Glenn Hegar
Texas Comptroller of Public Accounts
Glenn Hegar
Texas Comptroller of Public Accounts
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Glenn Hegar
Texas Comptroller of Public Accounts
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Guidance for Bulk Challenges

Entities, including, state, local, and tribal governmental entities, and service providers, can also submit bulk challenges, which are challenges with respect to multiple locations. To submit a bulk challenge, follow these steps:

Choose a methodology.

There are three options:

  1. Knowledge of Infrastructure
  2. Information Collected from Individual Consumers
  3. Other

According to the BDC Bulk Fixed Challenge Data Specifications (PDF), published by the FCC on November 17, 2022:

A “Knowledge of Infrastructure” challenge could be based on knowledge of where network facilities and plant exist. This knowledge could be based on, for example, local building permit records, rights-of-way records, franchise agreements or an on-the-ground examination of broadband infrastructure in a particular structure. The second methodology option would be based on information collected from individual consumers about the broadband services available, and not available, to them. If the bulk fixed challenge data is based on a methodology other than these two options, then the filer should choose “Other.”

The information required will vary depending on the methodology chosen.

Select the code for the technology of the service being challenged, as shown on the broadband map.

It must be one of the following codes:

  • 10 – Copper Wire
  • 40 – Coaxial Cable/HFC
  • 50 – Optical Carrier/Fiber to the Premises
  • 60 – Geostationary Satellite
  • 61 – Non-geostationary Satellite
  • 70 – Unlicensed Terrestrial Fixed Wireless
  • 71 – Licensed Terrestrial Fixed Wireless
  • 0 – Other
Identify the Reason for the Challenge.

The FCC identifies nine codes for a bulk fixed availability challenge on page 8 of the BDC Bulk Fixed Challenge Data Specifications (PDF).

The value must be one of the these codes:

  • 1 – Provider failed to schedule a service installation within 10 business days of a request.
  • 2 – Provider did not install the service at the agreed-upon time.
  • 3 – Provider requested more than the standard installation fee to connect the location.
  • 4 – Provider denied the request for service.
  • 5 – Provider does not offer the technology entered above at this location.
  • 6 – Provider does not offer the speed(s) shown on the broadband map for purchase at this location.
  • 8 – No wireless or satellite signal is available at this location.
  • 9 – New, non-standard equipment is required to connect this location.

The value may not be 8 or 9 unless the technology value is:

  • 60 – Geostationary Satellite
  • 61 – Non-geostationary Satellite
  • 70 – Unlicensed Terrestrial Fixed Wireless
Gather all Materials.

Bulk challengers must submit:

  • Evidence and details about the disagreement
  • The challenger’s methodology
  • The basis for determinations underlying the challenge
  • Communications with provider if any
  • Outcome of communications with provider
Enter the information into the Broadband Data Collection (BDC) System.

This is a brief overview of the process. For details, refer to the latest BDC Bulk Fixed Challenge Data Specifications (PDF).


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