FCC Form 477 and RDOF

Broadband Grant Programs use Census Block maps as the basis for which areas qualify for funding

Sylvan Township Michigan, Form 477 25/3 served areas by Census Block

This image shows a township divided into Census Blocks. The light green colored blocks are reported to have a minimum of 25 Mb/s download and 3 Mb/s upload Internet speeds (25/3) available from a cabled ISP.  The yellow colored blocks are reported as having 10/1 maximum speeds to no service whatsoever. However, for this explanation, the green blocks are what is important since being classified as being in a 25/3 area, homes and businesses in these areas that are not actually served, do not get considered for funding by programs that use Form 477 as their baseline criteria.

What is Form 477? 

Form 477 is an FCC mandated reporting tool for all Internet Service Provider's (ISPs) to identify service coverage areas of their systems.  Form 477 is a self-service, on-line form that requires any ISP providing Internet or Internet based Telephone services, a means to report their respective coverage areas.  The reporting is required twice a year and provides a consolidated view of where Internet services are available, how many providers offer service, who the providers are, and what level of performance should be expected from each provider.  Click on the

Idea Bulb for an interactive

nationwide map for FCC Form 477.

 

The ISP reports service areas based on Census Blocks.  A provider that reports a particular technology and bandwidth in a census block may not necessarily offer that service everywhere in the census block, leading to misreporting of actual service areas.

Census blocks are statistical areas bounded by visible features, such as streets, roads, streams, and railroad tracks, and by nonvisible boundaries, such as selected property lines and city, township, school district, and county limits and short line-of-sight extensions of streets and roads.  Census blocks may have only one or two property parcels, or may contain dozens of individual parcels. There is no correlation between the method of determining Census Blocks, and how property lines are drawn into parcels.  In some cases, a Census Block may actually split a parcel.

A Township Example

Census Blocks blocks do not represent individual parcels very well when identifying who has access to Broadband Internet

This next map is the same area, with the Census Blocks still outlined, but with the individual parcels also shown.  A physical survey by Telecommunication experts that are able to identify how a parcel may be served, or unserved by any particular technology, has been completed.  The light green indicates parcels that have access to 25/3 or better reliable internet service (in this instance, Cable or Fiber), and the peach colored areas are parcels with 10/3 or less (most parcels in these areas reported far less than 10/3). 

Sylvan Township Michigan, actual served areas by Census Block
MapKey1.PNG

Note how many Census Blocks have both served (green) and unserved (pink) parcels, and also unoccupied "non-parcels" in white. The pink and white parcels in a Census Block that is considered served, are not considered eligible for any type of grant programs to get 25/3 service extended to them.  Also note, except for the gold colored parcels, that areas not colored pink or green are unoccupied areas such as State Forest or Wetlands, Farm Land, Industrial, or undeveloped land.  (The gold area is a small private ISP providing fiber in this area). These unoccupied areas are an important concern to the next image down.

When Form 477 is used to define Federal and State Grant Broadband Grant programs like RDOF, homeowners and businesses get left out

Among others, the Rural Digital Opportunity Fund (RDOF) is an FCC administered grant program that awarded $9.2B in 2021 to ISP's across 49 states to build high speed internet in unserved areas.  RDOF used FCC Form 477 data to determine where funding was needed.  The blue areas of the map below show where RDOF funding was awarded in this township. Compare this to the map above.  Note how many pink parcels did not get included in the RDOF process, and especially note the unoccupied white parcels that were included in the awarded areas (now lighter blue).  If an unoccupied area is within the RDOF awarded area, the ISP is (reportedly) obligated to provide service there (even if it is unoccupied forest or agricultural land).  But, the ISP is not obligated to build the areas that are still pink even though they are (mostly residential) homes and businesses that have no access to high speed broadband internet service.  Without this parcel level of detail, municipal planners have no good way to determine who is being left out, and where money is being earmarked for non-occupied, or already served areas.

MapKey.PNG
Sylvan Township Michigan, with RDOF awarded areas

A County Wide Example

 

Census Blocks can cover very large areas magnifying the problem of reported served areas based on just a few parcels

The image on the right is FCC form 477 data (in yellow) indicating the areas of this county that are reported to have access to Cable only, with a minimum of 25/3 service.  In this case, the yellow areas indicate that a single cable provider offers the minimum threshold service of 25/3, and therefore, these areas do not qualify for federal funding for rural Broadband.  The white areas on this map indicate unserved areas based on Form 477 and should qualify for federal funding.  But in the case of RDOF, some of the areas, especially in the north part of the county, were left out.  But on the west side of the county, US Park land (light green) qualified for RDOF. 

Leelanau County showing FCC 477 served areas

Not all unserved areas based on FCC Form 477 are included in the Grant programs

Leelanau County with RDOF and FCC Form 477

The areas that were awarded RDOF funding based on FCC Form 477 are shown here.  Only the blue and light red areas will receive funding to support new services.  The dark green area also qualified for funding but seems contrary to the purpose of RDOF since it only covers mostly unoccupied areas and is for a new Satellite service provider that, when active, will cover the entire county/region.  It is not clear why the remaining FCC identified unserved areas (in white) were not included in the RDOF funding.  Note also that in addition to the Satellite provider being awarded mostly forest and sand dunes, (green) much of the blue area is also unoccupied US park areas awarded to a cable provider.  

Aside from the FCC 477 and RDOF data, this is the actual served and unserved areas in this county

This image displays data based on an actual physical survey of the entire county, showing what is actually served, and which areas do not have access to high speed Broadband Internet.  The dark blue areas have a single cable provider, and access to speeds up to 1 Gb/s (40 times the FCC threshold), however, the yellow area represents all parcels with no cable access at all.  The white areas are unoccupied parcels and therefore also unserved.  The small light green, red and purple areas in the north part of the county are in the planning stages of fiber (not funded through RDOF)

Leelanau County Actual Served-Unserved survey

Combining FCC, RDOF and actual data, this shows about 22% of the occupied parcels in this county remain without a plan for Broadband

Leelanau County Actual Served-Unserved with RDOF

Overlaying the FCC and RDOF data creates a much clearer picture of what kind of future planning is required.  The dark blue areas are the served areas and the light blue and pink will be filled in through RDOF funding over 6 years, but now, using yellow for unserved areas, the map shows how much was missed for RDOF funding, and where the gaps are that need to be included in future planning, regardless of who provides it, or where the funding should come from.