Important Deadline: Corrections to Dec. 2015 Form 477 Data Due by Oct. 7

In a September Public Notice, the FCC’s Wireline Competition Bureau released “weighted average” study area deployment percentages for each rate-of-return carrier. On Friday, the Bureau released a Public Notice revising and updating these percentages. As described below, this data utilizes December 2015 Form 477 broadband deployment data to calculate two reforms for rate-of-return carriers that remain on legacy support: the capital investment allowance (CIA) for 2017 and the five-year buildout obligations.

Any carriers that submitted revised Form 477 data to the FCC since August 29, 2016, must notify Bureau staff in order for the revisions to be included in these calculations. All revisions must be submitted and the FCC staff notified by this Friday, October 7 or the revised data will not be included in the calculations.

Review Form 477 Data to Ensure Accuracy
The weighted average percentages were determined by first identifying those census blocks within each carrier’s study area that have been reported by the 2010 U.S. Census as containing housing units. Those blocks were then compared with December 2015 Form 477 broadband deployment data to determine the census blocks containing housing units where the carrier reports broadband deployment at 10/1 or greater. The number of housing units in those blocks were then totaled and divided by the total number of housing units the Census reports for the entire study area to obtain the weighted average broadband deployment for each rate-of-return carrier.

In its Public Notices, the Bureau explained that the Form 477 data used in the calculations contained revisions made until August 29 and provided for an opportunity for any revisions made prior to Friday, October 7 to be included in the calculations. JSI has been informed that in order for the changes to be included in the CIA and buildout obligations, the FCC staff person listed on the Public Notice must be notified that the revisions have been made. Accordingly, if your company made revisions to its December 2015 Form 477 data after August 29 or makes any revisions before the October 7 deadline, you must notify the Bureau in order for the revisions to be included in the calculations.

In light of the critical use of this data, JSI strongly encourages clients to review their December 2015 broadband deployment data to ensure that it accurately reports broadband deployment as of December 31, 2015. As a reminder, Form 477 instructions require that filers report broadband “availability” for each census block in terms of the “highest advertised speed.” Bureau staff that handle Form 477 data have informed us that in more practical terms, this means the point of sale where the potential customer learns what the true maximum speeds are for his/her location.

If you would like our assistance in revising your Form 477 data, notifying the Bureau of revisions made after August 29, or if you have any questions about Form 477 reporting, please contact a member of our team by clicking the button below.

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