The current FCC 477 filing requirement has been a big undertaking for many carriers and, as a result of new FCC requirements, is about to get BIGGER. It is unique in that it requires broadband reporting by US Census tract. It also requires reporting by VoIP providers.
The new 477 requirements that will be implemented in 2014 further expand the scope and complexity of these reports. One of the big changes that will impact the processing of 477 data is the requirement to provide subscriber data for voice services by census tract rather than just listing zip codes. Since the number of phone subscriber records is likely to be much greater than the number of broadband subscriber locations, it will increase the census tract lookup processing time and effort.
There will also be a new requirement to file broadband deployment data by census block (not to be confused with continuing to file subscriber data by census tract as we currently do). Some carriers have been doing so voluntarily on a state by state basis through the NTIA National Broadband Map initiative. Filing deployment data will become mandatory for all facilities-based providers on a nationwide basis. When TMI handles the NTIA requests, we end up with different methodologies for each company to make it as accurate as possible given the data each company has to work with. This makes us think that for many carriers the census block level requirement will be completely new and challenging.
A third challenge will be the new requirement to report broadband data based on maximum advertised speeds v. the speed tiers currently reported. The new 477 will also require reporting the number of access lines bundled with broadband services. For both of these requirements, the new data specifications will necessitate changes to the input and processing of the data that needs to be addressed well in advance of the September 2014 due date of the new 477.
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