How to Report 477 Data to the FCC – CNS | Cooperative Network Services

How to Report 477 Data to the FCC

A lot of telecom companies, ISPs especially, struggle with accurately reporting the census blocks they serve with broadband Internet service to the FCC. It’s not always easy to pull the necessary data (served census blocks), especially for smaller providers that already have a lot on their plates. Of course, that’s no excuse, as the filing of 477 Broadband Deployment data is a requirement imposed by the FCC and should be performed twice a year.

 

What is 477 Data Used For?

FCC Form 477 collects information about internet connections from the provider to the end-users’ locations. Using this information, the FCC can better understand how broadband is being deployed across the country and what kind of competition exists in certain areas. 477 data also drives rural broadband funding programs for high-cost areas, like the Rural Digital Opportunity Fund (RDOF), which is intended to help bring broadband to more rural census blocks that currently have low-speed, or no access to the internet. The RDOF auctions use census block groups as the minimum bidding size, but the actual counts and locations are derived by the individual unserved/underserved census blocks within the block groups.

Unfortunately, there are several ways the 477 data can be incorrect, meaning information used to determine the rules and processes for funding mechanisms like the RDOF auctions, as well as other vital deployment  and broadband adoption programs, is missing (or has incomplete) or inaccurate.

 

Challenges with 477 Data

477 data is far from perfect. In fact, there are several problems with this reporting method.

1. Self-Reporting

There is no set-and-established method of reporting. Because providers are required to self-report, they might do so erroneously, based on outdated data, poor database management, or lack of time and resources to pull the necessary information. In fact, some providers might even skip reporting altogether, leaving a void in the information the FCC has available to examine programs such as the RDOF auctions.

2. Overstated Availability

The boundaries of census blocks and telecom study areas usually don’t match. This leads to an overstatement of the availability of service providers within census blocks. If a provider “can” serve at least one location in a census block within 10 days, the entire block is considered served at the highest advertised speed.

3. Semantics of Reasonableness

Reporting of FCC Form 477 requires that providers indicate that they can serve an area within a reasonable time, not that they actually do provide that service.

4. Advertised Speeds vs. Actual Speeds

All broadband providers must file Form 477 to report where they offer internet access at speeds exceeding 200 kbps in at least one direction. But here’s the thing, just because they advertise those speeds, it doesn’t mean they’re actually providing them to any of their customers; there is quite a difference between advertised speeds and actual speeds.

5. Inaccurate Reporting

Many providers have proven that their data is inaccurately reported, often missing blocks where they do serve.

 

What Does All This Mean?

Since many providers have incorrectly reported 477 data, FCC coverage maps are incorrect. Moreover, providers may be knowingly reporting incorrect data to the FCC, which has untold consequences. One thing we know for sure is that inaccurate reporting impacted eligible RDOF areas if providers did not report all served blocks.

Which Data Does an ISP Report on FCC Form 477?

Data to report includes:

  • Carrier Name
  • Deployment Date
  • FCC Technology codes used in fixed broadband deployment
Code Technology of Transmission
10 Asymmetric xDSL
11 ADSL2, ADSL2+
12 VDSL
20 Symmetric xDSL*
30 Other Copper Wireline (all copper-wire based technologies other than xDSL; Ethernet over copper and T-1 are examples)
40 Cable Modem other than DOCSIS 1, 1.1, 2.0, 3.0, or 3.1
41 Cable Modem – DOCSIS 1, 1.1 or 2.0
42 Cable Modem – DOCSIS 3.0
43 Cable Modem – DOCSIS 3.1
50 Optical Carrier / Fiber to the end user (Fiber to the home or business end user, does not include “fiber to the curb”)
60 Satellite
70 Terrestrial Fixed Wireless
90 Electric Power Line
0 All Other
  • Max advertised upload and download speeds
  • Here’s a quick look at one provider’s 477 data:

 

How CNS Can Help with Your Form 477 Reporting

If you have not visually verified all of the census blocks in your 477 list, you simply cannot be sure the data is accurate.

The CNS Broadband Operations map can be used to identify and verify the accuracy of your reported blocks, create a new list of all served blocks, assist with challenging census blocks for programs like the RDOF auction, and prepare for the following reporting period.

Looking for an easy button? With the help of our GIS team, we can dive into the task of your 477 cleanup, ensuring you report the most accurate and up-to-date information possible. Get in touch with us to learn more!