​​On September 8, 2020, NRECA filed comments with the FCC in response to the Second Report and Order and Third Further Notice of Proposed Rulemaking requesting comment on the establishment of the Digital Opportunity Data Collection and modernizing the FCC Form 477 Data Program.  The proposal seeks to improve the granularity of broadband data collection, implement a data verification system, and establish a challenge process that will allow communities and individuals to challenge incumbent claims of sufficient service where it does not actually exist.