PUBLIC NOTICE
Federal Communications Commission
445 12
th
St., S.W.
Washington, D.C. 20554
News Media Information 202 / 418-0500
Internet: https://www.fcc.gov
TTY: 1-888-835-5322
DA 17-286
Released:  March 29, 2017
THE WIRELESS TELECOMMUNICATIONS BUREAU AND THE 
WIRELINE COMPETITION BUREAU PROPOSE TO RELEASE FORM 477 
4G LTE MOBILE SPEED DATA TO FACILITATE IMPLEMENTATION 
OF MOBILITY FUND II SUPPORT
WT Docket No. 17-80
WC Docket No. 10-90
WT Docket No. 10-208
WC Docket No. 11-10
In the Mobility Fund II R&O and FNPRM, the Commission affirmed that it sought to promote the 
deployment of 4G LTE in all areas where it would not be offered by the private sector in the absence of 
universal service support.
1
  To identify those geographical areas potentially eligible for such support, the 
Commission decided to use 4G LTE deployment at a minimum advertised download speed benchmark of 
at least 5 Mbps, based on service providers’ Form 477 filings.
2
The Commission concluded that any 
census block not fully covered by unsubsidized 4G LTE of at least 5 Mbps advertised download speed
will encompass areas that are eligible for support in the Mobility Fund II auction.
3
  While the 
Commission directed the Wireless Telecommunications Bureau (WTB) and the Wireline Competition 
Bureau (WCB) to make an initial determination of eligible areas by census block based on the Form 477 
filings, it also stated its intention to “provide a robust process for interested parties to challenge our list of 
presumptively eligible areas for MF-II support.”
4
To aid interested parties, and to provide additional information about the geographical areas 
eligible for Mobility Fund II support, we propose to release minimum advertised or expected 4G LTE
speed data included in the December 31, 2015, and June 30, 2016 Form 477 filings (and any subsequent 
Form 477 filings) to facilitate Mobility Fund II analysis.
5
  Disclosure of the minimum advertised or 
expected speeds associated with service providers’ 4G LTE coverage submitted in their Form 477 filings 
will enable a transparent process for challenges,
6
and final determinations of areas eligible for Mobility 
Fund II support.  Strong public interest benefits support disclosing the minimum advertised or expected 
                                                     
1
Connect America Fund; Universal Service Reform – Mobility Fund, Report and Order and Further Notice of 
Proposed Rulemaking, FCC 17-11 at 22, para. 51 (Mar. 7, 2017) (Mobility Fund II R&O and FNPRM).
2
Mobility Fund II R&O and FNPRM at 22, 24, paras. 51, 56.
3
Mobility Fund II R&O and FNPRM at 23, para. 52.
4
Mobility Fund II R&O and FNPRM at 30, para. 66.
5
For the Form 477 data filed, if a service provider does not advertise minimum speeds, it must indicate the 
minimum speeds “that users should expect to receive.”  FCC Form 477, Local Telephone Competition and 
Broadband Reporting, Instructions at 24 (2016) (FCC Form 477 Instructions), 
https://transition.fcc.gov/form477/477inst.pdf.
6
Mobility Fund II R&O and FNPRM at 86-87, paras. 232-33.
24G LTE speeds.
7
  Making these data available to the public will provide service providers, states, and 
experts with the opportunity to review and evaluate the data independently to ensure the accuracy of the 
information.  Further, with respect to minimum advertised speeds, because it is advertised by service 
providers, much or all of that information is already available to the public. The public interest in 
providing such speed information would substantially outweigh any potential competitive harms to the 
providers in maintaining its confidentiality.
8
  
In the Modernizing Form 477 Order, the Commission noted that while deployment data generally 
will be treated as public, certain specific speed and spectrum parameters included in mobile deployment 
data may be used by providers for internal network planning purposes.
9
  Accordingly, the Commission 
provided that “[f]ilers may request confidential treatment of those specific elements of their deployment 
data.”
10
  In implementing the requirements of the Modernizing Form 477 Order, Section 5.8 of the Form 
477 Instructions requires facilities-based providers of mobile wireless broadband connections to submit 
polygons in a shapefile format representing geographic coverage nationwide for each specified mobile 
broadband transmission technology (e.g., LTE) deployed in each frequency band.
11
If a Form 477 filer 
wished to request non-disclosure of “some or all of the terrestrial mobile wireless deployment spectrum 
and speed parameters information” in its submission, it was directed to check a single non-disclosure 
check box.
12
  
Because of the streamlined check box approach on Form 477, filers have not been required to 
include with their filings a statement of the reasons underlying their request for withholding the materials 
pursuant to Section 0.459(b) of the Commission’s rules.
13
  Accordingly, we will afford these filers an 
opportunity to provide any such reasons, and state why their individual circumstances warrant 
withholding the aforementioned data from disclosure.  Affected parties must oppose disclosure of their 
aforementioned Form 477 4G LTE speed data and provide a full justification in support of their request 
for confidentiality under Section 0.459(b) no later than April 12, 2017.
14
All filings should refer to WT 
Docket No. 17-80.
                                                     
7
We do not propose to disclose the speed data associated with the specific spectrum bands that providers are using 
to provide mobile LTE broadband service, as such data do not appear to be necessary for implementation of
Mobility Fund II.  Modernizing the FCC Form 477 Data Program, WC Docket No. 11-10, Report and Order, 28 
FCC Rcd 9887, 9923, paras. 82-83 (2013) (Modernizing Form 477 Order); Wireline Competition Bureau Releases 
Data Specification for Form 477 Data Collection, WC Docket No. 11-10, Public Notice, 28 FCC Rcd 12665, 12671 
(WCB 2013) (Data Specification for Form 477 Public Notice).
8
Form 477 requires mobile broadband service providers to submit certain information related to mobile broadband
deployment and subscriptions. Modernizing Form 477 Order, 28 FCC Rcd at 9908-09, para. 42; Data Specification 
for Form 477 Public Notice, 28 FCC Rcd at 12671.
9
Modernizing Form 477 Order, 28 FCC Rcd at 9923, paras. 82-83.
10
Modernizing Form 477 Order, 28 FCC Rcd at 9923, para. 82; see also 47 CFR § 1.7001(d)(2)(ii); FCC Form 477 
Instructions at 32.  
11
FCC Form 477 Instructions at 24.  
12
FCC Form 477 Instructions at 16; see also Data Specification for Form 477 Public Notice, 28 FCC Rcd at 12668.  
The filer was not able to specify whether it was requesting confidential treatment of all this information, or only of 
some of this information.
13
47 CFR § 0.459(b).
14
47 CFR § 0.459(b).  In the case of any request for confidentiality that is subsequently denied, the provider may 
file an application for review by the Commission in accordance with 47 CFR § 0.459(g).  Materials will be accorded 
confidential treatment until the Commission acts on any timely applications for review, and until a court acts on any 
timely motion for stay of such an order denying confidential treatment.  Id.
3Under the Commission’s current procedures for the submission of filings and other documents,
15
submissions in this matter may be filed electronically through the Commission’s Electronic Comment 
Filing System (ECFS) or by hand delivery to the Commission.
? To file electronically,
16
comments shall be sent as an electronic file via the Internet to 
http://apps.fcc.gov/ecfs.  In completing the transmittal screen, commenters should include their 
full name, U.S. Postal Service mailing address, and the applicable docket number.  Parties may 
also submit an electronic comment by email.
? To file by paper, the original and four copies of each filing must be filed by hand or messenger 
delivery, by commercial overnight courier, or by first-class or overnight U.S. Postal Service mail.  
All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary must be 
delivered to FCC Headquarters at 445 12th St., S.W., Room TW-A325, Washington, D.C. 20554.  
The filing hours at this location are 8:00 a.m. to 7:00 p.m.  All hand deliveries must be held 
together with rubber bands or fasteners.  Any envelopes must be disposed of before entering the 
building.  Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority 
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.  U.S. Postal 
Service first-class, Express, and Priority mail should be addressed to 445 12th Street, S.W., 
Washington, D.C. 20554.  All filings must be addressed to the Commission’s Secretary, Office of 
the Secretary, Federal Communications Commission.
One copy of each pleading must be delivered electronically, by email or facsimile, or if delivered 
as paper copy, by hand or messenger delivery, by commercial overnight courier, or by first-class or 
overnight U.S. Postal Service mail (according to the procedures set forth above for paper filings), to: Matt 
Warner, Competition and Infrastructure Policy Division, Wireless Telecommunications Bureau, at 
matthew.warner@fcc.gov or (202) 418-7447 (facsimile).  
This proceeding has been designated as a “permit-but-disclose” proceeding in accordance with 
the Commission's ex parte rules.
17
  Persons making ex parte presentations must file a copy of any written 
presentation or a memorandum summarizing any oral presentation within two business days after the 
presentation (unless a different deadline applicable to the Sunshine period applies).  Persons making oral 
ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all 
persons attending or otherwise participating in the meeting at which the ex parte presentation was made, 
and (2) summarize all data presented and arguments made during the presentation.  If the presentation 
consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s 
written comments, memoranda or other filings in the proceeding, the presenter may provide citations to 
such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant 
page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them 
in the memorandum.  Documents shown or given to Commission staff during ex parte meetings are 
deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b).  
In proceedings governed by rule 1.49(f) or for which the Commission has made available a 
method of electronic filing, written ex parte presentations and memoranda summarizing oral ex parte 
presentations, and all attachments thereto, must be filed through the electronic comment filing system 
available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable 
.pdf).  Participants in this proceeding should familiarize themselves with the Commission’s ex parte rules.
                                                     
15
FCC Announces Change in Filing Location for Paper Documents, Public Notice, 24 FCC Rcd 14312 (2009). 
16
Electronic Filing of Documents in Rulemaking Proceedings, GC Docket No. 97-113, Report and Order, 13 FCC 
Rcd 11322 (1998).
17
47 CFR §§ 1.1200(a), 1.1206.
4This action is taken pursuant to Sections 4(i) of the Communications Act, 47 U.S.C. § 154(i), 
Section 4 of the Freedom of Information Act, 5 U.S.C. § 552(b)(4), and authority delegated under section 
0.331 of the Commission’s rules, 47 CFR § 0.331, and is effective upon its adoption.
For further information, contact Kate Matraves, Competition and Infrastructure Policy Division, 
Wireless Telecommunications Bureau, at (202) 391-6272 or Matt Warner, Competition and Infrastructure 
Policy Division, Wireless Telecommunications Bureau, at (202) 418-2419.
-FCC-