FCC%20Form%20477

1

• FCC Form 477
• Data Collection Workshop
• June 29, 2005

2
Agenda

• Welcome
• Rodger Woock, Chief, Industry Analysis and
  Technology Division,
• Wireline Competition Bureau
• Overview
• Ellen Burton, Industry Analysis and
  Technology Division
• Filing Procedures, Certification Statement
• Cover Page
• Suzanne Mendez, Industry Analysis and
  Technology Division
• Parts I V of the Form
• Jim Eisner, Industry Analysis and
  Technology Division
• Questions and Answers
• Workshop participants members of FCC Form
  477 Inter-Office
• Working Group

3
Overview

• How frequently is Form 477 due?
• Who must file the form?
• Which parts must be completed?
• How many separate forms must be
• submitted in any filing round?

4
How frequently is Form 477 due?

• Form 477 is due twice each year.
• The September 1 filing contains data as of
• June 30 of the current year.
• The March 1 filing contains data as of
• December 31 of the preceding year.

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Who must file the form?

• All facilities-based providers of
• broadband connections to end-user
• locations must file.
• All local exchange carriers (ILECs and
  
• CLECs) must file.
• All facilities-based providers of mobile
  
• telephony services must file.

6
Which parts must be completed?

• Complete only the parts that apply to you.
• Leave other parts of the form blank.
• When a particular question (i.e., a row in
• the Form 477 Excel spreadsheet) does
• apply to you, answer all subparts of
• that question.

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Form 477 structure
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Part I Broadband - Who must file?

• Facilities-based providers. . .
• . . . of broadband connections. . .
• . . . to end-user locations . . .
• . . . must file Form 477.

9
Characteristics of a Form 477 broadband connection

• It terminates at an end-user location.
• It enables the end-user to receive infor-
• mation from and/or send information to
• the Internet at information transfer rates
• exceeding 200 kbps in at least one direction.
• - Point-to-point high-capacity circuits
  within
• a private corporate network are excluded.
• - ISDN speed connections are excluded.

10
Who is a Form 477 broadband end user?

• An end user is a residential, business,
• institutional, or government entity.
• An end user uses the broadband connection
• for his or her own purposes.
• An end user does not resell the broadband
• connection.
• - ISPs are generally not Form 477 broadband
• end users.

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Who is a Form 477 facilities-based provider?

• The facilities-based provider of a broadband
• connection is the entity that
  provisions/equips the
• connection as broadband.
• The term entity includes affiliates.
• The facilities-based provider need not have a
  retail
• relationship with the end user of the
  broadband
• connection.

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Many types of entities are facilities-based
providers

• Cable systems (w/cable modem service)
• ILECs and CLECs (w/DSL or DS1/T-1, etc.)
• WISPs that offer broadband-speed services
• Satellite broadband service providers
• Electric utilities offering Access BPL (but not
  
• if only Wi-Fi or other in-premises
• applications)
• Municipalities that offer broadband-speed
• services
• Etc.

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Ways to be a Form 477 facilities-based provider

• The entity (including affiliates) owns a
• physical facility and equips it as broadband.
  
• The entity (including affiliates) equips
• licensed or unlicensed spectrum as
• broadband.
• The entity leases a UNE or other facility from
• an unaffiliated entity and equips it as
• broadband.

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Example Who is the facilities-based provider?

• To provide the one-stop shopping experience for
  high-
• speed Internet service, AOL is partnering
  with
• telecommunications wholesaler Covadthat
  leases
• phone lines from the regional phone
  companiesAOL
• will handle all the branding, marketing and
  customer-
• service calls while Covad will provide the
  high-speed
• phone lines and modems.
• Sidebar 1.5 megabits DSL_at_
  29.95/month
• 3 megabits DSL_at_
  39.95/month
• AOL Aims to Get Up to
  Speed with DSL
• 
  Washington Post, 6/2/05

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Example Who is the facilities-based provider?

• To provide the one-stop shopping experience for
  high-
• speed Internet service, AOL is partnering
  with
• telecommunications wholesaler Covadthat
  leases
• phone lines from the regional phone
• companiesAOL will handle all the branding,
• marketing and customer-service calls while
  Covad will
• provide the DSLAMs for the high-speed phone
  
• lines and modems.
• Sidebar 1.5 megabits DSL_at_
  29.95/month
• 3 megabits DSL_at_
  39.95/month
• AOL Aims to Get Up to
  Speed with DSL
• 
  Washington Post, 6/2/05

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Example Who is the facilities-based provider?

• Covad is the facilities-based broadband
• provider in this example.
• The broadband end users are the
• consumers of AOLs high-speed
• Internet-access service.

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Part II Fixed Local Telephone - Who must file?

• Local Exchange Carriers must file.
• Both ILECs and CLECs must file.
• CLECs that are purely resellers must
• file.

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Voice over Internet Protocol (VoIP)

• The regulatory status of local telephone service
  provided by VoIP is the subject of an open
  proceeding, IP-Enabled Services (WC Docket No.
  04-36).

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Voice over Internet Protocol (VoIP)

• There are no questions on Form 477 about
  services
• provided by entities exclusively utilizing
  VoIP.
• All questions about fixed local telephone
• services appear in Part II of the form.
• LECs must complete Part II.
• The Commission noted that some LECs may be
• including local VoIP in their Form 477
  filings.
• (Data Collection Order, FCC 04-266, rel. Nov.
  12, 2004, at
• para. 23).

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Part III Mobile Telephone - Who must file?

• All facilities-based providers of mobile
• telephony services must file Form 477.
• An entity that solely resells mobile telephony
  
• services should not file Form 477.
• A mobile telephony service resellers
• subscribers must be reported by the
• underlying, facilities-based carrier.

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Who is a Form 477 facilities-based mobile
telephony provider?

• A carrier that serves mobile telephony
  subscribers
• using spectrum for which the carrier
  (including
• affiliates) holds a license is a
  facilities-based
• provider.
• A carrier that serves subscribers using
  spectrum
• that it manages is a facilities-based
  provider.
• A carrier that uses spectrum that it has
  obtained the
• right to use via lease or other arrangement
  with a
• Band Manager is a facilities-based provider.

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How many separate forms must be submitted in any
filing round?

• Data for different states may not be
• combined.
• - The state is determined by the end users
  
• location.
• - The state is not determined by the
• headquarters location.
• Information for ILEC and CLEC operations
• may not be combined on a single form.

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Obtaining a blank form and the reporting
instructions

• FCC Form 477 and detailed reporting instructions
  are available online at www.fcc.gov/formpage.htm
  l477.
• FCC Form 477 is an Excel spreadsheet. The
  instructions, which include the required
  Certification Statement, are found in a separate
  Adobe Acrobat file.

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How to submit a completed Form 477

• It is recommended that filers submit a complete
  Form 477 via email to FCC477_at_fcc.gov. Please
  remember to include the Form 477 as an attachment
  within the email.

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How to submit a completed Form 477 - Continued

• The FCC also accepts completed Form 477s via
  private overnight delivery service or by hand or
  messenger delivery. The completed forms must be
  saved on a compact disc or on a floppy diskette.
• Note Paper copies of completed forms may not be
  submitted.

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Certification Statement

• A Certification Statement must be completed for
  filing a Form 477. The Certification Statement
  is found on page 14 within the reporting
  instructions.
• An officer of the reporting entity must sign the
  Certification Statement.
• The officer who signs the Certification Statement
  may also be the contact person for the Form 477
  filing, but doesnt have to be.

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How to submit a completed Certification Statement

• A completed Certification Statement can be sent
  to the Commission via
• 1) Fax to [phone],
• 2) Scan and attach it to an email sent to
• FCC477_at_fcc.gov, or
• 3) Mail it to the Commission.

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Certification Statement Multiple Form 477
filings

• Note A single Certification Statement can be
  submitted to cover multiple Form 477s. Within
  the Certification Statement, there is a line for
  Number of files provided for this reporting
  period. Be sure to accurately report the number
  of files being submitted on this line.

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FCC Form 477 Cover Page
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FCC Form 477 Cover Page
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FCC Form 477 Cover Page

• Helpful Reminders
• Be sure to review the helpful reminders on the
  right-hand side of the Cover Page.
• You will be required to correct and re-submit any
  completed form that includes formulas or
  references in a data cell, in which you have
  moved or reformatted cells, or in which you have
  inserted or deleted rows or columns.

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How to properly name the Form 477 Excel file
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Filling out Column (a) for Part I

• In column (a), providers report the number of
  lines for each
• technology. There is a row to fill out for each
  technology listed
• below
• I - 1. Asymmetric xDSL.
• I - 2. Symmetric xDSL.
• I 3. Traditional wireline such as T-carrier.
• I 4. Cable modem.
• I 5. Optical carrier (fiber to the end user).
• I 6. Satellite.
• I 7. Terrestial fixed wireless (licensed or
  unlicensed).
• I 8. Terrestial mobile wireless (licensed or
  unlicensed).
• I 9. Electric power line.
• I 10. All other technologies.

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Part I - Counts versus percentages

• In Parts I-III, counts are reported in column
  (a). In the other columns, percentages of the
  counts reported in column (a) are reported.
• The exception to this rule is Section B of Part
  I, which is also a percentage.

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Part I - Column (b)

• Providers report the percentage of the high-speed
  lines that are residential.
• A residential broadband connection is a broadband
  connection that is used to deliver
  Internet-access services that are primarily
  purchased by, designed for, and/or marketed to
  residential end users.

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Part I - Column (c)

• Report the percentage of the high-speed lines
  that are provided over your local loop facility.
• In this column, please exclude lines that you
  provision as broadband over UNEs, special access
  lines, or other leased lines.

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Part I - Column (d)

• Report the percentage of lines that are billed
  (or incorporated in a service billed) to end
  users by you, or your affiliates or agents.
• In the example presented earlier, which included
  AOL and Covad, Covad would report 0 since Covad
  does not bill its end users.

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Part I - Column (e)

• Report the percentage of lines that are provided
  to residential customers and have information
  transfer rates exceeding 200 kbps in both
  directions.
• Note that column (e) has to be less than or equal
  to the percent residential reported in column (b).

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How is broadband speed measured?

• Providers should consider the end users
  authorized maximum information transfer rate on
  the connection.
• The Commission does not require reporting
  entities to measure the information transfer
  rates actually observed by end users of
  particular broadband connections.

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Part I - Columns (f) - (j)

• In columns (f) through (j), providers report the
  percentage of lines that are over 200 kbps in
  both directions. Note There are more speed
  categories in the new form.
• The sum of columns (f) through (j) needs to be
  less than or equal to 100. Reported lines that
  are less than 200 kbps in the slower direction
  are excluded from columns (f) through (j).

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Part I - Columns (f) - (j) - Continued

• The speed break-outs for information
• transfer rates in the faster direction are
• Greater than 200 kbps and less than 2.5 mbps
• Greater than or equal to 2.5 mbps and less than
  10 mbps
• Greater than or equal to 10 mbps and less than 25
  mbps
• Greater than or equal to 25 mbps and less than
  100 mbps
• Greater than or equal to 100 mbps

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Who files Part I.B (Broadband)?

• You are an ILEC (or an affiliate of an ILEC) and
  reported asymmetric or symmetric xDSL connections
  in Part I.A, or
• You are a cable company (or an affiliate of a
  cable company) and reported cable modem
  connections in Part I.A.

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How to fill out Part I.B for ILECs

• In I-11, ILECs report their best estimate of the
  percentage of residential end user premises in
  their service area, in the state, in which
  broadband connections could be provided using
  installed distribution facilities.
• The service area of ILECs consists of those
  residential end user premises to which the ILEC
  can deliver telephone service.

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How to fill out Part I.B for cable companies

• In I-12, cable modem providers report their best
  estimate of the percentage of residential end
  user premises in their service area, in the
  state, in which broadband connections could be
  provided using installed distribution facilities.
• The service area of cable systems consists of
  those residential end user premises to which
  systems can deliver cable service over the cable
  plant that it owns.

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How is voice service defined for use in Form 477,
Part II?

• Voice telephone service means local exchange
• or exchange access services that allow end users
• to originate and/or terminate local telephone
• calls on the public switched network.
• These lines can be used for voice telephone
  calls.
• These lines can also be used for other types of
  calls carried over the public switched network
  (for example, fax transmissions and dial-up
  connections to the Internet).

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How are voice service lines to end users counted
in Part II?

• Voice telephone service lines (or the
  fixed-wireless equivalent) that are provided to
  end users over high-capacity lines must be
  counted as the number of activated, charged-for
  DS0 (64 kbps) channels, and not as the
  theoretical capacity of the high-capacity line.
  Examples are provided in the FAQs and in the
  instructions.

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Part II, Section A -End User Lines

• Carriers report the number of voice telephone
  service lines provided to end users in column (a)
  of the first row of Part II. These lines can be
  provided over your own facilities, or acquired
  from another carrier via resale or via UNEs.
• In columns (b) through (j), carriers report a
  percentage of their end user lines.

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Part II - Column (b)

• Carriers report the percentage of lines that are
  provided to residential end users.
• Note This is a change from previous filings
  (where filers were required to estimate the
  percentage of lines provided to residential and
  small business end users, defined as locations
  to which the filer provided fewer than four
  lines.)

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Part II - Column (b) - Continued

• An ILEC may report the percentage of lines it
  provides to end users which are tariffed
  residential lines, or which it provides to
  shared-tenant service providers in apartment
  buildings or similar residential settings.
• Carriers that do not have separate residential
  tariffs or price lists should use marketing or
  other information about the demographic
  characteristics of the areas they serve to
  develop an estimate, or should undertake a
  limited special study.

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Part II - Column (c)

• In column (c), LECs report the percentage of
  lines for which they are the default interstate
  long distance carrier. These are lines over
  which the reporting carrier provides both local
  and long distance service.

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Part II - Column (d)

• In column (d), LECs should report the percentage
  of lines that are both serving residential
  customers and that they are the default long
  distance provider for.
• Column (d) must be less than or equal to both
  columns (b) and (c). Note An error message
  will appear if column (d) is greater.

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Part II - Columns (e) - (h)

• In column (e), carriers report the percentage of
  end user lines provided over their own local loop
  facilities or the fixed wireless last-mile
  equivalent.
• In column (f), carriers report the percentage of
  lines provided over UNE loops obtained without
  UNE switching.
• In column (g), carriers report the percentage of
  lines provided over UNE-Platform.

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Part II - Columns (e) - (h) - Continued

• In column (h), carriers report the percentage of
  lines provided by reselling another carriers
  service (including Centrex/Centron or channelized
  special access service).
• Note The sums of columns (e), (f), (g), and (h)
  need to equal 100. These four categories are
  mutually exclusive.

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Part II - Columns (i) (j)

• In column (i), carriers report the percentage of
  lines provided over coaxial cable at the end user
  premises (cable telephony).
• In column (j), carriers report the percentage of
  lines provided over fixed wireless facilities at
  the end user premises.
• Note The sums of columns (i) and (j) cannot
  exceed 100.
• LECs providing service over twisted copper pair
  should have 0 in both columns (i) and (j).

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Who reports in SectionsB and C of Part II?

• Carriers only report if they are providing lines
  to other carriers.

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How to fill out SectionsB and C of Part II

• In Sections B and C, carriers have to report
  counts in column (a), but they do not have to
  report any percentage break-outs of those counts.
  
• In Section B, carriers count resold lines in
  voice-grade equivalents.
• In Section C, carriers counts UNEs irrespective
  of the capacity of the UNE.

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Part II.B of the form

• Voice telephone service that you provided to
• unaffiliated communications carriers,
• categorized by
• II2. Lines and channels you provided to
  unaffiliated communications carriers under Total
  Service Resale arrangements.
• II3. Lines and channels you provided to
  unaffiliated communications carriers under other
  resale arrangements, such as resold Centrex or
  resold channelized special access service.

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Part II.C of the form

• UNE loops that you provided to unaffiliated
• communications carriers, categorized by
• II4. Lines and channels that you provided to
  unaffiliated communications carriers under a UNE
  loop arrangement, where you did not provide
  switching for the line.
• II5. Lines and channels that you provided to
  unaffiliated communications carriers under a UNE
  loop arrangement, where you also provided
  switching for the line (UNE-Platform).

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How to fill out Part III

• In column (a), facilities-based carriers report
  the number of mobile telephony subscribers they
  serve. You must include
• - subscribers that you bill directly
• - subscribers billed by an unaffiliated
  reseller
• - your pre-paid subscribers
• In column (b), the filer should report the
  percentage of the subscribers that it bills
  directly or serves on a pre-paid basis.
  Note This is a change from previous filings
  (where pre-paid subscribers were not included in
  column (b)).

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How to allocate wireless telephony subscribers by
state

• Use the area code of the phone number provided to
  the mobile handset, car-phone, or other voice
  unit to determine the state-specific Form 477 in
  which to report the subscriber.
• Note This is a change from previous filings
  (where filers were directed to use the
  subscribers billing address to determine the
  state).

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Part IV Explanation and Comments

• Filers must report if there is a non-zero entry
  in column (a) of Line A.I-10 (Other
  Technologies). These filers must identify the
  type of technology used to provide broadband
  connections.
• Other filers complete Part IV to furnish relevant
  explanatory information for the data. For
  example, an explanation should be provided if a
  percentage figure has changed noticeably from an
  earlier filing.

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Part V ZIP Code Listings

• Broadband ZIP Code Listings
• Report, in the appropriate column, the five-digit
  ZIP Codes for the state in which you provide
  at least one of the broadband connections
  reported in Part I of the form.

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Part V ZIP Code Listings - Continued

• The technology break-outs are
• (a) Asymmetric xDSL
• (b) Symmetric xDSL
• (c) Cable modem
• (d) Optical carrier (fiber to the end user)
• (e) Satellite
• (f) Terrestrial fixed wireless
• (g) Terrestrial mobile wireless
• (h) Electric power line
• (i) Other including traditional wireline
• Note Other traditional wireline is merged
  with other
• technologies.

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Part V Exception for mobile wireless ZIP Codes

• Mobile wireless broadband in column (g) should be
  the ZIP Codes in the state in which the mobile
  wireless broadband service providers service is
  advertised and available to actual and potential
  subscribers.

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Part V Local telephone service ZIP Codes

• Report, in column (j), the five-digit ZIP Codes
  for the state in which you provide at least one
  of the end-user voice telephone service lines
  reported in Part II of the form.

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Form 477 contact info.

• Resources
• Everything discussed today can be found at
  www.fcc.gov/broadband/data.html.
• For questions, the Form 477 Team can be
• reached
• 1) Via email at 477INFO_at_fcc.gov. or
• 2) By telephone at [phone]