FCC Revises Certain Form 477 Reporting Requirements and Initiates Digital Opportunity Data Collection (DODC)

The Federal Communications Commission (“FCC” or “Commission”) has adopted a number of changes to the Form 477 data collection, which includes no longer treating as confidential service providers’ minimum advertised or expected speed data for mobile broadband services.

Specific changes beginning with the March 2020 Report (covering data as of December 31, 2019) include:

  • Fixed Broadband Deployment – Fixed broadband providers will no longer report the maximum downstream and upstream contractual or guaranteed data throughput rate for each census block.
  • Mobile Voice and Broadband Deployment – Mobile voice and broadband providers will no longer report on deployment by spectrum band.  The FCC has also eliminated the use of outdated technology codes, but mobile voice and broadband providers will now be required to report deployment using four technology categories:  5GNT (New Radio); LTE (Long Term Evolution) and Voice-over-LTE (VoLTE); CDMA-based (aggregates CDMA and EVDO/EVDO Rev A categories); and GSM-based (combines GSM, WCDMA/UMTS/HSPA and HSPA+ categories).
  • Mobile Broadband Service Availability – Mobile broadband providers will no longer report census-tract level mobile retail availability data.

    Beginning with the September 2020 report (covering data as of June 30, 2020), mobile broadband and voice providers will no longer report subscription at the state level, but instead will be required to submit subscription data at the census-tract level based on the subscriber’s place of primary use for postpaid subscribers and based on the subscriber’s telephone number for prepaid and resold subscribers. The FCC is currently seeking further comment on how to apply place of primary use to prepaid and resold subscribers.

    Additionally, the FCC will gather geospatial broadband service availability data with its recently-adopted Digital Opportunity Data Collection and mapping. Specifically, the FCC will require all broadband providers to submit granular maps where they have broadband capable networks and where they make service available.   The new fixed broadband reporting requirements will become effective after the FCC releases an order designating specification for coverage polygons (coverage areas captured in GIS-compatible formats, similar to shapefiles) and after the Office of Economics and Analytics issues a Public Notice announcing the availability of new collection platform to be developed by USAC and reporting deadlines. That has not yet occurred.