Broadband Mapping Requirements

Broadband Mapping Requirements Getting Tougher – But It Could Have Been Worse


Many rural carriers had a tough time this past spring adjusting to the FCC’s new Form 477 requirements on reporting broadband data at the Census Tract level.  But a fresh round of even newer requirements, this time from states, are likely to require many rural carriers to provide data on broadband availability, speeds, the technology used, etc. at an even more granular level called “street segments.” 

Most states are applying for stimulus funding from the National Telecommunications and Information Administration (NTIA), which has been charged by Congress with developing a national broadband map.  Data from the states will be used to compile this map.  In order to receive this stimulus funding, the states need to collect data according to NTIA rules.

What’s a street segment, and does it apply to your company?

States seeking mapping funds will collect broadband data from carriers on a more granular level than found on the FCC’s current Form 477.  In general, carriers will be allowed to report broadband data at the address level if they choose, or by either the Census Block or street segment level.  Census Blocks are more granular than the Census Tracts used by Form 477.  However, for Census Blocks that are greater than two square miles (which predominate in rural areas), carriers must report data by street segments, which are composed of address ranges within Census Blocks.  Street segment lists are available in the U.S. Census Bureau’s TIGER/Line Files, which are available for free.  Commercially available programs that provide similar granularity are also acceptable. 

So if you provide service within Census Blocks that are larger than two square miles, most states are likely to require reporting at the street segment level.  For more details, see links at the end of this article.

When do these new requirements take effect?

States obtaining funding from NTIA are required to provide “substantially complete” data to NTIA, which includes a large percentage of the service areas in their state, by February 1, 2010.  States are supposed to supply complete data by March 1, 2010.

What’s the relationship between FCC Form 477’s Census Tract level and the new, more granular requirements?  Will small carriers have to report at both levels, and to whom?

The FCC will still require broadband providers to fill out Form 477.  OPASTCO has recommended that any part of 477 that duplicates the new state reporting requirements, or requires similar data at a more granular level, should be phased out to eliminate unnecessary redundancy. 

OPASTCO maintained that carriers have only recently incurred costs to report broadband service at the Census Tract level, so the costs of more granular reporting so soon would be burdensome.  However, the Department of Commerce, which runs NTIA, disagrees, saying that the National Broadband Map project is an important national priority.

Was there any success in making this less hard?

The initial rules were actually worse.  When the requirements became known, many organizations, including OPASTCO, had multiple meetings with NTIA officials which resulted in several key improvements:

•    “Address Level” Requirements Altered – NTIA originally required states receiving funding to provide 11 fields of end-user data at the address level.  The industry noted that this level of reporting would be burdensome and result in a high error rate.  However, providers can still supply address level data if this option is less burdensome, which may be the case for very small companies.  However, as discussed above, NTIA allows data to be provided by (1) Census Blocks that are less than two square miles in area, or (2) street segments for census blocks that are larger than two square miles.. 

•    Data Speeds Will Be Reported at Service Area Level – Instead of reporting advertised upstream and downstream data speeds at each address, as originally required, data speeds will be provided across each service or franchise area.  Metropolitan or Rural Statistical Areas may also be used.  In addition, broadband providers will not be required to supply actual speeds experienced by customers, as called for by the original rules.  States will obtain that data through surveys, tests, or similar means.

•    Confidentiality of Proprietary Data Will Be Maintained – Various government agencies may have reasons to access proprietary data generated by this data collection.  Originally, NTIA merely requested that other agencies with access to this data maintain its confidentiality.  However, there are now requirements that protect the confidentiality of proprietary.

•    Average Revenue Per User Data Will Not Be Collected – Initially, states were to collect ARPU data, with the intent of measuring broadband affordability.  However, industry associations demonstrated to NTIA that there is little, if any, relationship between sensitive ARPU data and affordability.  Further, the collection of ARPU data would not help establish the National Broadband Map called for by law.  Therefore, ARPU data will not be collected.

While there remain concerns about the burdens and accuracy of the new requirements, the changes listed above represent significant improvements from the original version.  OPASTCO encourages its members to work with state data collection efforts to the greatest extent possible as they work with NTIA to establish the National Broadband Map.

The data collection information, as it was originally published by NTIA in a Technical Appendix beginning on page 32557, is available at
http://edocket.access.gpo.gov/2009/pdf/E9-16103.pdf

The clarifications which ease some of these requirements are available at
http://www.ntia.doc.gov/frnotices/2009/FR_mappingclarification_090807.pdf

Information on the Census Burea’s Tiger/Line files is available at
http://www.census.gov/geo/www/tiger/