In our Feb. 4 e-lert, we informed clients that JSI will conduct a webinar on Tuesday, Feb. 17, 2:00 p.m. - 4:00 p.m. (EST) on the FCC's new FCC's Form 477, "Local Competition and Broadband Reporting."  With today's e-lert, we note that Tuesday's webinar will include our review of the new online filing format and enable clients to express some of their concerns to the FCC's Wireline Competition Bureau staff. 
 
In working with the rural telecom associations and other firms trying to secure a 120-day delay in the filing deadline, JSI participated earlier this week in an ex parte conference call with Wireline Bureau staff.  During the meeting, the staff requested specific information regarding obstacles that rural carriers face in meeting the deadline.  When JSI described several issues clients must overcome in obtaining the data in the manner required by the revised online form, the Bureau staff replied that they would take these concerns "under consideration."  Then, the staff members expressed their interest in hearing more from the rural companies participating on the webinar, after which JSI extended an invitation for any interested Bureau staff to sit in on the session.  The Bureau staff accepted the invitation and plan to sit in on Tuesday afternoon.
 
JSI makes it clear that during the conference call this week, the Wireline Bureau staff indicated that there would be no 120-day delay in the filing deadline nor would there be an opportunity to comply with the March 2 filing using the old version of Form 477.  These confirmations were also confirmed by the FCC's public notice released late last night in which the Bureau reiterated the filing will be due on March 2, although the online system is still not available.  The notice also provides links to the "screen shots" of the pages of the electronic form and an "FAQ." 
 
JSI believes that if any delay is allowed, it will be for a shorter period of time and will not be announced until closer to the actual deadline.  Thus, the information that companies participating on our webinar can provide regarding the obstacles they face in completing the revised form could well influence FCC staff as they evaluate whether a delay should be granted and if so, how much extended time should be given.  
 
In the event that no delay is granted, JSI believes the FCC's public notice provides an opportunity to seek extensions through waivers that specify a timeframe in which Form 477 will be completed.  In a footnote in the notice, the FCC acknowledged that in approving the revised form, the Office of Management and Budget stated, "due to significant changes and increased burden from the proposed revisions, the Commission should be flexible with and assist respondents who may have difficulty in submitting information in the new format." (emphasis added)  Accordingly, the webinar discussion will include steps that companies can take, including filing waiver requests, in the event the FCC does not delay the deadline.  
Clients that would like to participate in the webinar or have questions regarding the revised FCC Form 477 should contact Kim Waldvogel (kwaldvogel@jsitel.com) in JSI's Maryland office, at 301-459-7590.