**Frequently Asked Questions (FAQs) about FCC Form 477**

(Local Telephone Competition and Broadband Reporting)

*Updated as of:* 1**/18/06**

*These FAQs clarify particular points about completing and filing Form
477,*

*but they are not a substitute for carefully reviewing the instructions
that are posted at
[www.fcc.gov/Forms/Form477/477instr.pdf](http://www.fcc.gov/Forms/Form477/477instr.pdf).*

*Form 477 filers with questions not addressed in these FAQs may send
them to*

*<477INFO@fcc.gov>.*

*A Small Entity Compliance Guide (DA 05-1676) is available at*

*[www.fcc.gov/ocbo/complianceguides.html](http://www.fcc.gov/ocbo/complianceguides.html).*

*Starting with the Form 477 filing that was due 9/1/05, there are no
exemptions based on number of connections, lines, or subscribers.*

[[]{#Return_to_Table_of_Contents .anchor}Overview](#overview)

1\. What is the purpose of this form?

2\. Where can I get a blank copy of the form?

3\. How often is Form 477 due?

4\. Who must file it?

5\. What is a *facilities-based* entity and what is *broadband* in this
data collection?

6\. Is there a glossary of terms used in this data collection?

[Exemptions from filing](#Exemptions_from_filing_Form_477)

7\. Are Broadband-over-Powerline (BPL) providers exempt?

8\. Are Wireless Internet Service Providers (WISPs) exempt?

9\. Are municipal, other governmental, or non-profit broadband providers
exempt?

10\. Are Internet Service Providers (ISPs) exempt?

11\. Are cable TV operators and direct broadcast satellite (DBS)
operators exempt?

12\. Are providers of long distance telephone service exempt?

13\. Are providers of Voice over Internet Protocol (VOIP) services
exempt?

14\. Are mobile telephony service resellers exempt?

[Determining the number of required
filings](#determining_the_number_of_required_filin)

15\. How many separate Form 477s must a reporting entity file?

16\. May ILEC and CLEC operations in a state be reported in a single
filing?

17\. May an ILEC make a single filing for multiple affiliated study
areas in a state**?**

[Filing_procedures](#filing_procedures)

[18. Is there a fee to file Form 477?](#filing_procedures)

19\. May I get an extension of time to file?

20\. Are there penalties for not filing Form 477?

21\. What happens if March 1 or September 1 falls on a holiday or
weekend?

22\. How are completed Form 477s submitted?

23\. May paper copies of Form 477 be submitted?

24\. Must redacted versions of the forms be submitted when the filer
asserts data are privileged and confidential?

25\. What is the Certification Statement and how is it submitted?

26\. May a single Certification Statement cover multiple Form 477s?

27\. May the same person sign the Certification Statement and be
identified on it as the contact person for the filing?

[Holding_companies, affiliates,
etc](#Holding_companies_affiliates_etc)[.]{.underline}

28\. Does nationality of an entity's holding company affect the
requirement to file Form 477?

29\. Which entity is responsible for filing Form 477 if a change of
control has occurred?

30\. How do joint ventures, partnerships, etc. avoid double-reporting
connections, lines, or subscribers?

31\. If my firm is a partner in a mobile telephony partnership and the
operator of the partnership files a Form 477 to report subscribers
served by the partnership, do I also have to file a Form 477 to report
all or a portion of the partnership's subscribers?

[Estimating_data](#Estimating_data)

[32. What if a provider has no basis for making an estimate specified in
the form?](#Estimating_data)

# [Selected terms](#selected_terms)

[33. What is the difference between](#selected_terms) *facilities-based*
broadband connections and connections that are provided over *own local
loop facilities*?

34\. How is broadband "speed" measured?

35\. Which broadband connections are *residential*?

36\. Which voice telephone service lines are *residential*?

37\. How does *other resale* differ from *Total Service Resale*?

[Reporting by cable TV system
operators](#reporting_by_cable_tv_system_operators)

[38. Should a cable TV system operator report the number of cable modem
service](#reporting_by_cable_tv_system_operators) *subscribers* it
actually has, or should it report the extent to which its cable modem
service is *available* to potential subscribers?

[Reporting by providers of DSL
connections](#reporting_by_providers_of_dsl_connection)

[39. Are asymmetric DSL connections and symmetric DSL connections
reported separately?](#reporting_by_providers_of_dsl_connection)

40\. Are providers of DSL connections required to report the extent to
which their broadband DSL connections are *available* to potential end
users?

41\. A LEC provides some "ISDN speed" DSL connections that operate at
about 128 kbps. Should they be reported on Form 477?

42\. Which entity in a holding company structure reports broadband DSL
connections when the LEC subsidiary owns the underlying "last mile"
facilities that terminate at the end-user premises?

[Reporting by
satellite_service_providers](#Reporting_by_satellite_service_providers)

[43. Should satellite services that transmit information to end users at
rates greater than 200 kbps in at least one direction be
reported?](#Reporting_by_satellite_service_providers)

[ZIP Code information](#ZIP_Code_information)

44\. Are the number of connections, lines, or subscribers reported for
individual ZIP Codes?

45\. What ZIP Code information must broadband providers report?

46\. How do terrestrial mobile wireless broadband providers report ZIP
Codes?

47\. What ZIP Code information must LECs report?

48\. What ZIP Code information must mobile telephony providers report?

[Reporting the number of voice telephone service lines provided to end
users](#reporting_the_number_of_voice_telephone_)

49\. What is *voice telephone service* for purposes of Form 477?

> 50\. How are voice telephone service lines counted for purposes of
> Form 477?

[Reporting unbundled network elements (UNEs) *provided to* other
entities](#reporting_unes_provided_to_other_entitie)

[51. Are LECs required to report the number of UNE loops they
provide?](#reporting_unes_provided_to_other_entitie)

52\. Are LECs required to report the number of UNE-Platform arrangements
they provide?

53\. How does an ILEC report UNE loops that it provides to its non-ILEC
affiliate?

54\. How are commercial agreements that replace expiring UNEs reported?

[Reporting unbundled network elements (UNEs) *obtained from* other
entities](#reporting_unbundled_network_elements)

55\. How are UNE loops *obtained from* other entities reported when they
are used to provide broadband connections?

56\. How are UNE loops *obtained from* other entities reported when they
are used to provide voice telephone service?

57\. Should inside wire subloop UNEs be reported?

# [Reporting_resold_lines](#reporting_resold_lines-1)

[58. How are resold connections, lines, or services reported on Form
477?](#reporting_resold_lines-1)

# [Reporting_private_lines](#reporting_private_lines-1)

[59. Should lines that are used in a corporate or other private,
defined-use network be reported on Form
477?](#reporting_private_lines-1)

[Reporting special access lines](#Reporting_special_access_lines)

60\. Where on the form do LECs report special access lines that they
provide?

61\. A LEC provides a high-capacity circuit (e.g., private line or
special access line) between an end user and an unaffiliated carrier,
but doesn't know how that circuit is deployed. How should it be
reported?

62\. My firm leases special access lines *from* other carriers and uses
them to provide 800 service and similar toll services to its own
end-user customers. Should it report those special access lines on Form
477?

# [Reporting_by mobile_telephony_service providers](#Reporting_mobile_telephony_subscribers)

63\. What is the definition of *mobile telephony subscriber*?

64\. Who reports pre-paid mobile telephony subscribers?

65\. Who reports subscribers that are billed by mobile telephony service
resellers?

66\. What is the difference between columns (a) and (b) in the Mobile
Local Telephone part of the form?

67\. How should mobile telephony subscribers be reported when a business
purchases service for a number of employees?

68\. Where do mobile wireless providers report their use of broadband
PCS spectrum?

\* \* \* \* \* \* \* \* \* \*

[Overview]{.underline}

[]{#overview .anchor}1. **What is the purpose of this form?**

The information collected on Form 477 provides June 30 and December 31
snapshots of the extent of broadband deployment and local telephone
competition throughout the United States. The information is
incorporated into the Commission's reports to Congress on broadband
deployment as it affects all Americans -- including those who live in
rural, sparsely populated areas. It assists the Commission in
identifying regulations that should be modified or are not necessary.
Twice each year, the Commission publishes the information collected on
Form 477 in an aggregated format to inform the public and policymakers
about trends in broadband and local telephone competition while
protecting the competitively sensitive information of individual filers.

2\. **Where can I get a blank copy of the form?**

For each semiannual filing, a blank Form 477 and detailed reporting
instructions are posted at
[www.fcc.gov/formpage.html#477](http://www.fcc.gov/formpage.html#477)
several weeks before the filing due date. Form 477 is an Excel
spreadsheet. The detailed reporting instructions, which include the
required Certification Statement, are in a separate Adobe Acrobat file.
Filers who are not able to download or use these materials should e-mail
477INFO@fcc.gov for assistance or contact a member of the FCC Form 477
team at (202) 418-0940 or via TTY at (202) 418-0484.

3\. **How often is Form 477 due?**

Twice each year -- on March 1 and on September 1:

-   The March 1 filing reports data as of the preceding December 31 (the
    December snapshot).

-   The September 1 filing reports data as of June 30 (the June
    snapshot).

Completed forms are due at the FCC on the due date. See FAQ #21 about
holidays. See FAQ #22 about using e-mail to file completed forms. A
filing may be submitted prior to its due date as long as it is submitted
on the form that was posted on the FCC's website for use in that
particular semiannual filing. See also FAQ #2.

4\. **Who must file it?**

The form must be filed by the following entities:

-   ***Facilities-based*** providers of ***broadband*** connections to
    end-user locations. (See FAQ #5 for definitions of these terms.)
    These entities will answer some questions in Part I of the form and
    some questions in Part V. Note that a facilities-based broadband
    provider may -- or may not -- have a retail relationship with the
    end user of the broadband connection. Also note that some retailers
    of high-speed Internet-access service are not facilities-based
    broadband providers for purposes of Form 477. (See FAQ #10 regarding
    ISPs.)

-   Local exchange carriers (LECs), including resellers as well as
    facilities-based carriers. Incumbent LECs (ILECs) and competitive
    LECs (CLECs) will answer some or all of the questions in Part II of
    the form and column (j) of Part V.

-   Commercial mobile radio service (CMRS) providers that serve mobile
    telephone service subscribers using spectrum for which the CMRS
    provider (or its affiliate) holds a license, or using spectrum that
    it manages for or leases from a spectrum licensee. These
    *facilities-based* entities must answer the two questions in Part
    III of the form. Entities that only resell mobile telephone service
    do not file Form 477; instead, the subscribers to the resold mobile
    telephone service are reported by the underlying, facilities-based
    carrier.

There are no exceptions to filing based on the number of connections,
lines, or subscribers. However, many filers will find that they are not
required to complete all sections of the form.

5\. **What is a *facilities-based* entity and what is *broadband* in
this data collection?**

With respect to Part I of Form 477, a ***facilities-based*** entity is
an entity (including subsidiaries and affiliates) that: owns the portion
of the physical facility that terminates at the end-user location as a
broadband connection; provisions/equips broadband wireless channels to
end-user locations over licensed spectrum or over spectrum that the
entity uses on an unlicensed basis; or obtains unbundled network
elements (UNEs), special access lines, or other leased facilities that
terminate at end-user locations and provisions/equips them as broadband.
This entity may -- or may not -- have a retail relationship with the end
user of the broadband connection. A ***broadband*** connection is a line
(or wireless channel) that terminates at an end-user location and
enables the end user to receive information from and/or send information
to the Internet at information transfer rates exceeding 200 kilobits per
second (kbps) in at least one direction.

6\. **Is there a glossary of terms used in this data collection?**

Part VI of the detailed reporting instructions is a glossary of selected
terms that appear on Form 477. See also FAQs #33--37. Filers must
interpret terms in the specific context of the detailed reporting
instructions.

[Return_to_Table_of_Contents](#Return_to_Table_of_Contents)

[]{#Exemptions_from_filing_Form_477 .anchor}[Exemptions from
filing]{.underline}

7\. **Are Broadband-over-Powerline (BPL) providers exempt?**

No. Access BPL broadband connections must be reported in Line A.I-9 of
Part I of the form. The responsibility to file Form 477 rests with the
entity that provides the broadband connection over facilities that it
owns, or over facilities that it has leased from an unaffiliated entity
and equipped to deliver information to and/or from the end-user premises
at broadband speeds. This entity may -- or may not -- have a retail
relationship with the end user. The number reported in Line A.I-9 should
include any Access BPL connections that are substantially deployed over
medium voltage power delivery lines but that make the "last hop" to the
subscriber premises using Wi-Fi or other fixed wireless technology as
well as Access BPL connections that are deployed over power delivery
lines all the way to the subscriber premises. In-house BPL applications
that only enable local distribution and sharing of a premises broadband
connection *should not* be reported anywhere on Form 477.

8\. **Are Wireless Internet Service Providers (WISPs) exempt?**

No. Entities that provide broadband connections to end user locations
*by using spectrum on an unlicensed basis* for the "last hop" to the end
user location must report information about those connections. Typically
this is done by completing the questions for broadband category 7
("terrestrial fixed wireless") in Part I of the form and also filling in
column (f) in Part V of the form. (If broadband connections are reported
in another technology category, such as "terrestrial mobile wireless,"
please put a brief explanatory note into Part IV of the form.) A WISP
should consider the user data rate (as opposed to the over-the-air raw
data rate, for example) when determining whether connections are
broadband for purposes of Form 477. (A broadband connection enables the
end user to receive information from and/or send information to the
Internet at information transfer rates exceeding 200 kbps in at least
one direction. See also FAQ #5.)

A WISP *should not* report subscribers to its broadband Internet-access
service when that service is delivered over a broadband connection to
the end user location that the WISP, or the WISP's customer, has
obtained from an unaffiliated entity such as a municipality, public
utility district, or DSL service provider ("DSL wholesaler.") The
underlying, facilities-based providers of wired broadband connections to
end user locations are responsible for reporting them, and any
particular broadband connection should be reported only once in this
data collection. See also FAQ #10.

Part II and Part III of Form 477 -- which are the parts of the form
where information about local telephone service is collected -- may not
apply to particular WISPs:

-   Only WISPs that are authorized (by the WISP's state
    telecommunications regulator) to operate as a CLEC need to consider
    Part II of the form, and they should also see FAQ #13.

```{=html}
<!-- -->
```
-   Only WISPs that offer mobile telephone service as commercial mobile
    radio service (CMRS) providers need to consider Part III of the
    form. Note that CMRS providers typically hold or operate spectrum
    licenses for cellular, PCS, or SMR services.

9\. **Are municipal, other governmental, or non-profit broadband
providers exempt?**

No. A municipal, other governmental, or non-profit entity may be a
*facilities-based* broadband provider for purposes of Form 477. See FAQ
#5.

10\. **Are Internet Service Providers (ISPs) exempt?**

An ISP that obtains a broadband connection or service from an
unaffiliated entity, which it incorporates into its own high-speed
Internet-access service, is exempt from reporting broadband connections
in Part I of Form 477. Instead, the obligation to report the broadband
connection rests with the underlying facilities-based provider. (If the
entities are affiliated, they may mutually agree that the ISP will
report the broadband connections on a Form 477 that it files. If so, the
ISP must report that the broadband connections are provided over its
"own local loop facilities" to the same extent that the underlying
facilities-based provider would report that information.) WISPs should
see FAQ #8.

11\. **Are cable TV operators and direct broadcast satellite (DBS)
operators exempt?**

Entities that provide *only* cable TV services or *only* direct
broadcast satellite (DBS) video services *should not* file Form 477
because they provide neither broadband connections (e.g., cable modem
service; satellite-based high-speed Internet access service) nor local
telephone service. (More specifically, cable TV services that *should
not* be reported on Form 477 are analog video services and advanced
video services, including digital video, video-on-demand, digital video
recorders, and high-definition television.) Cable TV operators that do
provide cable modem service should see FAQ \# 38. DBS operators that do
provide high-speed Internet access service should see FAQ \# 43.

12\. **Are providers of long distance telephone service** **exempt?**

Telecommunications carriers that provide *only* long distance telephone
services should not file Form 477. However, a LEC must report the extent
to which it (or its affiliate) is the presubscribed *interstate* long
distance carrier for the local telephone service lines that it provides
to its own end-user customers. Specifically, a LEC must report, in
column (c) of Part II, the extent to which it (or its affiliate) is the
presubscribed interstate long distance carrier for *all* the local
telephone lines it provides to its own end-user customers. And, in
column (d) of Part II, the LEC must report the extent to which it (or
its affiliate) is the presubscribed interstate long distance carrier for
lines it provides to its own *residential* end-user customers. (See #36
for residential definition.)

13\. **Are providers of Voice over Internet Protocol (VOIP) services
exempt?**

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, *Notice of Proposed Rulemaking*, 19 FCC Rcd 4863 (2004). When the
Commission adopted modifications to the Form 477, in November 2004, it
rejected suggestions that it add questions soliciting information about
local telephone service as provided by entities exclusively utilizing
VOIP. The Commission noted that entities that are filing local telephone
service information on Form 477 may already include information about
VOIP service in their filings.

14\. **Are mobile telephony service resellers exempt?**

Entities that solely resell mobile telephony services should not file
Form 477. Instead, subscribers to resold cellular, PCS, and other mobile
telephony services must be reported by the entity whose facilities serve
them. (See also FAQ #65.)

[Return_to_Table_of_Contents](#Return_to_Table_of_Contents)

[Determining the number of required filings]{.underline}

[]{#determining_the_number_of_required_filin .anchor}15. **How many
separate Form 477s must a reporting entity file?**

An entity that is subject to the reporting requirements of Form 477 (see
FAQ #4) must file at least one form for each state in which it operates.
If the entity has both ILEC and other operations in the state, it must
file at least two forms for that state. Information for ILEC and for
non-ILEC operations may not be combined on a single form. The entity
must use the identical "parent or controlling entity" name in item 3 of
the Cover Page section of each Form 477 it files.

16\. **May ILEC and CLEC operations in a state be reported in a single
filing?**

No. Information about ILEC and non-ILEC operations must be reported on
separate forms.

17\. **May an ILEC make a single filing for multiple affiliated study
areas in a state?**

Yes. And similarly, a holding company that has several non-ILEC
operations in a state (for example, a CLEC and a cable TV system), may
report information for all its non-ILEC operations, in that state, on a
single form.

[Return_to_Table_of_Contents](#Return_to_Table_of_Contents)

[Filing procedures]{.underline}

[]{#filing_procedures .anchor}18. **Is there a fee to file Form 477?**

No, there is no filing fee for Form 477.

19\. **May I get an extension of time to file?**

It is the policy of the Commission that extensions of time shall not be
routinely granted (*see* 47 C.F.R. 1.46(a)). Entities required to file
Form 477 should file by the filing due date and make a revised filing if
significantly different data become available after that date. (What
constitutes significantly different data is discussed on page 13 of the
detailed reporting instructions, under "Obligation to File Revisions.")

20\. **Are there penalties for not filing Form 477?**

Entities that are required to file Form 477 but fail to do so may be
subject to the enforcement provisions of the Communications Act and any
other applicable law. In particular, the Commission has authority
pursuant to sections 502 and 503 of the Communications Act to enforce
compliance by fine or forfeiture.

21\. **What happens if March 1 or September 1 falls on a holiday or
weekend?**

The filing is due the next business day.

22\. **How are completed Form 477s submitted?**

Completed Form 477s must be submitted on electronic media. Filers are
encouraged to deliver completed Form 477s as attachments to one or more
e-mail messages sent to FCC477@fcc.gov. The FCC has established this
mailbox with limited access to only those within the FCC required to
participate in the filing process. See also FAQ #25 about submitting the
required Certification Statement.

Filers who prefer to do so may -- alternatively -- submit completed Form
477s on IBM-format compact discs or floppy diskettes, along with the
signed original copy of the Certification Statement, via private
overnight delivery service or by hand or messenger delivery. See page 11
of the detailed reporting instructions (posted at
[www.fcc.gov/formpage.html#477](http://www.fcc.gov/formpage.html#477))
for the address to use for private overnight delivery, and the separate
address to use for hand or messenger delivery. Do not use United States
Postal Service First Class, Express, or Priority Mail because discs and
diskettes may be damaged by irradiation (cleaning). **Use only one**
filing method; do not make duplicate filings.

23\. **May paper copies of Form 477 be submitted?**

Paper copies of completed Form 477s may not be submitted. Filers who are
not able to use any of the filing methods discussed in FAQ #22 should
e-mail 477INFO@fcc.gov for assistance or contact a member of the FCC
Form 477 team at (202) 418-0940 or via TTY at (202) 418-0484.

24\. **Must redacted versions of the forms be submitted when the filer
asserts data are privileged and confidential?**

No. The FCC no longer accepts redacted versions of Form 477 filings. The
filer asserts data are confidential by selecting "Filer certifies that
some data in this report is privileged and confidential" from the
drop-down box for Question 8 of the Cover Page part of the form.

25\. **What is the Certification Statement and how is it submitted?**

The Certification Statement is the single page (page 14) that
constitutes Section V of the detailed reporting instructions, which are
posted as an Adobe Acrobat file at
[www.fcc.gov/formpage.html#477](http://www.fcc.gov/formpage.html#477).
It must be signed by an officer of one of the legal entities whose data
are being reported. The completed and signed statement may be faxed to
(202) 418-0520, or it may be scanned and attached to an e-mail sent to
FCC477@fcc.gov (separately, or along with one or more completed Form
477s). However, filers may not cut-and-paste or otherwise incorporate an
electronic version of the Certification Statement into a Form 477
spreadsheet. Filers who prefer to deliver their Form 477s on compact
discs or floppy diskettes should submit the signed original copy of the
Certification Statement at the same time; see FAQ #22.

26\. **May a single Certification Statement cover multiple Form 477s?**

Yes. A single Certification Statement covers the precise number of Form
477s (i.e., individual spreadsheet files) that the filer specifies on
the statement next to "Number of files provided for this reporting
period."

27\. **May the same person sign the Certification Statement and be
identified on it as the contact person for the filing?**

The officer who signs the Certification Statement may also be the
Contact Person for the filing. In that case, Commission staff will
contact that officer if there are any follow-up questions about details
of the filing.

[Return_to_Table_of_Contents](#Return_to_Table_of_Contents)

[]{#Holding_companies_affiliates_etc .anchor}[Holding companies,
affiliates, etc.]{.underline}

28\. **Does nationality of an entity's holding company affect the
requirement to file Form 477?**

No.

29\. **Which entity is responsible for filing Form 477 if a change of
control has occurred?**

The successor entity is responsible if there has been a change of
control between the "data as of" date (e.g., June 30, 2005) and the
filing due date (e.g., September 1, 2005).

30\. **How do joint ventures, partnerships, etc. avoid double-reporting
connections, lines, or subscribers?**

To avoid possible double-reporting of information, it may be advisable
for a joint venture or partnership to file a separate Form 477, in which
case it would identify itself as the filing "company" in Question 1 of
the Cover Page part of the form. The controlling owner, senior partner,
or operating partner would be reported as the "parent of controlling
entity" in Question 3 of the Cover Page part of the form, and any
necessary additional explanation could be provided in Part IV
("Explanations and Comments") of the form.

31\. **If my firm is a partner in a mobile telephony partnership and the
operator of the partnership files a Form 477 to report subscribers
served by the partnership, do I also have to file a Form 477 to report
all or a portion of the partnership's subscribers?**

No. The partnership's mobile telephony subscribers (i.e., activated,
revenue-generating handsets) should be reported only once, and by a
single entity. The partnership's subscribers should not be apportioned
among owners of the partnership. Because the operator of the partnership
is reporting, you should not include the partnership's subscribers in
any Form 477 that you file to report mobile telephony subscribers.

[Return_to_Table_of_Contents](#Return_to_Table_of_Contents)

[Estimating data]{.underline}

[]{#Estimating_data .anchor}32. **What if a provider has no basis for
making an estimate specified in the form?**

Because providers may not collect data in a manner that precisely fits a
particular percentage breakout of connections, lines, or subscribers,
the detailed reporting instructions allow these providers to make good
faith estimates (i.e., estimates accurate within plus or minus five
percentage points) based on databases maintained in the usual course of
business, or on demographic or other studies done for business purposes
such as the preparation of marketing plans or facilities deployment.
(See "General Note about Reporting Percentage Breakouts" on pages 4-5 of
the detailed instructions.) If these sources of information are
insufficient, a provider should analyze a sufficiently large sample of
its customer accounts or its other accounts to determine the
relationship between the requested estimate and the data that the
provider does have or can easily obtain in the usual course of business.

[Return_to_Table_of_Contents](#Return_to_Table_of_Contents)

[Selected terms]{.underline}

[]{#selected_terms .anchor}33. **What is the difference between
*facilities-based* broadband connections and connections that are
provided over *own local loop facilities*?**

In Part I.A of the form, any broadband connections to end-user locations
that the reporting entity provisioned over UNEs, special access lines,
or other leased facilities that it obtained from another entity and
provisioned as broadband *should* be included among the total
connections reported in column (a), but they *should not* be included in
the percentage of connections provisioned over own local loop facilities
that is reported in column (c) unless the UNEs, special access lines, or
other leased facilities were obtained from an *affiliated* entity.
(ILECs and their affiliates should also see FAQ #53.) *Own local loop
facilities*, for purposes of Form 477, means those wired "last mile"
facilities that the filer (including affiliates) actually owns as well
as facilities that the filer obtains the right to use from unaffiliated
entities as dark fiber or satellite transponder capacity (and that the
filer uses as part of its own system), and also wireless connections to
end-user locations that the filer provisions/equips over licensed
spectrum or over spectrum that the filer uses on an unlicensed basis.

34\. **How is broadband "speed" measured?**

In Part I.A of the form, facilities-based providers of broadband
connections must place the connections into "speed" categories. To do
this, the provider should consider the end user's authorized maximum
information transfer rate on that connection. The Commission expects
broadband providers to be mindful of general consumer protection law and
to advertise their services with sufficient accuracy to enable end users
to select the offering -- as distinguished by "speed tier" and other
features -- that best fits the end user's needs and budget. The
Commission does not require reporting entities to measure the
information transfer rates actually observed by end users of particular
broadband connections.

35\. **Which broadband connections are *residential*?**

For purposes of Form 477, 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. Such Internet-access services may differ in
price, "speed tier," or other features from Internet-access services
that are primarily purchased by, designed for, and/or marketed to
non-residential end users.

36\. **Which voice telephone service lines are *residential*?**

In Part II of Form 477, LECs are required to report the percentage of
voice telephone service lines (and wireless channels) they provide to
end users, in a state, that are used for *residential* service. To do
this, 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 and 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.

37\. **How does *other resale* differ from *Total Service Resale*?**

For purposes of Form 477, *other resale* means telephone services
provided to an *unaffiliated* carrier for resale to that carrier's own
end-user customers under an arrangement that is not *Total Service
Resale* (TSR). TSR is a specific form of resale in which the State
regulatory commission sets the wholesale rate based on the retail rate
less marketing, billing, collection, and other costs that will be
avoided, as provided for in sections 251(c)(4) and 252(d)(3) of the
Communications Act of 1934, as amended. Examples of *other resale*
include any negotiated commercial agreements that replace, or substitute
for, UNE-Platform, line-sharing, or other UNE arrangements with an
unaffiliated carrier. Examples of *other resale* also include using an
unaffiliated carrier's "channelized" tariffed special access circuits
(or tariffed private lines) to provide local telephone service to
end-user customers, or reselling an unaffiliated carrier's tariffed
Centrex service to end-user customers.

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[Reporting by cable TV system operators]{.underline}

[]{#reporting_by_cable_tv_system_operators .anchor}38. **Should a cable
TV system operator report the number of cable modem service
*subscribers* it actually has, or should it report the extent to which
its cable modem service is *available* to potential subscribers?**

In Part I.A of the form, a cable TV system operator must report the
actual number of broadband cable modem service subscribers that are
served over its system. It also must report, in Part I.B of the form,
the percentage of *residential* end-user premises, in its service area
in the state, to which its cable modem service is available (i.e., could
be provided using installed distribution facilities). For this purpose,
the "service area" consists of those residential end-user premises to
which the cable system can deliver cable TV service over its own
facilities.

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[Reporting by providers of DSL connections]{.underline}

[]{#reporting_by_providers_of_dsl_connection .anchor}39. **Are
asymmetric DSL connections and symmetric DSL connections reported
separately?**

Yes. Broadband *asymmetric* DSL connections are reported in Line I-1 of
Part I.A, while broadband *symmetric* DSL connections are reported in
Line I-2.

40\. **Are providers of DSL connections required to report the extent to
which their broadband DSL connections are *available* to potential end
users?**

Yes, if the facilities-based DSL provider is an ILEC, or is affiliated
with an ILEC. The percentage of *residential* premises, in the ILEC's
service area in the state, for which the filer's DSL connections are
available (i.e., could be provided using installed distribution
facilities) must be reported in Part I.B of the form. For this purpose,
the "service area" of the ILEC consists of those residential premises to
which the ILEC can deliver telephone service over local loop facilities
(or the fixed wireless last mile equivalent) that it owns.

41\. **A LEC provides some "ISDN speed" DSL connections that operate at
about 128 kbps. Should they be reported on Form 477?**

No. Do not report on Form 477 any DSL connections for which the end
user's authorized maximum information transfer rate ("speed") is less
than 200 kbps in the faster direction. Do not include these connections
when reporting the number of broadband connections to end-user premises,
in Part I.A of the form. Also, do not include these connections when
reporting, in Part I.B of the form, the extent to which an ILEC's DSL
connections are *available* to residences within its service area.

42\. **Which entity in a holding company structure reports broadband DSL
connections when the LEC subsidiary owns the underlying "last mile"
facilities that terminate at the end-user premises?**

The responsibility to report broadband DSL connections on Form 477 rests
with the subsidiary or affiliate that provisions/equips the connection
as DSL (e.g., the entity within the holding company structure that owns
the "DSLAM" that equips, as DSL, the physical facility that terminates
at the end-user location). This particular entity may -- or may not --
have a retail relationship with the end user at whose premises the DSL
connection terminates. For example, if an ILEC has a non-ILEC affiliate
that owns the DSLAMs that equip "local loops" that the ILEC owns, then:
the non-ILEC must report the broadband DSL connections, and it must
report that they are provisioned 100 percent over "own local loop
facilities." The non-ILEC must also report the percentage of the
broadband DSL connections that terminate at residential end-user
premises. (See FAQ #35 for definition of "residential" in this context.)

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[Reporting by satellite service providers]{.underline}

[]{#Reporting_by_satellite_service_providers .anchor}43. **Should
satellite services that transmit information to end users at rates
greater than 200 kbps in at least one direction be reported?**

The newer one-way and two-way satellite services designed to offer
primarily residential consumers Internet connectivity should be reported
as they go into service.

With respect to VSAT (i.e., Very Small Aperture Terminal) services, we
note that these services were introduced a number of years prior to
enactment of the 1996 Act and were initially deployed in corporate and
other private, defined-use networks. Such services should be reported
only to the extent that a particular end-user terminal allows an end
user to connect to the public Internet (at a rate greater than 200 kbps
in at least one direction) on demand (e.g., without advance scheduling).
Absent such enabled, in-service capability, an end-user terminal
deployed in a corporate network, "intranet", or "extranet" connecting a
defined set of entities, such as affiliates, franchisees, contractors,
or suppliers, should not be reported.

Additionally, when a VSAT end user with enabled, in-service connectivity
to the public Internet, as described above, has a satellite terminal
that also connects the end user to a corporate network, intranet, or
extranet, that terminal should be considered to serve a large business
customer (i.e., it should [not]{.underline} be included in the
percentage residential reported in column (b) and column (e) of Line
A.I-6).

ZIP Codes listed in Part V of the form should be the locations of the
end-user terminals. See also FAQ #45.

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[]{#ZIP_Code_information .anchor}[ZIP_Code_information]{.underline}

44\. **Are the number of connections, lines, or subscribers reported for
individual ZIP Codes?**

No; the number of connections, lines, or subscribers are reported *by
state*. Form 477 filers -- including any entities that operate in only
one ZIP Code in a state -- should note that they can request
non-disclosure of their data about connections, lines, or subscribers by
selecting "Filer certifies that some data in this report is privileged
and confidential" from the drop-down box for Question 8 of the Cover
Page part of the form.

45\. **What ZIP Code information must broadband providers report?**

An entity that reports any broadband connections in Part I.A of the form
must also report, in Part V of the form, *technology-specific* lists of
those ZIP Codes in the state in which the filer provides *at least one*
broadband connection that is *in service* to an end-user location. For
example, column (a) of Part V must contain a list of those ZIP Codes in
the state in which the filer has at least one asymmetric DSL connection
in service to an end-user location. The filer may -- or may not -- have
a retail relationship with that end user. It is very important to note
that these *are not* lists of ZIP Codes where the filer's broadband
connections are *available*. (Mobile wireless broadband providers are an
exception; see FAQ #46.)

46\. **How do terrestrial mobile wireless broadband providers report ZIP
Codes?**

In column (g) of Part V of Form 477, terrestrial mobile wireless
broadband providers must list the ZIP Codes, in the state, in which
their mobile wireless *broadband* service is advertised and available to
actual and potential subscribers. (This is an exceptional case among
broadband providers that must file Form 477; all other broadband
providers see FAQ #45.)

47\. **What ZIP Code information must LECs report?**

In column (j) of Part V of Form 477, a LEC must list the ZIP Codes, in
the state, in which it has *at least one* end-user customer for its
voice telephone service. It is important to note that this *is not* a
list of the ZIP Codes where the filer's voice telephone service is
*available*.

48\. **What ZIP Code information must mobile telephony providers
report?**

Mobile telephony carriers, as such, do not list ZIP Codes on Form 477.
But mobile telephony carriers that also provide terrestrial mobile
wireless *broadband* services should see FAQs #46.

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[Reporting the number of voice telephone service lines provided to end
users]{.underline}

[]{#reporting_the_number_of_voice_telephone_ .anchor}49. **What is
*voice telephone service* for purposes of Form 477?**

For Form 477, *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, whether used by the end
user for voice telephone calls or for other types of calls carried over
the public switched network (for example, fax transmissions and dial-up
connections to the Internet).

50\. **How are voice telephone service lines counted for purposes of
Form 477?**

Voice telephone service lines provided to the filing carrier's own
end-user customers (reported in item II-1 of Part II) and also lines
provided to unaffiliated carriers for resale to end users (reported in
items II-2 and II-3 of Part II) must be counted in *voice-grade
equivalents (VGE*) based on the services that the end user is paying
for. Therefore, voice telephone service lines 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. For example:

-   A traditional analog telephone line is one (1) VGE.

-   A Centrex-CO extension is one (1) VGE.

-   A Centrex-CU trunk is one (1) VGE.

-   A BRI (Basic Rate Integrated Services Digital Network) line
    provisioned as 2B+D is two (2) VGE.

-   A T-1/DS1 circuit provisioned as 8 local trunks is 8 VGE.

-   A fully channelized T-1/DS1 circuit is 24 VGE.

-   A fully channelized PRI (Primary Rate Integrated Services Digital
    Network) line over which an ISP's *dial-up* customers connect to the
    Internet (i.e., via a personal computer, a *local-area* telephone
    number that the ISP uses as an access number, and a standard modem
    connection) is 23 VGE.

-   A T-1/DS1 circuit provisioned as 8 voice channels and one broadband
    connection to the Internet, with any of the unused voice channels to
    be dynamically allocated for Internet use, is 8 VGE for purposes of
    Part II of the form. Note that, in this example, the end user also
    has one (1) broadband connection with an information transfer rate
    that is greater than 200 kbps and less than 2.5 mbps. (The amount of
    capacity available for Internet use is at least 16 of the potential
    24 voice-grade channels, or about 1.0 mbps.) If the carrier that
    provides these services to the end user owns the T-1/DS1 circuit,
    rather than leasing it from an unaffiliated entity, then it also
    should report one (1) broadband connection in Part I.A of the form
    (in response to item I-3) because it is the facilities-based
    provider of that broadband connection.

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[Reporting unbundled network elements (UNEs) *provided to* other
entities]{.underline}

[]{#reporting_unes_provided_to_other_entitie .anchor}51. **Are LECs
required to report the number of UNE loops they provide?**

The number of UNE loop arrangements (i.e., UNE loop without switching
for that line) provided to *unaffiliated* carriers must be reported in
Part II.C of the form, in response to item II-4. Each of the following
should be counted as one (1) line:

-   A UNE loop irrespective of its capacity (e.g., a DS0 UNE loop, a DS1
    UNE loop, and a DS3 UNE loop each count as one line).

-   A UNE loop provided to a carrier that engages in "line splitting"
    with a third carrier (e.g., one CLEC uses the high-frequency (data)
    portion of the loop and another CLEC uses the low-frequency (voice)
    portion).

-   A high-frequency (data) portion of a loop provided under a
    "line-sharing" UNE arrangement.

Carriers that have replaced UNE arrangements with negotiated commercial
agreements should see FAQ #54.

52\. **Are LECs required to report the number of UNE-Platform
arrangements they provide?**

The number of UNE-Platform arrangements (i.e., the combination of loop
UNE, switching UNE, and transport UNE) provided to *unaffiliated*
carriers must be reported in Part II.C of the form, in response to item
II-5. Lines provided to unaffiliated carriers under commercial
agreements that replace, or substitute for, UNE-Platform arrangements
should be reported, instead, in Part II.B, in response to item II-3
(*other resale*).

53\. **How does an ILEC report UNE loops that it provides to its
non-ILEC affiliate?**

The ILEC should not report on Form 477 any UNE loops that it provides to
its non-ILEC affiliate. Rather, for purposes of Form 477, the non-ILEC
affiliate must report the UNE loop as its own local loop. For example,
if the non-ILEC affiliate equips the UNE loop as a DSL connection, then
it must report that DSL connection in Part I.A of the form -- and must
include that connection in the percentage of reported DSL connections
that are provided over its "own local loop facilities" (reported in
column (c) of Part I.A). If the affiliate is a CLEC that uses the UNE
loop to provide a voice telephone service line to an end user, the CLEC
affiliate must report the line in Part II.A of the form -- and must
include the line in the percentage of lines provided over own loop
facilities (reported in column (e) of Part I.A).

54\. **How are commercial agreements that replace expiring UNEs
reported?**

Lines provided to *unaffiliated* entities under commercial agreements
that replace or substitute for UNE-Platform or other UNE arrangements
must be reported in Part II.B of the form, in the response to item II--3
(*other resale*).

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[Reporting unbundled network elements (UNEs) *obtained from* other
entities]{.underline}

[]{#reporting_unbundled_network_elements .anchor}55. **How are UNE loops
*obtained from* other entities reported when they are used to provide
broadband connections?**

An entity that obtains a UNE loop from an *unaffiliated* entity and
provisions/equips the UNE loop as broadband must report that connection
in Part I.A of the form. Entities that obtain UNE loops from
*affiliated* entities should also see FAQ #42.

56\. **How are UNE loops *obtained from* other entities reported when
they are used to provide voice telephone service?**

UNE loops, as well as any line-sharing or line-splitting UNEs, obtained
from other entities and used to provide voice telephone service to the
filer's own end-user customers must be included in Part II of the form
-- in column (a) of the response to item II--1. If the UNE loop was
obtained as a high-capacity (e.g., DS1) UNE and "channelized" into a
number of voice-grade (DS0) channels, the filer must report the number
of voice-grade channels (derived from that UNE) that its end user has
purchased. If UNE loops were obtained from an *unaffiliated* entity, the
end-user lines provisioned over them must be included in the percentage
of end-user lines "provided over UNE loops obtained without UNE
switching" (in column (f) of item II-1). If an *affiliated* entity owns
the UNE loops, the end-user lines derived from them must be included,
instead, in the percentage of end-user lines "provided over your own
local loop facilities" (in column (e) of item II--1).

57\. **Should inside wire subloop UNEs be reported?**

No, inside wire UNEs *should not* be reported separately on Form 477.
If, for example, a carrier *obtained both* a loop UNE and an inside wire
UNE from an unaffiliated carrier and used them to provide a voice
telephone service line to its own end-user customer in a multiunit
premises, it should count that as one line provided over a UNE loop (in
its responses to item II-1 of Part II of the form). Meanwhile, the
unaffiliated carrier that *provided* these UNEs should report that it
provided one line under a UNE loop arrangement (in its response to item
II-4 of Part II.) If, alternatively, the carrier owned the local loop
facility that terminates at the multiunit premises, and connected it to
an inside wire UNE that it *obtained from* an unaffiliated carrier, then
it should count that line as one end-user line provided over its "own
local loop facilities" (in its responses to item II-1 of Part II). In
this case, the unaffiliated carrier that *provided* (solely) the inside
wire UNE *should not* report it in its own Form 477 filing.

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[Reporting resold lines]{.underline}

[]{#reporting_resold_lines-1 .anchor}58. **How are resold connections,
lines, or services reported on Form 477?**

Resellers of broadband connections -- for example, an ISP that
incorporates a non-affiliated entity's broadband connection or service
into its own high-speed Internet access service -- *should not report*
broadband connections on Form 477. Instead, the facilities-based
provider of the connection is responsible for reporting it (in Part I.A
of the form).

Resellers of voice telephone service lines (or wireless channels)
*should report* -- in Part II.A of the form -- the number of resold
lines that they provide to their own end-user customers. And all LECs
report -- in column (h) of Part II.A -- the extent to which they rely on
resale to serve their own end-user customers. The carrier that provides
the local telephone line to the (unaffiliated) reseller also reports it
-- but in Part II.B of the form.

Mobile telephony service resellers *should not report* the number of
subscribers to whom they resell service. Instead, the entity whose
facilities serve the subscriber is responsible for reporting the
subscriber (in Part III of the form).

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[Reporting private lines]{.underline}

[]{#reporting_private_lines-1 .anchor}59. **Should lines that are used
in a corporate or other private, defined-use network be reported on Form
477?**

No, do not report such lines in Form 477. Also, if a LEC is uncertain
whether a line it provides under a private line tariff or a special
access tariff is part of an end-user private or defined-use network, see
FAQ #61.

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[Reporting special access lines]{.underline}

[]{#Reporting_special_access_lines .anchor}60. **Where on the form do
LECs report the special access lines that they provide?**

Lines *provided to* unaffiliated carriers -- or to end users -- under
special access tariffs are not reported anywhere on Form 477 *if* the
line is solely used for exchange access (i.e., to deliver an end user's
telephone traffic to and/or from the end user's interexchange carrier).
However, if a LEC provides a "channelized" high-capacity circuit to an
*unaffiliated* CLEC under a special access tariff (or under a private
line tariff), which the CLEC uses to provide voice telephone service
lines ("DS0's") to its own end-user customers, then the ILEC should
include -- in its response to item II--3 of Part II.B of the form -- the
number of DS0 channels on that circuit that the CLEC has purchased.

61\. **A LEC provides a high-capacity circuit (e.g., private line or
special access line) between an end user and an unaffiliated carrier,
but doesn't know how that circuit is deployed. How should it be
reported?**

If a LEC provides a high-capacity circuit that connects an end user to
an *unaffiliated* communications carrier -- under a special access
tariff or a private line tariff -- but can't reasonably judge how the
circuit is being used (e.g., to carry voice traffic; for broadband
access to the Internet or other public data network; as part of an
end-user private or defined-use network) by reference to its business
databases or by using in-house product design, marketing, or other
information, then the LEC *should not* report the line anywhere in Form
477.

62\. **My firm leases special access lines *from* other carriers and
uses them to provide 800 service and similar toll services to its own
end-user customers. Should it report those special access lines on Form
477?**

No, do not report these lines anywhere on Form 477.

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[]{#Reporting_mobile_telephony_subscribers .anchor}[Reporting by mobile
telephony service providers]{.underline}

63\. **What is the definition of *mobile telephony subscriber*?**

For purposes of Form 477, a mobile telephony subscriber is a mobile
handset, car-phone, or other revenue-generating, active, voice unit that
has a unique phone number and that can place and receive calls from the
public switched network. This includes subscribers to satellite,
cellular, and PCS mobile telephony services, and units in service that
combine voice telephony with other services. This *does not* include
subscribers to dispatch, one-way or two-way paging services, or voice
services that permit communications between only a narrow range of
locations.

64\. **Who reports pre-paid mobile telephony subscribers?**

Pre-paid mobile telephony subscribers must be reported by the carrier
that uses its own facilities to serve them. (In this context, *own
facilities* means spectrum for which the carrier, including affiliates,
holds a license, manages, or has leased.) Such carriers must include
pre-paid subscribers among the subscribers they report in column (a) of
Part III of the form. And they must use the *area code* of the pre-paid
subscriber's mobile handset, car-phone or other revenue-generating,
active voice unit to determine the state for which the pre-paid
subscriber is reported.

65\. **Who reports subscribers that are billed by mobile telephony
service resellers?**

Entities that resell to end users the mobile telephony services of an
unaffiliated mobile telephony carrier *do not* file Form 477. Instead,
the underlying "wholesaler" carrier that uses its own facilities to
serve the reseller's subscribers must include them among the subscribers
it reports in column (a) of Part III of the form. (In this context, *own
facilities* means spectrum for which the carrier, including affiliates,
holds a license, manages, or has leased.) And it must use the *area
code* of the subscriber's mobile handset, car-phone or other
revenue-generating, active voice unit to determine the state for which
the subscriber is reported.

66\. **What is the difference between columns (a) and (b) in the Mobile
Local Telephone part of the form?**

In column (a) of Part III, a carrier should report the number of mobile
telephony subscribers (see FAQ #63) that are served over its own
facilities. (In this context, *own facilities* means spectrum for which
the carrier, including affiliates, holds a license, manages, or has
leased.) The number reported in column (a) should include subscribers
that are billed by unaffiliated mobile service resellers as well as
subscribers that the filer bills directly or serves on a pre-paid basis.
In column (b), the filer should report the number of subscribers that it
bills directly or serves on a pre-paid basis. Thus, if a
facilities-based mobile telephony carrier *does not* "wholesale" any
service to unaffiliated mobile wireless resellers (who in turn market
the service and bill subscribers), the correct entry in column (b) would
be 100 (percent).

67\. **How should mobile telephony subscribers be reported when a
business purchases service for a number of employees?**

Count as one subscriber each activated, revenue-generating mobile
handset, car-phone, or other voice unit that is billed to the business
customer. Use the *area code* of the phone number provided to the mobile
handset, car-phone or other voice unit to determine on which
state-specific Form 477 the subscriber must be reported.

68\. **Where do mobile wireless providers report their use of broadband
PCS spectrum?**

It depends on how the filer is using that spectrum. If the filer is
using its spectrum license to provide mobile telephony service, then the
subscriber must be reported in Part III of a Form 477 that's filed for
the state associated with the area code of the subscriber's mobile
handset. But, if the filer is using its spectrum license to provide a
mobile *broadband* service (see FAQ #5 for definition), then the
subscriber must be reported in Part I.A -- *if* the subscriber's billing
address is within an area where the filer's mobile wireless broadband
service is available. (The mobile wireless broadband subscriber must be
reported on a Form 477 that's filed for the state that appears in the
subscriber's billing address.)

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