FCC Broadband Data Collection in West Virginia

On June 30, 2022, the Federal Communications Commission (FCC) released the first version of the Location Fabric dataset related to the Broadband Equity, Access, and Deployment (BEAD) program under the Infrastructure, Investment and Jobs Act. The Broadband Serviceable Location Fabric (Fabric) is a dataset of locations compiled of building footprint and rooftop centroids that are known to receive mass-market broadband services.

The West Virginia Department of Economic Development (WVDED) is responsible for challenging both the availability and location data of the fabric for two reasons; to impact the overall BEAD allocation for West Virginia and to ensure no West Virginians are excluded from the final version of the National Broadband Map.

The anticipated BEAD allocation to eligible entities is determined by the number of unserved broadband serviceable locations (BSLs) located in each state. However, eligible entities are competing for the same pool of funding. The allocation is determined by the sum of the three following factors:

1. Minimum Initial Allocation: $100,000 allocation
2. High-Cost Allocation: The number of unserved locations in high-cost areas divided by the total number of unserved locations in high-cost areas in the United Stated and multiplying multiplied by $4,245,000,000. The designation of high-cost areas will be determined by the NTIA later this year.

Unserved Locations/Total Number of US Unserved Locations X $4,245,000,000

1. Remaining Funds Allocation: The funds remaining after subtracting each Eligible Entity's Minimum Initial Allocation; and the total High-Cost Allocation from $41,601,000,000 to result in the "Remaining Funds." Remaining Funds for a Eligible Entity is calculated by dividing the numbers of unserved locations in the Eligible Entity by the total number of unserved location in the United States and multiplying the result by the Remaining Funds.

Version 1 of the BDC fabric consists of 902,699 broadband serviceable locations (BSLs). Locations are classified by the following building types:

• R - Residential
• B - Business
• X - Residential and Business
• E - Enterprise
• C - Community Anchor Intuition
• G - Group Quarters (e.g., university dorm building)

Upon the "pre-production draft" release of the  National Broadband Map  on November 18, 2022, the public was encouraged to submit a challenge if their location was missing or labeled inaccurately. The Department conducted a bulk fabric challenge to identify as many missing locations to be included in the second version published by the FCC.

138,568 missing locations have been submitted to the FCC. The methodology used was identifying broadband serviceable addresses from the West Virginia Statewide Address and Mapping System (SAMS) that did not share the same spatial relationship as the Version 1 Fabric dataset. GIS layers utilized were Microsoft Building Footprints and West Virginia tax parcels.

Only 10.6% of the locations challenged the Department were accepted by the FCC. However, thanks to the participation of West Virginians, an additional 3,294 missing locations were challenged and accepted.

Several implications in the bulk fabric challenge is that the SAMS dataset includes more locations than what may be realistically broadband serviceable and some locations are not accurately classified. The dataset has been filtered with best practices to consists of only broadband serviceable structures; however, the Department has identified some counties have broadband serviceable structures classified as "Accessory Building," "Unidentified," or "Address Conflated" that are residential homes.

To air on the side of the consumer which mitigates the risk of leaving out West Virginians to receive connectivity through either BEAD or the West Virginia Broadband Investment Plan, the Department did not filter out the above referenced classifications from the dataset.

FCC Response

Implications in the methodology have been assessed and revised for submitting a bulk challenge to Version 2 of the Fabric. Some examples include adding a 10m buffer to the building footprints to account for any address that may be not completely within a polygon boundary and limiting the use of tax parcels that are not related to a broadband serviceable structures.

Although imperfect practices that yielded rejected responses such as "the geographic coordinates for the challenge intersect with the footprint of an existing BSL," the Department is left with the question as to why 35,799 locations failed due to "the address provided for the challenge could not be validated."

The following tables demonstrate challenges submitted to the FCC and the responses received.

Version 2 of the Fabric was released on 12/31/2022. The total number of BSLs is 900,408. This is 2,291 less than Version 1. With a total of 17,966 locations accepted into the new fabric from the the first challenge, the reduction raises questions. However, this may demonstrate improvement in the overall accuracy of the Fabric.

14,670 of the accepted addresses (2 missing) have been added to the second version of the Fabric with an additional 11,176 addresses from public challenges (or added by CostQuest from an improved production process). With only 874,603 locations from Version 1 included in Version 2, Version 2 removed 28,096 locations.

Addresses removed from the Version 2

There were 28,096 addresses that did not make it into Version 2 of the Fabric. 2,586 of these locations are classified as a residential structure in the SAMS dataset. However, some locations included in the first version of the Fabric that are not present in the SAMS address dataset have been removed. This demonstrates that the accuracy of the map is improving.

The contrarian view in the map below shows a SAMS address classified as single family whereas the BDC address which is classified as a business, is missing from Version 2. Examples as such bring on complexity to assessing the overall accuracy in both datasets.

The November 18 release of the National Broadband Map was the first public view of broadband availability in the United States. Compared to prior years of ISPs filing with the FCC (Form 477) that was based on one offering in a census block, broadband availability is now filed at the address level.

Services deemed as Reliable Broadband Services in the BEAD NOFO

The BEAD  Notice of Funding Opportunity (NOFO)  states the following technologies as "Reliable Broadband Services"

• Fiber-optic technology
• Cable Modem/Hybrid fiber-coaxial technology
• Digital subscriber line (DSL) technology
• Terrestrial fixed wireless technology - Licensed spectrum or hybrid license-unlicensed sprectrum

Satellite and unlicensed fixed wireless are not considered reliable broadband services by NTIA. Although the National Broadband Map displays almost all address locations and service polygons as served by satellite services, this representation does not impact the number of unserved locations factored into the BEAD allocation.

The Department conducted a bulk fixed challenge (availability challenge) to determine locations suspected to be overreported. Two methodologies were utilized; physical field surveys and GIS/desktop analysis.

FCC BDC Locations: BEAD Tiers

BEAD classified broadband serviceability into three tiers:

• Served - Locations that have access to 100/20 Mbps
• Underserved - Locations with speeds between 25/3 - 100/20 Mbps
• Unserved - Locations that do not have access to speeds of 25/3 Mbps

The first breakdown of service tiers does not account for federal commitments such as RDOF. Therefore, many unserved locations are displayed in the following map.

With RDOF removed from the equation, there are 190,708 in Version 1 of the Fabric.

When accounting for RDOF (reclassing locations within RDOF census blocks), there are 114,231 unserved locations.

The Department is preparing to submit another bulk fabric challenge to the FCC for the development of fabric version 3. When the data is submitted, this blog will be updated with the Department's findings.