2 11, 2021

CAF-BLS Cos. Without Locations in HUBB Must Contact USAC About Samples for Broadband Pre-Testing

2021-11-02T14:02:42-04:00November 2, 2021|e-Lerts|

Legacy CAF-BLS companies that may not have adequate locations in the HUBB for a random sampling before broadband performance pre-testing begins in January 2022 must contact USAC by Monday, November 8, 2021. All Legacy CAF-BLS companies, along with A-CAM II, Alaska Plan and CAF Phase II Auction carriers, must begin pre-testing in first quarter 2022 as part of the FCC’s performance measures testing framework. Companies will use a USAC-generated random sample of broadband locations deployed (and reported in the HUBB) that have active subscribers.

However, USAC has identified three scenarios where CAF-BLS companies may not have any locations or enough locations reported in the HUBB for the random sampling:

  1. Fully Deployed Prior to May 25, 2016 – Under this scenario, CAF-BLS companies have not reported any locations into the HUBB because they were fully deployed in their service territory prior to May 25, 2016 and therefore have no HUBB filing obligations.
  2. No Reported Deployments to Date – Since CAF-BLS companies only have one deployment milestone at the end of 2023, there may be some companies that do have a HUBB filing obligation but have not yet submitted any locations in HUBB due to no deployment of 25/3 broadband during the period May 25, 2016 to present.
  3. Limited Deployment to Date – Under this scenario, CAF-BLS carriers have entered some locations in the HUBB due to deployment of 25/3 broadband after May 25, 2016 but must rely on locations that were fully deployed prior to May 25, 2016 to meet their buildout obligations. For example, a company may have a buildout requirement of 3,000, but 2,800 of these were prior to May 25, 2016 and therefore only 200 locations are in the HUBB.

USAC has asked any Legacy CAF-BLS companies that fall under scenarios 1 and 2 to contact them at HCproduct@USAC.org by November 8. USAC is meeting with the FCC to discuss scenario 3 and is planning to send an updated email with language that is directly applicable to this situation. USAC is likely to ask companies under scenario 3 to tell them how many locations and at what speeds were deployed pre-2016 to be added to those that they did upload into HUBB. Regardless, USAC will follow up with CAF-BLS companies under each of the three scenarios on how to obtain random location samples for speed and latency pre-testing in 2022.

If you have any questions about this requirement or any other questions related to broadband performance testing, please contact Lans Chase at 770-569-2105 or Paul Nesenson at 651-452-2660.

26 10, 2020

JSI Encourages Early Preparedness for the 2021 Broadband Location Data Filing

2021-11-02T13:22:29-04:00October 26, 2020|e-Lerts|

Consider Reviewing Your Geocoded Data for Accuracy

As the end of construction season and the year fast approach, now is a good time to review your HUBB reporting status and determine the dataset you will file for the March 1, 2021 HUBB filing. A-CAM II and CAF-BLS companies should be aware of the additional HUBB reporting requirements for this filing only. In addition to the requirement to report broadband locations deployed in 2020, A-CAM II companies can report deployment of locations made prior to 2019. CAF-BLS companies can report any broadband locations deployed between May 25, 2016 and December 31, 2018. This is the only opportunity for companies receiving A-CAM II and CAF-BLS support to report locations deployed prior to 2019, and all filers must be aware that the HUBB will only accept geocoded location data with a date that falls in the reporting period for your funding category.

Although the HUBB reporting deadline is not until March 1, 2021, JSI recommends that you start the process of collecting and uploading your data now so that you can address any potential issues early. You can prepare by reviewing USAC’s guide on HUBB data formatting instructions, as well as error codes to use for revising your previously-filed HUBB data if it is determined that revisions are needed.

Companies that have been filing the HUBB for several years may want to consider undertaking a thorough review of mapping their previously-filed locations to check for accuracy, especially as the first milestone certification for A-CAM I will be due with the 2020 data on March 1, 2021. Mapping and geocoding techniques have gotten better each year, which enables more accurate reporting going forward and the ability to correct data that has already been filed.

To request assistance with evaluating existing HUBB data for geocode accuracy, or any questions about mapping HUBB locations, contact Paul Nesenson in our Minnesota office at 651-691-4045. If you need assistance or have questions regarding HUBB reporting requirements, please contact Lans Chase at 770-569-2105.

20 03, 2020

JSI Preparing Joint Waiver for Those Penalized for Not Filing “No Locations” in the HUBB

2020-03-20T09:47:28-04:00March 20, 2020|e-Lerts|

Other similarly situated companies invited to participate

Last year, JSI filed a petition for waiver on behalf of a group of “Impacted RLEC HUBB Filers” who were penalized high-cost USF support because they did not certify “no locations” on their March 2018 HUBB report. In each case, the companies received confusing guidance from USAC or had other technical and administrative issues with completing the certification by the deadline. To add to the confusion, the FCC waited until the day of the deadline to inform HUBB filers about the need to file even though they had no locations to report, plus its guidance was ambiguous, stating that filers “can” certify instead of “must.” Based largely on the fact that the March 2018 filing was the first HUBB filing for all carriers, the FCC granted the waiver for the Impacted RLEC HUBB Filers and other similarly situated rate-of-return companies in the December 2, 2019, HUBB Waiver Order.

Other rate-of-return companies have approached JSI since the FCC granted the waivers last year about similar issues they encountered with certifying “no locations” in their March 1, 2019, HUBB filings (USAC is just now reducing support for last year’s filing). Although these companies have similar fact patterns that fit the precedent established in the FCC’s HUBB Waiver Order, the fact that this is the second HUBB filing makes seeking waiver of this deadline more challenging. Nonetheless, companies that have had USF payments reduced simply for not filing “no locations” have no recourse other than filing a waiver if they seek to have the reduction rescinded.

Accordingly, JSI encourages companies that have had support reduced due to not filing “no locations” in the HUBB for either last year or this year to contact JSI about participating in this second Impacted RLEC HUBB Filers petition for waiver. To participate in the joint waiver, or if you have HUBB-related questions about late filings and penalties, please contact John Kuykendall or Cassandra Heyne in the Maryland office at 301-459-7590.

28 01, 2020

FCC Sets Uniform Reporting Deadlines for CAF Phase II Auction Winners

2021-04-05T15:04:35-04:00January 28, 2020|e-Lerts|

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 Lans Chase in the Georgia office at 770-569-2105.

9 01, 2020

Webinar: Mapping Your Steps to the 2020 HUBB Filing

2020-01-09T15:16:15-05:00January 9, 2020|Webinar Recordings|

Prepare now for the HUBB filing, so you aren’t scrambling at the last minute

The March 1, 2020, HUBB filing is rapidly approaching. This will be the first time that all rate-of-return companies, plus companies that receive Connect America Fund (CAF) Phase II support, will be required to complete the HUBB filing even if they do not have any data to report.

Because there will be so many first-time filers in 2020, JSI recently hosted a webinar so that everyone is well prepared for the March deadline. We went over all the details of exactly what needs to be filed and how to file it using the HUBB portal. Plus, we talked a bit about how JSI can help if you need a hand with geocoding your locations, inputting data, or just reviewing your filing for accuracy before you hit “submit.”

A recording of the webinar is available for $249. Contact Brenda Cordwell in the Maryland office at 301-459-7590 if you’d like to purchase the recording of this webinar.

11 07, 2018

FCC Establishes Rules to Measure Broadband Performance

2018-07-11T14:23:03-04:00July 11, 2018|e-Lerts|

Requires Testing to Begin Third Quarter 2019

Late Friday, the FCC released an Order announcing new rules for carriers to measure broadband speed and latency performance, with the main requirements summarized in the Order’s Appendix A. At this time, the rules apply to all Eligible Telecommunications Carriers (ETCs) that have mandatory buildout obligations and report location data in USAC’s HUBB portal. This includes A-CAM and legacy carriers with less than 80% 10/1, as well as Rural Broadband Experiment and Connect America Fund (CAF) Phase II support recipients. However, given that the Order envisions that all high-cost USF recipients “that served fixed locations” must conduct the tests, it is possible that legacy carriers with greater than 80% 10/1 that report location information on the Form 481 will eventually be required to comply.

The number of subscribers to be tested will be based on the number of subscribers at locations that are supported by the CAF (for example, A-CAM supported census blocks or entire study areas for CAF-BLS recipients with buildout obligations), with a maximum of 50 randomly selected subscribers per state per speed tier for speed testing and 50 randomly selected subscribers per state for latency. The subscribers eligible for testing must be at locations that are reported in the HUBB where there is an active subscriber. Testing must be conducted for one week during each quarter of the year. In those weeks, testing must be performed between the hours of 6:00 p.m. to 12:00 a.m. local time each day, including weekends (testing hours).

Carriers may choose between three testing options. The first option is a program that some of the larger carriers have participated in called Measuring Broadband America (MBA). Under this option, carriers may enter into arrangements with entities that manage and perform testing for the MBA. A second option is for carriers to use their own existing network management systems and tools, “ping” tests, and other commonly available measurement and network management tools (known as “off-the-shelf” testing). The third option would be for the carrier to implement a provider-developed self-testing configuration.

The first tests begin in the third quarter of 2019. The certification for these tests will be due by July 1, 2020, and will cover data for third and fourth quarters of 2019. Subsequent tests will be conducted for the full calendar year and submitted/certified by the following July 1. The data will be subject to audit by USAC. Further guidance regarding submission of the data will be provided by the Wireline Bureau in a future Public Notice.

JSI will be providing additional information regarding these new rules in the coming weeks. If you have any questions, contact John Kuykendall, Cassandra Heyne or Terri Parrilla in JSI’s Maryland office at 301-459-7590.

23 02, 2018

Clearing Up HUBB Requirement Confusion for Some CAF-BLS Clients

2018-02-23T10:12:52-05:00February 23, 2018|e-Lerts|

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.

5 01, 2018

Countdown is On to the First HUBB Deadline

2018-01-16T16:22:11-05:00January 5, 2018|e-Lerts|

For many rate-of-return carriers, the first HUBB broadband deployment location data report is due on March 1, 2018. JSI strongly encourages clients to have their required broadband location data prepared no later than the end of January in case additional time is needed to correct errors detected by the HUBB data validator. As a reminder, rate-of-return carriers have the following 2018 deadlines and broadband location data requirements:

  • March 1, 2018: CAF-BLS (Legacy) support recipients with defined deployment obligation (i.e., carriers with less than 80% broadband deployment in their study areas) must report all broadband locations newly deployed between May 25, 2016, and December 31, 2017.
  • March 1, 2018: A-CAM support recipients must report all broadband locations newly deployed during calendar year 2017.
  • July 1, 2018: CAF-BLS (Legacy) support recipients with no defined deployment obligation (i.e., carriers with 80% or greater broadband deployment in their study areas) must 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. 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.

In our experience with testing HUBB data so far, JSI has found the HUBB data validator to be accurate at detecting errors in geocodes. Most frequently we have observed geocodes that do not have five or six digits, geocodes where the latitude and longitude are flip-flopped, and locations that are outside of the eligible A-CAM census blocks. The data validator provides helpful feedback to fix errors effectively.

JSI regulatory staff are available to assist with reviewing your HUBB data, running it through the HUBB data validator, and submitting the data on your behalf via the USAC E-file system. Please let us know as soon as possible, if you have not already done so, if you would like our assistance with the HUBB reporting. The countdown is on, so contact Cassandra Heyne in the Maryland office at 301-459-7590 or Lans Chase in the Georgia office at 770-569-2105 with any questions you have about the HUBB report.

11 07, 2017

FCC Changes Annual Form 481 Reporting Requirements for High-Cost ETCs

2017-12-14T10:21:55-05:00July 11, 2017|e-Lerts|

On July 7, 2017, just six days after the 2017 Form 481 filing deadline, the FCC released an Order simplifying future annual reporting requirements for ETCs receiving high-cost support. These changes eliminate the following information currently collected: 1) network outage information; 2) unfulfilled service requests; 3) number of complaints per 1,000 subscribers for voice and broadband services; 4) voice and broadband service rates; and 5) the requirement for ETCs to certify compliance with service quality standards. These changes will become effective after approval by the Office of Management and Budget (OMB), which we hope will happen before the 2018 filing is due next July.

The FCC believes that the eliminated Form 481 information is either available in other formats, such as in the Network Outage Reporting System (NORS); duplicative; not cost efficient to provide; or does not provide the information that it was originally intended to provide, such as to monitor the progress of rate-of-return carriers’ broadband deployment pursuant to the reasonable request standard, which has been replaced with specific broadband obligations. The FCC believes these changes will reduce the reporting obligations for ETCs, but still keep with its goal of protecting the program against waste, fraud and abuse.

The FCC has also directed USAC to work with other stakeholders including states and Tribal governments to improve access to publicly filed information. To reach this goal, USAC will develop an online portal to provide access for high-cost ETCs’ information, eliminating the need for filing duplicate copies of the annual report with the FCC, states and Tribal governments beginning in 2018 or upon completion of the online portal.

Although these changes in reporting simplify some aspects of the annual ETC compliance filing process, in 2018, rural ILECs must report location data for the first time, either in USAC’s High Cost Universal Service Broadband (HUBB) portal or on Form 481 if the company remained on legacy support and has over 80% 10/1 coverage (see JSI’s February 27 e-Lert for more information on HUBB reporting).

For assistance with Form 481 or HUBB reporting, please contact Cassandra Heyne in JSI’s Maryland office at 301-459-7590 or Lans Chase in JSI’s Georgia office at 770-569-2105.

20 04, 2017

USAC Releases FCC Form 481 and Opens HUBB Portal

2017-12-14T10:26:05-05:00April 20, 2017|e-Lerts|

This week, the Universal Service Administrative Company (USAC) notified Eligible Telecommunications Carriers (ETCs) that it has released the revised 2017 FCC Form 481 and ETCs may begin reporting information through USAC’s E-File system. However, the Office of Management and Budget (OMB) has not yet approved this year’s Form 481, so ETCs will not be allowed to certify their filing until the FCC form is approved by OMB. This year’s deadline is July 3, 2017.

As anticipated, 2017’s Form 481 no longer requires a five-year network improvement plan progress report. It also does not yet require legacy high-cost support recipients that have deployed broadband service to more than 80% of their territory to report geocoded broadband deployment locations.

Now that the form has been released, JSI is preparing company-specific data requests and its reporting materials in order to assist you with meeting your company’s reporting obligations. JSI consultants will soon be contacting clients to address their individual needs.

HUBB Portal Now Open
Also this week, USAC announced the opening of the new High Cost Universal Broadband (HUBB) portal. As you may recall, earlier this year the FCC delayed the deadline for rate-of-return carriers to report newly served broadband locations until March 1 next year.

Carriers that wish to begin filing geocoded broadband locations may now do so via the HUBB portal, also accessible through USAC’s E-File system. JSI encourages clients to begin reporting their location information in the HUBB now and not wait until the March 1, 2018, deadline.

If you have questions about FCC Form 481 or HUBB reporting obligations, please contact Cassandra Heyne in JSI’s Maryland office at 301-459-7590 or Lans Chase in JSI’s Georgia office at 770-569-2105.

Source: JSI e-Lert

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