers understand the challenge process to continue the submission of high-quality challenges to ensure the accuracy of the Fabric.
Some commenters have provided anecdotal examples of unsuccessful challenges that they suggest show the challenge process needs improvement before the Commission can rely on the Fabric. For example, the National Rural Electric Cooperative Association (NRECA) claims a member cooperative “submitted a location challenge specifying about 5,000 locations that should be BSLs . . . but CostQuest accepted only about 700 of the locations as valid BSLs.” Because NRECA's comments do not provide enough information to identify the provider that had problems with the Fabric challenge process, the Bureau is not able to specifically identify the reason for the provider's low success rate for its challenges. Nevertheless, the Bureau notes that NRECA acknowledges the
low success rate may be because the data used by the provider to support its challenges do not meet the Commission's requirements for a BSL, and that, in fact, the Fabric may already contain a BSL for the challenged locations. The Bureau, therefore, disagrees with commenters who argue that low-quality Fabric challenges, which resulted in rejections, are a reflection of the difficulty of the challenge process and should delay the application of the Fabric to high-cost deployment obligations.
Commission staff have taken a number of steps to ensure that providers understand Fabric challenge outcomes and to address provider concerns about the Fabric challenge process. The Commission also continues to make improvements to the challenge process based on stakeholder feedback and lessons learned. Fabric challenges are focused on which locations are BSLs, and are resolved by the Commission's Fabric contractor, CostQuest, based on guidance from Commission staff. When providers file a Fabric challenge, the Broadband Data Collection (BDC) system notifies them of the challenge outcome. When providers have made the Commission aware of concerns related to their Fabric challenge results, the Bureau has worked closely with the provider and CostQuest, to review their submissions and to identify opportunities for improvements to the Bureau's modeling or other elements of the Fabric creation and challenge review processes. Consistent with the requirements of the Broadband DATA Act, the Fabric is updated twice per year and, as a result, the final adjudication for certain types of Fabric challenges, such as requests to add or remove a location, can only be completed shortly before the release of the updated version of the Fabric. The Bureau has begun to provide certain types of Fabric challenge results earlier in the process, generally within weeks of the challenge being submitted. The Bureau believes providing results to challengers closer to the time of submission will allow them to better review their results and either resubmit a different type of Fabric challenge or to raise concerns with FCC staff about their challenge results.
<E T="03">Adjustments.</E>
In identifying the eligible locations that are relevant to a high-cost support recipient's service area, the Bureau adopts its proposal to exclude group quarters locations, which are currently included as BSLs in the Fabric, from revised location totals to remain consistent with our previous guidance to exclude such locations from our high-cost support mechanism location counts. Although the Coalition of RDOF Winners (RDOF Winners) suggested that the Bureau should include group quarters when recalculating location totals, model-based support amounts have been calculated excluding group quarters, and carriers that participated in competitive bidding may have relied on the fact that they did not have to serve group quarters when determining how much support they would need to meet their obligations. Moreover, carriers have likely relied on the guidance provided by WCB to plan their deployments. While there is a potential for some confusion given that the Fabric includes group quarters as BSLs, the Bureau notes that the Fabric has a unique building type code for group quarters locations. Ultimately, the Bureau finds on balance that the risk of disruption to ongoing deployment if the guidance changed to require funded carriers to serve group quarters strongly outweighs the potential for confusion.
The Bureau also adopts its proposal that if a portion of a parcel i
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