FCC Extends HUBB, Form 477 Broadband Reporting Deadlines

2017-12-14T11:00:27-05:00February 27, 2017|e-Lerts|

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

Webinar – All About HUBB: Prepping for the First Geocoded Location Report

2018-09-05T09:22:52-04:00February 2, 2017|Webinar Recordings|

Everything you need to know about HUBB & reporting your company’s broadband locations

Rate-of-return carriers have until March 1, 2017, to submit their very first geocoded location data through USAC’s new High Cost Universal Broadband (HUBB) portal. Rate-of-return carriers’ reports must include the longitude and latitude of residential and business locations where they deployed broadband in the previous year, but there are key differences in the data required from A-CAM electors and CAF-BLS (legacy High Cost) recipients. In a recent webinar, JSI explained the new requirements so that carriers are completely prepared for the March 1 deadline.

The webinar, “All About HUBB: Prepping for the First Geocoded Location Report,” covered everything you need to know about the HUBB portal, including:

  • HUBB requirements for A-CAM electors
  • HUBB requirements for CAF-BLS recipients with less than 80% 10/1 Mbps broadband deployment
  • Latest developments on location data reporting requirements in Form 481 for CAF-BLS recipients with greater than 80% 10/1 Mbps broadband deployment
  • Common geocoding apps and desktop software, and how to use them
  • Walking through the HUBB data validator
  • Ensuring your data is accepted and error-free
  • Requirements after 2017
  • Review of the latest guidance and news from the FCC and USAC

A recording of the webinar is available for $249. If you are interesting in purchasing the recording, please contact Brenda Cordwell at 301-459-7590.

For more information about the HUBB or these reporting requirements, contact John Kuykendall or Cassandra Heyne in the Maryland office at 301-459-7590.

Reminder: Upcoming March 1 Deadlines

2017-05-19T10:09:36-04:00January 31, 2017|e-Lerts|

JSI reminds its clients of several important March 1, 2017, filing deadlines. These deadlines affect wireline, wireless and VoIP telephone providers and video/cable companies.

FCC Form 477
FCC Form 477, Local Telephone Competition and Broadband Reporting, for data as of December 31, 2016, must be submitted by March 1 via the FCC’s online filing system. Reporting is required for all:

  • Facilities-based providers of broadband connections to end-user locations;
  • Wired or fixed-wireless local exchange telephone service providers;
  • Interconnected VoIP service providers; and
  • Facilities-based providers of mobile telephony and mobile broadband service.

Note that the FCC has added a new cable modem technology code for fixed broadband deployment: Code 43 for cable modem DOCSIS 3.1. If your company has deployed DOCSIS 3.1 technology to any census blocks as of December 31, 2016, use technology Code 43 when reporting fixed deployment for those blocks.

For assistance with Form 477 reporting, contact Marty Kluh in JSI’s Maryland office at 301-459-7590.

Semi-Annual Copyright
Video/cable operators must submit their cable copyright statement of account forms and royalty payments for the second half of calendar year 2016 to the Library of Congress Copyright Office by March 1. All cable copyright royalty fees must be made via electronic funds transfer. Video/cable providers should note the following:

Semiannual gross receipts of $527,600 or more for the July 1-December 31, 2016, accounting period must be reported on the SA3 Long Form and require detailed reporting of distant signal carriage. If you have completed SA1-2 Short Form statements in the past and are approaching this threshold, you should review your channel lineup as the carriage of distant signals significantly affects your copyright royalty fee calculation. If you completed the SA3 Long Form in the past but have revised your channel lineup for broadcast stations, please make sure that these revisions are noted on the SA3 Long Form.

If you have questions about any of this information or would like JSI’s assistance with your copyright filing, contact Kim Waldvogel in JSI’s Maryland office at 301-459-7590.

Geocoding Location Broadband Deployment Report
The new Geocoding Location Broadband Deployment Report must be submitted in the High Cost Universal Broadband (HUBB) Portal (some companies’ reports are due March 1, 2017, and others July 1, 2017, as follows):

  • Companies that selected the A-CAM must report all newly served or newly able to be served locations in funded census blocks built out in calendar year 2016. This includes fully funded and capped census blocks.
  • Legacy/CAF-BLS companies with less than 80% 10/1 deployment must report geocoded locations by March 1, 2017, of all newly served or newly able to be served locations in their entire service area built out from May 25, 2016, through December 31, 2016.
  • Legacy/CAF-BLS companies with 80% or greater 10/1 deployment are required to report location information to USAC by July 1, 2017, as part of the FCC Form 481 reporting. JSI will provide additional information as it is released by the FCC or USAC.

JSI is holding a webinar on these new reporting requirements this Thursday, February 2 at 2 p.m. Eastern (1 p.m. Central). More details about the webinar, “All About HUBB: Prepping for the First Geocoded Location Report,” and online registration are available on our website.

For more information about the HUBB filings or Thursday’s webinar, contact Cassandra Heyne at 301-459-7590.

CPNI Annual Certification
CERTIFICATION IS NO LONGER REQUIRED

Please note that the rule requiring CPNI annual certification was eliminated when the CPNI Broadband Order became effective on January 3, 2017. The section containing the filing requirement (Section 64.2009), which included requirements for carriers to train personnel and to have a disciplinary process in place, was eliminated. Although this specific rule was eliminated, please note that other CPNI rules are in effect along with the potential fines if violated. Therefore, even though the annual certification is no longer required, companies should continue to train their staff and have a disciplinary process in place to ensure that the company stays in compliance. (See JSI’s January 13 e-Lert for more details.)

Source: JSI e-Lert

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