To the Virginia Department of Housing and Community Development:

CTIA respectfully submits this letter in response to the Virginia Department of Housing and Community Development’s (“Department’s”) proposed revised guidelines (“Guidelines”) for the Virginia Broadband Availability Map – Internet Service Provider Service Territory Data Submission Process. 

CTIA applauds the Department for revising its earlier issued guidelines for the Virginia Broadband Availability Map (“VBAM”) to better align with the Federal Communications Commission’s (“FCC’s”) rules for its Broadband Data Collection (“BDC”).  This approach will leverage the tremendous work the FCC has done to reform the mapping process and will also enable the Department to fully comply with the General Assembly’s directives in the 2021 Budget Bill (“Budget Bill”).^[1]  To ensure the Department’s collection fully comports with the Budget Bill, CTIA requests that the Department only collect outdoor stationary maps consistent with the FCC’s initial 4G LTE collection, and otherwise defer collection of 5G-NR and remaining data until the FCC begins collecting this information.

Syncing the Department’s collection with the FCC’s will allow the Department to publish an “initial map” of broadband coverage in the Commonwealth by July 1, 2022 because the Department can use the 4G LTE coverage maps submitted by many CTIA members pursuant to the BDC rules.[2]  These maps are sufficient to satisfy the Budget Bill, which does not require the VBAM to include 5G-NR coverage data.[3]  And given the Budget Bill’s requirement to align with the FCC’s rules, deferring the collection of 5G-NR or any in-vehicle coverage maps until the FCC has collected the data is the appropriate course.  Indeed, the only practicable way to implement the General Assembly’s directive for the Guidelines to not exceed requirements in the FCC’s rules is for providers to submit their data after the FCC’s rules have been fully implemented. 

For similar reasons, the Department should not require providers to submit maps of in-vehicle coverage.  The FCC collected outdoor stationary maps of 4G LTE coverage per the BDC rules from AT&T, T-Mobile, UScellular, and Verizon.  This collection did not include in-vehicle coverage maps.[4]  Because providers will be modeling their outdoor stationary coverage using consistent parameters, adding in-vehicle coverage maps for each technology will not meaningfully improve policymakers’ or consumers’ understanding of where coverage is available.[5] 

If the Department does not eliminate the in-vehicle requirement, which is CTIA’s primary recommendation, it should, at a minimum, defer collection of in-vehicle coverage maps because the FCC has not yet set parameters for all of the many different variables that can affect in-vehicle test results.  Until the FCC sets these parameters, the Department will not be in a position to ensure that the VBAM’s requirements do not exceed the FCC’s as the Budget Act requires. 

CTIA thanks the Department for the opportunity to comment on these important issues, and looks forward to working cooperatively with the Department on the development of more accurate and granular maps of broadband coverage in the Commonwealth.

Sincerely,

/s/ Benjamin Aron

Benjamin Aron

Assistant Vice President, State Regulatory Affairs