# Presentation: 407876

## FCC Form 477
Data Collection Workshop

June 29, 2005

**Data Collection Workshop**
**June 29, 2005**

## 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

## 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?

## 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.

## 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.

## 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.

## Form 477 structure

## Part I:  Broadband - Who must file?

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

## 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.

## 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.

## 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.

## 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.

## 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.

## 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 Covad...that leases
-     phone lines from the regional phone companies...AOL
-     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@ $29.95/month
- 	                       3 megabits DSL@ $39.95/month
-                       “AOL Aims to Get Up to Speed with DSL”
-                                            Washington Post, 6/2/05

## 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 **Covad**...that leases
-     phone lines from the **regional phone **
**    ****companies**...AOL  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@ $29.95/month
- 	                       3 megabits DSL@ $39.95/month
-                       “AOL Aims to Get Up to Speed with DSL”
-                                            Washington Post, 6/2/05

## 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 AOL’s high-speed
-    Internet-access service.

## 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.

## 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).

## 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).

## 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 reseller’s
-    subscribers must be reported by the
-    underlying, facilities-based carrier.

## 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.

## 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 user’s
-       location.
-    - The state is not determined by the
-      “headquarters” location.
-   Information for ILEC and CLEC operations
-    may not be combined on a single form.

## Obtaining a blank form and the reporting instructions

- FCC Form 477 and detailed reporting instructions are available online at:  _[www.fcc.gov/formpage.html#477](http://www.fcc.gov/formpage.html#477)__. _
- FCC Form 477 is an Excel spreadsheet.  The instructions, which include the required Certification Statement, are found in a separate Adobe Acrobat file.

## How to submit a completed Form 477

- It is recommended that filers submit a complete Form 477 via email to: _[FCC477@fcc.gov](mailto:FCC477@fcc.gov)__.  Please remember to include the Form 477 as an attachment within the email._

## 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.

## 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 doesn’t have to be.

## How to submit a completed Certification Statement

- A completed Certification Statement can be sent to the Commission via:
-    1)  Fax to (202) 418-0520,
-    2)  Scan and attach it to an email sent to
-         _[FCC477@fcc.gov](mailto:FCC477@fcc.gov)__, or_
-    3)  Mail it to the Commission.

## 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.

## FCC Form 477 – Cover Page

## FCC Form 477 – Cover Page

## 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.

## How to properly name the Form 477 Excel file

## 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.

## 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.

## 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.

## 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.

## 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.

## 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).

## 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.

## 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).

## 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

## 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.

## 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.

## 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.

## 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).

## 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._

## 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.

## 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.)*

## 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.

## 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.

## 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*.

## 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.

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

- In column (h), carriers report the percentage of lines provided by reselling another carrier’s 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.

## 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).

## Who reports in SectionsB and C of Part II?

- Carriers _only_ report if they are providing lines to other carriers.

## How to fill out SectionsB 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.

## Part II.B of the form

- Voice telephone service that you provided to
- unaffiliated communications carriers,
- categorized by:
- II–2.  Lines and channels you provided to unaffiliated communications carriers under Total Service Resale arrangements.
- II–3.  Lines and channels you provided to unaffiliated communications carriers under other resale arrangements, such as resold Centrex or resold channelized special access service.

## Part II.C of the form

- UNE loops that you provided to unaffiliated
- communications carriers, categorized by:
- II–4.  Lines and channels that you provided to unaffiliated communications carriers under a UNE loop arrangement, where you did not provide switching for the line.
- II–5.  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”).

## 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))*.

## 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 subscriber’s billing address to determine the state)*.

## 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.

## 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.

## 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.

## 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 provider’s service is advertised and available to actual and potential subscribers.

## 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.

## Form 477 contact info.

- Resources
- Everything discussed today can be found at:  _[www.fcc.gov/broadband/data.html](http://www.fcc.gov/broadband/data.html)__. _
- For questions, the Form 477 Team can be
- reached:
- 	1)  Via email at:  _[477INFO@fcc.gov](mailto:477INFO@fcc.gov)__. or_
-    2)  By telephone at (202) 418-0940