On January 27, 2020 the FCC released a Public Notice that waived the previously-imposed patchwork-style deadlines and aligned the CAF Phase II auction deadlines with all high-cost support recipients’ deadlines. Specifically, the HUBB report will be due by March 1 each year for every high-cost support recipient, rather than having different dates for CAF Phase II auction recipients based on when they were authorized for funding. CAF Phase II auction and New York CAF winners will begin filing location information in the HUBB by March 1, 2021. The FCC also set January 1, 2020, as the commencement of the deployment timeline for all CAF Phase II support recipients. These companies must meet the 40% buildout milestone by December 31, 2022; and complete the buildout by December 31, 2025.

Throughout 2019, the FCC rolled out announcements that CAF Phase II auction winners were authorized to begin receiving funding after completing all of the application requirements and obtaining their letters of credit and ETC designations. So far, the FCC has released six separate public notices authorizing a batch of companies each to begin receiving CAF Phase II auction support, and two additional notices authorizing New York state CAF recipients. Each one included a corresponding date by which the companies included in the notice were to file their first and subsequent HUBB reports, and when the recipients were required to complete and offer service to 40% of the locations in their funded areas. The result was that companies had different deadlines for reporting and buildout milestones, which, according to the January 27 Public Notice, “created a patchwork of obligations and deadlines” that “may create confusion amongst some support recipients as to the appropriate applicable deadlines.”

JSI also reminds rural broadband providers that the next reverse auction for funding (the Rural Development Opportunities Fund or RDOF) kicks off with a vote at the January 30, 2020, FCC open meeting. In addition to answering your questions about the RDOF, JSI is available to assist with HUBB filings and other annual reporting requirements for CAF Phase II funding recipients.

For questions about the uniform reporting deadlines, contact Cassandra Heyne in the Maryland office at 301-459-7590 or Lans Chase in the Georgia office at 770-569-2105.