Form 477 Expansion Plan

FCC expands data collection program for broadband/voice service providers; someday the FCC will also want to know what planet you’re from.

FCC <3 DATA. (Translation from the ’net-speak: The FCC loves DATA.) In particular, the kind of data that broadband and voice service providers are required to report and that, presumably, assist the FCC in making informed policy decisions.

So we probably shouldn’t be surprised that the Commission has decided to collect even more of it through a modified “Form 477 Data Program” as broadband and voice services continue to evolve (but not quite to this level . . .yet).

FCC Form 477 has been around since the turn of the century. Many providers of broadband, local and mobile phone, and interconnected VoIP services are already familiar with it, since they’ve had to file it twice a year for some time now. But get ready, the FCC has now made several changes to the types of data it will be collecting.

The changes are part of an overall Commission effort to comply with requirements of the Broadband Data Improvement Act and the FCC’s own recommendations in the National Broadband Plan.  Also spurring the changes: next year the Commission will be assuming responsibility for collection of broadband deployment data under the State Broadband Initiative program.  Historically, the National Telecommunications and Information Administration has taken care of that chore, but that’s set to end in the fall of 2014.

So, starting most likely in 2014, through its modified Form 477 program the FCC will be collecting even more data about:

  • “deployment” (i.e., where a service is available, as well as the speed of and technology used for the service);
  • “subscriptions” (i.e., how many consumers are signed up for the service);
  • and other provider-specific information.

The data collection specifics vary greatly by service and provider type, but here are a few highlights from the Report and Order.

  • Fixed broadband data will be reported on a “census block” basis.
  • Mobile providers (voice and broadband) will generally report by network coverage areas.
  • Broadband providers will report maximum advertised connection speeds for fixed services and minimum advertised connection speeds for mobile services.
  • Zip-code reporting for voice (fixed and interconnected VoIP) subscriptions will be replaced by more detailed reporting of data on a “census tract” basis.
  • Filers will be required to submit additional company information, including Filer 499 ID numbers and emergency contact details.

While there are many changes to the particular data being collected, the Commission (thankfully?) didn’t extend the Form 477 reporting obligations to any additional categories of service providers. The reporting obligations will continue to apply to “facilities-based” providers of broadband services to end user locations (including by cable, copper, wireless, mobile or satellite), local telephone services, and facilities-based mobile telephony services. The reporting requirements will also continue to apply to all providers of interconnected VoIP services. More detailed descriptions of the types of covered providers can be found in the current Form 477 instructions.

Another piece of (semi) good news is that the Commission has directed the Wireline Competition Bureau to explore ways to make the Form 477 reporting process easier for all filers. In so doing the FCC specifically suggests the development and testing of a “client-side” software application which can be provided to filers to assist in complying with the data reporting requirements. If the deployment is successful, this would be, to our knowledge, the first piece of client-side software issued by the FCC. What’s next, a mobile app for paying FCC regulatory fees?

As we’ve mentioned regularly in the past, new “information collections” are subject to the Paperwork Reduction Act review process, which can normally take several months (of paperwork, we assume). Those PRA review folks will certainly have their hands full with all the new information collection requirements in this item. We’re not in any rush, though, and will patiently await publication of the effectiveness of the new rules in the Federal Register. As usual, check back here (not too soon, in this case) for updates.

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