The FCC’s Form 477 Already Gathers Sufficient Granular Broadband Information The FCC Can Enhance When Needed
PITTSBURGH, October 13, 2017 – The American Cable Association called on the Federal Communications Commission largely to maintain its current Form 477 collection of data about broadband deployment. ACA noted that less than five years ago the FCC adopted new, significantly more onerous broadband deployment collection requirements, which has served the FCC well in understanding the deployment landscape. ACA also explained that the FCC has enhanced this data on numerous occasions when needed for specific proceedings.
“Currently, broadband providers are required twice a year to go through the laborious exercise of reporting subscriber and deployment data to the FCC. This ties-up in-house resources and forces many providers to hire consultants and buy new software. Making this information even more granular, as the FCC is considering, would impose significant additional burdens on broadband providers, especially the many hundreds of smaller providers who are ACA members. Instead, the FCC should be looking at ways to relieve smaller providers of the current burdens, including by moving to an annual collection.” ACA President and CEO Matthew M. Polka said.
ACA set forth its views in comments (attached) on the Further Notice of Proposed Rulemaking (FNPRM) on updating the broadband connection data the FCC collects in Form 477.
As fixed broadband service providers, ACA members file Form 477 data on their voice and broadband subscriptions and on their broadband deployment and thus are in good position to comment on Form 477 data collection and whether it strikes an appropriate balance between the benefits of the collection and its burdens.
ACA members already find complying with Form 477’s requirements to continuously file subscribership data on a census tract level and deployment data on a census block basis to be a significant burden. Imposing more granular deployment collection requirements would increase ACA members’ in-house and, where relevant, consultant/vendor costs considerably.
ACA said the collection of broadband and voice services data will best achieve the FCC’s aims by adopting the following approach:
• The FCC should link any data collection to its purpose, both in the type and extent of the data collected and in measures to ensure the data are accurate when submitted and valid for the time during which they will be used;
• The FCC should avoid imposing on providers, particularly small- and medium-sized providers, unduly burdensome data collection requirements;
• The FCC – where it finds it needs to collect more expansive or more granular data than now collected via Form 477 – should use mechanisms other than Form 477 so it can obtain the specific data it needs most efficiently and with the fewest burdens imposed on filers.
About the American Cable Association: Based in Pittsburgh, the American Cable Association is a trade organization representing nearly 750 smaller and medium-sized, independent cable companies who provide broadband services for nearly 7 million cable subscribers primarily located in rural and smaller suburban markets across America. Through active participation in the regulatory and legislative process in Washington, D.C., ACA’s members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business. For more information, visit https://acaconnects.org/