SUBMITTING A CHALLENGE
Who can submit a bulk fixed availability challenge?
Service providers, governments, and other entities may submit bulk challenges, as well as bulk crowdsource information, to the Broadband Data Collection (BDC) fixed availability data published on the FCC’s National Broadband Map. Bulk fixed challenge and crowdsource data must be submitted in the BDC system via file upload and conform to the FCC’s data specifications.
Individuals and entities may submit single-location challenges to the BDC fixed availability data using a form provided on the National Broadband Map. See: https://help.bdc.fcc.gov/hc/en-us/articles/10476040597787-How-to-Submit-an-Availability-Challenge
What is the deadline for submitting fixed availability challenges?
There is no deadline for submitting fixed availability challenge data. The FCC will accept fixed availability challenges on a rolling basis. However, entities are encouraged to file their challenges as soon as possible.
What is the difference between a bulk fixed challenge and a bulk fixed crowdsource data submission and how will the FCC use the information?
The main difference is that a challenge initiates a more formal process which will necessarily result in a resolution. Crowdsourcing is a less formal process through which information may be submitted in order to inform the FCC’s understanding of the availability data. Crowdsourced submissions can be used in connection with things like verification, outreach to filers, audits, and investigations. Additionally, unlike a challenge, crowdsource data may be submitted in situations where the observed speed of the service does not match its advertised speed by using category code seven (7) as the category / reason for the crowdsource data in the data file. For more information about the differences between Challenge and Crowdsource data, visit: https://help.bdc.fcc.gov/hc/en-us/articles/10390788241307-Differences-between-Bulk-Fixed-Availability-Challenge-Data-and-Crowdsource-Data
Where can I find the data specifications for fixed availability challenges?
You can find Challenge Data Specifications in the Data Specifications for Bulk Fixed Availability Challenge and Crowdsource Data document here: https://us-fcc.app.box.com/v/bdc-bulk-fixed-challenge-spec
What do I need to submit to file a bulk challenge to the fixed broadband availability data published on the National Broadband Map?
Filing requirements vary slightly based on what methodology the challenger utilizes.
In all cases, the data must include the name and contact information of the challenger, the location of the dispute based on the Broadband Serviceable Location Fabric (Fabric), the category of the challenge, and evidence to support the challenge.
For more information, and examples, see: https://help.bdc.fcc.gov/hc/en-us/articles/10389893104923-Overview-of-Bulk-Fixed-Availability-Challenges
Do I need to include a header row even if a field will be blank?
Yes, when uploading files in the BDC System, users must include the headers specified for each upload file, and the text in the headers must match what is specified. File templates that include the specified header rows are available for download from the FCC’s website here: https://help.bdc.fcc.gov/hc/en-us/articles/10390523851803-How-to-Format-Bulk-Fixed-Challenge-and-Crowdsource-Data, and additional information is available in the Bulk Fixed Challenge and Crowdsource Data Specification at https://us-fcc.box.com/v/bdc-bulk-fixed-challenge-spec.
Even if a field is left blank, the category must still be included in the file or else the submission will fail.
Can an entity submit multiple bulk availability challenges over several different days?
Yes. Entities may submit multiple bulk challenge submissions in the BDC system.
Will actual speeds delivered be considered as part of the bulk fixed challenge process?
Information about the performance of a service that has been installed, such as speed test data, is not an accepted basis of an availability challenge. It can, however, be submitted as crowdsource data by using category code seven (7) as the category / reason for the crowdsource data in the data file. For more information about crowdsource data, visit: https://help.bdc.fcc.gov/hc/en-us/articles/10390133372955-Overview-of-Bulk-Fixed-Crowdsource-Data.
Performance information can also be submitted in an informal complaint through the Consumer Governmental Affairs Bureau complaint system: https://consumercomplaints.fcc.gov/hc/en-us
Note, this scenario is different from a provider stating that their reported maximum advertised speed is not available for purchase, which would form the basis of an availability challenge.
What can I do if the maximum advertised speeds are not available at my location?
If a provider has reported a certain speed is available at a location but you contact them and try to obtain that service and the provider denies your request (i.e., we can only make a lower speed available to you), that would form the basis of a fixed availability challenge.
Why is documented evidence not required from an individual challenger?
The FCC designed the individual fixed challenge process to be as consumer friendly as possible. While we don't require individuals to upload a file as evidence, they do have to provide a description that should include details of a request for service (or attempted request for service), including the date, method, and content of the request and details of the response from the provider, or evidence showing no availability at the disputed location.
What are some examples of supporting documentation that bulk fixed challengers may submit?
For a challenge based on knowledge of infrastructure (methodology 1), examples of supporting documentation include local building permit records, rights-of-way records, franchise agreements, or an on-the-ground examination of broadband infrastructure in a particular structure. Please be sure to include any corresponding labels, legends, codes, or other explanatory information so that the FCC and the provider can understand your supporting documentation.
For a challenge based on information collected from individual consumers (methodology 2), examples of supporting documentation could include documentation collected from individual consumers (emails, screenshots, other correspondence) of requests for service and provider responses, screenshots from provider availability tools, and photographs of circumstances relating to a challenge (e.g., equipment, where the reported technology is subject to challenge).
I am an Internet service provider (ISP) and have business locations where we provide service that are not showing up as broadband serviceable locations on the map. How can we add these locations to the map?
If an ISP serves locations that are not identified as broadband serviceable on the map, the ISP should submit a Fabric challenge (or, a location challenge) and not a fixed availability challenge. You can submit Fabric challenges either as an individual challenge directly from the map or as a bulk Fabric challenge.
What if a provider reports availability on the map and you know it doesn't serve the area, but can't prove whether they have the infrastructure or not? For example, calling to request service for several addresses and the response was “service is not available, but you can request to be put on the wait list.”
You don't have to base your challenge on infrastructure. Instead, you can submit this challenge under methodology 2 (Information Collected from Individual Consumers) and format your submission accordingly.
Should we include satellite and wireless technologies in a challenge or just focus on wired?
Challenges to satellite and terrestrial fixed wireless are considered part of the bulk fixed availability challenge process. Similar to other technologies, challenges to those services can be submitted individually via the map or in the BDC system via bulk upload.
What counts as a nonstandard equipment or connection charge? For example, a provider requires a more expensive antenna and a 2-year contract; is that a nonstandard connection charge that would potentially count for purposes of submitting that category of challenge?
That challenge code addresses situations where the provider is charging the customer something that they are not automatically charging other new customers. In your example, if the customer is told that in order to make this connection you (and not everybody else) must get this special antenna, that could serve as the basis of a fixed availability challenge.
ABOUT THE MAP
Would it be possible for the FCC to add latitude and longitude to each Location ID for the reports available for download?
Latitude and longitude are elements of the Fabric. To the extent you want to include latitude and longitude in the availability data, you can execute a Fabric license agreement.
Would it be possible to modify the mapping tool so there is a toggle switch that turns the hexagons on and off?
Not currently. As you zoom out on the map it becomes quite impossible to see individual points. The hexagons show you a percent of coverage to identify areas with greater or lesser availability. Users can download the data and map the locations themselves if they wish.
Would it be possible to modify the mapping tool so the Location ID is shown by address?
When you click on the “availability challenge” link on the map for a location, the unique Location ID for the point populates in the pop-up module.
Our state is showing 100 percent covered on the map because one of the satellite providers reports that it can serve via satellite at a speed of 350 megabits download and 40 megabits upload. Is there a way to filter out satellite so they can see underserved areas as defined by NTIA?
Yes. On the map, you can click on the gear icon in the upper right-hand side of the page to customize your view and choose the technologies and speeds that you are interested in seeing displayed. Please note that this will filter just the map itself; the percent of units covered chart will remain static. Also, you can download the data in a CSV format to perform further analysis.
Are GIS data by state available and, if so, where?
Downloads of GIS files (polygons) for the fixed broadband availability data on the map are not available. They are available for the mobile coverage maps.
How often will the map be updated to reflect fixed availability challenges?
The FCC plans to regularly refresh the data shown on the National Broadband Map based on the results of fixed availability challenges that are conceded or resolved. Users will also be able to view pending availability challenges on the map by clicking on the “Toggle Layers” icon on the left side of the screen, and checking the “Availability Challenge” box. A yellow circle will appear around any location at which an availability challenge has been filed.
The map indicates whether a point has been challenged. As a state broadband office, are we able to access map services like a live data feed of this status info to track the challenge status?
Currently we have not enabled API driven or other map services access for the data that are on the National Broadband Map. However, API access that would allow parties to get status updates pertaining to challenges and other information is a functionality that we are actively working to make available in the future.
USING THE DATA
How am I able to associate the downloaded data to the locations that I'm wanting to challenge?
First, you need to obtain a license to access the Fabric data set. Once you have accessed the Fabric data, you can join the Location ID field in the Fabric data set to the Location ID field in the availability data set that you have downloaded from the map.
What are some examples of analytic software that could be used to do some of this work, and is there funding to purchase this software?
The FCC doesn't make funding available for that purpose. There are several packages that don't require expensive purchases that could be used. You could use post GIS, QGIS, and the geo pandas library of python. There are several open-source SQL options such as PostgreSQL. In addition to those software options, we also are aware of several states partnering with academic institutions in their state, such as universities to assist with the challenge process.
Can you explain the filtering a little more? Many of the files that are available for download are larger than what Microsoft Excel can handle.
That is correct. There are preset filters available from the map to filter data by provider for the whole country or by state and technology for fixed broadband. And then we would recommend opening those files, working with them in another type of database software to do the filtering for different providers or different speeds or geographies and then if you kind of isolate that smaller set that might be something you could work with and excel at that point. I think making data available, different filters is something we may consider doing in the future.
Who will evaluate fixed challenges, and on what basis?
Under the Commission’s rules, a provider must respond to a challenge that is submitted against it within 60 days of being notified by either accepting/conceding the challenge or denying it. If the provider disputes the challenge, the provider and the challenger then have an additional 60 days from the date the provider submits its reply, to attempt to resolve the challenge. If a challenge is not resolved by the parties, the Commission will review the evidence and make a determination. More information can be found at: https://help.bdc.fcc.gov/hc/en-us/articles/11296823221403-How-Providers-Should-Respond-to-Fixed-Availability-Challenges-.
Will challenges persist over time?
Yes, challenges that are upheld will persist across availability collections. However, ISPs may build out and expand their infrastructure during filing windows – in that situation, there is a process to update the data.
What happens if more than one challenge is submitted by different parties at the same location?
Each valid challenge will be served on the provider and ultimately resolved or adjudicated, even if multiple challenges to the same location are submitted.
If a fixed availability challenge is upheld, how does that impact the locations in the area? Does the house next door need to be challenged?
The FCC will independently review the data for patterns, but challenges only pertain to the particular challenged locations. As such, in the case of a successful individual challenge, only the particular challenged location will be updated. In the case of a successful bulk challenge submission, every successfully challenged location will be updated on the map.
When an entity uses Methodology 2 to file bulk challenges (Information Collected from Individual Consumers), does it need to include contact information for each individual end-user? What about bulk crowdsource data?
Yes. Contact details must be provided for each individual consumer whose information is used in a bulk challenge and crowdsource submission filed under this methodology. Contact information for bulk challenges and crowdsourced data using Methodology 2 (Information Collected from Individual Consumers) will be collected via the upload file, not the web form.
If a reported service is not available due to oversubscription, is that a valid basis for a challenge?
Yes. By reporting that service is available at a location, a provider is representing that it either serves the location or could serve it within ten business days of a request with a standard installation (i.e., without charges or delays attributable to the extension of the provider’s network). If a provider does not have capacity on its network to meet this standard, service is not available at that location and should not be included in the provider’s BDC availability data. For certain types of satellite and fixed wireless service, “the signal is not available” is a challenge code that challengers could use.
However, if capacity issues result in performance being slow or unreliable, that should be addressed in the FCC’s consumer complaint process rather than in the BDC.
I am a governmental entity and I have infrastructure data that was collected before a filing window. Can I use that data as the basis for a challenge?
No. In order to file that data as a challenge, it needs to be information collected after the filing window “as of” date.
How does the map define whether a service is “available”?
A service is available if the provider has an existing connection, or could and is willing to serve that location within 10 business days with a standard installation.