By now, everyone should be familiar with the FCC’s Form 477 Report.  Of course it’s more than a “report”, consisting of text files showing a providers voice and broadband subscription counts by census tract and broadband deployment by block.  The Form 477 is due twice each year on March 1 and September 1.

What you may not know is how important the data gathered in the Form 477 has become.  For example: 

• Voice and broadband providers cannot participate in the upcoming CAF II Competitive Auction unless they have filed Form 477 reports for the last two years.
• Small providers of voice and broadband internet access service are given an additional year to comply with the FCC’s new Broadband Privacy Rules.  A small provider is defined as one that has fewer than 100,000 voice or broadband subscriber lines as reported on the most recent Form 477.
• 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.

And 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.

We don’t know which states have requested access to Form 477 data or what it might be used for.  But we do know that several states now ask for the same or similar data under their own authority.  For instance:

• New Jersey requires each provider to submit copies of NJ-specific Form 477 extracts for voice subscription twice a year.
• In August 2016, the Maryland PSC requested voice subscriber counts and copies of Form 477 data in Case No. 9414, “In the Matter of Tariffing Requirements for Competitive Local Exchange Telephone Companies with 20,000 or Fewer Subscribers.”
• California recently adopted a rule that requires all certificated or registered providers to “submit annually to the Communications Division by April 1st, voice and broadband subscriber and deployment data at a census block level as of the prior calendar year’s end in a form designated by Communications Division Staff. “  Note that this request appears to be more granular than the FCC Form 477 which requires subscription data at the larger tract level. 
• The Washington State UTC requires carriers to provide the total number of voice grade equivalent lines as filed in the carrier’s FCC Form 477 and how many of those lines had access to 911.  This question is showing up on more state annual reports each year.  The question also hints at possible uses of Form 477 voice data during 911 audits or other fees based on line counts.  Be sure your Form 477 state totals match those used in state specific reports for other agencies.

TMI, a provider of Form 477 *support services for 7 years, has performed census tract and block lookups for over 39 Million client address records and prepared approximately 950 separate FCC Form 477 Filings.  We understand that making sure your company files its FCC Form 477 accurately and on time grows more important every day.

*support services include:  geocoding, census tract and block lookup, text file preparation, and online submission services

We can assist with custom broadband deployment maps and files for all types of fixed carriers.