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OMB Approves New Form 477, WISPA Files for Extension and Members Urged to Prepare

Washington D.C. – The Office of Management and Budget (OMB) on January 30 approved the FCC’s newly revised broadband reporting form, FCC Form 477.  Broadband providers will be expected to file the new form by March 2 through the FCC’s Web site. The old version of Form 477 will not be accepted. Based on the new instructions for the revised form, the level of information is much more granular than collected in the past. This change in reporting requirements will take significantly more time for carriers to compile than in past years. Due to the increase in the time and burden that it will take to complete the requirement, the OMB has recommended that the FCC be “flexible with and assist respondents who may have difficulty in submitting information in the new format.”

This is the first filing under the commission’s new data collection requirements passed in June 2008. The FCC order mandates that carriers switch to census tract data collection instead of reporting by zip code. The order also mandates that providers categorize upload and download speeds according to the following new tiered approach.

The OMB has only approved the use of the new form for a one year period. Prior to renewal of the use of this form, the FCC is directed to re-evaluate the requirement and the reporting methods to consider the actual burden of cost and time on filers – especially small entities. The OMB recommends that the FCC make revisions after this one-year period to minimize the burden.

WISPA recommends that member companies take measures to capture the actual cost and time of compliance with this filing requirement. Upon conclusion of the first filing, WISPA will gather filing burden costs and present findings to the FCC to educate the commission as to the true burden on small companies and make recommendations for changes.

Since the new final form is not expected to be approved until the February 23rd, WISPA has filed for a 30 day extension of time for small broadband providers to complete and file the form. The association noted that the extension will help ensure that the filers will have enough time to accurately complete the new form and provide more useful data to the commission. This filing is a collaborative effort with WCA and Comptel.

Although the new form is not actively available yet,the updated instructions are available in pdf format on the OMB’s Web site.  In addition to the instructions, a screenshot is available showing what the new form will look like. Once finalized with a few minor edits by the FCC,the instructions will be available through the FCC’s site.

WISPA advises its membership to begin collecting and organizing the data required under the new form as the time available to compile the information is very limited.  Batch Geocoding services are available at the following website.  http://www.ffiec.gov/Geocode/default.aspx

The FCC’s June 12 order amending Form 477 may be downloadedhere.

About the Wireless Internet Service Providers Association (WISPA):

WISPA (Wireless Internet Service Providers Association) represents approximately 300 wireless broadband service providers throughout the United States, as well as dozens of vendor members, and is dedicated to promoting and improving the WISP industry through public outreach and direct engagement with regulators. We welcome you to our web site and invite you to read about the association and its efforts atwww.wispa.org. ##

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