The Key to a Successful FCC Form 477
- September 21, 2016 | Avalara
Every March and September, communications service providers (CSPs) are required to fill out Form 477. This monster of a form, intended to help the FCC determine local telephone service, VoIP and broadband service areas, takes hours to complete—sometimes days for the first-timer. The user guide alone covers 100+ pages.
When you're new to the job of translating street addresses to census tracts, FCC Form 477 can be incredibly overwhelming. Failing to file may put your company at risk of fines as high as $500 a day.
But there is a trick—a tool, really—that makes the process much more efficient and accurate. In fact, this one tip can turn an overwhelming process into a simple biannual task.
What is this tip? Location data.
Form 477 and U.S. Census Tracts
Form 477 relies heavily on census tracts. These small subdivisions divide counties and other geographic entities into smaller groups of 1,200 to 8,000 people for statistical comparisons. The ideal size of a tract is 4,000 people.
In regions like New York and Los Angeles, one census tract has a very small geographic footprint. But in states such as Wyoming and Montana, those tracts will look very different. Instead of representing a subset of a city, they might encapsulate multiple counties. And when the FCC analyzes coverage in those tracts, accurate reporting is essential.
In other words...
The haphazard or hurried reporting job won't suffice. Completing Form 477 in a timely, efficient manner means accurately identifying these tracts. While the FCC provides tools you can use to help translate customer billing addresses into census tracts, there's a bigger issue that must be addressed first:
The accuracy of customer locations.
Whether from a zip code database update or mistyping on the part of a customer, outdated and inaccurate customer addresses can be a real problem in FCC regulatory reporting. For a customer location to be translated into the correct census tract, it has to be extremely precise and error-free.
Identifying Locations for Form 477
When you begin this process for the first time, the first step is to scrub the customer location data you have on file. While combing through your data, be sure you can verify the accuracy of each customer location by asking questions such as:
- Does the city match the zip code?
- Is the zip code still accurate or has the database changed?
- Is the correct county listed?
- How many addresses are actually placeholders, such as P.O. boxes?
- Does the address match the customer's primary place of use (PPU)?
If this sounds like a long, arduous process—that's because it is. For the growing provider currently offering service in a handful of jurisdictions, it might be possible to manually vet locations against the United States Postal Service. That's option one. Or, as a second option, you could try a third-party verification service or list scrubbing software. And then there's option three...
Using Geospatial Data
Identifying correct jurisdictions at the national, state and local levels—all the way down to special tax districts-is a job that requires geo-coding. This process translates customer locations into exact latitude-longitude pairs, which can then be matched easily to the correct census tracts.
Spatial, or location-based, data allows companies to identify the exact geographic coordinates of an address. For example, the Avalara Geo for Communications module will take a customer's account and translate the billing address into a precise latitude and longitude pair. This type of GIS-based automation ensures true accuracy in a way other methods can't.
P.S. Did you know? Geo-coding can be added to Avalara's tax automation software to determine accurate customer location IDs. In fact, this geographical information has been proven so reliable that in Florida, CSPs are held harmless from manually identifying or monitoring customer locations when they use a certified solution like Avalara Geo for Communications. Learn more at communications.avalara.com.