On Wednesday, September 20, JSI met with members of the FCC’s Wireline Competition Bureau to discuss the broadband location reporting requirements for CAF-BLS recipients with 80 percent or greater broadband deployment that have no buildout obligations. These carriers must report on their Form 481 progress on the number of locations where 10/1 Mbps or better broadband service has been deployed within their study area during the prior calendar year. Although it is expected that the FCC will require this data to be reported on the Form 481 due July 1, 2018, the FCC has yet to provide any guidance as to what data would need to be reported or the format.

In the meeting, JSI urged the FCC to adopt the least burdensome reporting requirements, proposing that the FCC merely require a place on the Form 481 where companies on legacy support with no buildout requirements would indicate the number of locations where 10/1 Mbps or better broadband has been deployed during the reporting period. In our discussions, FCC staff indicated that they were considering such an approach and may also require data for additional speed tiers. JSI also urged that under no circumstances should carriers be required to provide geocoded data on the Form 481 and that the reporting not be required until the Form 481 due July 1, 2019.

JSI also clarified that A-CAM recipients will only be required to report pre-existing locations in eligible, funded census blocks. As a reminder, by March 1, 2018, A-CAM recipients must report geocoded location information for all newly deployed locations during the calendar year 2017 timeframe in USAC’s HUBB portal, but have until March 1, 2019, to report pre-existing locations. CAF-BLS recipients with buildout requirements must report geocoded location information for newly deployed locations during the May 25, 2016, to December 31, 2017, timeframe in the HUBB by March 1, 2018.

JSI expects that the FCC will release official guidance on these topics in the near future, and in the meantime we will continue working with clients on their broadband location data collection to prepare for next year’s HUBB or Form 481 filings. If you have any questions about the reporting requirements or JSI’s meeting with FCC staff, please contact Cassandra Heyne in the Maryland office at 301-459-7590 or Lans Chase in JSI’s Georgia office at 770-569-2105.