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Rule2022-10541

Wireless Telecommunications Bureau Adopts Drive Test Parameters and Model for Alaska Plan Participants

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Published

May 18, 2022

Effective

June 17, 2022

Issuing agencies

Federal Communications Commission

Abstract

In the document, the Wireless Telecommunications Bureau (Bureau) of the Federal Communications Commission (Commission) adopts the drive test parameters and a drive test model required of two Alaska Plan mobile-provider participants: GCI Communication Corp (GCI) and Copper Valley Wireless (CVW). The Bureau also requests comment on requiring these mobile providers to submit new drive-test data if they fail to demonstrate compliance with their approved performance plan.

Full Text

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<title>Federal Register, Volume 87 Issue 96 (Wednesday, May 18, 2022)</title>
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[Federal Register Volume 87, Number 96 (Wednesday, May 18, 2022)]
[Rules and Regulations]
[Pages 30108-30128]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2022-10541]

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FEDERAL COMMUNICATIONS COMMISSION

47 CFR Part 54

[WC Docket No. 16-271; DA 22-484; FR ID 86215]

Wireless Telecommunications Bureau Adopts Drive Test Parameters
and Model for Alaska Plan Participants

AGENCY: Federal Communications Commission.

ACTION: Final order; Alaska Plan.

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SUMMARY: In the document, the Wireless Telecommunications Bureau
(Bureau) of the Federal Communications Commission (Commission) adopts
the drive test parameters and a drive test model required of two Alaska
Plan mobile-provider participants: GCI Communication Corp (GCI) and
Copper Valley Wireless (CVW). The Bureau also requests comment on
requiring these mobile providers to submit new drive-test data if they
fail to demonstrate compliance with their approved performance plan.

DATES: The Order is adopted and effective on June 17, 2022.

FOR FURTHER INFORMATION CONTACT: For additional information on this
proceeding, contact Matthew Warner of the Wireless Telecommunications
Bureau, Competition & Infrastructure Policy Division,
<a href="/cdn-cgi/l/email-protection#1954786d6d717c6e374e786b777c6b597f7a7a377e766f"><span class="__cf_email__" data-cfemail="4805293c3c202d3f661f293a262d3a082e2b2b662f273e">[email&#160;protected]</span></a>, (202) 418-2419.

[[Page 30109]]

SUPPLEMENTARY INFORMATION: This is a summary of the ``Order'' portion
of the Bureau's Alaska Plan Drive Test Order and Request for Comment,
adopted on May 5, 2022, and released on May 5. 2022. The ``Request for
Comments'' portion is published elsewhere in this issue of the Federal
Register. The full text of this document is available for public
inspection on the Commission's website at: <a href="https://www.fcc.gov/document/alaska-drive-test-order-and-request-comment">https://www.fcc.gov/document/alaska-drive-test-order-and-request-comment</a>.

I. Introduction

1. In the Order portion of this document, the Wireless
Telecommunications Bureau (Bureau) adopts a drive-test model and
parameters for the drive tests that are required of certain mobile
providers participating in the Alaska Plan. The Bureau will use these
drive-test data to determine whether mobile providers that receive more
than $5 million in annual support for the deployment of mobile voice
and broadband service in remote areas of Alaska have met their
performance commitments. In the Request for Comment portion of the
document, we seek comment on a proposal to require mobile-provider
participants subject to the drive-test requirement to submit new drive-
test data consistent with the drive-test model and parameters if they
fail to meet a buildout milestone and later seek to cure a compliance
gap.

II. Background

2. Unique circumstances in Alaska make deploying communications
infrastructure particularly challenging in that state. In the 2016
Alaska Plan Order, the Commission adopted an Alaska-specific, 10-year
universal service plan to address these unique circumstances. The
Alaska Plan Order froze mobile-wireless service-provider participants'
preexisting support at December 2014 levels (frozen support) and sought
to have those providers commit to expand Fourth-Generation, Long-Term
Evolution (4G LTE) service at speeds of at least 10/1 Mbps in eligible
areas, subject to certain exceptions (such as where middle-mile
infrastructure capability is limited). In areas with limited middle-
mile infrastructure, providers were allowed to make a lesser commitment
until better middle-mile infrastructure became available.
3. Provider Commitments. Eight mobile providers chose to
participate in the Alaska Plan and submitted for Bureau approval
performance plans in which they committed to provide mobile voice and
broadband services to delineated populations in remote eligible areas
of Alaska. Providers, as part of their performance plans, were required
to identify both the last-mile mobile technology (e.g., 3G, 4G LTE)
that they would use to serve delineated populations and the type of
middle-mile connectivity (e.g., fiber, satellite) on which they would
rely to provide mobile services. Where Alaska Plan participants could
provide fiber-based 4G LTE, their speed commitments in those areas were
greater than or equal to speed commitments with other technology
combinations, consistent with the deployment standard set forth in the
Alaska Plan Order (4G LTE at speeds of at least 10/1 Mbps). For those
areas where the provider had to provide service over a performance-
limiting satellite backhaul connection, the Bureau permitted providers
to commit to previous-generation last-mile technologies and slower
speeds.
4. Each participating mobile provider committed to meet buildout
requirements at the end of year five (ending December 31, 2021) and
year 10 (ending December 31, 2026) of the Alaska Plan and to certify
that it met the obligations contained in the performance plan at each
of these buildout milestones. The Commission stated that it would rely
on participating providers' FCC Form 477 data--which report inter alia
mobile wireless broadband coverage by technology and minimum advertised
or expected speed--in determining whether the providers' five-year and
10-year milestones have been met. The Commission delegated authority to
the Bureau to require additional information necessary to establish
clear standards for determining whether providers have met their five
and 10-year commitments.
5. Drive Tests. Mobile participants that receive more than $5
million annually in Alaska Plan support must accompany their milestone
certifications with drive-test data. The drive-test data must show
mobile transmissions to and from the network that meet or exceed the
minimum speeds set out in the approved performance plans in the areas
where support was received. The Alaska Plan Order specifies that these
participants ``may demonstrate coverage of an area with a statistically
significant number of tests in the vicinity of residences being
covered.'' Given the unique terrain and lack of road networks in remote
Alaska, providers may conduct drive tests by means other than
automobiles (such as snow-mobiles or other vehicles appropriate to
local conditions). Two of the eight mobile participants--GCI
Communications Corp. (GCI) and Copper Valley Wireless (CVW)--exceed the
$5 million annual support threshold, and accordingly, they must provide
drive-test data supporting the speed certifications consistent with
their performance plan commitments.
6. Alaska Drive-Test Parameters and Model. In the Alaska Drive Test
Public Notice, the Bureau proposed a model for conducting the drive
testing (Alaska Drive-Test Model), which included the drive-test
information to be submitted and the format in which it should be
submitted. The parameters proposed in the Notice included, for example,
the submission of latitude and longitude coordinates to identify the
location of the test, a timestamp for the time the test was taken, the
type of device and related software used for the test, last-mile
technology tested, and recorded download and upload speeds.
7. The proposed Alaska Drive-Test Model was designed to ensure that
the service providers required to conduct drive testing would obtain a
``statistically significant number of tests in the vicinity of
residences being covered.'' The proposed Alaska Drive-Test Model uses
stratified random sampling to determine test locations within a grid
system based on the service provider's reported coverage area. Under
the proposal, the Commission would begin with the populated areas
contained in the performance plans for each type of technology and
backhaul and then overlay a one-square kilometer grid system to create
a frame around the covered populated area corresponding with the
performance commitments. Staff would then stratify the frame into sets
of grids determined by statistical formulae based on theoretical
population of the grid cells (e.g., lowest population grid cells would
be in the first stratum; highest population grid cells would be in the
highest-numbered stratum) and would select a random sample of grid
cells for testing from each stratum within the frame. The Bureau
proposed that, within each grid cell, a service provider would conduct
a minimum of 20 tests, consisting of download and upload components, no
less than 50% of which would be conducted from a vehicle while in-
motion. To be considered valid, each test would have to be conducted
between the hours of 6 a.m. and 10 p.m. within the selected grid cell,
and the test data would have to report all relevant parameters. Staff
would construct a confidence interval for the drive-test results that
would be used to verify that a provider's commitments have been met or
to determine the

[[Page 30110]]

percentage by which the provider has failed to meet its commitments.
8. The Bureau sought comment on the parameters and proposed Alaska
Drive-Test Model and on any alternatives that it should consider. GCI
filed comments, and both GCI and CVW made ex parte presentations to
staff about the proposed Alaska Drive-Test Model. No other party filed
comments or made such presentations. Based on concerns that were
expressed about the initial deadline, the Bureau extended the drive-
test data-submission deadline, moving it from March 1, 2022 to
September 30, 2022. The Commission will continue to monitor the
situation and will remain flexible where warranted.

III. Discussion

9. We adopt the proposed parameters and the proposed Alaska Drive-
Test Model with the modifications specified below. We will use data
derived from these parameters, combined with FCC Form 477 coverage data
and complementary middle-mile data, to verify that covered service
providers have met their commitments. Upon submission of the drive test
data that we discuss in this Order, a corporate officer of the mobile-
provider participant must certify to the data's accuracy, consistent
with the obligations of 47 CFR 54.321(a). When submitting the drive
test data, a corporate officer of the mobile-provider participant must
submit this certification: ``I certify that I am an officer of the
reporting carrier; my responsibilities include ensuring the accuracy of
certifications which are required to be reported pursuant to 47 CFR
54.321(a). The reporting carrier certifies that the data received or
used from drive tests analyzing network coverage for mobile service
pursuant to 47 CFR 54.321(a) are complete, accurate, and free from
misrepresentation.'' The Commission staff will provide details to GCI
and CVW on how to submit the drive test data.

A. Drive-Test Parameters

10. We adopt a modified version of the drive-test parameters
proposed in the Alaska Drive Test Public Notice (attached as Appendix
A). These parameters specify the categories of data to be collected as
well as the data structure and format in which the data must be
reported. In addition to the parameters the Bureau proposed, the Bureau
adopts other changes to the parameters; most notably, we have altered
the parameters in Appendix A with respect to the data to be collected
for 2G/Voice. In the Notice, the Bureau proposed that, for 2G, a data
rate of 22.8 kbps or higher for download and upload tests would be
appropriate because that should be a minimally sufficient speed to
provide a serviceable voice call. GCI expressed concern that speed-test
data would not accurately represent the ability to place a voice call
over a 2G network, particularly for non-GSM standards such as CDMA or
UMTS. GCI proposed that, instead, providers demonstrate voice coverage
by placing voice calls between five and 30 seconds in duration to a
telephone number established for test calls.
11. We find GCI's suggestion to be a reasonable approach, and
therefore we will require it instead of the approach we proposed in the
Notice. Because GCI is the only provider subject to drive testing that
has a 2G commitment and GCI's particular 2G requirement is voice only,
we agree with GCI that a test assessing the availability of voice
service would be appropriate. Accordingly, GCI must use voice calls to
demonstrate its ``Voice/2G'' coverage in areas that it is required to
drive test, and Appendix A now includes parameters for voice-only
testing. This change from the original proposal enables GCI to enter
information that records a successful call completion using 2G
technology, regardless of data rate, consistent with the voice-only
commitment. The new fields for GCI's voice-only testing are the voice
originating, voice terminating, rxlev, and rxqual fields. The voice
originating field is a field for providing information for outbound
calling and the voice terminating field is for receiving inbound calls
for the testing. The rxlev and rxqual fields represent data elements
that are necessary to determine the signal quality and strength and
corresponding quality of the network for voice calls.
12. We also adopt other modifications to the proposed data
specifications for mobile speed tests. As set forth in more detail in
Appendix A, we modify the proposed data specifications to add new
drive-test parameters within existing categories--specifically, device
Type Allocation Code (TAC), warmup duration, warmup bytes transferred,
spectrum band, and success flag. Most of the parameters that we
altered--device TAC, warmup duration, warmup bytes transferred, and
spectrum band--resulted from the Bureau's experience constructing the
Broadband Data Collection but will also aid understanding of the data
derived from the Alaska Plan drive tests. The device TAC provides the
type of device used in the testing and helps us better understand the
results, particularly if results indicate a problem with a network that
may be attributable to the type of device. The warmup bytes and
duration are the bits recorded during the testing ramp-up time, and
collecting ramp-up bits as a separate field is required to ensure we
are accurately measuring the network's maximum transmission data rate.
The spectrum band records the spectrum band or bands utilized during
the drive test, which can affect wireless performance. Finally, because
the drive tests need to exceed the minimum commitments in the mobile-
provider participants' performance plans, the success flag field was
added to record where the data indicate that the tests were successful
to that end (or not).

B. Alaska Drive-Test Model

13. We adopt the proposed Alaska Drive-Test Model (attached as
Appendix B), with limited clarifications and modifications. The Alaska
Drive-Test Model uses a stratified random sample of a frame. A frame
consists of the complete set of units within a commitment eligible to
be sampled, which for the purposes of the Alaska Plan drive testing are
one-square kilometer grids in which a provider has at least 100,000
square meters of covered populated area. The construction of this frame
is a multi-part process. First, we will create a set of ``eligible
populated areas.'' Census blocks eligible for frozen-support funding
would be included, and these census blocks would be merged with the
populated areas of the Alaska Population-Distribution Model. Second,
staff will merge the FCC Form 477 reported coverage areas (for which a
provider committed to deploy and that are subject to testing) with the
eligible populated areas to create a set of ``covered populated
areas.'' Third, Commission staff will overlay a grid of 1 km x 1 km
squares onto the covered populated areas. Lastly, any grid cell that
contains fewer than 100,000 square meters of covered populated area, or
10% of the grid cell, will be excluded from the frame.
14. The frame is divided into subsets of similar characteristics,
called strata. This methodology allows fewer grid cells to be selected
for testing while producing a statistically equivalent level of
accuracy as sampling the entire frame, thus reducing the burden of
testing. We will use the cumulative square root of the frequency (CSRF)
method to define the breaks between strata based on a scale along the
cumulated square root of the frequency of grid cells belonging to equal
intervals of the stratification variable. Using the CSRF method will
help to ensure that

[[Page 30111]]

grid cells with low population are confined to a single stratum within
each frame. The number of strata for a frame depends on the number of
grid cells in that frame and the distribution of the populations within
the frame. Two to eight strata are likely to be necessary per frame.
1. Commitment-Based Frames
15. Frames are based on providers' commitments. In particular,
Commission staff will create separate frames where a provider committed
to different speeds based on different middle-mile or last-mile
technologies in its Bureau-approved performance plan. CVW is subject to
one frame because it committed to 10/3 Mbps 4G LTE in all of the areas
where it receives Alaska Plan support. GCI is subject to five frames,
as GCI committed to five different speeds based on various combinations
of middle-mile and last-mile technologies:
<bullet> Fiber-based 4G LTE at a minimum speed of 10/1 Mbps;
<bullet> Microwave-based 4G LTE at a minimum speed of 2/.8 Mbps;
<bullet> Satellite-based 4G LTE at a minimum speed of 1/.256 Mbps;
<bullet> 3G or better at a minimum speed of .2/.05 Mbps; and
<bullet> Voice/2G.
16. GCI argues that, instead of basing frames on middle-mile and
last-mile technologies, we should assign frames based only on the
speeds a provider reports via its FCC Form 477 filings. GCI asserts
that a speed-only approach better reflects the intent of the Alaska
Plan Order and that the Commission intended to use information about
middle-mile and last-mile technologies only to determine whether mobile
carriers' proposed speed commitments were reasonable. Pointing to
language in the Alaska Plan Order, which states that drive tests must
show mobile transmissions that meet or exceed ``the speeds delineated
in the approved performance plans,'' GCI contends that the Bureau's
drive-test proposal ``changes the yardstick by which providers will be
measured.''
17. We disagree. The Alaska Drive-Test Model's integration of
middle-mile and last-mile technologies is consistent with the Alaska
Plan Order, the Commission's rules, the provider performance plans that
the Bureau approved, and the policy undergirding the Alaska Plan. In
2016, the Commission sought to advance, to the extent possible, the
number of locations in Alaska that have access to at least 10/1 Mbps 4G
LTE. It permitted the Bureau to approve lesser commitments ``in
particular circumstances'' if a provider's ability to achieve 10/1 Mbps
4G LTE was limited, for example, by a lack of access to middle-mile
infrastructure. In areas where such limitations did not exist,
providers were expected to extend 4G LTE service, which was the latest
mass-market technology available at the time the Commission adopted the
Alaska Plan. Additionally, if backhaul becomes newly available in an
area where a provider has not committed to provide 10/1 Mbps 4G LTE,
then that provider must submit revised commitments that take into
account the new backhaul option. While GCI argues that the Commission
only intended to use information about middle-mile and last-mile
technologies to determine whether mobile providers' proposed speed
commitments were reasonable, GCI does not address how the Commission
could determine whether a mobile provider has met those commitments
without also collecting information about its speeds for each specified
technology and middle-mile facility.
18. Contrary to GCI's assertions, we have not ``change[d] the
yardstick by which providers will be measured.'' To implement the
framework described above, the Commission required providers to
identify in their performance plans the populations that they proposed
to cover at the five- and 10-year milestones, ``broken down for each
type of middle mile, and within each type of middle mile, for each
level of data service offered.'' This approach is mirrored in the
Commission's rules, which require mobile providers to build out to the
``population covered by the specified technology, middle mile, and
speed of service in the carrier's approved performance plan, by the
interim milestone.'' In addition, every performance plan that providers
submitted and the Bureau approved--including GCI's original plan and
updated plans--identifies the providers' speed commitments based on
available middle- and last-mile technology employed.
19. The Alaska Drive-Test Model, by taking into account middle- and
last-mile technologies, will allow CVW and GCI to show that they have
met the speed commitments delineated in their approved performance
plans. While GCI is correct that the drive-test data will demonstrate
network throughput (i.e., speeds), the minimum speeds it is required to
show are--and must be--``delineated'' in its approved plan in terms of
populations covered by specific combinations of middle- and last-mile
technologies. GCI's suggested reading of the Commission's rules, in
contrast, would require us to ignore the rules' repeated references to
middle- and last-mile technologies in describing how providers are
required to identify and meet their commitments. The Commission could
have required in the Alaska Plan Order that providers base their
commitments solely on speed criteria, but it explicitly required the
inclusion of middle-mile and last-mile technology for the population
served as part of the performance plans, consistent with the
Commission's goal of expanding Alaskans' access to 10/1 Mbps 4G LTE
technology to the greatest extent possible, unless an exception was
warranted.
20. Moreover, failing to account for last-mile and middle-mile
technologies in the Alaska Drive-Test Model could allow participants to
skirt their commitments. For example, speed tests conducted in close
proximity to a tower providing 3G service using microwave backhaul
could produce test results of 10/1 Mbps or better. If that grid cell's
population is credited toward a provider's fiber-fed 4G LTE performance
obligation, this would offset the need for the provider to demonstrate
10/1 Mbps 4G LTE service in another area that should otherwise receive
this level of service based on fiber-based middle-mile facilities.
21. Finally, we note that, under the Alaska Plan, approval of a
provider's plan to maintain lower levels of technology ``in particular
circumstances . . . to a subset of locations'' is limited to those
locations; it is not a fungible token to provide lower levels of
service anywhere in the provider's service area. In other words, a
provider may not underperform in areas where it committed to 10/1 Mbps
4G LTE, even if it overperforms in areas where it was allowed a lesser
commitment due to ``unique limitations'' in those areas. To the extent
``unique limitations'' no longer prevent a provider from achieving 10/1
Mbps 4G LTE in an area, the appropriate course of action would be for
the provider to update its performance plan, as required under the
terms of the Alaska Plan Order.
2. Grid Cells With No Roads
22. Some parts of remote Alaska lack any roads, and some large
areas have a low population density. Nonetheless, providers committed
to serve many of these areas, and they receive support from the Alaska
Plan to do so. As discussed further below, we cannot ignore these areas
when evaluating CVW's and GCI's performance commitments, and thus we
find it necessary to include in the testing sample grid cells with no
roads as well as grid cells with low populations,

[[Page 30112]]

consistent with the Alaska Plan Order and our proposals in the Alaska
Drive Test Public Notice. While we cannot ignore these areas when
evaluating CVW's and GCI's performance commitments, we note that the
Alaska Drive-Test Model includes a number of design features that
should limit the areas without roads or with little population that the
two providers must test, as we detail below.
23. We acknowledge that remote Alaska has unique challenges,
including roadless areas, and these unique challenges are the reason
the Commission created a separate universal service support mechanism
for Alaska. Some of the roadless remote areas, however, are in the
vicinity of covered residences and must be tested to achieve
statistically significant testing of each provider's coverage
sufficient to enable the Bureau to determine whether a provider has
satisfied its commitments. A quality communications network is all the
more essential where the local population lacks roads, and to the
extent that providers have received universal service support to cover
such populated areas, they are required to demonstrate their claimed
coverage.
24. We also find it necessary to include in the testing sample grid
cells with a modeled population of less than one person--including such
grid cells with no roads--consistent with the Alaska Plan Order and our
proposals in the Alaska Drive Test Public Notice. Providers committed
to cover delineated eligible populations in their performance plans,
including some areas that are sparsely populated. While providers only
test populated areas, in some instances, the number of grid cells
within the populated area of a census block can outnumber the people.
Where the aggregate number of grid cells in a covered populated area
exceed the number of people in that area, such grid cells will appear
to have less than one person. However, to ``demonstrate coverage of an
area with a statistically significant number of tests in the vicinity
of residences being covered,'' these areas are necessary to test as
part of the coverage that the provider committed to and receives
support to provide mobile service.
25. GCI argues that it should not be required to test sparsely
populated grid cells, and both GCI and CVW express concern that testing
in grid cells with no roads will be extremely difficult. But the Alaska
Drive-Test Model has design features that should help address concerns
about these grid cells. The model stratifies each frame using CSRF
based on grid-level estimates of covered population. This includes
creating a single stratum within each frame of all grid cells with a
population of less than one person. Further, the sample is apportioned
across a frame using Neyman allocation, a technique that draws more
samples from more highly populated strata relative to lower populated
strata. Accordingly, the stratum containing grid cells with a
population of one person or more will have a greater number of grid
cells compared to strata containing grid cells of population less than
one, and more samples will be drawn from the higher populated strata.
This has a compounding effect that limits the number of grid cells with
a population less than one that will be selected for testing. In
addition, the Alaska Population-Distribution Model distributes
population near roadways for census blocks that contain roads, making
it more likely that areas near roads will be covered populated areas
and selected for testing.
26. GCI claims that many testable grid cells are too sparsely
populated for worthwhile testing. GCI's analysis of the Alaska Drive-
Test Model claims that 53% of the grid cells would have less than one
person and that based on GCI's analysis, 48% of grid cells would have
less than one person per grid cell and no roads. GCI argues that grid
cells with less than one person should be eliminated from testing and
grid cells with no roads should be required sparingly, given the
burdens of conducting drive testing. Similarly, CVW notes that some
grid cells would be inaccessible mountains or islands with no public
access. GCI evaluated the grid cells in its coverage areas and
determined that 59% of the grid cells would have no roads, that 49% of
the grid cells would be more than a mile from the nearest road, and
that 12% of the grid cells would be more than ten miles from the
nearest road.
27. GCI has not presented its data or the methodology underlying
its calculations, and we were not able to reproduce it. However, for
several reasons, we believe that GCI's calculations result in
significant over-estimates. First, the Alaska Drive-Test Model's de
minimis population standard has the effect of reducing the number of
grid cells without roads that would otherwise be included in the
testing frame. Second, as noted above, we designed the sample and
stratification so that there would be substantially more grid cells
that are populated compared with grid cells with population less than
one in the sampling methodology to increase the probability that a
populated grid cell would be selected for testing compared with a grid
cell with population less than one. Third, because there is a high
correlation between populated grid cells and grid cells with roads, our
sampling methodology should not only increase the percentage of
populated grid cells that are tested but also increase the percentage
of tested grid cells that have roads. Accordingly, for all of these
reasons, we believe that GCI's calculations result in over-estimates.
28. We also disagree with GCI that the burdens of testing in these
areas outweigh the benefits of testing in areas where GCI is receiving
universal service support. If we excluded such grid cells in the
sampling, GCI would continue to receive Alaska Plan support in remote
areas of Alaska without adequate means to verify coverage, which runs
contrary to the principles outlined in the Alaska Plan Order. Low
population density and areas with no roads are features in many parts
of remote Alaska--a fact of which CVW and GCI were aware when they
elected to participate in the Alaska Plan--yet these providers
nonetheless committed to covering these remote areas using universal
service support. For these reasons, we decline to eliminate testing for
grid cells with no roads, including those grid cells with a population
of less than one. Although CVW and GCI must drive test some grid cells
that do not have roads, the Commission foresaw this potential issue and
accounted for it by allowing drive tests to be conducted ``by means
other than in automobiles on roads.'' We provide further relief for the
providers by allowing use of unmanned aircraft systems (UASs), subject
to the waivers we describe below.
a. Grid Cells With No Roads and Population of One or Greater
29. For the reasons described above, we find it necessary to
require testing of grid cells with no roads and population of one or
greater. To the extent a grid cell with a population of one or greater
does not include an accessible road, the accommodation to use off-road
vehicles should improve testability. If there are instances where a
mobile-provider participant claims that it cannot use on-the-ground,
off-road vehicles to test such a grid cell, it may seek a waiver from
the Bureau to use a UAS to test that particular grid cell. This waiver
request should provide a statement regarding why good cause exists to
waive the on-the-ground testing requirement for that grid cell, contain
evidence supporting that claim, and be filed in WC Docket No. 16-271.
UASs should mirror on-the-ground vehicles to the extent possible,
matching on-the-

[[Page 30113]]

ground vehicle speed (for example, matching nearby speed limits) and
flying at the lowest, safest possible elevation, to best reflect on-
the-ground usage. Additionally, UASs performing drive tests must: (1)
At all times operate at less than 200 feet above ground in remote areas
of Alaska where road-based testing is impractical/impossible; (2) limit
power to the minimum necessary to accomplish testing; and (3) upon
receipt of a complaint of interference from a co-channel licensee,
notify the Commission and either remedy the interference or cease
operations.
30. To the extent that a mobile provider seeks to use UASs to
conduct testing, it may do so if the allocation and service rules
permit airborne use of the spectrum that will be used to provide the
mobile service to be tested as part of the drive tests. Otherwise, the
provider must additionally obtain a waiver from the Commission
(pursuant to Section 1.925) of any airborne limitations.
b. Grid Cells With No Roads and Population of Less Than One
31. For the reasons described above, we also find it necessary to
require testing of certain grid cells with no roads and population of
less than one. However, as an alternative to testing with an automobile
or other terrestrial off-road vehicle (e.g., snowmobile or all-terrain
vehicle), we will allow use of UASs for the first, and least densely
populated, stratum without requiring the waiver that we will require
GCI and CVW to obtain to use UASs for testing grid cells with one or
more people. GCI and CVW both express concern with drive testing where
no roads exist. This additional UAS option is provided to address their
concerns. Of the two to eight strata per frame, the first stratum
contains the grid cells with less than one person per grid cell and no
roads. As these grid cells are likely the most logistically difficult
to test and may contain uninhabitable or untraversable terrain, the
added flexibility offered by a UAS without a waiver should make the
testing easier for these areas. UAS performing drive tests must: (1) At
all times operate at less than 200 feet above ground in remote areas of
Alaska where road-based testing is impractical/impossible; (2) limit
power to the minimum necessary to accomplish testing; and (3) upon
receipt of a complaint of interference from a co-channel licensee,
notify the Commission and either remedy the interference or cease
operations. We note that while we will not require a waiver for use of
UASs for testing these grid cells, we will require a waiver for use of
any allocation or service rules that prohibit airborne use of the
spectrum that will be used to provide the mobile service to be tested
as part of the drive tests (consistent with the requirement we adopt
above for use of UAS to test grid cells with no roads and a population
of one or more people).
3. Distant Communities
32. GCI expresses concern that the number of ``communities'' that
it needs to travel to is the biggest driver of its testing costs. GCI
notes that there are 205 communities within its footprint and that,
while GCI may be able to drive to some communities, ``given the
distances between communities and the lack of interconnected roads,
[GCI's testing teams must] often [travel to these communities] by small
aircraft.'' To the extent GCI has to charter a flight to many of these
communities, this would increase the costs and complexities associated
with drive testing all of its assigned grid cells.
33. To help reduce the burdens of traveling to many different
communities, we have added an optimization to the sampling process that
will likely reduce the number of incorporated and census designated
places where GCI and CVW would have to travel. Given that GCI did not
provide a definition of ``communities,'' we believe incorporated and
census designated places are the closest proxy, as there are 284
incorporated and census designated places in GCI's footprint, and
incorporated and census designated places are integrated into census
data, which are used throughout this modeling. We implement these
additional steps in direct response to GCI's concerns and describe this
additional process in Appendix B, infra.
4. In-Motion Testing Requirement
34. We adopt the proposal to require at least 50% of drive tests to
be conducted while in motion. Requiring that 50% of the drive tests be
conducted while in motion strikes a balance of ensuring that the drive
tests are a sufficient representation of how consumers use their mobile
devices, which is both in a stationary and in-motion environment.
Requiring some in-motion tests also helps ensure that tests are
conducted in multiple locations within the grid cell.
35. We disagree with GCI that the proposed in-motion requirement is
unnecessary. The Alaska Plan Order referred to these as ``drive
tests,'' which suggests some degree of motion consistent with a driving
experience. The drive testing data to be submitted is to ``show[ ]
mobile transmissions to and from the network meeting or exceeding the
speeds delineated in the approved performance plans.'' Mobile service,
as defined in the Communications Act and the Commission's rules,
supports an in-motion requirement for at least some drive tests.
Moreover, requiring drive tests in motion is also consistent with the
in-vehicle mobile propagation modeling that mobile broadband service
providers must submit as part of the Broadband Data Collection, which
providers could verify through on-the-ground data submitted in response
to cognizable challenges and/or verification inquiries initiated by
Commission staff. The Commission also explained for the Broadband Data
Collection that it was important for consumers to be able to challenge
mobile broadband service providers' coverage in both stationary and in-
vehicle (i.e., in-motion) environments. Because mobile service assumes
a service that works with mobile stations that are designed to move and
ordinarily do move, in-motion tests are necessary to ensure that mobile
service is being provided.
36. GCI contends that in-motion tests from a non-standard road or a
trail could be hazardous with little daylight and winter weather. The
concerns posed by drive testing during winter weather are no longer
relevant because we have moved the deadline for the data from March 1,
2022, to September 30, 2022. GCI further argues that an in-motion
requirement is unnecessary because many grid cells lack roads and may
not reasonably accommodate in-motion tests and, similarly, that many
grid cells with roads have small populated areas, which makes it
difficult to conduct a sufficient number of in-motion tests. As noted
previously, where roads are insufficient, the drive test model allows
tests to be conducted by vehicles other than automobiles on roads.
Further, we have limited the grid cells with small testing areas by
removing from drive testing the de minimis grid cells with less than
100,000 square meters of covered populated area.
5. Early Upgraded Areas
37. Mobile service providers participating in the Alaska Plan are
free to upgrade areas early with technologies beyond what they have
committed to, notwithstanding the commitments set out in their
performance plans. In the Alaska Drive Test Public Notice, the Bureau
stated, for instance, that where providers have deployed 5G-NR, it
would be included in the ``LTE'' frame. Moreover, GCI updated its
performance

[[Page 30114]]

plan twice based on commercial availability of new middle-mile
infrastructure, consistent with the Alaska Plan Order requirements, but
it did not commit to improve those areas by the five-year milestone
(positioning itself to be able to upgrade those areas by the final, 10-
year milestone instead).
38. GCI has noted that, in some areas, it ``has deployed a more
advanced technology but does not yet provide the speed associated with
that technology or frame. For example, ``an area served with fiber may
have LTE technology, but the locations more distant from the tower . .
. do not receive 10/1 Mbps.'' GCI claimed it ``never expected that pops
served with less than 10/1 Mbps would count toward the number of pops
served at 10/1 Mbps but also never expected the Commission to disregard
them completely for the purpose of assessing the number of pops served
with 2/.8 Mbps or lower speeds.'' GCI also claimed that, if it believed
all fiber areas upgraded to 4G LTE were required to have 10/1 Mbps or
better, it would have delayed some of its 4G LTE deployments until year
six or later and excluded those areas as appearing on its FCC Form 477
submission as having 4G LTE.
39. We agree with GCI that we should not punish providers for
deploying 4G LTE to some areas earlier than they committed to in their
performance plan at the five-year milestone. Accordingly, where 4G LTE
is indicated on FCC Form 477 at less than 10/1 Mbps in fiber-based
areas, those areas will be included in the 3G frame (3G or better
frame) and will be attributed to 3G commitments. If we were to include
these areas (which may not yet be engineered to achieve 10/1 Mbps) in
the fiber-based 4G LTE frame, then it could lead to higher fail rates
in the frame. These higher fail rates would make GCI appear as if it
had not met its commitments in places where GCI actually met (or
exceeded) its five-year commitments. The approach we adopt will
therefore avoid punishing GCI where it deployed 4G LTE early but was
not ready to add those areas to its five-year commitments of 10/1 Mbps
fiber-based LTE service. We will follow a similar approach for 4G LTE
areas that would be included in the microwave and satellite 4G LTE
frames. For example, if GCI deployed 4G LTE to a microwave-based area,
as indicated by FCC Form 477 and corresponding middle-mile data, but
GCI's FCC Form 477 filing shows minimum expected speeds as less than
2/.8 Mbps for such areas, then those areas will be included in the 3G
or better frame. This clarification should ensure that GCI is being
held to its commitments while not being penalized for deploying more
advanced technology ahead of schedule.
6. Multiple Last-Mile Technologies in a Grid Cell
40. When multiple technologies overlap within a grid cell,
Commission staff will attribute the overlapped area to the frame with
the more advanced technology. For example, in grid cells where fiber-
based 4G LTE at 10/1 Mbps and 3G completely overlap in a grid cell,
staff will attribute the grid cell to the fiber-based 4G LTE frame for
satisfaction of the fiber-based 4G LTE commitments. Attribution to the
more advanced technology allows the provider to receive due credit
where it has built out consistent with its most rigorous performance
requirements. Alternatively, in grid cells where fiber-based 4G LTE at
10/1 Mbps only partially overlaps 3G coverage, staff will attribute the
grid cell portion covered by fiber-based 4G LTE to the fiber-based 4G
LTE frame and the remaining covered area of the grid cell to the 3G
frame. In this instance, a grid cell could be contained in multiple
frames.
41. GCI claimed that more than half of the cells within its covered
populated areas have multiple or overlapping technologies. GCI argued
that, where a grid cell is both in a 4G LTE and 3G frame, once it
passes for 4G LTE, the grid cell should be removed from the 3G frame so
that pops in the 3G frame are not attributed as a ``fail.''
42. We clarify that if a grid cell is selected for both 4G LTE and
3G testing, staff would evaluate both selections from the same drive
tests. If the drive tests show that GCI passes the 4G LTE standard for
that grid cell, then GCI will also receive credit for that grid cell
passing the 3G standard; thus, GCI would not receive a ``fail'' for the
3G selection, obviating the need to remove the grid cell from the 3G
frame. If, however, the testing threshold only passes for the 3G
requirements, then the grid cell would be attributed as a ``pass'' to
3G but a ``fail'' as to 4G LTE, consistent with the pass/fail approach
described below.
7. Pass/Fail Approach
43. We adopt the pass/fail approach to testing for the Alaska
Drive-Test Model proposed in the Alaska Drive Test Public Notice. For
each grid cell in the sampling frame, the results of the tests will
establish whether the provider delivers coverage at the minimum speeds
to which it committed. When replicated throughout all of the randomly
selected grid cells that are required for testing, the Commission will
evaluate the percentage of the provider's coverage area where it has
met its commitments. To demonstrate coverage in an area with a
statistically significant number of tests, the Alaska Drive-Test Model
requires the tests to pass at a rate capable of ensuring that the
provider has met its milestones.
a. Pass/Fail Testing
44. We adopt the following pass/fail methodology for the Alaska
Drive-Test Model: 85% of drive test results in a grid cell must show
speeds that meet or are above the minimum committed-to speed for that
frame in order for the service to be considered ``available'' in that
grid cell. Successful tests measure whether a mobile-provider
participant meets a minimum expected speed in a given grid cell, with
``expected'' defined as being available at least 85% of the time. It
does not mean that 85% of the population of that grid cell can expect
to receive the tested speed 100% of the time. Although the Alaska Plan
Order required mobile-provider participants to commit to a minimum
download and upload speed(s), we do not expect mobile-provider
participants to meet the minimum speed requirements on every single
test, given that the performance of wireless networks is highly
variable. Accordingly, we have set the pass rate at 85% to account for
this variability.
45. To the extent that GCI may intimate that the 85% pass rate is
too high, we do not alter it. The 85% pass rate we adopt for the Alaska
Plan drive tests is similar to--but more lenient than--both the
propagation modeling standard and the on-the-ground challenge data
threshold adopted for the Broadband Data Collection. In the Second
Report and Order in that proceeding, the Commission defined the
parameters that service providers must use when modeling whether
broadband is available using technology-specific minimum download and
upload speeds with a cell edge probability of at least 90% and assuming
minimum 50% cell loading. Additionally, mobile providers that submit
on-the-ground speed test data to rebut a challenge to their coverage
data are required to meet analogous thresholds to those required of
challengers and demonstrate that sufficient coverage exists at least
90% of the time through a challenged area. These defined parameters in
the Broadband Data Collection are more stringent than the propagation
coverage relied on for the Alaska Plan drive test methodology, which
uses the provider-defined propagation coverage from Form 477. Given
that the provider has more discretion to set coverage parameters more
favorably for itself in its Form 477 filings, it would have

[[Page 30115]]

actually been appropriate for us to adopt a higher pass rate percentage
than the Broadband Data Collection; we nonetheless adopt the 85% pass
rate here to eliminate all doubt about the fairness of the pass rate.
Neither GCI nor CVW propose an alternative percentage as more
appropriate for the pass rate as applied by the model. We find
compelling reasons to adopt an 85% pass rate, as we proposed, for
Alaska Plan drive test data.
46. GCI argues that it should receive partial credit for the
percentage of tests recorded above the minimum threshold when that
percentage is below 85%. GCI states that ``rather than applying the 85
percent pass rate as an `all or nothing' bar for allowing a cell to be
deemed covered, pops could count toward the commitment levels in
proportion to the speeds that the speed tests confirm.'' GCI provides
the example that, ``if 50 percent of the drive tests show speeds at or
above 10/1 Mbps and 50 percent of the tests show speeds of .2/.05 Mbps,
then 50 percent of the pops associated with that cell would count
toward compliance with the 10/1 Mbps commitments, and 50 percent of the
pops would count toward compliance with the <.2/.05 Mbps commitments.''
47. We do not find GCI's arguments persuasive. Our statistical
framework is designed around grid cells being the smallest unit of
testing and is not designed to measure partial grid cells. GCI's
example of counting a 50% pass rate as indicative of 50% of the
population receiving service is an incorrect interpretation of what
testing represents--rather, a 50% pass rate indicates that service is
available 50% of the time. Further, GCI's proposal to count failed
tests toward a lesser standard is incompatible with random sampling as
it would apply results to a standard that was not selected for testing
in a given grid cell. This would mean that results are no longer
random.
48. Moreover, GCI and CVW committed to provide ``minimum expected
upload/download speeds'' in their performance plans. In addition, GCI
was the only provider to emphasize in its performance plans that it
would be responsible for this minimum speed throughout all of its
committed-to coverage area to the edge. Thus, GCI's own commitments
emphasize that it needs to provide the minimum speeds throughout the
coverage area of the specified commitment and should not receive
partial credit to the extent it did not provide its minimum committed-
to speed to the edge of such coverage.
49. In addition, GCI's suggested ``partial credit'' approach would
require an alternative drive-test methodology with a corresponding
assessment regarding how that methodology would be ``statistically
significant.'' But GCI does not provide a usable alternative
methodology to replace the proposed drive test model. GCI's edit to the
proposed drive-test methodology lacks a statistical basis from which,
based on a limited set of tests, we could infer whether GCI had met its
commitments. Partial credit also is inconsistent with the approach
adopted in the Broadband Data Collection proceeding.
50. Finally, while we acknowledge that service declines farther
away from the cell site, this service quality deterioration can be
addressed in a number of ways, including adding more cell sites. GCI
receives support to meet its commitments, and if it does not meet them
initially, the drive tests can help it understand where improvements
are needed in its network, which will help it deliver the services it
committed to Alaskans.
b. No Lower Speed Tier Credit for Failed Grid Cells
51. The Alaska Drive-Test Model's use of frames will allow
providers to separately test the areas where they committed to
different minimum speeds based on middle-mile availability and last-
mile technology used, consistent with how the providers delineated
these speeds in their performance plans. In doing so, the Alaska Drive-
Test Model will ensure that the drive tests yield data that allow
Commission staff to assess whether the providers have met their
commitments.
52. GCI expressed concern that the Alaska Drive-Test Model
disregards data that show improvement, if fewer than 85% of tests in a
grid cell are below the minimum speed threshold for a frame. GCI
provided the example that, ``if 80 percent of tests in a cell reflect
speeds of 10/1 Mbps, and 20 percent of tests reflect speeds of 9/1
Mbps, the cell is deemed unserved at any speed--even though all tests
reported far faster speeds than required in the next lower speed tier
(2/.8 Mbps.).'' Where GCI fails a 4G LTE/3G grid cell for 4G LTE, GCI
argued that, if the speeds are sufficiently above the 3G commitment,
the grid cell should be a ``pass'' for the 3G frame.
53. Where a grid cell is selected for only 4G LTE testing, we
cannot credit the grid cell to 3G if it fails the 4G LTE speed tier.
This suggestion, if adopted, would result in an under-sampling for the
4G LTE frame and an oversampling for the 3G frame. Further, this would
have the effect of removing population from one frame and adding it to
a different frame, thereby disturbing the original distribution of the
grid cells across stratum as calculated prior to testing. For example,
suppose there is a grid cell for which one of the providers has claimed
100 people are covered by 4G LTE, but for which testing shows only 80%
of the results exceed the minimum performance threshold. GCI's proposal
would reallocate the population from the 4G LTE frame (and the stratum
within the 4G LTE frame to which that grid cell is assigned) to a
different frame and stratum for which the testing would show that the
performance benchmarks have been met (in this case, the 3G frame).
However, as the stratification and sample allocation processes
primarily consider population, this would mean that, after testing was
completed, the total populations of the strata would have changed and,
accordingly, the strata within each frame would no longer have the
correct distribution of grid cells. Additionally, the number of samples
optimally selected in each frame would also no longer be correct. This,
in turn, would mean that the results could no longer be measured at the
specified 90% confidence interval the Alaska Drive-Test Model sets for
statistical significance.
c. Waterfall Model
54. For the reasons described above, the Alaska Drive-Test Model
does not allow for partial credit where a mobile-provider participant
fails a test in a higher performance tier. Frames are created based on
the population covered at a particular minimum speed by technology from
FCC Form 477 data set plus additional middle-mile data. If, however,
the FCC Form 477 data show population coverage beyond what is committed
to at the five-year mark, then the testing of that frame could show
that the mobile-provider participant covered more people than it
committed to in its performance plan. Where this happens, the
commitments for the next lower tier last-mile technology will be
accredited with the excess covered population of the higher technology
tier.
55. GCI suggests that it should receive partial credit for
providing service at lower speeds if it does not meet the 85%
successful testing standard at the sampled technology, and for support,
it cites to the Alternative Connect America Model (ACAM) waterfall
methodology. For the ACAM waterfall methodology, a provider must
satisfy a particular number of locations at a particular speed tier,
and if a provider satisfies more than that, then the credit flows to
the satisfaction of the next lower speed tier. For example, if 60
locations need to have 25/3 Mbps performance, 10 locations must have
10/1 Mbps

[[Page 30116]]

performance, and 30 locations must have 4/1 Mbps performance, and the
provider supplies 80 locations with 25/3 Mbps, then the 25/3 Mbps and
10/1 Mbps speed tier commitments would be fully satisfied, and 4/1 Mbps
speed tier would be partially satisfied.
56. The ACAM waterfall methodology does not, as GCI suggests,
support allowing failed performance at higher speed tiers and receiving
credit for those failed tests in the lower speed tiers. The ACAM
waterfall methodology requires complete satisfaction of the higher
performance tier, and if the provider connects locations beyond the
minimum required in the higher performance tier, the excess coverage
would flow down to the next level tier. If the provider does not
completely satisfy the higher tier, then no excess is present, and no
``waterfall'' occurs: The provider needed to deploy to more locations
in that tier and does not receive credit in other tiers for this
failure. GCI's proposal is thus inconsistent with the ACAM waterfall
methodology.
57. The Alaska Drive-Test Model, as originally proposed and adopted
here, includes a waterfall methodology similar to the one used in ACAM
that is tailored to the drive-test requirement. Specifically, where a
provider has committed to multiple tiers of technology (i.e., 2G, 3G,
and 4G LTE), any excess coverage would be applied to the next lower
tier of technology. In the Alaska Drive Test Public Notice, the Bureau
provided the example: ``if a provider has committed to cover 25,000
people with 4G LTE and the upper limit of the confidence interval shows
adequate coverage for 30,000 people, then the remaining 5,000
[population] coverage can be applied to its 3G commitment.'' The Alaska
Drive Test Public Notice further stated that ``[t]his process is
iterative, so any further excess coverage can be applied to its 2G
commitment.'' In other words, the Alaska Drive-Test Model includes a
waterfall methodology that would credit lower tier commitments when
there is excess performance of the higher tier commitments.

IV. Procedural Matters

A. Final Regulatory Flexibility Certification

58. The Regulatory Flexibility Act of 1980, as amended (RFA),
requires that a regulatory flexibility analysis be prepared for notice-
and-comment rule making proceedings, unless the agency certifies that
``the rule will not, if promulgated, have a significant economic impact
on a substantial number of small entities.'' The RFA generally defines
the term ``small entity'' as having the same meaning as the terms
``small business,'' ``small organization,'' and ``small governmental
jurisdiction.'' In addition, the term ``small business'' has the same
meaning as the term ``small business concern'' under the Small Business
Act. A ``small business concern'' is one which: (1) Is independently
owned and operated; (2) is not dominant in its field of operation; and
(3) satisfies any additional criteria established by the Small Business
Administration (SBA).
59. An Initial Regulatory Flexibility Certification (IRFC) was
incorporated in the Notice in this proceeding. In the Notice, the
Bureau observed that the drive testing proposals required by the Alaska
Plan apply only to wireless participants receiving more than $5 million
in annual Alaska Plan support, excluding the smaller wireless
participants that receive less than that amount in annual support. And,
the proposals, if adopted, would apply to only two entities, one of
which does not qualify as a small entity. Therefore, we certify that
the requirements of the Order will not have a significant economic
impact on a substantial number of small entities.
60. The Commission will send a copy of the Order, including a copy
of the Final Regulatory Flexibility Certification, in a report to
Congress pursuant to the Congressional Review Act. In addition, the
Order and this final certification will be sent to the Chief Counsel
for Advocacy of the SBA and will be published in the Federal Register.

B. Congressional Review Act

61. The Commission has determined, and the Administrator of the
Office of Information and Regulatory Affairs, Office of Management and
Budget, concurs, that this rule is ``non-major'' under the
Congressional Review Act, 5 U.S.C. 804(2). The Commission will send a
copy of this Order to Congress and the Government Accountability Office
pursuant to 5 U.S.C. 801(a)(1)(A).

V. Ordering Clauses

62. Accordingly, it is ordered, pursuant to the authority contained
in Sections 1 through 4, 201, 254, 301, 303, 307, 309, 332 of the
Communications Act of 1934, as amended, 47 U.S.C. 151 through 154, 201,
254, 301, 303, 307, 309, 332 and Sections 0.91, 0.131, 0.291, 0.311,
54.317, 54.320, and 54.321 of the Commission's rules, 47 CFR 0.91,
0.131, 0.291, 0.311, 54.317, 54.320, and 54.321, and the delegated
authority contained in the Alaska Plan Order, 31 FCC Rcd 10139, 10160,
10166 through 67, paras. 67, 85, this Order is adopted, effective 30
days after publication in the Federal Register, except that the
deadline for filing updated coverage data shall be on 10 days after the
adoption of the Order in accordance with the Public Notice.
63. It is further ordered that the Office of the Managing Director,
Performance Evaluation and Records Management, shall send a copy of
this Order in a report to be sent to Congress and the Government
Accountability Office pursuant to the Congressional Review Act, 5
U.S.C. 801(a)(1)(A).
64. It is further ordered that the Commission's Consumer and
Governmental Affairs Bureau, Reference Information Center, shall send a
copy of this Order and Request for Comment, including the Initial
Regulatory Flexibility Certification and the Final Regulatory
Flexibility Certification, to the Chief Counsel for Advocacy of the
Small Business Administration.

Federal Communications Commission.
Amy Brett,
Acting Chief of Staff Wireless Telecommunications Bureau.

Appendix A--Mobile Speed Test Data Specification

1. Overview

The Alaska Plan requires certain plan participants to conduct
and report speed tests of their networks, as described in this Order
and appendices. Appendix A describes the data to be collected and
the format in which it is to be reported.

2. Sample Data

BILLING CODE 6712-01-P

[[Page 30117]]

[GRAPHIC] [TIFF OMITTED] TR18MY22.005

[[Page 30118]]

[GRAPHIC] [TIFF OMITTED] TR18MY22.006

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[GRAPHIC] [TIFF OMITTED] TR18MY22.007

BILLING CODE 6712-01-C

3. Mobile Speed Test Data

This section details the data structure common for all mobile
speed test data in the Alaska Plan. This file contains records of
each mobile speed test in JavaScript Object Notation (JSON) format
matching the specification in the table and sections below:

a. Submission Object

----------------------------------------------------------------------------------------------------------------
Field Data type Example Description/notes
----------------------------------------------------------------------------------------------------------------
test_id.............................. String................. 1599236609............. Unique identifier used
by the app or entity
to differentiate
tests.
--Value must be unique
across all data
submitted by the same
entity.
device_type.......................... Enumerated............. Android................ Type of device.
--Value must be one of
the following:
{iOS/Android/
Other{time} .
manufacturer......................... String................. Google................. Name of the device
manufacturer.
model................................ String................. PIXEL 6................ Name of the device
model.
operating_system..................... String................. Android 12............. Name and version of the
device operating
system.
device_tac........................... String................. 35142059............... 8-digit Type Allocation
Code of the device.
--Value is not
available on iOS and
may be null for these
device types.
--Value may be null if
the device does not
return a valid value
or else returns a
value of unknown.
app_name............................. String................. FCC Speed Test app..... Name of the mobile
speed test app.
app_version.......................... String................. 2.0.4058............... Version of the mobile
speed test app.
provider_name........................ String................. GCI.................... Name of the mobile
service provider.

[[Page 30120]]

tests................................ Test Object............ Information about the
test metrics.
Note: The specification
for the Test Object is
described in Section
b.
----------------------------------------------------------------------------------------------------------------

b. Test Object

----------------------------------------------------------------------------------------------------------------
Field Data type Example Description/notes
----------------------------------------------------------------------------------------------------------------
download............................. Download Test Object... Information about the
download test metric.
Note: This object is
only required for 3G,
4G LTE, and 5G-NR
network generation
speed tests and would
be omitted for 2G
network generation
voice tests.
Note: The specification
for the Download Test
Object is described in
Section c.
upload............................... Upload Test Object..... Information about the
upload test metric.
Note: This object is
only required for 3G,
4G LTE, and 5G-NR
network generation
speed tests and would
be omitted for 2G
network generation
voice tests.
Note: The specification
for the Upload Test
Object is described in
Section d.
voice_terminating.................... Mobile Terminating Information about the
Voice Test Object. mobile terminating
voice test metric.
Note: This object is
only required for 2G
network generation
voice tests and would
be omitted for 3G, 4G
LTE, and 5G-NR speed
tests.
Note: The specification
for the Mobile
Terminating Voice Test
Object is described in
Section e.
voice_originating.................... Mobile Originating Information about the
Voice Test Object. mobile originating
voice test metric.
Note: This object is
only required for 2G
network generation
voice tests and would
be omitted for 3G, 4G
LTE, and 5G-NR speed
tests.
Note: The specification
for the Mobile
Originating Voice Test
Object is described in
Section f.
----------------------------------------------------------------------------------------------------------------

c. Download Test Object

----------------------------------------------------------------------------------------------------------------
Field Data type Example Description/notes
----------------------------------------------------------------------------------------------------------------
timestamp............................ Datetime............... 2021-07-08T09:02:42-08: Timestamp of the time
00. at which the test
metric commenced.
--Value must match
valid ISO-8601 format,
including seconds and
timezone offset,
i.e.,: YYYY-MM-
DD[T]hh:mm:ss<plus-
minus<ls-thn-eq>hh:mm.
warmup_duration...................... Integer................ 3000622................ Duration in
microseconds that
connection took to
stabilize (e.g., TCP
slow start) before the
test metric commenced.
warmup_bytes_transferred............. Integer................ 31900808............... Measured total amount
of data in bytes that
were transferred
during the period the
connection took to
stabilize (e.g., TCP
slow start) before the
test metric commenced.
duration............................. Integer................ 4997185................ Duration that the test
metric took to
complete in
microseconds.
bytes_transferred.................... Integer................ 97382448............... Measured total amount
of data in bytes that
the test metric
transferred.
bytes_sec............................ Integer................ 19487461............... Measured number of
bytes per second that
the test metric
transferred.
locations............................ Array [Location Object] List of geographic
coordinates of the
locations measured
during the speed test.
Note: The specification
for each Location
Object element is
described in Section
g.

[[Page 30121]]

cells................................ Array [Cell Object].... List of cellular
telephony information
measured during the
speed test.
Note: The specification
for each Cell Object
element is described
in Section h.
success_flag......................... Boolean................ true................... Boolean flag indicating
whether the test
completed successfully
and without a change
in state or
connectivity.
----------------------------------------------------------------------------------------------------------------

d. Upload Test Object

----------------------------------------------------------------------------------------------------------------
Field Data type Example Description/notes
----------------------------------------------------------------------------------------------------------------
timestamp............................ Datetime............... 2021-07-08T09:02:51-08: Timestamp of the time
00. at which the test
metric commenced.
--Value must match
valid ISO-8601 format,
including seconds and
timezone offset,
i.e.,: YYYY-MM-
DD[T]hh:mm:ss<plus-
minus<ls-thn-eq>hh:mm.
warmup_duration...................... Integer................ 3000213................ Duration in
microseconds that
connection took to
stabilize (e.g., TCP
slow start) before the
test metric commenced.
warmup_bytes_transferred............. Integer................ 8337402................ Measured total amount
of data in bytes that
were transferred
during the period the
connection took to
stabilize (e.g., TCP
slow start) before the
test metric commenced.
duration............................. Integer................ 5000085................ Duration that the test
metric took to
complete in
microseconds.
bytes_transferred.................... Integer................ 15129062............... Measured total amount
of data in bytes that
the test metric
transferred.
bytes_sec............................ Integer................ 3025761................ Measured number of
bytes per second that
the test metric
transferred.
locations............................ Array [Location Object] List of geographic
coordinates of the
locations measured
during the speed test.
Note: The specification
for each Location
Object element is
described in Section
g.
cells................................ Array [Cell Object].... List of cellular
telephony information
measured during the
speed test.
Note: The specification
for each Cell Object
element is described
in Section h.
success_flag......................... Boolean................ true................... Boolean flag indicating
whether the test
completed successfully
and without a change
in state or
connectivity.
----------------------------------------------------------------------------------------------------------------

e. Mobile Terminating Voice Test Object

[[Page 30122]]

f. Mobile Originating Voice Test Object

g. Location Objects

Each element of the ``locations'' array contains the geographic
coordinates of the locations measured at the start and end of the
speed test, as well as during the test (if measured).

h. Cell Objects

Each element of the ``cells'' array contains telephony
information about the cell/carrier.

[[Page 30123]]

cell_connection...................... Enumerated............. 1...................... Connection status of
the cell.
--Value must be one of
the following codes:
0--Not Serving.
1--Primary Serving.
2--Secondary
Serving.
--Value is not
available on iOS and
may be null for these
device types.
--Value may be null if
the device does not
return a valid value
or else returns a
value of unknown.
network_generation................... Enumerated............. 4G..................... String representing the
network generation of
the cell.
--Value must be one of
the following:
{2G/3G/4G/5G/
Other{time}
network_subtype...................... Enumerated............. LTE.................... String representing the
network subtype of the
cell.
--Value must be one of
the following:
{1X/EVDO/WCDMA/GSM/HSPA/
HSPA+/LTE/NRSA/
NRNSA{time} .
rssi................................. Decimal................ -57.2.................. Measured Received
Signal Strength
Indication (RSSI) in
dBm of the cell.
--Value is not
available on iOS and
may be null for these
device types.
--Value is required for
all network
generations and
subtypes.
rxlev................................ Decimal................ -80.2.................. Measured Received
Signal Level in dBm of
the cell.
--Value is not
available on iOS and
may be null for these
device types.
Value is only required
for tests with a
network generation and
subtype of 2G--GSM,
and must be null for
all other network
generations or
subtypes.
rsrp................................. Decimal................ -92.1.................. Measured Reference
Signal Received Power
(RSRP) in dBm of the
cell.
--Value is not
available on iOS and
may be null for these
device types.
--Value must be null
for 2G or 3G tests.
--Note: This value
represents the
Synchronization Signal
(SS) for 5G-NR tests
and the Channel-
specific Reference
Signal (CRS) for 4G
LTE tests.
rsrq................................. Decimal................ -12.5.................. Measured Reference
Signal Received
Quality (RSRQ) in dB
of the cell.
--Value must be null
for 2G or 3G tests.
--Note: This value
represents the
Synchronization Signal
(SS) for 5G-NR tests
and the Channel-
specific Reference
Signal (CRS) for 4G
LTE tests.
sinr................................. Decimal................ 21.3................... Measured Signal to
Interference and Noise
Ratio (SINR) in dB of
the cell.
--Value is not
available on iOS and
may be null for these
device types.
--Value may be null for
2G or 3G tests.
--Note: This value
represents the
Synchronization Signal
(SS) for 5G-NR tests
and the Channel-
specific Reference
Signal (CRS) for 4G
LTE tests.
rxqual............................... Integer................ 3...................... Measured Received
Signal Quality of the
cell.
--Value is not
available on iOS and
may be null for these
device types.
--Value must be between
0 and 7.
--Value is only
required for tests
with a network
generation of 2G and
network subtype of
GSM, and must be null
for all other network
generations or network
subtypes.
ec_io................................ Decimal................ -8.3................... Measured Energy per
Chip to Interference
Power Ratio in dB of
the cell.
--Value is not
available on iOS and
may be null for these
device types.

[[Page 30124]]

--Value is only
required for CDMA 1X,
EVDO, WCDMA, HSPA, and
HSPA+ network
subtypes, and must be
null for all other
network subtypes.
rscp................................. Decimal................ -87.2.................. Measured Received
Signal Code Power in
dBm of the cell.
--Value is not
available on iOS and
may be null for these
device types.
--Value is only
required for WCDMA,
HSPA, and HSPA+
network subtypes, and
may be null for all
other network
subtypes.
cqi.................................. Integer................ 11..................... Measured Channel
Quality Indicator
(CQI) of the cell.
--Value is not
available on iOS and
may be null for these
device types.
--Value is only
required for WCDMA,
HSPA, HSPA+, LTE, and
NR network subtypes,
and may be null for
all other network
subtypes.
spectrum_band........................ Integer................ 66..................... Spectrum band used by
the cell.
--Value is not
available on iOS and
may be null for these
device types.
--Value may be null for
2G or 3G tests.
--Value may be null if
the device does not
return a valid value
or else returns a
value of unknown.
--Note: The reported
band value corresponds
to the Operating Bands
tables as follows:
--4G LTE: 3GPP TS
36.101 section 5.5
--5G-NR: 3GPP TS 38.101
table 5.2-1
spectrum_bandwidth................... Numeric................ 15..................... Total amount of
spectral bandwidth
used by the cell in
MHz.
--Value is not
available on iOS and
may be null for these
device types.
arfcn................................ Integer................ 66786.................. Absolute radio-
frequency channel
number, measured
absolute physical RF
channel number of the
cell.
--Value is not
available on iOS and
may be null for these
device types.
----------------------------------------------------------------------------------------------------------------

Appendix B--Drive-Test Procedures for Alaska Drive-Test Model--
Technical Appendix

I. Introduction

This technical appendix provides the process for Alaska Plan
mobile service providers receiving more than $5 million annually in
support to gather drive testing data to include with its performance
plan milestone certifications. The Alaska Plan requires such testing
to include ``a statistically significant number of tests in the
vicinity of residences being covered'' to demonstrate that plan
participants have met the commitments in the performance plans
approved by the Wireless Telecommunications Bureau (Bureau).
Remote Alaska is extraordinarily sparsely populated; virtually
all its county-level geographies have population densities of three
or fewer people per square mile. Accordingly, testing every location
for a provider's coverage would be unduly burdensome, and testing a
sample of locations is required.
For the sampling required to implement the testing procedures
under the Alaska Plan, the Alaska Drive-Test Model uses stratified
random sampling. This sampling methodology balances between the
statistical significance required by the Alaska Plan and the burden
on providers to conduct tests from a sufficient number of locations.
The following sections describe the details of the testing
process. These technical details serve as a guide to both the Bureau
and the providers doing the testing in determining:
<bullet> Where, within the geographic boundaries of the coverage
map, a provider should conduct testing;
<bullet> how many locations a provider must test;
<bullet> what speed test measurements will be accepted for staff
analysis by the Bureau; and
<bullet> how Bureau staff will evaluate the test data and
adjudicate whether the provider has passed or failed the testing
process.

II. Sample Frame Construction

To select locations for testing, one must first construct a list
(known as a ``sampling frame'' or ``frame'') of possible locations
to select from. The construction of this frame is a multi-part
process. First, we will create a set of ``eligible populated
areas.'' Census blocks eligible for frozen-support funding would be
included, and these census blocks would be merged with the populated
areas of the Alaska Population-Distribution Model. Second, staff
will merge the FCC Form 477 reported coverage areas (for which a
provider committed to deploy and that are subject to testing) with
the eligible populated areas to create a set of ``covered populated
areas.'' Third, staff will overlay a grid of 1 km x 1 km squares
onto the covered populated areas. Due to the fact that the Alaska
Population-Distribution Model uniformly distributes population
within the populated areas of a census block, the covered populated
areas of a block likewise have a uniform population distribution.
The total population of each grid cell is the sum of the populations
of the covered populated areas contained within a given grid cell.
For example, if a grid cell contains 25% of the covered populated
area of a census block, that grid cell would be credited with 25% of
that block's covered population. That same grid cell might also
contain 100% of a second census block's covered populated area. So
all of that census block's covered population would be credited to
that grid cell, and the grid cell's total population will be the sum
of these two populations. Lastly, any grid cell that contains fewer
than 100,000 square meters of covered populated area, or 10% of the
grid cell, will be excluded from the frame.\1\ This

[[Page 30125]]

ensures that all grid cells have a reasonable testable area,
reducing burden on providers. Grid cells with smaller levels of
covered populated area are less likely to have areas that are
publicly accessible or large enough to conduct mobile testing.
Figures 1-4 below detail this process.
---------------------------------------------------------------------------

\1\ For clarification, the population of grid cells with a de
minimis populated area will be credited towards the commitments
represented by the frames from which the respective grid cells were
removed. For example, a grid cell that was removed from a frame
measuring fiber-based 4G LTE at 10/1 Mbps because it had a testable
area of less than 100,000 square meters would have its population
credited towards that provider's fiber-based 4G LTE at 10/1 Mbps
commitment.
[GRAPHIC] [TIFF OMITTED] TR18MY22.008

For commitments that do not promise different speeds for
different middle-mile technologies, staff will construct the frame
based on the reported technology coverage from the provider's FCC
Form 477 submission. For areas served by more than one technology,
as reported on the FCC Form 477, staff will only include the latest
generation technology in the frame for any areas covered by multiple
technologies. For example, if an area is covered by both 2G and 3G,
then the area will only be included in the 3G frame. As no
commitments were made for 5G-NR service, any 5G-NR coverage would be
included within the LTE frame.\2\ Where a provider has committed to
different speeds in different areas due to different middle-mile
technologies, the frame would rely on additional data submitted by
the provider to differentiate the covered areas of a given
technology (e.g., LTE) with multiple middle-mile types.
---------------------------------------------------------------------------

\2\ If a provider's FCC Form 477 submissions show more than one
level of speed for a given technology, then only the area of the
submission with speeds equaling or exceeding the committed service
will be included in that frame, with the rest of the area included
in the frame of the lower last-mile technology. For example, if a
provider has committed to LTE at 10/1 Mbps speeds, and shows in its
FCC Form 477 LTE submission areas that have 10/1 Mbps LTE speeds,
and other areas with 5/1 Mbps speeds, only the 10/1 Mbps areas would
be included in the LTE frame, while the 5/1 Mbps areas would be
instead included in the 3G frame, which could also be described as
``3G or better.'' This will prevent a provider who has begun
upgrading an area's service, but that has not yet finished the
upgrade, from being penalized by having it tested against a standard
of a fully upgraded service area.
---------------------------------------------------------------------------

III. Frame Stratification

Frame stratification is the process of dividing a frame into
subsets of similar characteristics, called strata. This methodology
allows fewer grid cells to be selected for testing while producing
the statistically equivalent level of accuracy as sampling the
entire frame, thus reducing testing burden.
The number of strata for each frame depends on the number of
grid cells in a given frame. To create the strata, the Bureau will
use the cumulative square root of the frequency (CSRF) method, based
on grid-level estimates of covered population. CSRF is a standard
stratification method used to define the breaks between strata. It
creates equal intervals not on the scale along the stratification
variable (in this case, covered population) scale, but rather on the
scale along the cumulated square root of the count (frequency) of
grid cells belonging to equal intervals of the stratification
variable. The first stratum in each frame would contain all grid
cells with a population of less than one.
Based on the data staff currently have, each frame will likely
contain between two and eight strata. Staff analysis has found that
this stratification method produces strata of more equal sizes than
other potential stratification methods (e.g., based on census
tracts), which reduces the number of grid cells that need to be
selected for testing.

[[Page 30126]]

Further, staff will select certain grid cells with probability 1
(grid cells that are called certainties) within each stratum. This
ensures that grid cells that have a high population within a given
stratum are tested; this should prevent the testing results of the
stratum from being skewed by outlier results from low-weighted grid
cells.

IV. Sample Size Calculation and Allocation and Sample Selection

The Bureau will determine the number of grid cells that the
provider has to test (that is, the sample size, n), based on two
statistical assumptions. The first is that the variance of the
desired estimate of average population served cannot exceed a
specified value, V. The second is that the cost of drive testing is
constant in every grid cell selected in the sample. Under these
assumptions, a theoretical value for the sample size can be
calculated as detailed below.
Let L denote the number of strata in the frame and let the index
h distinguish these L strata. Further, denote or define the
following quantities:
[GRAPHIC] [TIFF OMITTED] TR18MY22.009

Guided by the allocation scheme from the previous section, staff
will use geographic information systems (GIS) tools or statistical
software to randomly select grid cells in each stratum. Staff will
then conduct a four-step optimization analysis, as follows.
First, we will draw a sample according to the adopted stratified
random design. If there are multiple frames for a provider, we will
sample independently from each frame. These multiple samples will be
subjected to the rest of the optimization steps together as one set.
We will then repeat this process at least one hundred times, each
time yielding a sample, or group of samples, that are valid under
the design.
Second, from this set of valid samples, we will identify the
sample or samples with grid cells that contain the least number of
incorporated and census-designated places.
Third, if there are multiple samples identified in the previous
step, we will then determine which of the remaining samples contains
the fewest number of selected grids that are located outside of
incorporated and census-designated places.
Fourth, if there remains more than one sample identified in the
previous step, we will randomly pick one.
The optimal sample so identified likely will result in a
significant reduction in the number of communities that have to be
visited for the required testing. The provider subject to testing
will be notified of the sample grid cells in which it will be
required to conduct on-the-ground speed tests.\3\
---------------------------------------------------------------------------

\3\ If a grid cell that is in multiple frames is randomly
selected for testing more than once, the provider only needs to
conduct one set of tests for that grid cell. The results can be used
for all frames for which the grid cell was selected.
---------------------------------------------------------------------------

V. Drive-Testing Data Collection

Within each selected grid cell, a carrier must conduct a minimum
of 20 tests, no less than 50% of which are to be conducted while in
motion from a vehicle. This is the minimum number of tests to
support the use of the binomial distribution to approximate the
normal distribution that is needed in calculating the gap in
coverage based on a one-sided 90% confidence interval, as discussed
later in Section VII. To be considered valid, each test must be
conducted between the hours of 6:00 a.m. and 10 p.m. local time,
within the selected grid cell, and report all relevant parameters
defined in Appendix A. Each component of a test (i.e., download and
upload speeds) should have a duration between 5 and 30 seconds.
Mobile tests are considered to be located within the grid cell
containing the starting location, as a tester has full control over
the starting location of a test but may not always be able to
control the ending location of a test. Testers should, however,
attempt to conduct a mobile test within a single grid cell as much
as is reasonably and

[[Page 30127]]

safely possible. A mobile test should initiate when moving away from
the location of a stationary test after having reached the speed of
the surrounding traffic, or a safe and reasonable operating speed in
the event no traffic is present.

VI. Statistical Analysis of Testing Results

Upon receipt of drive-testing submissions, the Bureau will
perform a statistical analysis of the data to estimate the desired
total population covered. Because the sample is selected using
stratified random sampling, estimation techniques appropriate for
this particular sampling method must be used.
Stratified random sampling requires an aggregate measurement
from a sampled grid cell that will be combined with measurements
from the other sampled grid cells to calculate stratum-level
estimates of total covered population. These estimates will, in
turn, be combined to produce an overall estimate of covered
population. Drive tests conducted in a sample grid cell will be
aggregated based on the following rule:
Let p be the percentage of drive tests that meet or exceed the
applicable minimum. If p is at least 85%, then the full population
of the sample grid cell will be deemed as covered; otherwise, 0%
will be deemed as covered.
To calculate the stratum-level estimates and the overall
estimate of the covered population, the Bureau will use the
estimation method appropriate for stratified random sampling,
described next.
[GRAPHIC] [TIFF OMITTED] TR18MY22.010

Combining these stratum-level estimates, we arrive at the
overall covered population mean, calculated as:
[GRAPHIC] [TIFF OMITTED] TR18MY22.011

Finally, the overall covered population total, X, is estimated
as X = NX.

VII. Adjudication of the Outcome of the Testing Process

Because the estimate of the total covered population comes from
a sample, direct comparison of X against the committed covered
population is not appropriate. Instead, staff will construct a
confidence interval that takes into account the variability arising
from the estimate X and use this confidence interval to adjudicate
the outcome of the testing process.
Because the Alaska Plan calls for a tiered approach in levying
penalties for providers failing the testing process, the Bureau will
use a one-sided 90% confidence interval for X to quantify the gap in
coverage. In particular, the Bureau will use the upper limit of this
confidence interval, which is calculated as X + 1.28n[radic]V(x).
This will be added to the population of grid cells with a de minimis
populated area that had been previously removed from the tested
frame.
The compliance gap is then calculated as:

Gap in Coverage = Total Population Coverage Commitment -
(1.28N[radic]V(x) + De Minimis Grid Cells).

If the gap in coverage is no more than 5% of the total
population of a given commitment, no penalties will apply.
Otherwise, penalties will apply according to the tiers adopted by
the Commission.
Additionally, it is possible to have a negative gap in coverage
if the upper limit of the confidence interval is greater than the
total committed population. If a provider has committed to multiple
tiers of technology (i.e., 2G, 3G, and 4G LTE), then any excess
coverage, as defined by a negative gap in coverage, can be applied
to the next lowest tier of technology. For example, if a provider
has committed to cover 25,000 people with 4G LTE and the upper limit
of the confidence interval shows adequate coverage for 30,000
people, then the remaining 5,000 coverage can be applied to its 3G
commitment. This process is iterative, so any further excess
coverage can be applied to its 2G commitment. Accordingly, the
formula above would be re-written as:

Gap in Coverage = Total Population Coverage Commitment - X +
(1.28N[radic]V(x) + De Minimis Grid Cells + Excess Coverage from
Higher Technology).

This methodology therefore will not punish carriers for
improving coverage beyond what they committed.

Appendix C--Current Performance Plans

I. Copper Valley Wireless

[[Page 30128]]

[GRAPHIC] [TIFF OMITTED] TR18MY22.012

II. GCI
[GRAPHIC] [TIFF OMITTED] TR18MY22.013

[FR Doc. 2022-10541 Filed 5-17-22; 8:45 am]
BILLING CODE 6712-01-P

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