The FCC Broadband Data Taskforce recently released recommendations on best practices to submit bulk challenges to the Broadband Serviceable Location Fabric (BSL Fabric). The BSL Fabric is a dataset of geographic coordinates for building footprints (i.e., structures) that the FCC has determined are broadband serviceable locations (BSLs) and serves as the foundation upon which fixed broadband availability data is reported to the FCC. Twice each year, an updated iteration of the BSL Fabric is released in conjunction with the opening of the Broadband Data Collection (BDC) filing windows for reporting broadband availability as of June 30 or December 31. Combined, these data sets are incorporated into the FCC Broadband Map updates.[1]

Bulk Fabric Challenge Best Practices

The FCC Public Notice outlines the following practices and recommendations for preparing bulk Fabric challenges: [2]

  • Do not submit address lists. Although joining challenger's address-based data to the address information in the BSL Fabric to associate unique location IDs with the challenger's address data may be a useful initial step, specific address data is an unreliable determinant of the precise geographic coordinates of structures where broadband can be installed. Challengers should be aware that if an address is missing from the BSL Fabric, it does not necessarily indicate the location is missing. Challengers should not submit a list of addresses (from an internal billing system or E911 database, for example) as a bulk challenge.
  • Geospatial analysis is likely to improve outcomes. Challengers should conduct a geospatial analysis of both its address data and the BSL Fabric data, using a tool such as Quantum Geographic Information System (QGIS). Loading additional datasets such as building footprint imagery and road data (such as Google Maps or OpenStreetMap) is likely to improve the quality of challenges. After uploading data sources, challengers should perform a geospatial process to eliminate locations from a challenge that are likely already designated as BSLs in the Fabric and focus on the remaining locations.
  • Coordinates must align with building footprints. Geographic coordinates for a Fabric challenge must fall within a building footprint. If a set of coordinates submitted by a challenger either falls in the middle of a road or otherwise outside of a building footprint, the challenge is likely to be rejected.
  • Buffer distance disqualifiers. Points that fall within a set "buffer distance"[3] of an existing location point in the Fabric should be eliminated from a challenge.
  • Validate address information. Challengers should run address information through the United States Postal Service Coding Accuracy Support System (USPS CASS) validation.[4]

Challenge Process Deadlines

While challenges to Fabric data can be submitted on a rolling basis, bulk challenges submitted by March 15, 2023, are more likely to be adjudicated and reflected in the third version of the Fabric which will serve as the basis for the BDC June 30, 2023, BDC data submission. As of January 3, 2023, the FCC is only accepting challenges to Fabric version two.[5]

As reflected in the following chart, there is significant overlap between the Fabric and BDC submission deadlines and the impact on the FCC Broadband Map. 


Deadline and Type of Data Reporting Information

March 1, 2023

Next BDC filing deadline, reporting broadband availability data as of December 31, 2022, based on BSL Fabric version two.

March 15, 2023

BSL Fabric challenges submitted by this date will most likely be incorporated into BSL Fabric version three, which will be used for reporting BDC availability data as of June 30, 2023.

Spring 2023 [6]

Anticipated date for updated FCC Broadband Map, based on December 31, 2022, availability data as overlaid on BSL Fabric version two.

June 2023

Anticipated date for release of BSL Fabric version three, to be used for September 2, 2023, BDC filing.

September 1, 2023

BDC filing deadline, reporting June 30, 2023, data based on BSL Fabric version three.

November 2023

Anticipated date for updated FCC Broadband Map, based on June 30, 2023, availability data reported and overlaid on BSL Fabric version three.

BSL Fabric challenge submissions and BDC data filings can be cumbersome and time-consuming for providers. DWT is available to assist clients with these processes to ensure timely and accurate submissions for all broadband data filings.

* On the date of this publication, Edlira Kuka was a law student at Seattle University School of Law and worked as a communications law, regulation & policy manager at DWT. On November 7, 2023, Edlira was admitted to practice law in the District of Columbia and became an attorney with DWT's Communications Practice. 

[1] Another DWT advisory, dated December 2, 2022, included information about the Broadband Map publication and challenge process. Challenges to the Broadband Map may be filed on a rolling basis and will be incorporated into the map as they are processed.

[2] Additional resources on the Fabric challenge process can be accessed here:

[3] Maximum Buffer Requirements for Wireline Fixed Availability Data, (Updated April 22, 2022).


[5] Bulk challenges to Fabric version one filed between November 11, 2022-January 2, 2023, are being carried over and adjudicated against Fabric version two and do not need to be resubmitted.

[6] NTIA targets June 30 as the date it will allocate each state and territory's BEAD Program funding.