FCC Seeks Comments for 477 Broadband Data Collection

The FCC has released a NPRM to revise it’s current Form 477 that collects voice and broadband data. The comment period ends on September 25, 2017.

The Commission in its NPRM for Form 477 asks if there are other external uses of data for the Commission to account for and if the data is designed well for the Commission and stakeholder use.  That data should be improved further to better understand broadband services to the user.  It also evaluates the current uselessness of the language and action within the form to have the industry and the public comment. Currently, adoption and deployment data are collected, but through this reevaluation, comment and possible change of process, further actions may be done to deepen the data set.

Some questions, comments and suggestions given by the FCC on the NPRM are listed below. These listed are just a few of the proposals given to the 477 Form:

• 3) Are there other external uses of the data for which the Commission should account if the Commission makes changes to the collection?
• 4-6) Seek input on properties on characteristics or properties of next generation mobile technologies may require modification.  Providers, not the Commission, decide the speeds of service they offer and my chose among different reasonable bases for their filings.
• 7) Is there a way by which the Commission can improve its current data collection to better understand and evaluate the actual consumer experience?
• 8) Should the Commission require filers to use predictive propagation models to prepare their Form deploying filings?  If so, the Commission seeks comment on the extent to which it should take additional steps to specify possible eligible models for this purpose, and to standardize to some extent the output of those models as well as certain input parameters.
• 9) What parameters would the Commission need to standardize to allow for meaningful comparison among providers’ LTE data submission? To what extent should the providers be free to determine their speeds?
• 10) Should there be a required actual speed test data up to a certain geographic level to be more accurately reflect consumer experience?
• 11) Should the Commission require separate reporting of 5G mobile broadband deployment?
• 12) Would it be appropriate to make additional modifications to Form 477 to include satellite broadband data in the mobile broadband data collection, and, if so, how?
• 14) Should providers be required to submit shapefiles depicting their broadband network coverage areas for each transmission technology deployed in each frequency band?
• 15) Should the Commission consider adopting an alternative process under which provider might provide list of bands and the associated amount of spectrum use to provision various mobile technologies by some geography such as the CMA?
• 16)  Should the Commission eliminate or modify the requirement that mobile broadband providers report coverage information for each technology deployed in their network?  Should the commission simplify the filing process by requiring coverage be provided for four areas of technology – 3G, 4G non-LTE/LTE, and 5G – and are the distinctions of these categories clear enough?
• 18) What should the local retail presence information reflect?  The Commission proposes to eliminate the requirement to submit mobile broadband service availability data, as it not producing accurate information about where services are affirmatively available to American consumers.
• 19) Should filers be required to to submit the voice coverage boundaries “where providers expect to be able to make, maintain, and receive voice calls?”
• 22) Should the Commission continue to collect separate voice deployment data for VoLTE and mobile switched voice?
• 23) The data is not sufficiently granular for meaningful evaluation of mobile service subscribership as noted.  Subscription data at a more disaggregated geographic level would improve the Commission’s ability to provide more accurate mobile competition analysis, particular in the secondary market transactions.
• 24-25) Are subscribers’ billing addresses sufficiently correlated with the areas in which subscribers use their mobile devices to be meaningful in analysis.
• 26-27) Should the Commission eliminate the separate reporting of available contractual or guaranteed data throughput rates for business/enterprise/governmental services, while maintaining separate indicators for mass market/consumer service and/or business/enterprise/government deployment.
• 28-29)  To lessen the burden on filers would information about business/enterprise/government services still be valuable in the absence of speed data, or would it be better to remove the requirement to report these data altogether?
• 30) Should the Commission require fixed broadband providers to indicate whether total customers served on a particular technology could be increased in each census block if they they report deployment data?
• 31) Are there specific costs for fixed broadband providers to report such data, and how to ensure that reporting the data would be as minimally burdensome on filers as possible?
• 32-35) Should giving fixed-broadband providers be give the option to report their deployment data by filing geospatial data showing coverage areas?  Should the Commission assume that all homes within a block have service even if only a fraction of a blocks’ area has service?
• 36) Should it be required for providers to geocode all addresses at which service is available.  The Commission seeks comment on the costs and benefits associated with this approach, and on ways that the Commission could ease the burden on filers?
• 37-38) The Commission notes that NTIA collected sub-block level data for blocks larger than two square miles for the National Broadband Map, but also that such data did not provide an indication of where homes lacked broadband availability.
• 39) Should the Commission collect geocoded deployment data for blocks that are less-than-fully covered from each provider?
• 40) Do filers maintain the data needed to comply with the reporting requirements and, if not, what costs will be associated with obtaining them, both at the outset and on an ongoing basis?
• 41-42) Will removing the option of filing abbreviated fixed broadband deployment data improve accuracy of the data?
• 45-45) Should satellite have more coverage , in particular, more difficult for providers to characterize at the census block level.
• 47) The Commission proposes that certain collected data that are currently treated as confidential be made public and should not be treated as confidential.
• 48) Commission proposes that, if detailed propagation model parameters are submitted in the Form 477 filings, some of these parameters should be treated as public information, as the Commission believes that such parameters are to competitively sensitive.
• 49) The Commission seeks comment on whether disclosure of this information would be beneficial and, if so, whether any measures are necessary to ensure that the interests of the filers are protected.

The Commission also would like comments on whether collecting a twelve-month cycle of data would render the data less useful for it’s purposes since the rate of deployment and uptake are at higher speeds in the industry.  The NPRM suggests a searchable national map of the most recently available Form 477 broadband deployment data which can have significant value for the public and the industry.  The Commission proposes collecting new or different data to ensure data capture is at the most relevant and reduce the burdens on small providers and other filers.

Those interested in commenting are encouraged to do so.  Comments are due on or before September 25, 2017 and reply comments are due on or before October 10, 2017. If you anticipate that you will be submitting comments, but find it difficult to do so within the period of time allowed by this document, you should advise the contact listed below as soon as possible.