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POLICY INITIATIVE: THE DATA IMPERATIVE - FCC SECTION 706 NOI

FCC GN Docket No. 25-223 | SBC Comments Filed September 2025

Section 706 of the Telecommunications Act requires the FCC to annually assess whether advanced telecommunications capability is being deployed “to all Americans” in a reasonable and timely fashion. SBC has filed comprehensive comments urging the Commission to include indoor wireless coverage in this assessment.

The Gap

Current FCC methodologies measure only outdoor coverage. Yet Americans spend 90% of their time indoors, originate over 80% of 911 calls from inside buildings, and conduct 70–80% of all wireless usage indoors. The evolution to 5G has widened this gap—higher-frequency signals penetrate buildings substantially worse than 4G, while coverage maps continue to rely on outdoor-only computer models.

What Good Data Enables

  • Policy Decisions: Informed policymaking at federal, state, and local levels regarding in-building wireless infrastructure requirements.
  • Business Decisions: Efficient private-sector investment in in-building systems, driven by real performance data rather than optimistic coverage predictions.
  • Public Safety: Accurate identification of areas where first responders face communication gaps during emergencies.
  • Global Competitiveness: Alignment with international markets—Singapore, Hong Kong, and the United Kingdom already conduct systematic indoor connectivity evaluation.

SBC’s Recommendation

The FCC should include indoor coverage in Section 706 assessments, leverage existing third-party measurement platforms such as Ookla and OpenSignal that already collect billions of indoor measurements, and initiate rulemaking under 47 U.S.C. § 642(b)(3) to address 5G’s distinct indoor propagation characteristics.

Congress explicitly required assessment of telecommunications availability in “classrooms” and mandated that the FCC account for building materials’ effects on signal propagation. Section 706 analysis cannot accurately assess deployment “to all Americans” without examining indoor coverage where these services are actually used.

 

READ SBC's FCC FILING