High-Cost Program Fabric Resources

All High-Cost Programs

The Wireline Competition Bureau (Bureau) has adopted the use of the Broadband Serviceable Location (BSL) Fabric (Fabric) when verifying compliance with the high-cost obligation to make broadband available to residences and small businesses in areas eligible to receive high-cost support.  See https://docs.fcc.gov/public/attachments/DA-25-32A1_Rcd.pdf.   

High-cost carriers are encouraged to review the data they previously submitted to the High-Cost Universal Broadband (HUBB) portal and data they have submitted as part of the Broadband Data Collection (BDC) reporting to identify any inconsistencies. 

Rural Digital Opportunity Fund (RDOF), Bringing Puerto Rico Together Fund (PR Fund) and Connect USVI Fund

RDOF, PR Fund, and Connect USVI Fund carriers are transitioning from reporting in the HUBB using latitude/longitude/addresses to reporting deployment using BSLs and Fabric Location Ids. 

Alternative Connect America Cost Model (A-CAM)

If an A-CAM carrier identifies a discrepancy between the HUBB data it filed and its BDC reporting, the carrier can take one of the following steps to address the discrepancy:  1) remove the location from its HUBB submission or modify the attributes of its HUBB submitted location(s) to align with Fabric BSL(s), or 2) submit a Fabric challenge through the National Broadband Map or the Broadband Data Collection system if the carrier believes the Fabric is not accurate.

Rural Digital Opportunity Fund Fabric True-up Process

RDOF carriers’ authorized required location total is based on the number of locations estimated by the Connect America Cost Model (CAM).  The Bureau will conduct a process by which it will revise the number of locations that each RDOF carrier must serve based on the actual number of locations in the carrier’s RDOF service area as shown by the Fabric.  Specifically, the Bureau will announce revised location totals for each RDOF carrier within a reasonable amount of time after the Fabric version used for the BDC collection as of December 31, 2026 is made available to licensees (December 2026 Fabric).  Carriers are on notice that any outstanding or pending challenges that were filed but not incorporated in the December 2026 Fabric will not be considered for determining the final deployment obligation.  Accordingly, RDOF carriers should file challenges to the Fabric by no later than September 1, 2026 to add or remove locations from the Fabric and to ensure that they have sufficient time to complete the challenge process in order for successful challenges to be reflected in the December 2026 Fabric.  More information about the 2026 Key Dates for the Fabric and National Broadband Map, including filing of challenges, will be available here:  https://www.fcc.gov/BroadbandData.

Interim Service Milestones

RDOF carriers’ interim service milestones (40%, 60%, 80%) will remain based on the RDOF carrier’s authorized model-estimated location total (e.g., 40% of the number of locations estimated by the CAM).  Prior to the Bureau’s release of the final required location lists in December 2026, if a RDOF carrier appears to be unable to meet an interim service milestone because there are significantly fewer existing locations between its interim required locations list and the estimated number of locations by the CAM, a RDOF carrier can seek waiver of non-compliance with the relevant service milestone.  The Bureau will find good cause exists to waive the relevant service milestone if:  1) the RDOF carrier demonstrates with Fabric data that it has identified all existing locations in its service area, and 2) USAC verifies that the support recipient offers service meeting the relevant requirements to all existing locations. 

A RDOF carrier should wait until the year of the relevant service milestone that it is unable to meet before filing a petition for waiver to ensure that the waiver is based on a recent version of the Fabric prior to the service milestone.  If a RDOF carrier’s Fabric Location ID list in the HUBB does not include a location that the RDOF carrier believes is an eligible location (i.e., a housing unit or small business to which mass market services will be made available), the RDOF carrier should submit a Fabric challenge to have that location added to the Fabric.  If a RDOF carrier’s Fabric Location ID list in the HUBB includes a location that the RDOF carrier believes is not an eligible location, the RDOF carrier should submit a Fabric challenge to have that location removed from the Fabric.  A carrier must be able to demonstrate that a Fabric challenge was successful before the Bureau will consider the location to be added or removed from the carrier’s Fabric Location ID list. 

100% Service Milestone

After the Bureau has adopted the new location totals based on the December 2026 Fabric, a RDOF carrier with more locations in its RDOF service area than the authorized model-estimated location total or the same number of locations as the authorized model-estimated location total must serve the authorized model-estimated number of locations by December 31, 2027 (if authorized in 2021) or by December 31, 2028 (if authorized in 2022 or 2023).  In addition, a carrier that has more locations than its authorized model-estimated location total will have until December 31, 2029 (if authorized in 2021) or until December 31, 2030 (if authorized in 2022 or 2023) to serve the additional locations above the model-estimated total. 

If a RDOF carrier has fewer locations than the authorized model-estimated location total in a service area, the RDOF carrier will be required to serve 100% of the new lower number of locations by December 31, 2027 (if authorized in 2021) or by December 31, 2028 (if authorized in 2022 or 2023).

The Commission directed RDOF carriers to notify the Bureau no later than March 1st following the fifth year of deployment—i.e., March 1, 2027—if there are fewer actual locations in a carrier’s RDOF service area than its authorized model-estimated location total.  RDOF carriers with fewer locations shall submit a notification in ECFS in WC Docket Nos. 10-90 & 19-126, and AU Docket No. 20-34 by March 1, 2027, and may incorporate the Fabric by reference by certifying that there fewer locations identified in the latest version of the Fabric in the carrier’s relevant service area than the carrier’s model estimated locations total, https://www.fcc.gov/ecfs/search/search-filings.

PR Fund and Connect USVI Location Adjustment Process

The Bureau will conduct a location adjustment process for PR Fund and Connect USVI Fund carriers within a reasonable amount of time after the version of the Fabric used for the BDC collection as of December 2025 (December 2025 Fabric) is made available to licensees.  

When the Bureau has opened the submission window, PR Fund and Connect USVI Fund carriers must submit a document in the Commission’s Electronic Comment Filing System (ECFS) in WC Docket Nos. 18-143 and 10-90 certifying that they have reviewed the Fabric and there are more or fewer locations identified in the latest version of the Fabric in the carrier’s relevant service area than the carrier’s authorized model-estimated location total, https://www.fcc.gov/ecfs/search/search-filings.  

Carriers are on notice that any outstanding or pending challenges that were filed and not incorporated into the December 2025 Fabric will not be considered for determining the final deployment obligation.  Accordingly, PR Fund and Connect USVI Fund carriers should have filed challenges to the Fabric by September 12, 2025, to add or remove locations from the Fabric. 

Alternative Connect America Cost Model (A-CAM)

The Bureau will conduct a voluntary location adjustment processes for A-CAM I, Revised A-CAM I, and A-CAM II carriers to seek a downward adjustment in their location totals by using the Fabric to demonstrate the actual number of locations in their service areas.  

A-CAM I Carriers Location Adjustment Process

A-CAM I carriers that want to seek a downward adjustment in their required location totals must submit a request in ECFS in WC Docket No. 10-90, https://www.fcc.gov/ecfs/search/search-filings.  The Bureau will open a window for such requests within a reasonable amount of time after the version of the Fabric that is used for BDC collection as of December 31, 2025 (December 2025 Fabric) is made available to licensees.

Carriers will be required to certify that they have reviewed the December 2025 version of the Fabric and that there are fewer locations identified in the December 2025 version of the Fabric in the carrier’s service area than the carrier’s authorized model-estimated location total.  Carriers are on notice that any outstanding or pending challenges that were filed but not incorporated in the release of these Fabric versions will not be considered for determining the final deployment obligation.  Accordingly, A-CAM I carriers should have filed challenges to the Fabric by September 12, 2025 to add or remove locations from the Fabric.

Revised A-CAM I and A-CAM II Carriers Location Adjustment Process

Revised A-CAM I and A-CAM II carriers that want to seek a downward adjustment in their required location totals must submit a request in ECFS in WC Docket No. 10-90, https://www.fcc.gov/ecfs/search/search-filings.  The Bureau will open a window for such requests within a reasonable amount of time after the version of the Fabric that is used for BDC collection as of June 30, 2026 (June 2026 Fabric) is made available to licensees.

Carriers will be required to certify they have reviewed the June 2026 version of the Fabric and there are fewer locations identified in the June 2026 version of the Fabric in the carrier’s service area than the carrier’s authorized model-estimated location total.  Carriers are on notice that any outstanding or pending challenges that were filed but not incorporated in the release of these Fabric versions will not be considered for determining the final deployment obligation.  Accordingly, Revised A-CAM I and A-CAM II carriers should file challenges to the Fabric by March 2, 2026 to add or remove locations from the Fabric and ensure they have sufficient time to complete the challenge process so that successful challenges are reflected in the June 2026 Fabric. 

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