CAF-BLS (Legacy) support recipients with 80% or greater deployment of 10/1 Mbps, based on their 2015 Form 477 filings, have no defined buildout requirements and therefore do not have to report deployment data through the Universal Service Administrative Company’s (USAC’s) High Cost Universal Broadband (HUBB) portal. Only A-CAM recipients and those CAF-BLS companies with less than 80% broadband deployment must report locations using HUBB by March 1 (see our January 5th e-lert for more details).

But over the past couple of days several CAF-BLS clients that have no buildout requirements have reported that USAC representatives informed them that they must meet the March 1 HUBB filing deadline. JSI reached out to the USAC representatives and made them aware of USAC’s HUBB Frequently Asked Questions, which makes it clear that CAF-BLS companies with 80% or greater deployment of 10/1 are not obligated to make any filing in the HUBB. The USAC representatives agreed and are now in the process of updating its contact list to remove companies with no HUBB filing requirements.

JSI takes this opportunity to reassure CAF-BLS clients with 80% or greater deployment of 10/1 that they have no requirements to file anything in HUBB.  Instead, these companies will report progress on the number of locations where 10/1 Mbps or better broadband service has been deployed during the prior calendar year on the Form 481 due July 1. The exact specifications of this requirement are not yet available, but in conversations with the FCC, JSI learned that geocoded locations will not be required.

If you have any questions regarding this issue, please contact Cassandra Heyne in the Maryland office at 301-459-7590 or Lans Chase in the Georgia office at 770-569-2105.