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FCC Form 477 & RDOF - Washtenaw

Comparing Census Blocks to Parcels at a Township Level

Sylvan Form 477.jpg

Form 477 was an FCC mandated reporting tool for all Internet Service Provider's (ISP's) to identify service coverage areas of their systems.  Form 477 was 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 was required twice a year and provided 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.

The ISP reports service areas based on Census Blocks.  A provider that reports a particular technology and bandwidth in a particular census block may not necessarily offer that particular 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.

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.

Census Blocks - Form 477 used Census Blocks, rather than parcels or address points (as is the case now with the new Broadband Data Collection (BDC) system).  But since every Grant program up until now have been based on the old Form 477 system, and there is no clear guidance yet on how the new BDC will impact the latest *NOFO's, especially **BEAD, or even consider existing grant programs that are in progress, it is important to understand how reporting by Census Block will still leave parcels in limbo.  

*Notice of Funding Opportunities   

**Broadband Equity, Access, and Deployment

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). 

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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.

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, based on FCC Form 477 data.  The blue areas of the map below show where RDOF funding was awarded in this township.  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 (lighter blue).  If an unoccupied area is within the RDOF awarded area, the ISP is obligated to provide service there.  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.

Sylvan RDOF2.jpg

FCC Form 477 & RDOF - Leelanau

Comparing Census Blocks to Parcels at a County Level

Census Blocks - Form 477 used Census Blocks, rather than parcels or address points (as is the case now with the new Broadband Data Collection (BDC) system).  But since every Grant program up until now have been based on Form 477, it is important to understand how Form 477 still has an impact on the BDC and current Grant programs.

The map on the right is data from the FCC form 477 base on Census Blocks rather than individual parcels. The yellow indicates the areas in Leelanau County that were reported to have access to Cabled services above the minimum threshold service of 25/3, and therefore, did not qualify for federal funding for rural Broadband.  The white areas are shown as unserved on the 477 map, 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 still left out. But on the west side of the county, US Park land (light green) qualified for RDOF. 

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The areas that were awarded RDOF funding based on FCC Form 477 are shown below.  Only the blue and light red areas will receive funding to support new services.  The dark green area also qualified for funding but mostly covered unoccupied areas by a satellite service provider and has since been forfeited.  It is not clear why the remaining FCC identified unserved areas (in white) were not included in the RDOF funding.  Note that much of the blue awarded areas are also in unoccupied US Park areas (Sleeping Bear Dunes).  Again, the yellow indicates what has been reported as "served".

Leelanau FCC 477 RDOF2.jpg

With all of the FCC data removed, the map here shows the individual parcels (occupied addresses) that are actually serviceable, and which areas do not have access to high-speed Broadband Internet.  The blue and burgundy areas have either HFC or FTTH with access to speeds up to 1 Gb/s (40 times the FCC threshold), however, the white area represents all parcels with no cable access at all.

LeelanauServed Only.png

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, light blue and pink will be filled in through RDOF funding over 6 years, but all of the white was not being planned for, and still mostly ineligible for funding based on Form 477.  This became the basis for the county's current planning efforts.  Click here to see where Leelanau County is today.

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