What has changed in the Form 477 process or timing?
The FCC’s Form 477 is designed to gather location-specific information about the availability of broadband access across the United States. The same report is also used to track the geographic penetration of competitive options for local services, including traditional landline voice services, VoIP and wireless. This data is gathered from all providers of these services twice a year.
The data gathered is used to populate a broadband availability map and to determine where pockets of underserved locations exist for which federal subsidies are available through the Connect America Fund. In response to concerns that the data is inaccurate and collection is overly burdensome, the FCC opened a docket in August 2017 to gather input for changing the frequency and complexity of the data gathering effort.
The FCC investigation sought input on:
Changing the filing frequency from semi-annual to annual
Refining the definition of broadband “availability” (aka deployment) by adding subcategories of service to include indicate where customers can be upgraded or new customers accommodated.
Increasing granularity of reported data by requiring submissions to include all service addresses, geospatial coordinates, or some other sub-block level information and typical service interval information.
Improving mobile and satellite subscriber information by gathering data at the Census tract rather than by state level.
Making certain currently confidential information publicly available.
Making Form 477 Data available to the public through a searchable map.
I
t may come as no surprise to FCC watchers that there have been no decisions resulting from this investigation to date. Given that the next Form 477 report is due March 1, 2019 any decision at this point will not impact the up-coming report. There is a possibility that a decision could be issued that would impact the September report, but that is still unlikely.
Please refer to our earlier blogs for more details about the 477 report. Some key points covered in those blogs include:
The Most Frequently Asked Questions About Form 477 Reporting 2017
See the answers to frequently asked questions and more.
- Are small companies exempt from this requirement?
- What are penalties for failing to file a 477 Report?
- If we sell high capacity data services (such as Ethernet or T1 service) and customers connect our transmission services through their own systems to an Internet Service Provider, do we report those connections?
- How are errors detected?
What you may not know is how important the data gathered in the Form 477 has become. For example:
- The FCC will not accept applications to obtain numbers directly from Numbering Administrators unless an interconnected VOIP provider is current on its FCC Form 499 and Form 477 filings.
- The FCC has made it easier for states to access Form 477 subscriber data via an updated data-sharing agreement. Be advised that a request for confidential treatment during a Form 477 electronic filing does not prevent data from being shared with individual states.
More Reasons Why Your FCC Form 477 Filings Are So Important 2016
On March 30, 2016, the FCC released an order regarding Reform of the FCC’s high cost support funding for rate-of-return (ROR) carriers. One of the FCC’s goals is to provide increased funding for deployment of 10/1 Mbps or greater broadband services in areas served by ROR carriers.
- For competitive providers – under-reporting blocks served or maximum advertised speeds can result in support being given to a ROR carrier in the same service area.
- For ROR ILECs – over reporting of blocks served or maximum advertised speeds can result in support being lost or a lower support amount offered under both model based and legacy support mechanisms.
Mining Gold from your FCC Form 477 2015
Once that data has been gathered and filed, it can easily be repurposed – put to good use by other departments. Here are just a few ideas on how Form 477 data can be utilized:
- Sales and Network Planning – Overlay your company's service areas or customer base with ILEC territories. This might provide insights into which ILEC territories are best for sales efforts or sales implementation. Seeing your data on a map makes it easy to pinpoint geographic areas for future expansion.
- Customer Loss Reports – provide a list of terminated accounts twice a year. A review of the services and locations for these customers might indicate service deficiencies or win-back strategies that could reduce disconnects.
- Incorporating Demographic or Economic Data into Forecasts and Plans – Filers of Form 477 reports map customer locations and service areas to census tracts and blocks. The resulting outputs can then be merged with detailed demographic or economic data collected by the US Census Bureau or other government agencies or private organizations. For example, residential service providers could look for future service areas that mirror the demographics or economic mix of its existing customer base.
Time to Prepare for FCC Form 477 – Again 2015
As a reminder, if you provide one or more of the following services must file the Form 477:
- Facilities-Based Broadband
- Local Exchange Telephone Service
- Interconnected Voice over Internet Protocol (VoIP) Service
- Facilities-Based Mobile Telephony Services
Received any Inquiries from FCC Auditors Re: FCC Form 477 filing? 2015
- The FCC compares responses year over year which triggers questions
- The FCC notes items that are unusual and may indicate a misinterpretation of their rules.
- The base fine for failure to file is $3,000 per violation or per day of a continuing violation.
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