Amend 02 - Questions and Answers.pdf

AMENDMENT 0002

Questions and Answers - Solicitation 273FCC21R0005

June 24, 2021

1. The Third Report and Order states that the definition of a Broadband Serviceable Location (BLS) is "subject to further refinement in the competitive bidding process." Does the desired fabric include data regarding wired and wireless coverage at each location as specified in 47 U.S.C. §§ 642(c)(1)(A)-(B)?

A1. No. This solicitation is to deliver the Broadband Serviceable Location (BSL) Fabric: “a common dataset of all locations in the United States where fixed broadband internet access service can be installed, as determined by the Commission” as described in 47 U.S.C. §642(b). This solicitation does not include the provision of data regarding wired and wireless coverage or the broadband maps required by 47 U.S.C.

§642(c).

2. Third Report and Order further states, " We also adopt the proposal to create two other maps that identify carrier-specific fixed and mobile coverage data, including reported technologies and speeds by provider." (emphasis added). Are those two other maps part of this RFP?

A2. No. This solicitation is to deliver the BSL Fabric: “a common dataset of all locations in the United States where fixed broadband internet access service can be installed, as determined by the Commission” as described in 47 U.S.C. §642(b). This solicitation does not include the broadband maps required by 47 U.S.C. §642(c).

3. Can the FCC confirm that a small business subcontracting plan is not required? And if it is required, please indicate which Volume it should be submitted under.

A3. A small business subcontracting plan is not required as part of the proposal package. Per FAR 52.219-9 and 19.702(a)(1)(i), the apparently successful offeror will be required to submit an acceptable subcontracting plan if it is a large business.

4. In Attachment II - Instructions to Offerors and Evaluation Criteria, 4. Volume I – Business, Section d.

Compliance Matrix (page 3) and Volume II – Technical Approach (page 4), the FCC references a Compliance Matrix. Does the FCC want to see two distinct compliance matrices for each Volume? If yes, what specifically does the FCC want to see for each of them? Is there a format preferred by the FCC for the Compliance Matrix?

A4. A Compliance Matrix should be included in Vol I – Business. The compliance matrix should 1) create a high-level outline based on the RFP instructions; 2) address evaluation criteria; 3) address the statement of objectives; and 4) any other requirements.

The reference to Compliance Matrix on page 4, VOLUME II – Technical Approach, was an error and has been removed in the amended RFP, see Attachment II – Instructions to Offerors and Evaluation Criteria.

5. In Attachment 1 – Statement of Objectives, 3.1 Project Activities, Sections 3.1.1.B and 3.1.2.F (pages 6-8), can the FCC provide more details on the challenge process and what level of support is required from vendors? Specifically:

See Answer to questions regarding challenge process on Page 10.

a. Which entity is responsible for managing the challenge process? See Page 10.

b. Which entity is responsible for communicating directly with the challenger? See Page 10.

c. What information will be available with each challenge? See Page 10.

d. Will the FCC validate challenges submitted? See Page 10.

e. Once the FCC sends the challenge to the vendor, is the vendor expected to further validate the challenge, or just update the BSLF under the FCC’s direction? See Page 10.

6. In Attachment II - Instructions to Offerors and Evaluation Criteria, Evaluation Factors – (1) Technical Approach (pages 10-11), how will the FCC validate the completeness and accuracy rates claimed by different vendors? How will the FCC confirm whether each point falls on the building?

A6. As noted, the Technical Approach will be evaluated under an adjectival rating scheme. Offerors need to describe their approach for creating the dataset and the required quality reports in the PWS; and describe their approach to ensuring quality in their QASP. Whether a vendor has provided sufficient evidence in those documents to support their claims, including explaining their approach to ensuring points fall within building footprints, and demonstrating that is the case in a statistically meaningful way would be considered in evaluating and assessing ratings for that factor as it relates to the feasibility of the approach.

7. In Attachment II - Instructions to Offerors and Evaluation Criteria, 7. Volume IV – Past Performance, Factor 3: Past Performance (pages 7-8), the FCC requires offerors to identify three (3) contracts/task orders with the Federal Government (preferred), or with State, local, commercial, or non-profit customers that demonstrate recent and relevant positive past performance, but only one (1) of the three examples of past performance can be for a subcontractor. Are the number of past performance contracts/task orders required here maximums or minimums? In other words, may an offeror provide more than three contracts/task orders indicating positive past performance for itself, and more than one for a subcontractor as long as the minimum number for each is satisfied?

A7. The requirement is to identify three (3) contracts/task orders only. Per Attachment II – Instructions to Offerors and Evaluation Criteria, “ A relevancy determination will be made for each of the three (3) contracts submitted by the Offeror. For the Offeror, information on no more than three (3) contracts should be submitted for consideration; information on additional contract will not be evaluated. If additional contracts are submitted, they will be evaluated in order of receipt of the Past Performance Questionnaires up to the required number.”

8. Instructions to Offerors and Evaluation Criteria 7. VOLUME V – PRICE Pricing (pg. 8). What is your budget range for this solicitation?

A8. Congress appropriated a total of $98 million in the Consolidated Appropriations Act, 2021 for the FCC to implement the Broadband DATA Act (47 U.S.C. §641 et seq). Those appropriations include funding for the BSL Fabric through this solicitation, as well as all the other required activities in the Broadband DATA Act (e.g., creating and publishing a map of broadband availability, system development for a data-collection system; administration of challenge and crowdsource processes; audits;

and technical support for filers).

9. Statement of Objectives (SOO) 3.1.1 Required Activities B. Fabric Dataset (pg. 5-6). How will FCC visualize the Fabric deliveries? For example, will they exclusively use GIS?

A9. FCC will use GIS tools, but may use other types of tools or analysis.

10. Is the FCC willing to consider the creation of “private map layers” so that the data contributors from Industry can keep control of their data?

A10. Yes. As noted in section 3.3 of the SOO, “Vendors may describe more restrictive limits for data that are not required.” Offerors should describe limitations to data rights or provide examples of data layers that would not be publishable as part of their Data Usage Rights proposal(s).

11. Statement of Objectives (SOO) 3.1.2 Support and Special Projects Activity (Optional) . Optional Item “B” USPS address validation (pg. 7). Is the intention of this activity for the FCC, in addition to seeking a Fabric with a complete universe of broadband serviceable locations, is to recognize the subset of that universe which are addresses that are USPS verifiable?

A11. The intent of this activity is to improve and standardize address data that are included in the Fabric.

12. Optional Item “D” Creation of Census-Bureau-data-based quality report (pg. 7). Would you consider an offeror to deliver commercially available Census datasets with attribution that will allow you to connect Fabric data to Census data?

A12. No. The purpose of this Optional Activity is to compare Fabric data to non-public Census data about the location of all known living quarters in the U.S.

13. What is contained in the quality reports required and how frequently are they reported?

A13. The Offeror, FCC and Census Bureau will need to determine jointly what data can be included in the reports to improve Fabric quality while satisfying Census Bureau requirements to maintain the confidentiality of the underlying Census data.

14. How and where will the offeror's staff access the Census data from the US Census Bureau?

A14. Offeror’s staff would work with the FCC and Census Bureau staff to determine security requirements including the location of the work.

15. Optional Item “E” Address matching (pg. 8)

a. How will the ISP data be made available? Through the HUBB?

A15a. Offeror and FCC staff and contractors would establish a secure means of exchanging data to complete ISP address matching. It will not be via the HUBB.

b. How frequently will we receive ISP data?

A15b. ISPs are required to submit data twice each year; and we anticipate the same cadence for address matching if FCC chooses to proceed with the special project.

c. Will the format and structure be delivered via API?

A15c. Offeror and FCC staff and contractors would establish a secure means of exchanging data to complete ISP address matching. We expect the data would be delivered via API.

16. Statement of Objectives (SOO) 3.3 Data Usage Rights (pg. 8-12)Would derivatives be subject to the same terms as the license entered into and would those license terms also be perpetual?

A16. At a minimum, Offerors must provide the rights in derivate data/works described in paragraph 3.3.1 of the SOO, Tier 1: Minimum Required Data Usage Rights. To the extent an Offeror is proposing data usage rights that don’t exactly match any of the three Tiers described in the SOO, Offerors should describe their proposed data usage rights in their proposals and indicate how/if these rights vary for derivatives.

17. Will all entities granted access to the deliverables as part of this license be subject to the same terms of this license?

A17. Offerors should describe the Data Usage Rights they are willing to provide different categories of users as part of their proposal. At a minimum, Offerors must provide the rights described in paragraph

3.3.1 of the SOO, Tier 1: Minimum Required Data Usage Rights. There are different minimum levels of rights described for different categories of users.

18. The requirements indicate that "The Contractor shall grant to other federal government agencies, including but not limited to the U.S. Department of Agriculture's Rural Utility Service, the National Telecommunications and Information Administration, the U.S. Department of Transportation, and the Federal Geographic Data Committee.” Can an exhaustive list of agencies be provided?

A18. We anticipate the need to share with government agencies with interest in address data (or databases), or in improving broadband availability. The FCC is not currently able to provide an exhaustive list since the that list may change over time.

19. Regarding the requirement to include copies of applicable third-party license agreements: These third-party license agreements may be numerous, as well as confidential. Will an attestation that responding vendor has obtained the appropriate rights to all third-party data required as part of the deliverable be sufficient? Or, alternatively, can an abstract/summary of material third-party license agreements be provided?

A19. Offerors can submit an abstract/summary of material third-party license agreements but should ensure that FCC has sufficient detail to evaluate the proposed Data Usage Rights properly.

20. In Attachment 1, SOO, page 7, section 3.1.2, do the Optional Services need to be priced as a single bundle or can the offeror propose smaller bundles? If the latter, how should the offeror reflect smaller bundles in the pricing matrix?

A20. The RFP has been amended to reflect a $1.5M per year ceiling for the Support and Special Projects Optional Services. Please see Attachment II – Instructions to Offerors and Evaluation Criteria. Should an optional service be exercised a RFP/SOW will be sent to the Contractor for pricing at that time.

21. In Attachment 1, SOO, page 7, section 3.1.2.C, will the FCC be facilitating access to this data, or is it the responsibility of the offeror? If known, can the FCC provide a rough quantity and description of these data sets?

A21. If FCC exercises this Optional Activity, FCC would facilitate access to government entities' location data. At this time, FCC is unable to provide the quantity or description of these data sets.

22. In Attachment 1, SOO, will the FCC facilitate access to public records data that would not be available to the offeror as a commercial data entity?

A22. FCC will facilitate access to data as required and it is able to, though it is currently unaware of public records that are not available to commercial entities.

23. In Attachment 1, SOO, page 8, section 3.1.2.F, what roles does the FCC envision the offeror will take in the Challenge Process, e.g. would the offeror be exercising judgment on specific challenges? Is there a service level agreement or turnaround expectation? See Page 10.

See Answer to questions regarding challenge process below.

24. In Attachment 1, SOO, page 10, section 3.3.1, does the provision "The FCC shall retain full, unlimited rights to any correction data submitted to the FCC by third parties…" permit the offeror to only utilize the data for improving the offeror's data that is delivered to the FCC or can the improvements be utilized beyond the scope of deliveries to the FCC?

A24. Per the SOO, page 10, section 3.3.1, the Contractor shall be granted a non-exclusive, perpetual, irrevocable license to use such data for the purpose of correcting or otherwise modifying the Contractor’s data. Offerors can use data they receive as part of their work with the FCC to correct or otherwise modify their data; such license is not limited to improving the Contractor's data that is delivered to the FCC.

25. Page 7, Section 3.1.2: For the optional Support and Special Projects tasks, can the FCC quantify the number and/or the frequency of such services being requested each year (ie. monthly, quarterly, etc…)?

a. If not, shall the Contractor state assumptions for these tasks in the proposal, stating an estimated number of times data will be validated, total number of records to be reviewed, etc…?

A25. Delivery of Support and Special Projects depends on the individual activities. We anticipate that those tied to regular filings, like address matching, or tied to Fabric releases like validation of Fabric addresses, would be twice per year. Others, like the incorporation of location data could be one-time or occasional activities. Offeror should describe their assumptions in describing their proposed approach.

Should a Support and Special Projects optional service be exercised a RFP/SOW will be sent to the Contractor for pricing at that time. For the purposes of evaluation and the best value tradeoff, the Support and Special Projects CLIN ceiling amount is $1.5M per year. See the Amended Attachment II – Instructions to Offerors and Evaluation Criteria.

26. Page 7, Section 3.1.2: For the optional Support and Special Projects tasks which require reviewing data and/or data validation from government entities, will the FCC make this data available to the Contractor?

A26. Yes, FCC will facilitate access to data if such activity is required.

27. Page 7, Section 3.1.2: For the optional Support and Special Projects task which requires communicating with ‘ISPs, state, Tribal, and local governments, consumers, and other entities ‘, will the FCC provide the contact information for these organizations?

A27. Yes, FCC will facilitate contact for such organizations as required.

28. Will the data product provided to the Commission be subject to Peer Review under OMB Peer Review Bulletin, 70 Fed. Reg. 2664?

A28. No, FCC is not planning to subject the Fabric to Peer Review.

29. Attachment II, page 2, Sections 2.3 & 4 - Can the Government confirm that the Solicitation/Contract (SF1449) and Amendments (SF30) should be included in Volume I – Business?

A29. Ref Section 2.1 - The Solicitation/Contract (SF1449) and Amendments (SF30) shall be emailed directly to the Contract Specialist at Teresa.Dailey@fcc.gov. Do not include these documents in Volume I

– Business.

30. Attachment II, page 2, Section 2.4.1 - Will the Government confirm that the use of font size smaller than 12 point is acceptable in tables and graphics in order to best demonstrate technical capabilities and solutions?

A30. Yes, a font size smaller than 12 point is acceptable in tables and graphics only. Font size needs to be legible.

31. Attachment II, pages 5 & 10, Sections 5 (QASP) and Evaluation Criteria Factor 1, Item 2 (QASP) – The Instructions to Offerors states a requirement for a Quality Assurance Surveillance Plan, while the Evaluation Criteria states a requirement for a Quality Control/Quality Assurance Plan. Can the Government clarify whether a QASP or QC/QAP should be submitted?

A31. Removed “Quality Control/Quality Assurance Plan” verbiage and replaced with “Quality Assurance Surveillance Plan” verbiage in Evaluation Criteria.

32. Attachment II (7), pages 7 & 8 – Evaluation Criteria #7. Past Performance & #7. Price - The Instructions to Offerors lists Volume IV – Past Performance and Volume V – Price as number 7. For purposes of referencing the instructions within the Compliance Matrix and Table Summaries, can the Government please clarify the numbering within the Instructions?

A32. Volume V – Price should be #8. See revised Attachment II – Instructions to Offerors and Evaluation Criteria.

33. Attachment II (5), page 4 - For purposes of referencing the Instructions to Offerors within the Volume I – Business required Compliance Matrix and the Volume II – Technical Approach required Table Summary, can the Government please provide numbering within the Volume II – Technical Approach instructions?

A33. Yes, numbering has been added to Volume II – Technical Approach. See revised Attachment II - Instructions to Offerors and Evaluation Criteria

34. Attachment I & II, pages 8 & 1 – Attachment II - Instructions to Offerors and Evaluation Criteria states, “The Offeror is responsible for ensuring the Past Performance Evaluation Survey is received prior to the closing date and time of the RFP.” Attachment I – Past Performance Questionnaire states, “To qualify for evaluation under this procurement, the form must be received by the Contracting Officer – Teresa.Dailey@fcc.gov no later than COB on June 29, 2021.”

Will the Government consider amending the Past Performance questionnaire to reflect a due date of no later than the closing data time of the RFP?

A34. Yes, date is revised to reflect a due date of no later than July 1, 2021 at 4:00 PM EDT.

35. Attachment 1 – SOO – Section 3.2, Item 3, page 8 – The Statement of Objectives states that “the contractor is prohibited from ‘selling, leasing, or otherwise disclosing for monetary consideration any Personally Identifiable Information’ developed, accessed, collected, disclosed, obtained, or maintained in connection with this agreement to any entity other than for purposes authorized by this contract or by statute developed in the course of this work.”

The Broadband Deployment Accuracy and Technology Availability Act (Broadband DATA Act) appears to be more restrictive as it does not contain the underlined clause above. In addition, the Act has a 2nd clause. Both clauses state the following:

Item AA:

o ”Prohibit the entity awarded the fabric from selling, leasing, or otherwise disclosing for monetary consideration any personally identifiable information to any other entity other than for purposes authorized under this title.”

Item BB:

o “Requires the entity awarded the fabric to include in any contract with any other entity a provision that prohibits that other entity from engaging in an action that is prohibited under subitem

(AA).”

We assume that in referencing the Broadband Data Act, Items AA and BB apply. Is this assumption correct? If so, will the Government amend the solicitation language to reflect this guidance?

A35. The FCC interprets the cited Item AA of the Broadband Data Act (47 U.S.C.

642(b)(1)(A)(ii)(III)(cc)(AA)) to prohibit only “selling, leasing, or otherwise disclosing for monetary consideration any Personally Identifiable Information developed, accessed, collected, disclosed, obtained, or maintained in connection with the agreement . . . .” Therefore, the solicitation does not need to be revised in this regard. The Statement of Objectives (SOO) has been amended to reflect the requirement in 47 U.S.C. 642(b)(1)(A)(ii)(III)(cc)(BB). Please see Section 3.2.3 of the Amended SOO.

36. Attachment 1 – SOO, Section 3.3.3, page 8 – Tier 3: Most-Preferred Data Usage Rights, the requirement appears not to allow the Offeror to restrict use of its data (“...shall grant to any party accessing the data made publicly available by the FCC...”).

The requirement appears to conflict Item BB of the Broadband DATA Act (text in previous question).

Does the Government concur with this conclusion? If so, will the solicitation language be amended to reflect this guidance?

A36. The SOO states that “The Contractor shall grant to any party accessing the data made publicly available by the FCC a limited end-user license to such data." Pursuant to the revisions to Section 3.2.3 of the Amended SOO, any such license would need to include the restrictions in 47 U.S.C.

642(b)(1)(A)(ii)(III)(cc)(BB). Taken together, this means these third parties will be granted a limited end-user license that will allow them to access the data, but not to perform any of the explicitly restricted activities. Therefore, there is no conflict with the requirements of 47 U.S.C.

642(b)(1)(A)(ii)(III)(cc)(BB).

37. Attachment 1 – SOO, Section 3.3.1, page 9 – The Statement of Objectives Section 3.3.1 it states the rights of the FCC, including:

“Unlimited rights to access, prepare, use, copy, modify, reproduce, prepare derivative works (e.g., maps, reports of location-weighted broadband availability by geography, sample frames for auditing, or additional quality reports), and distribute the data for internal use, including by and to personnel, third-party contractors, and other entities granted the same license, as necessary to accomplish the goals of the Broadband Data Collection;”

Can the contractor assume these same examples of derivative use and restrictions on the rights to use are limited to “accomplish the goals of the Broadband Data Collection” are applicable only to “other federal government entities” note at the end of section 3.3.1?

A37. Yes. The description of derivative works included at the start of SOO Section 3.3.1, also applies to the “[r]ights to publish…derivative data” that applies to “other federal government agencies” at the end of Section 3.1.1.”

38. Attachment 1 – SOO, Section 3.3.1, page 9 – The Statement of Objectives Section 3.3.1 it states, “Rights to publish all of the relevant fields listed in section 3.1.1, paragraph B.ii above, about BSLs for a subset of locations to support Universal Service Fund programs;” Considering "all records less 1" could be defined as a "subset", can the Government define what a typical "subset" represents?

A38. The FCC generally limits fixed Universal Service Funding to locations that lack availability of 25 Mbps downstream, 3 Mbps upstream terrestrial broadband, making the subset of locations those that lack such broadband availability. While we expect that benchmark to shift over time, and we anticipate that the Broadband Data Collection could reveal some number of locations as lacking service that appear as served under the current data collection, we do not expect the number of locations eligible for Universal Service Funding to change in the near term.

39. Attachment 1 – SOO, Section 3.3.1, page 9 – The Statement of Objectives Section 3.3.1 it states, “Rights to publish all of the relevant fields listed in section 3.1.1, paragraph B.ii above, about BSLs for a subset of locations to support Universal Service Fund programs;”

Can the Government confirm that the Contractor will be involved in determining what can be published (e.g., full states are subsets of the data)?

A39. Yes. As noted above, we anticipate Universal Service Funding to be available to a relatively small subset of all locations in the U.S.

40. Attachment 1 – SOO, 3.3.1, page 9 – The Statement of Objectives Section 3.3.1 it states, “Rights to publish all of the relevant fields listed in section 3.1.1, paragraph B.ii above, about BSLs for a subset of locations to support Universal Service Fund programs;”

Can the Government confirm that the publication includes the contractors “restriction on use” language?

A40. Yes. Any data release will be governed by the Data Usage Rights in the applicable license.

41. Attachment 1 – SOO, 3.3.1, page 9 – The Statement of Objectives Section 3.1.1 it states, “The Contractor shall create and make accessible to the FCC an Application Programming Interface (API) to receive data for corrections to BSLs (from FCC site and governmental or other entities that might have location-specific information), and ability to incorporate updates to the Fabric coming from the Fabric challenge process, as appropriate.”

Can the Government please define if the contractor has a role in the validation of the corrections to BSLs or updates from the challenge process? If so, what is the expectation of the contractor?

See Answer to questions regarding challenge process below.

42. Attachment 1 – SOO, 3.3.2, page 11 – The Statement of Objectives Section 3.3.2 it states, “Rights to publish or otherwise make publicly available the data on the FCC’s website, for download, or via API access, subject to an end-user license.”

Depending on the size and quantity of requests, this requirement could add significant expense to the monitoring of adherence to license terms by users.

Will the Government allow the Offeror to place a reasonable limit to the geographic extent that any user can access and/or download?

A42. So long as the Offeror proposes to provide at least the minimum data usage rights described in SOO paragraph 3.3.1, the Offeror may choose to include restrictions on the licenses it will provide. For example, SOO paragraph3.3.2 (Preferred Data Rights) allows the Offeror to restrict third-party use of Fabric data via an end-user license, consistent with the requirements of Preferred Data Rights, in order to limit the cost. The Offeror’s data usage right proposal(s) should describe the data usage rights offered, including any restrictions thereon, in sufficient detail to be evaluated as described in the Instructions and Evaluation Criteria.

43. Attachment 1 – SOO, 3.3.3, page 12 – The Statement of Objectives Section 3.3.3 states, “Rights to access the data subject to this end-user license via API and/or download from the FCC’s website.”

Can the Government define who will act as the gatekeeper on licensing requirements – such as, reviewing the validity of the request, the type of requestor (e.g., provider, state agency, interested party, other government entity, etc..), requesting signature (or click) on a license, managing, monitoring, and tracking adherence to license terms, etc. – given the various levels of access rights this will require multiple license versions?

A43. Offeror should describe their proposed approach based on the Data Usage Rights included in their proposal(s). Attachment II – Instructions to Offerors and Evaluation Criteria has been amended to reflect this.

44. Attachment 1 – SOO, 3.3.3, page 12 – The Statement of Objectives Section 3.3.3 states, “Rights to access the data subject to this end-user license via API and/or download from the FCC’s website.”

Our assumption is that the Offeror will have the latitude to reject a license request for documented valid reasons. Is this assumption correct?

A44. The question is a little unclear because the quoted statement does not appear in SOO Section 3.3.3, rather it is in Sections 3.3.1 and 3.3.2. However, as a general rule, offerors may place restrictions in their end-user licenses, so long as they still provide the minimum data usage rights described in Section 3.3.1 of the SOO. The Offerors proposed data usage rights, including any restrictions, should be clearly described in its data usage rights proposal(s) and will be evaluated in accordance with the evaluation criteria. The Offeror may enforce the agreed-upon terms of their license agreements as necessary.

45. Attachment 1 – SOO, 3.3.3, page 12 – The Statement of Objectives Section 3.3.3 states, “Rights to access the data subject to this end-user license via API and/or download from the FCC’s website.”

Can the Government please define how the contractor will interact with the FCC’s web databases to provide the list of “licensed” users?

A45. Offerors can describe how they would implement this requirement as part of their proposal(s). FCC does not anticipate creating a list of licensed users, particularly for Tier 3 rights; but instead anticipates such users agreeing to any use limits as part of their access to the data.

See below answer to questions #5, 23, and 41 regarding challenge process:

The FCC anticipates that the Broadband Data Collection system will ingest Fabric challenge data from the public. The information collected as part of the challenge will vary by the nature of the challenge.

For example, a challenge to change a BSL’s business/residential status or the number of units in a BSL might include only the BSL ID along with the alternate information from the challenger. A request to add a new BSL would have to include the geographic coordinates and all other Fabric fields.

The FCC anticipates that, if the Special Project is authorized, the FCC would provide the challenge data to the Contractor via secure data transfer (e.g., via API). In advance of, and after the beginning of, the challenge process, the FCC will develop methodology and bright line rules, in consultation with the contractor, that will provide guidance on the conditions under which the contractor should “approve” certain types of challenges and update the Fabric. The goal of this methodology and set of rules would be to address as many challenges as possible in an automated fashion. The FCC anticipates that at least some types of challenges would require the contractor to compare the challenge information to other data sources the contractor uses in developing the Fabric; and in some circumstances could provide the contact information of the challenger to the Contractor to gather more information about the challenges. In new or unusual challenges where a methodology for an adjudication has not been established, FCC would consult with and provide guidance to the contractor to determine whether updates to the Fabric are warranted.