Industry Asks FCC to Ease Form 477 Broadband and Voice Data Duties, Wary of Granularity
Industry generally urged the FCC to streamline Form 477 data reporting duties for broadband and voice providers and be cautious about adding new requirements, particularly if costly. Many backed moving from twice-a-year to annual filings and resisted collection of more granular data, while a few took contrary views. Comments were posted Tuesday and Wednesday in docket 11-10 on a Further NPRM seeking to make industry data, which is used for USF, more useful while scrapping unnecessary burdens (see 1708030026).
Sign up for a free preview to unlock the rest of this article
Communications Daily is required reading for senior executives at top telecom corporations, law firms, lobbying organizations, associations and government agencies (including the FCC). Join them today!
CTIA backed collecting data on an annual basis, eliminating reporting by spectrum band and, if that's done, simplifying reportable technology tiers to 3G/4G and 4G LTE, with voluntary 5G submissions. "Most importantly," the FCC "must continue to provide filers with flexibility to determine how to categorize" their technologies, said the wireless group. The Rural Wireless Association said data "should yield standardized and easily comparable information." CTIA, the Competitive Carriers Association (here) and T-Mobile (here) urged the FCC to complete and digest a one-time Mobility Fund II data collection before adopting Form 477 changes. T-Mobile and RWA supported annual data collection.
Verizon said the FCC "substantially expanded" the form's data obligations since 2000. The agency should "consider the extent to which it is seeking duplicative or uninformative data as well as the burdens the data collection imposes," the telco said. AT&T said collecting more granular data is desirable, "but not when it results in a significant increase" in costs or "when the increased granularity sacrifices the confidentiality of competitive sensitive data." AT&T backed FCC proposals to modify mobile broadband deployment collection but opposed other changes to mobile subscription and fixed broadband deployment collection.
NCTA said the FCC should avoid collecting data "so detailed that it is expensive for providers to produce, difficult for the Commission to process, or unhelpful to the public." Providers shouldn't be required to report broadband deployment data below the census block level or report Wi-Fi access points, said the cable group, which backed annual reporting. Comcast opposed various possible reporting requirements, including of deployment data for Wi-Fi, a "portable" service, as a proxy for mobile broadband deployment. The American Cable Association voiced much concern about proposals for more granular broadband data, which it called costly for small providers.
The FCC shouldn't require broadband deployment data below the census block level, and should eliminate "the separate reporting of available contractual or guaranteed throughput rates" for business data services (BDS), said USTelecom, which backed annual data collection. But Incompas said, "Form 477 should collect the number of facilities-based connections for BDS services that each provider has by census block by guaranteed data throughput rate." Windstream urged the FCC to keep and expand the BDS data requirements.
New America's Open Technology Institute called the form "a valuable tool long overdue for modernization." Recommendations include that the "commission (1) collect data at a more granular geographic scale; (2) collect broadband pricing data; (3) continue collection by spectrum band and semi-annually." Some others also supported more granular data reporting and opposed annual data collection.
ITTA and WTA opposed more granular reporting and backed annual filings (here, here). The Small Company Coalition said annual collection was particularly important for its carriers. NTCA proposed eliminating and amending some Form 477 requirements, and using "geocoding for reporting new installations and upgrades." The Wireless ISP Association said the FCC "must take into account the inherent differences in deployment and technology between wired broadband services and fixed wireless broadband services." Sacred Wind Communications said some proposals "would pose significant complications for tribal areas."
Hughes Network Systems and ViaSat supported annual data collection. The FCC should adopt the Measuring Broadband America Report's four census regions to create reporting blocks that accurately capture the ubiquity of satellite broadband while providing some granularity, said Hughes. ViaSat proposed changes to Form 477, which imposes "a substantial burden" because the company must report far more census block-level data than others.