Each year TMI geocodes millions of address records for over 100 telecommunications and cable companies for FCC reporting. The results are used to create files organized by US Census tract and block that are uploaded into the FCC 477 database. The FCC 477 database is used to determine the strength and locations of voice and broadband competition. In recent years, it has been used as a substitute for a nationwide broadband deployment map for the purposes of identifying under-served locations for which supplemental government funding may be made available.
Data is gathered twice annually – by March 1st for data as of December the prior year and again by September 1st for data as of June the same year. The FCC is investigating whether to revise the frequency of these filings. The pending inquiry will also consider whether the data should be provided at a more granular level and what data should be made public instead of being treated as confidential. Comments on the new inquiry will be due later this quarter. In the meantime, the upcoming filing that is due by September 1st is not affected by this inquiry.
Below are the answers to the most common questions we receive about 477 filings.
Q. Who must file 477 Reports?
A. All voice service providers (including VoIP providers and resellers) and all facilities-based providers of broadband Internet access service who provide broadband connection to business, governmental or residential end users. This includes WISPs and rural entities.
Q. Are small companies exempt from this requirement?
A. There is no exemption for small companies.
Q. Do we refile each spring and fall even if we have no changes?
A. Yes, the report is resubmitted in full twice a year.
Q. What are penalties for failing to file a 477 Report?
A. Any penalties would be based on the circumstances. A minimum penalty for failure to file based on precedent is $3,000. Repeated failure to file would result in higher forfeitures. The FCC could impose forfeitures of up to $160,000 per violation or each day of a continuing violation, up to a maximum of $1,575,000. Failure to file could also prevent the provider from bidding on Connect America Funding. Conversely, providers may be offered subsidies in areas you serve if you have not been filing data.
Q. Do only facilities-based providers file a 477 Report?
A. No. For broadband connections and mobile services, only facilities-based providers must file. However, ALL companies that provide interconnected local voice (or VoIP) service to end users must file, including resellers.
Q. What is a broadband connection?
A. For the purposes of the FCC 477 report, a broadband connection is a connection to an end-user location that enables the end user to send or receive data from the Internet at speeds greater than 200 kbps. The actual Internet access service that is provided over that connection may or may not be sold to the end user by the facilities-based provider that is obligated to report.
Q. If we sell high capacity data services (such as Ethernet or T1 service) and customers connect our transmission services through their own systems to an Internet Service Provider, do we report those connections?
A. No, if you are not providing the ability to connect to the ISP, it is not by definition a broadband connection and is not included in the reporting obligation. On the other hand, if you provide the connection to the ISP, who in turn bills the customer directly, you are providing a broadband connection that should be reported.
Q. Are all VoIP services included?
A. Only VoIP services that are interconnected to the public switched network are included. This includes most VoIP offerings, including SIP trunking and hosted PBX service.
Q. Can the 477 report be submitted in a paper filing?
A. No, the 477 report is actually an electronic filing and must be filed directly into an online system using Census tract and block information.
Q. Can we send in addresses and have the FCC determine the Census tract and block?
A. No, that is not an option.
Q. How can we find the Census tract and block for a particular street address?
A. The process is a version of geocoding. You can obtain individual locations using GPS. You can look up individual addresses manually on a map or send them to a service to convert from street address (or latitude/longitude coordinates) to Census block codes, sometimes referred to as GeoIDs. Multiple street addresses may share one Block or GeoID. Geocoding small or large quantities of addresses is included in the 477 services offered by TMI and some other filers.
Q. What if our best source of data is a fiber or cable route map?
A. It is possible to use maps of facilities or service locations to create deployment files by Census tract and block, but it does not help with subscription files, which is where you have an actual working account. Map shape files can also be used to supplement subscription address data to create a more complete picture of where service is available.
Q. What exactly does a GeoID mean?
A. The GeoID for a location is a 15 digit code that identifies the state, county, census tract, census block group, and block of a particular location. The tracts and blocks in a GeoID are defined areas that vary in size and may be visualized on a map as a two dimensional shape. Nationwide, there are approximately 74,000 Census tracts and over 11,000,000 blocks.
Q. What methods are available for Geocoding?
A. The three main methods are 1) finding each location in the field using GPS; 2) using web-based maps to look up each location; 3) automated address geocoding. Only an automated system can quickly match large quantities of addresses.
Q. What degree of accuracy is required for this report?
A. There are many reasons to try to be accurate as possible, but perfection is elusive. Based on geocoding methodology, the quantity and quality of the addresses used for input, and the up-to-date status of the Census information used, the tract and block matching can vary in reliability. You may find that you must rely on imperfect matches that are determined to be relatively close. Visualizing the results on a map after geocoding can be helpful for finding misidentified locations.
Q. How are errors detected?
A. Certain input and format errors cannot be entered into the FCC’s system. An error message is generated by the system. Successfully submitted reports are spot checked by FCC staff later and they may ask questions if the data is inconsistent. They may question, for example, a large change in subscriber counts in states or tracts. Or a deployment file that does not include blocks in the same Census tracts that were included in the subscription file part of the filing.
Q. Can a filing be revised?
A. You can revise your data at any time.
Q. Is 477 data treated as confidential?
A. At this point you can request confidential treatment only for subscription data. State agencies can obtain access to the confidential data, and aggregated subscription data for multiple entities is made available to the public by the FCC. Service provider availability data in the deployment file is publicly available at the block level. Changes to confidentiality is proposed as an issue in the new FCC 477 rulemaking proceeding.
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