FCC Updates FCC Form 477 Reporting Requirements

On June 27, 2013, the Federal Communications FCC (“FCC”) issued an Order, in which it modernizes the FCC Form 477 data collection program.  The changes to the program involve data collection using census tract and removal of certain reporting requirements that will be initiated with the September 1, 2014 filing, which covers January 1, 2014 – June 30, 2014.

The FCC states that the main goal in initiating these rules is to improve the quality of the data collected in the Form 477 to populate the National Broadband Map and aide in policy making.  The modified collection program will streamline the process for providers by eliminating certain data collections, but does involve collection methods which may be new to certain clients. Notably changes to the FCC Form 477 data collection process follow.

Fixed broadband deployment data will now be collected by census block, while facilities-based providers of mobile broadband and mobile voice services will provide data showing their network coverage areas using a standard geographic information system software.

Providers of broadband services will not be required to submit broadband deployment data in predetermined speed tiers. Instead providers simply provide advertised speeds—the maximum advertised speed in each census block for fixed broadband, and the minimum advertised speed in each coverage area for mobile broadband.

Fixed voice and interconnected VoIP (“iVoIP”) providers will be required to file total and residential subscription data by census tract, rather than the previous process of requiring such providers to submit the list of ZIP codes in which they provide service to end users.

The nomadic category has been eliminated from the form, meaning that filers are no longer required to report the percentage of VoIP subscriptions with nomadic functionality.   But all “over-the-top” interconnected VoIP service providers must still file the form.

The FCC has also removed the wholesale reporting requirement. Specifically, iVoIP providers will no longer be required to report the number of companies purchasing their VoIP components or services for resale.

To enhance the FCC’s ability to meet public safety needs and obligations, the form will collect emergency contact information from providers.

Finally, the scope of providers that must file broadband and voice subscription data did not change with the June 27th Order.  Only facilities-based providers of fixed broadband service and facilities-based providers of mobile broadband and mobile voice services will be required to file deployment data with the FCC on the Form.  Mobile MVNOs and resellers should not file deployment or subscription data on the Form.

CLIENT ACTION ITEMS:

Managed Compliance Services Subscribers:  Clients who file Form 477 through The Commpliance Group may contact us to determine how to associate subscriber addresses with census tracts and other data collection inquiries.

Non-Subscribers:  Clients not currently subscribed to our Managed Compliance Service through The Commpliance Group, but who require assistance in evaluating Form 477 obligations may contact Christopher Canter, at cac@commpliancegroup.com, to make appropriate arrangements.

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