Federal Communications Commission	DA 25-1097



DA 25-1097
Released:  December 22, 2025

BROADBAND DATA TASK FORCE AND OFFICE OF ENGINEERING AND TECHNOLOGY APPROVE CELLWATCH MOBILE SPEED TEST APPLICATION FOR USE IN THE BROADBAND DATA COLLECTION MOBILE CHALLENGE PROCESS
ET Docket Nos. 24-2, 22-152
WC Docket No. 19-195

By this Public Notice, the Broadband Data Task Force (Task Force) and the Office of Engineering and Technology (OET) approve the Georgia Institute of Technology’s (Georgia Tech) third-party mobile speed test app, CellWatch v1.0, for use in the FCC’s Broadband Data Collection (BDC) mobile challenge process.  Concurrent with this Public Notice, the Task Force and OET will list the CellWatch v1.0 app as approved on the FCC’s Third Party Apps webpage:  https://www.fcc.gov/BroadbandData/third-party-mobile-speed-test-apps. Establishing the Digital Opportunity Data Collection, WC Docket No. 19-195, Order, 37 FCC Rcd 3007, 3021, para. 25 (WTB/OEA/OET 2022) (Mobile Technical Requirements Order) (stating that the Commission will publish on its website “a list of approved third-party apps and any available data specifications for third-party apps”).  The Commission already provides data specifications for third-party apps on its Third Party Apps webpage,  https://www.fcc.gov/BroadbandData/third-party-mobile-speed-test-apps.

Background.  In the Third-Party App Procedures Public Notice, the Task Force and OET adopted procedures for third-party mobile speed test application developers to submit, for OET review and approval, proposals for mobile speed test applications for use in collecting and submitting mobile network performance data as part of the BDC. Broadband Data Task Force and Office of Engineering and Technology Announce Procedures for Third-Party Mobile Speed Test Applications Seeking Approval for Use in the FCC's Broadband Data Collection, WC Docket No. 19-195, ET Docket No. 22-152, Public Notice, 37 FCC Rcd 5004, 5004, para. 1 (OET 2022) (Third-Party App Procedures Public Notice).  In 2021, the Commission adopted a requirement that consumers submitting on-the-ground data to challenge mobile wireless broadband coverage availability and/or quality of service data do so “us[ing] a speed test application that has been designated by OET, in consultation with [the Office of Economics and Analytics] and [the Wireless Telecommunications Bureau], for use in the [mobile] challenge process.”  Establishing the Digital Opportunity Data Collection; Modernizing the FCC Form 477 Data Program, WC Docket Nos. 19-195 and 11-10, Third Report and Order, 36 FCC Rcd 1126, 1166, para. 103 (2021) (BDC Third Report and Order).  Additionally, the Commission specified that “applications approved by OET for collecting consumer challenges must automatically collect [specific] information associated with each speed test” and that “designated applications must allow consumer challengers to submit all of the information required to support a challenge directly to the Commission from their mobile device.”  Id. at 1166-67, para. 103.
  On July 10, 2024, Georgia Tech submitted a proposal to OET seeking approval of the Android-only mobile speed test app “CellWatch v1.0” to collect and submit BDC mobile challenge data. Application of Georgia Institute of Technology, ET Docket No. 22-152 (filed July 10, 2024), https://www.fcc.gov/ecfs/search/search-filings/filing/10710974725173 (Georgia Tech Application); see Third-Party App Procedures Public Notice, 37 FCC Rcd at 5006-10, paras. 6-15.  The Georgia Tech mobile speed test app will collect data for the mobile challenge process.  Georgia Tech Application at 4.  It will not collect data for the mobile crowdsource process.  Id.
  Georgia Tech’s proposal included a beta version of the CellWatch v1.0 app, sample test data, and a privacy policy. See Georgia Tech Application. 
  
The Task Force and OET conducted an initial review of the proposal, found that Georgia Tech had provided sufficient information and details related to the various requirements to warrant public comment on the proposal prior to approval, and subsequently sought public comment on the CellWatch v1.0 app. Broadband Data Task Force and Office of Engineering and Technology Seek Comment on Georgia Institute of Technology’s Third-Party Mobile Speed Test App, ET Docket Nos. 24-2 and 22-152, WC Docket No. 19-195, Public Notice, 39 FCC Rcd 10617 (OET 2024) (CellWatch Public Notice). 
   
Discussion.  The sole commenter in this docket – the Competitive Carriers Association (CCA) – does not address the merits of Georgia Tech’s proposed CellWatch v1.0 app. Letter from Angela Simpson, General Counsel and SVP, Legal and Regulatory Affairs, and Alexandra Mays, Assistant General Counsel and Director, Regulatory Affairs, Competitive Carriers Association, to Marlene H. Dortch, Secretary, FCC, ET Docket Nos. 24-2 and 22-152, WC Docket No. 19-195, at 1 (filed Nov. 1, 2024).  In its letter, “CCA commends the Commission’s efforts to enhance the mobile challenge process by potentially expanding crowdsource data from third-party apps.  In that regard, CCA does not oppose Georgia Tech’s application.  However, CCA is concerned that allowing additional speed test apps alone will not solve the underlying issues that are undermining a vigorous and user-friendly challenge process as called for in the Broadband DATA Act and that are plaguing the Commission’s mobile availability maps.”
  At the conclusion of the comment period, Georgia Tech submitted a production version of the CellWatch v1.0 app and OET staff conducted testing.  The OET staff evaluation confirmed that the CellWatch v1.0 app meets the requirements to qualify as a valid BDC mobile challenge app, as outlined in the Broadband DATA Act Broadband Deployment Accuracy and Technological Availability Act, Pub. L. No. 116-130, 134 Stat. 228 (2020) (codified at 47 U.S.C. §§ 641-646) (Broadband DATA Act).
 and OET Bulletin 75. “OET Bulletin 75” refers to OET Bulletin No. 75, Broadband Data Collection Program: Third-Party Speed Test Mobile Application Approval Process Guidance, FCC Office of Engineering and Technology, FCC/OET-75 (Apr. 14, 2022) (OET Bulletin 75).  This document is available on the FCC’s website under “OET - Bulletins On-line” at https://www.fcc.gov/general/oet-bulletins-line.
  Based on the evidence in the public record and OET’s testing and review, we approve the CellWatch v1.0 app for use in the BDC mobile challenge process.  
The review process for the CellWatch v1.0 app established that the app correctly and consistently captures mobile speed test data and meets the most up-to-date functionality requirements. See Broadband Data Task Force and Office of Economics and Analytics Publish Additional Data Specifications for the Submission of Mobile Speed Test and Infrastructure Data into the Broadband Data Collection, Public Notice, 37 FCC Rcd 3126, 3126 (OEA 2022); see also FCC, Broadband Data Collection Data Specifications for Mobile Speed Test Data (2025), https://help.bdc.fcc.gov/hc/en-us/articles/6789299021723-Key-Reference-Documents (BDC Data Specifications for Mobile Speed Test Data).  See also BDC Third Report and Order, 36 FCC Rcd at 1166-67, paras. 103-04.
  The review process involved OET staff conducting trials on the app’s operation, which included:  (i) validating collected information; (ii) ensuring the inclusion of a privacy notice; (iii) confirming that the app provided a means for obtaining end user consent; (iv) checking that the app provided functionality for the user to certify as a subscriber of the mobile broadband provider; (v) ensuring the app asks users to certify whether each test was taken in an in-vehicle mobile or outdoor pedestrian environment; and (vi) verifying that the app has a user-friendly data display and data export capabilities. See BDC Third Report and Order, 36 FCC at 1167, para. 104 (setting forth the user testing certification).
 
From an infrastructure perspective, the CellWatch v1.0 app’s test servers are well distributed geographically, have robust failover strategies, include optimal server selections, sufficient measurement server capacity, effective monitoring of the health and quality of the measurement infrastructure and collected data, and clearly defined capacity upgrade thresholds. Third-Party App Procedures Public Notice, 37 FCC Rcd at 5007-08, para. 9.
  Furthermore, the testing results confirmed that the FCC BDC backend systems would accept the CellWatch v1.0 transmitted data submissions. See BDC Third Report and Order, 36 FCC Rcd 1166-67, paras. 103-04.   

Following the OET Bulletin 75 Appendix A procedures, FCC staff evaluated the CellWatch v1.0 app performance through a statistical approach that compared the collected download and upload speed test data from the CellWatch v1.0 app against the FCC Mobile Speed Test app. See OET Bulletin 75 at 23-24, 25.
  The analysis determined CellWatch v1.0 mean upload and download speeds are correlated See id. at 25.
 and found no statistically significant difference in the pass rates See id. at 25; see also 47 CFR § 1.7004(c)(3)(i).  For 4G LTE coverage, these values are 5 Mbps download and 1 Mbps upload (i.e., 5/1 Mbps).  Id.  For 5G-NR coverage, there are two sets of minimum speed threshold values, 7 Mbps download and 1 Mbps upload (i.e., 7/1 Mbps), and 35 Mbps download and 3 Mbps upload (i.e., 35/3 Mbps).  Id.
 when compared to the FCC Mobile Speed Test app. 
Consistent with the Third-Party App Procedures Public Notice, we approve the CellWatch v1.0 app for a five-year term beginning December 22, 2025, and expiring after December 22, 2030 (Initial Term). Third-Party App Procedures Public Notice, 37 FCC Rcd at 5012, para. 23.
  This approval is subject to the terms described below regarding major and minor changes to the app.  Georgia Tech may request, between six months and three months prior to the end of the Initial Term, that its app approval be renewed for an additional term of up to five years.  See id.
  
We remind Georgia Tech of the requirements associated with major and minor modifications to an approved mobile speed test app. Id. at 5011, paras. 18-19; see also OET Bulletin 75 at 21-22 (providing further guidance on major and minor changes to approved third-party mobile speed test apps).
  Any modification to an app that affects its testing methodology or compliance with technical and data requirements, including a change to the upload, download, or latency testing protocols or to the measurement procedures, will be considered a “major” change. Third-Party App Procedures Public Notice, 37 FCC Rcd at 5011, para. 18. 
  If a third-party app developer would like to make a major change to its app, it must submit a new proposal in ECFS using the docket number associated with the initial proposal.  The proposed updated app will be made available for public comment and must receive OET’s prior approval before updating the app in an app store. See id.  See also OET Bulletin 75 at 21.  If a third-party app developer makes any major changes without OET’s prior approval, “data from such third-party app will not be considered for either challenge or crowdsourcing processes unless and until such changes have been approved by OET.”  OET Bulletin 75 at 21-22. 
  A third-party app developer does not need OET approval to make a minor change, “A minor change is one that does not modify the third-party app’s testing methodology or technical and data requirements.”  Third-Party App Procedures Public Notice, 37 FCC Rcd at 5011, para. 19.  “Minor changes may include updates to the end user’s interface, adding support for new operating system versions and hardware, security updates, or withdrawal.”  Id.  If a third-party app developer is uncertain whether a change is minor, it should contact OET for guidance.  OET Bulletin 75 at 22.
 but it must notify OET of the proposed change prior to updating the app in an app store. Third-Party App Procedures Public Notice, 37 FCC Rcd at 5011, para. 19. 
  Notice of a minor change must be filed in ECFS using the docket number associated with the initial proposal. Id.
  When a third-party app developer submits such notification, it must include a description of the change, identify the new third-party app version, and indicate the date when older third-party app versions will no longer be used for BDC challenge data submissions (and crowdsourced submissions, where applicable). Id.
  OET may choose whether to use data submitted after the minor change, and OET reserves discretion to require the third-party app developer to reclassify a minor change to a major change. Id.

If Georgia Tech wishes to discontinue its approved third-party app’s participation in the BDC program, it must notify the Commission at least 60 days in advance of such discontinuance. Id. at 5012, para. 25.
  Additionally, Georgia Tech must provide notice to all affected end users at least 30 days before such discontinuance to minimize disruptions to the data collection process. Id.
 
Further Information.  Questions regarding this Public Notice may be directed to Robert Acacio, Office of Engineering and Technology, Robert.Acacio@fcc.gov, or Jamile Kadre, Broadband Data Task Force, Jamile.Kadre@fcc.gov.  
–FCC–
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