Late Friday, February 24, the FCC extended two deadlines for broadband reporting obligations that were supposed to occur this week. First, an FCC Order extends the March 1, 2017, deadline for rate-of-return carriers to submit geo-located broadband data in USAC’s High Cost Universal Service Broadband (HUBB) portal. Second, a separate Public Notice extends the March 1, 2017, deadline for carriers to file FCC Form 477 data for the period ending December 31, 2016, due to technical difficulties associated with the FCC Form 477 filing interface. The FCC has not yet set a due date for Form 477 data and indicated that it would announce the new due date once the technical difficulties are resolved. JSI will issue another e-Lert once the new Form 477 deadline is announced.

HUBB Reporting Deadline Extended
In its Order, the FCC extended this year’s March 1 deadline for both rate-of-return carriers remaining under legacy support that have defined buildout obligations and those that have elected Alternative Connect America Cost Model (A-CAM). The FCC also clarified what constitutes “pre-existing” locations for A-CAM electors as being those locations deployed prior to January 1, 2017, and extended the broadband reporting deadline for recipients of Connect America Fund (CAF) Phase II support. Under the extension, carriers have the following deadlines to report geolocation information into the HUBB portal, which has not yet been opened because it has not yet been approved by the Office of Management and Budget (OMB).

  • CAF-BLS (Legacy) support recipients with defined deployment obligation (i.e., carriers with less than 80% broadband deployment in their study areas) have until March 1, 2018, to report all broadband locations newly deployed between May 25, 2016, and December 31, 2017;
  • A-CAM support recipients have until March 1, 2018, to report all broadband locations newly deployed during calendar year 2017;
  • A-CAM support recipients have until March 1, 2019, to report all preexisting broadband locations (those served prior to January 1, 2017); and
  • CAF Phase II support recipients have until July 1, 2017, to report all broadband locations newly deployed during calendar year 2016.

All of the above deadlines assume OMB approves the FCC’s broadband data collection program. If OMB does not grant its approval prior to the above deadlines, broadband reporting obligations are extended until two weeks after OMB approval is published in the Federal Register.

As was already made clear before the Order, carriers remaining under legacy support with 80% or greater 10/1 deployment are required to report location information to USAC as part of the FCC Form 481 reporting and not in the HUBB. JSI is coordinating with NTCA regarding the association’s efforts in filings with the FCC to ensure that no buildout information will be required on this year’s Form 481 and will provide additional information as it is released by the FCC or USAC concerning future reporting requirements and due dates.

JSI encourages clients to continue developing strategies to accurately capture and report newly deployed broadband locations. As we have learned through the process of preparing broadband geo-location information for upload into USAC’s HUBB, this can be a difficult task and the extension allows companies additional time to identify and accurately capture broadband deployment data. Additionally, a number of clients have identified potential problems with previously-filed FCC Form 477s. JSI encourages clients that discover errors on their Form 477 filings to file revisions if the error amounts to a difference of 5% or more of the data reported. Further, to the extent that the HUBB is approved by OMB prior to the above-mentioned deadlines, JSI continues to encourage clients to upload broadband deployment data on a routine basis such that clients do not have to report all locations before the applicable deadline.

JSI remains committed to assisting interested clients with compliance activities associated with broadband reporting obligations. Our broadband reporting team will be available to answer any questions and assist in preparing and uploading newly deployed broadband locations to ensure clients remain in compliance with their reporting obligations. For assistance with HUBB reporting, please contact Cassandra Heyne in JSI’s Maryland office at 301-459-7590. For assistance with FCC Form 477 reporting, please contact Marty Kluh in JSI’s Maryland office at 301-459-7590.

Source: JSI e-Lert