I am submitting these comments as an individual with experience with broadband since 1999. I have written a book on DSL and am wrapping up a book on 5G. I have written over 2,000 news reports on telecom, including hundreds on wireless. At the invitation of the FCC OET, I presented at two workshops for the Broadband Plan. My work has been cited by The New York Times, The Washington Post, The Wall Street Journal, and many other publications. Yadda, yadda, yadda. 

I decided to submit because AT&T lied in its comment https://ecfsapi.fcc.gov/file/1007604908368/ATT%20DODC%20Reply.pdf 

"THERE IS BROAD AGREEMENT THAT IT IS NOT YET TIME TO REQUIRE REPORTING ON 5G COVERAGE As AT&T observed in its comments, it would be premature for the Commission to require wireless providers to submit coverage maps for 5G service at this time.17 There is universal support in the comments for this position."

 I did not find any support for this position in the first four comments from those primarily concerned with the public interest, something that would be obvious to AT&T's distinguished if they had bothered to read the filings. They did not address the issue of 5G coverage reporting at all, much less supported the AT&T position.   

In addition, this is total b______ 

"AT&T pointed out, requiring 5G coverage maps in this early stage of 5G deployment could reveal sensitive information about cell site locations."

AT&T's competitors can easily find out the locations of cell sites through several commercial services or by drive tests in the few areas not commercially surveyed. The AT&T lawyers certainly know this and are insulting the commission by making this obviously ridiculous claim. T-Mobile provides public maps of where it has 5G. In France and England, it is standard practice for all carriers to report their tower locations. 

In addition, it is absurd to think that information should be hidden from the FCC because it might reveal

"customer locations, in cases where 5G is being deployed in high-band spectrum for specific enterprise customers." 

Fewer than 1 in 1,000 customers in Korea, the world leader in 5G, fit the description of "high-band spectrum for specific enterprise customers." I strongly doubt the figure will be higher in the US, but cannot be definitive because AT&T and peers hide even basic deployment and subscriber information.

Only a limited number of very large enterprise customers will buy dedicated 5G networks. Competitors almost surely will be aware of such large prospective customers and can confirm with drive tests.

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I would like to confirm the CPUC contention that propagation maps are highly inaccurate. Only actual drive tests can be considered accurate. I consulted on a wireless deployment across most of Vermont, including working with the network designers and propagation maps from one of the world's largest vendors of 5G radios. Everyone knew the tools were very limited. When the network was actually built, the reality was far short of the claims of the model.

AT&T itself does not rely on propagation maps but rather spends millions on field tests. If it didn't do that, it would not have good information on coverage.

It is highly likely that AT&T knows its own network coverage.