Rural Digital Opportunity Fund, Bringing Puerto Rico Together, Connect USVI
Transition from Latitude/Longitude/Address to Fabric ID Reporting in the HUBB
The FCC Broadband Data Collection (BDC) is regularly updating the National Broadband Map to show where broadband service is available nationwide, location by location, as reported by Internet service providers. The BDC relies on the Broadband Serviceable Location Fabric (Fabric), a single, standardized dataset of all locations in the U.S. where fixed broadband access service is available or could be installed.
Carriers receiving High Cost support (with the exception of carriers participating in Enhanced ACAM) have been required to report deployments in their authorized areas using the lat/long/address of the location connected.
In 2025, the FCC and USAC are transitioning Rural Digital Opportunity Fund, Bringing Puerto Rico Together, and Connect USVI carriers from reporting in the HUBB using lat/long/addresses to reporting deployment using Fabric Locations IDs.
Below is the timeline for the transition and information about how the FCC will monitor and enforce compliance with interim and final broadband deployment milestones. In addition, as detailed in this public notice https://docs.fcc.gov/public/attachments/DA-25-361A1.pdf and described below, the FCC has provided certain limited and targeted relief from network testing and letter of credit requirements.
| RDOF | PR-USVI |
March 3, 2025
| In the High Cost Universal Broadband (HUBB) Lat/Long Version ( carriers report broadband deployment to locations using geocoordinates and address ), RDOF carriers certified deployment that occurred in 2024 (40% milestone 2021 authorized carriers)
| In the HUBB Lat/Long Version, PR/USVI carriers certified deployment that occurred in 2024 (40% milestone)
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Enforcing non-compliance with deployment obligations in 2025
USAC/FCC will assess compliance with end of 2024 deployment obligations using HUBB Lat/Long data. Any USAC verifications will come from these data.
RDOF and PR/USVI carriers that are subject to quarterly broadband deployment reporting in 2025. Throughout 2025, required quarterly deployment reporting may occur in the HUBB Lat/Long Version, but USAC/FCC will provide additional guidance as the filing process may change temporarily to accommodate the transition. Quarterly reporting will move to the HUBB Fabric Version for March 2, 2026 (see below for March 2, 2026 filing) and from then on quarterly reporting will continue in the HUBB Fabric Version (see DA 25-32) (carriers report broadband deployment to locations using Locations IDs from the Broadband Serviceable Location Fabric (Fabric)).
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| RDOF | PR-USVI |
May 2025 | USAC/FCC makes available an interim required locations list for RDOF carriers using the latest version of the Fabric.
| USAC/FCC makes available an interim required locations list for PR/USVI using the latest version of the Fabric |
On or around July 1, 2025 | USAC opens HUBB Fabric Version for RDOF carriers to begin reporting and get accustomed to the HUBB Fabric Version
| USAC opens HUBB Fabric Version for PR/USVI carriers to begin reporting and get accustomed to the HUBB Fabric Version
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Between December 1 and December 31, 2025 | USAC/FCC make available the next interim required location lists for RDOF carriers using latest version of the Fabric
| USAC/FCC make available the next list of required locations for PR/USVI carriers using the latest version of the Fabric. This will be list used for the final list of required locations for PR/USVI
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Between January 1, 2026 and March 2, 2026 | In the HUBB Fabric Version, RDOF carriers certify deployment through the end of 2025 (including all prior years) (60% milestone for 2021 authorized carriers; 40% milestone for 2022/2023 authorized carriers)
| In the HUBB Fabric Version, PR/USVI carriers certify deployment through the end of 2025 (including all prior years) (60% milestone) |
March 2, 2026 will be the first time that RDOF and PR/USVI carriers certify broadband deployment in the HUBB Fabric Version. There will be no restrictions on the date of deployment that the carrier may report (by March 2, 2026, carriers certify the locations where they deployed voice and qualifying broadband as of the end of 2025).
Carriers’ previous years reporting based on Lat/Long will be replaced (“flash cut”) by the reporting in the HUBB Fabric Version. USAC/FCC will preserve the data from the HUBB Lat/Long version but USAC/FCC will not use that data in assessing compliance with broadband deployment milestones. In other words, USAC/FCC will assess compliance using reporting in the HUBB Fabric Version starting with the 12/31/2025 deployment milestones.
For RDOF, compliance with the 40% (just for carriers authorized in 2022/2023), 60% and 80% milestones will be assessed comparing the number of locations certified in the HUBB Fabric Version against the CAM’s estimated number of locations at the time of authorization (and subject to any defaults for which early support recovery was timely paid).
For PR/USVI, compliance with the 60% and 80% milestones will be assessed comparing the number of locations certified in the HUBB Fabric Version against the number of census locations at the time of authorization.
Enforcing non-compliance with deployment obligations in 2026
An RDOF carrier authorized in 2021 and all PR/USVI carriers :
If the carrier has been verified to have met the 60% milestone or higher using HUBB Lat/Long data and allowed to reduce the value of its LOC to one year of support and in the HUBB Fabric Version certifies to less than 60% of the estimated number of CAM (or census) locations, the carrier will not be required to increase the value of the LOC—WCB waived the requirement citing the burdens on the carrier versus the risk to the program.
If the carrier has been verified to meet the optional or 40% milestone, but does not certify enough locations to meet the 60% milestone, it must value the LOC pursuant to the RDOF rules.
Regardless of whether the carrier has been verified to have met the 60% or higher milestone in the HUBB Lat/Long version, if in the HUBB Fabric Version, the carrier certifies to less than 60% of the estimated number of CAM (or census) locations, the carrier will be subject to 54.320(d)(1) (the non-compliance tiers). We anticipate at most this will be quarterly reporting as it takes a 15% gap or higher for any support withholdings.
An RDOF carrier authorized in 2022/2023 :
If the carrier has been verified to have met the 40% milestone or higher using HUBB Lat/Long data and allowed to reduce the value of its LOC to one year of support and in the HUBB Fabric version certifies to less than 40% of the estimated number of CAM will not be required to increase the value of the LOC—WCB waived the requirement citing the burdens on the carrier versus the risk to the program.
If the carrier has been verified to meet the optional milestone, but does not certify enough locations to meet the 40% milestone, it must value the LOC pursuant to the RDOF rules.
Regardless of whether the carrier has been verified to have met the 40% or higher milestone in the HUBB Lat/Long version, if in the HUBB Fabric Version, the carrier certifies to less than 40% of the estimated number of CAM (or census) locations, the carrier will be subject to 54.320(d)(1) (the non-compliance tiers). We anticipate at most this will be quarterly reporting as it takes a 15% gap or higher for any support withholdings.
Carriers that have met the 100% milestone (terminated LOC)
Any carrier that was verified to have meet its 100% milestone using HUBB Lat/Long data and has terminated/allowed to terminate its LOC will not be required to go back and get an LOC in any situation.
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| RDOF | PR-USVI |
Between December 1 to December 31, 2026 | USAC/FCC makes available the next list of required locations for RDOF carriers using the latest version of the Fabric This will be list used for the final list of required locations once WCB formally adopts new location totals in 2027.
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Between January 1, 2027 and March 1, 2027 | In the HUBB Fabric Version, certification of all deployment through the end of 2026 (80% milestone for 2021 authorized carriers, 60% milestone for 2022/2023 authorized carriers)
| In the HUBB Fabric version, certification of all deployment through the end of 2026 using the final list of required locations for PR/USVI (80% milestone) |
Enforcing non-compliance with deployment obligations in 2027 and Beyond In 2027 and beyond, USAC/FCC will apply the rules of the programs for non-compliance. There will not be any general relief from the requirement to increase the value of the LOC if a carrier does not meet the end of 2026 milestone and FCC/USAC will apply the applicable non-compliance rule in 54.320(d).
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Rural Digital Opportunity Fund 2028 – 2032 HUBB Reporting
In or Around May 2027 FCC adopts the final list of required locations for RDOF carriers and FCC adopts/authorizes the revised location totals for each carrier.
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| 2021 Authorized RDOF Carrier with same or fewer Fabric Locations than CAM | 2021 Authorized RDOF Carrier with more Fabric locations than the CAM | 2022/2023 Authorized RDOF Carrier with same or fewer Fabric Locations than CAM | 2022/2023 Authorized RDOF Carrier with more Fabric locations than the CAM |
Between January 1, 2028 and March 1, 2028 | 100% Milestone certification: Compliance is based on either: 1) lower adjusted location total or 2) model-estimated total (if fabric location total is same as model estimate)
| 100% CAM Milestone certification: Compliance is based on the model-estimated location total | 80% milestone certification | 80% milestone certification |
Between January 1, 2029 and March 1, 2029 | 100% Milestone cure period certification | No Milestone certification | 100% Milestone certification: Compliance is based on either: 1) lower adjusted location total or 2) model-estimated total (if fabric location total is same as model estimate)
| 100% CAM Milestone certification: Compliance is based on the model-estimated location total |
Between January 1 and, 2030 and March 1, 2030
| N/A | 100% Milestone certification for additional locations above the model-estimated total
| 100% Milestone cure period certification | No Milestone certification |
Between January 1, 2031 and March 3, 2031
| N/A | 100% Milestone cure period certification
| N/A | 100% Milestone certification for additional locations above the model-estimated total
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Between January 1, 2032 and March 1, 2032
| N/A | N/A | N/A | 100% Milestone cure period certification
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Puerto Rico and US Virgin Islands 2028 – 2029 HUBB Reporting
Between January 1, 2028 and March 1, 2028
| In the HUBB Fabric Version, certification of all deployment through the end of 2027 using the final list of required locations for PR/USVI (100% milestone)
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Between January 1, 2029 and March 1, 2029
| In the HUBB Fabric version, certification of all deployment through the end of 2028 using the final list of required locations for PR/USVI (100% milestone cure period)
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Performance Measures Testing :
RDOF carriers received their first sample in Q4 2024 and began pre-testing in 2025. Under the performance measures testing orders, RDOF carriers are currently scheduled to get a new testing sample Q4 2026 and begin testing that new sample in Q1 2027.
PR/USVI carriers received their first sample in Q4 2023 and began pre-testing in Q1 2024 and testing in 2025. PR/USVI are currently scheduled a new testing sample in Q4 2025 and begin testing that new sample is Q1 2026.
Given how the Performance Measure Module is designed, the “flash cut” (i.e. removing the reported locations in the HUBB Lat/Long Version) will break the link to subscribers in PMM, and carriers will not be able to replace subscribers or submit performance data from the samples created using locations certified in the HUBB Lat/Lat Version. To ease administrative burdens for FCC/USAC/carriers, RDOF and PR/USVI carriers have been relieved from network testing in Q1 and Q2 2026. RDOF and PR/USVI carriers shall obtain a new sample in Q2 2026 and start/re-start testing in Q3 2026. Annual compliance for testing will be based on the two quarters of testing.