Entities – including service providers, state, local, and Tribal governments, and other third parties (e.g., consumer groups, non-governmental groups, etc.) – may dispute the availability of mobile broadband service by submitting the results of on-the-ground speed tests of mobile network coverage to the FCC.
Any entity interested in submitting such data must be registered in the BDC system.
Entities submitting mobile speed tests in bulk as part of the mobile challenge process may use their own hardware or software to collect speed test data, so long as they adhere to the following requirements:
- The submitted speed test results must conform to the set of metrics and parameters found in the Data Specifications for Mobile Speed Test Data.
- Entities may not use iOS devices to collect their data.
- The bulk speed test data must be submitted by uploading a file in the BDC system at bdc.fcc.gov.
- The file submitted must contain records of each mobile speed test and must be in JavaScript Object Notation (JSON) format.
- Entities must submit, in the BDC system, a complete description of the methodology used to collect their data.
- Submissions must be certified by a qualified engineer or official.
Bulk speed test data submissions will be validated to ensure each speed test was taken within the provider’s claimed coverage area, and between the hours of 6:00 a.m. - 10:00 p.m. local time. Valid speed tests from both consumers and entities will then be aggregated and analyzed at the end of each month. Once there are enough “failed” tests (i.e. showing speeds below 5/1 Mbps for 4G, or 7/1 or 35/3 Mbps for 5G) within a certain area and at different times of day, a challenge will be created. Specifically, groups of speed tests must meet three thresholds to create a “cognizable” challenge that will be sent to a provider for response:
- Geographic Threshold – “failed” tests must be geographically distributed across a hexagonal geographic area nearly the size of one square kilometer);
- Temporal Threshold – the tests must be taken at different parts of a day; and
- Testing Threshold – there must be a sufficient number of tests in the hexagonal geographic area. For more information, on these thresholds, see the Mobile Technical Requirements Order.
After a challenge is created, the provider that is the subject of the challenge will have 60 days to respond. A provider may either concede or rebut a challenge. To rebut a challenge, a provider is required to submit on-the-ground data or, in some circumstances, it may submit information about its network infrastructure. If a challenge is conceded by a provider or upheld by the FCC, the provider will have 30 days to update its mobile availability coverage data to indicate on the National Broadband Map that the challenged area was shown to have insufficient coverage.