On March 4, the FCC released its long-awaited new instructions for how ISPs are to report broadband coverage, speeds, and customers to the FCC. The order also provides a timeline for reporting to the FCC in the new formats. The new reporting is still called the FCC 477 data filing, but the format has changed significantly.
These reporting rules are the culmination of several years of effort by the FCC to revamp the way the agency collects broadband data. The current broadband data is so erroneous today from some ISPs that it’s hard to take any statistics coming out of the FCC seriously. But today’s blog is not to bash the FCC’s past mapping performance but to let ISPs know what must be reported this summer. Following are the highlights of the new rules, which can be found here.
Who Must File? Any fixed or mobile entity that acts as the ISP for at least one customer on June 30, 2022 must file. It seems like in almost every county I work in, I find an ISP or two that is not reporting to the FCC. I’m wondering if the agency is going to make any effort to find the non-filers.
Interestingly, any federal agency along with state, local, and Tribal governments can also file broadband mapping and coverage data. I don’t think this data is automatically going into the new FCC map, but rather starts building what the FCC is calling a challenge process for those that don’t agree with what ISPs report.
Due Date. The new FCC reporting portal will be open on June 30. ISPs must complete filings by September 1. The FCC expects to be on the normal schedule with two filings due in 2023.
The FCC warned separately a few weeks ago that it may accelerate and shorten the September 1 date, so I advise ISPs to report early. If this is like any other large government reporting portal, there are bound to be glitches this first time – so don’t wait until the last minute.
The New Reporting Data.
The big change is that ISPs must submit shapefiles for polygons that define the service territory. Each polygon should include existing customers along with homes or businesses that can be connected within 10 business days of a request for service. If an ISP doesn’t want to provide shapefiles it can provide the detailed location of each customer. WISPS and cellular carriers must file propagation maps from each transmitter along with details of signal strength and heat map data. The 477 reporting now also requires traditional telephone and VoIP subscriber data. Cellular carriers must show broadband and voice coverage separately if it’s not the same service area.
This is the most material change in the new 477 data and will have the biggest impact if ISPs file correctly. For example, if done right, these maps will identify the last home served along every road leaving towns served by a cable company. This reporting is a lot more complicated for rural ISPs, and as I’ve written recently, I don’t know how rural WISPs can meet this requirement with any accuracy.
How to File. ISPs can either input data into the new FCC portal or submit data to the FCC using an API.
Double Reporting. An important thing to note is that ISPs are required for this filing to file in both the new and the old 477 system – you must file twice.
The FCC is banking heavily on this new data being more accurate than the past 477 data. I think in some ways it will, if ISPs like the cable companies draw accurate shapefiles. But I’m extremely skeptical that this is going to fix the problem of ISPs overstating broadband speeds – and that’s the issue the FCC has promised will be fixed to support the BEAD grants. I guess we’ll find out some time this winter after the FCC crunches the new data.
Note that anybody who analyzes FCC data for broadband coverage and speed is likely to have a steep learning curve to understand the new data.