revised fcc form 477 - incompas 477 webinar for comp… · revised fcc form 477 presented by: hal...

Revised FCC Form 477

Presented by:Hal Stringer

Technologies Management, [email protected] Phone: 407-740-3023

TMI - 2600 Maitland Center Parkway, Suite 300, Maitland, FL 32751 www.tminc.comCOMPTEL Webinars powered by PGI

About Technologies Management, Inc.Technologies Management, Inc. (TMI) is a consulting firm specializing in state and federal regulatory compliance obligations for the Telecommunications and competitive Energy industries.

• Our clients range from the smallest entrepreneurs to the largest facilities-based global telecommunications service providers

• We file reports with the FCC and in all jurisdictions for 100 + companies and their affiliates

• Included among our extensive compliance reporting services are our 477 reporting services

• We perform over 2 million census tract lookups for over 50 different telecom/cable companies twice each year


Revised 477 Agenda

• Overview of what’s changed and why• Filer Identification• Local & VoIP Subscription

– Tract Level Details– State Level Summaries

• Fixed Broadband: – Tract Level Subscriptions– Block Level Deployment

• Final Thoughts, Q&A

• Facility-based wireless not covered in this presentation• All filers should be working now to prepare and organize data


Revised 477 - Resources

• Modernizing the FCC Form 477 Data Program– Report and Order Released June 27, 2013

• Changes Coming to the Form 477 Data Collection– Undated PDF

• Data Specification for Form 477 Data Collection– Released August 26, 2013

• Submission Interface Information for Form 477– Released March 27, 2014

• Form 477 Filing Window Public Notice– Released June 11, 2014– Pushes filing window back to July 31 through October 1, 2014


Census Geography Sidebar

• State (2-digit ID)• County (3-digit ID)• Tract (6-digit ID)

– about 74,000 nationwide

• Block (4-digit ID)– Over 11,000,000 nationwide– Appr. 6,200,000 are populated

• Block Group - All blocks in a tract with same first digit


Who & When to File• Five types of entities must file (no change):

– Facilities-Based Providers of Fixed Broadband Connections to End Users (Wired, Wireless, Satellite)

– Providers of Wired or Fixed Wireless Local Exchange Telephone Service– Providers of Interconnected VOIP Service– Facilities-Based Providers of Mobile Broadband Service– Facilities-Based Mobile Telephone Providers

• Normally Due Semi-Annually (no change)– March 1st – report data as of December 31 of prior year– September 1st – report data as of June 30 of current year

• For next filing based on June 30, 2013 data:– Start filing online July 31, 2014– Filings should be complete by Oct. 1, 2014


The Big Changes

• Old Reporting Process– Local Telephone Subscription Form 477, Zip Code List– Broadband Subscription Form 477, Tract Based– Broadband Deployment State/NTIA, Block Based

• New Reporting Process– Local Telephone Subscription Form 477, Tract Based– Broadband Subscription Form 477, Tract Based– Broadband Deployment Form 477, Block Based

• Why?– NTIA’s collection program coming to an end– To improve quality and usefulness of data collected– To reduce the reporting burden for filers


Overview of Changes – Fixed VoiceInformation

CollectedOld Form 477 (State Based)

Revised Form 477

Local Exchange Telephone Subscriptions -Summary

Part II.AFixed Voice Subscription:

a) Local Exchange Voice Grade Equivalent (VGE) and VoIP Subscription counts captured at census tract level. One or more files can be uploaded. Do not have to be state specific.

b) Total VGEs by state to be allocated across certain characteristics. Similar to percentages entered in Part II.A.

c) Total VoIP subscriptions by state to be allocated across certain characteristics. Similar to percentages entered in Part II.B.

Interconnected VOIP Subscriptions – Summary Part II.B

List of Zip Codes for Local and VOIP Services Part V

Filer ID and Contact Info Cover Page for Each State

Filer Identification: Some new fields (e.g., emergency contact). Data entered applies nationwide.


Filer Identification Information

• FRN• Provider Name• Holding Company / Common Control Name• Operations (ILEC or Non-ILEC)• USAC Study Area Codes (if filer is an ETC)• USAC Filer 499 IDs• Provider Website Address• Emergency Operations Contact Information • Data Contact Information• Certifying Official’s Information• Non-Disclosure Request


Voice Telephone Subscription

• Providers or local exchange telephone services and interconnected VoIP services must now report counts by census tract– 11-Digit Census tract ID– Service Indicator (Local or VoIP)– Count of all VGEs or VoIP subscriptions in tract– Number provided under Consumer grade service plans

• Provide state-level subtotals based on various service and provisioning characteristics– Local and VoIP have different characteristics to report


New to Tract-Level Reporting?

• Research your options for census tract lookups

• If address-based tract lookups, use clean service addresses

• Fewer Records > Fewer Lookups > Savings• Build well documented, repeatable queries

and processes


Screen Shot from PRA Filing


Local Exchange Telephone Subscription

• Most characteristics are like those in the current 477

• Bundle Status for VGEs is new – are they bundled with a broadband service that can be used to access the Internet

• This section contains the only reference to wholesale services in the entire Form 477

• What is the best source for these totals

• Make sure queries and processes are well documented and repeatable


Interconnected VoIP Subscription

• Most characteristics like those in the current 477

• Nomadic distinction goes away

• Questions about wholesale services go away

• What is best source for these totals

• Make sure queries and processes are well documented and repeatable


Overview of Changes forFacilities-Based Broadband Providers

Information Collected

Old Form 477 (State Based)

Revised Form 477

Broadband Subscriptions Summary Part I.A

No more summaries or speed tiers. Information can be computed from uploaded tract-level files directly.

Broadband Availability Part I.B(ILEC, Cable, Mobile)

Homes passed percentages no longer needed. New deployment data provides greater detail.

Broadband Subscription -Detail

Part VI(census tract files)

Fixed Broadband Subscription:Data captured at census tract level. One or more files can be uploaded. Do not have to be state specific. Mobile broadband no longer included.

Broadband Deployment –Detail

Currently filed with NTIA/SBBI on voluntary basis

Fixed Broadband DeploymentData captured at census block level. One or more files can be uploaded. Do not have to be state specific. Mobile broadband not included.


Fixed Broadband Subscription

• Information in new upload files includes:– 11-Digit Census Tract ID– Transmission Technology Code– Downstream Bandwidth– Upstream Bandwidth– Count of Connections– Count of Consumer Connections (not percentages)

• Similar to current census tract upload files except:– Mobile broadband not included anymore– Use bandwidth (speed) in Mbps as sold – no tiers– ILEC and cable providers no longer report “0” subscriber

tracts in defined service territories


Fixed Broadband Deployment(currently captured by NTIA)

• Information in new upload files includes:– 15-Digit Census Block ID– Name of Selling Entity (DBA)– Transmission Technology Code– Is Service Available to Mass Market Consumers?

• Max Advertised Up and Downstream Bandwidth– Is Service Available to Business/Government?

• Max Contractual Up and Downstream Bandwidth

• What is Service Availability?– if the provider does, or could provide a broadband

connection, within a typical service interval (7 to 10 business days) without an extraordinary commitment of resources


Fixed Broadband Deployment (cont.)

• Where to start?

• Build a method for updating this data as service foot print or speeds/technologies change

• Comparisons of deployment and subscriber data

• One last NTIA submission due in October

• FCC did not preempt states – some may continue to ask for broadband data under new state-funded programs


Requests for Non-Disclosure• Check boxes found in Filer Identification section

• What’s actually treated as confidential?– Emergency Contact information exempt from routine public

disclosure under FOIA– Subscription data subject to the following:

• Available to state commissions and other federal agencies upon request, if they are able to maintain confidentiality of data received.

• For all other requests, the provider (filer) will be notified and required to make a full showing to the Commission under section 0.459 of its rules

– Majority of deployment data considered public• Check box applies only to mobile deployment spectrum and speed

parameters• For all other deployment data, provider must submit a separate request

for confidentiality along with their Form 477 filing


Final Thoughts...

• Per the FCC’s PRA Filing:– The annual reporting burdens for this collection of

information ... are estimated to be: 2,002 respondents, 387 hours per response, 2 responses per year, for a total annual burden of 1,549,548 hours.

– This is not a trivial exercise!

• Consistency of information is important• New uses for the data by the FCC

• Questions?


Revised FCC Form 477

THE END

Presented by:Hal Stringer

Technologies Management, [email protected] Phone: 407-740-3023


revised fcc form 477 - incompas 477 webinar for comp… · revised fcc form 477 presented by: hal...

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