STATEMENT OF
CHAIRMAN AJIT PAI
Re: Modernizing the FCC Form 477 Data Program, WC Docket No. 11-10.
Sherlock Holmes once said, “It is a capital mistake to theorize before one has data.”
1
  Holmes 
was famous for quickly drawing advanced deductions and conclusions from just a dribble of data.  But 
inevitably, as the story went on, Holmes would find new clues and acquire new data, which would 
ultimately lead him to update his theories and solve the mystery.  Of course, Sherlock’s success hinged on 
the data being accurate—a meaningful representation of reality.
With this Further Notice, we aim to make sure our Form 477 data is as accurate as possible.  
Form 477 generates one of our most important data sets at the Commission, one we rely on every day.  
And the interest in Form 477 seems strong.  In the two congressional hearings in which I participated last 
month, Form 477 was mentioned by name a total of nine times.  That’s a pretty well-known dataset.
Maintaining updated and accurate data about broadband deployment is critical to bridging the 
digital divide.  It lets us target our efforts to those areas that most need it.  And it allows us to measure our 
progress in bringing digital opportunity to all Americans.  
But we’ve heard concerns about the quality of the Form 477 data we’ve been collecting.  That’s 
why, earlier today, we instituted a special, one-time data collection for purposes of the Mobility Fund 
Phase II reverse auction.  We wanted to make sure that for that auction, we were drawing on the correct 
data.
Going forward, we want to make sure that overall Form 477 is giving us the right snapshot of 
where connectivity is and where it isn’t.  So we’re teeing up ideas for collecting more granular and 
standardized data.
At the same time, we want to make sure we only collect what we need.  So in this Further Notice, 
we also explore whether there are parts of Form 477 for which the burdens of collection outweigh the 
benefits.  This is just good housekeeping.  Data collections that pile up for little reason other than inertia 
disserve the agency in its decision-making.  And every dollar we make providers—whether big or 
small—spend filing data that we don’t need is a dollar they can’t devote to connecting Americans.
Thank you to the staff that worked on this item. From the Wireline Competition Bureau: Kirk 
Burgee, Ellen Burton, Joseph Calascione, James Eisner, Chelsea Fallon, Ken Lynch, Virginia Metallo, 
Thom Parisi, Eric Ralph, Steve Rosenberg, Shane Taylor, Rodger Woock, Suzanne Yelen, and David 
Zesiger; from the Wireless Telecommunications Bureau: Judith Dempsey, Ben Freeman, Catherine 
Matraves, Jennifer Salhus, Paroma Sanyal, Ziad Sleem, Patrick Sun, Tom Tran, Matt Warner, and Joseph 
Wyer; from the International Bureau: Jose Albuquerque, Denise Coca, Jerry Duvall, Chip Fleming, 
Francis Gutierrez, Gabrielle Kim, Kerry Murray, Jim Schlichting, Daniel Shiman, Walt Strack, Troy 
Tanner, Irene Wu, and Michele Wu-Bailey; from the Office of General Counsel: Bill Dever, Rick Mallen, 
Keith McCrickard, and Joel Rabinovitz; from the Office of Strategic Planning and Policy Analysis: Paul 
LaFontaine, Wayne Leighton, and Henning Schulzrinne; and from the Office of Communication Business 
Opportunities: Maura McGowan, Chana Wilkerson, and Sanford Williams.
In The Adventure of the Copper Beaches, Sherlock Holmes cried out impatiently, “Data!, Data!, 
Data!  I can’t make bricks without clay.”  Thanks to your work, the Commission will soon have better 
clay to use in constructing its policies.
                                                     
1
Arthur Conan Doyle, The Adventures of Sherlock Holmes, A Scandal in Bohemia (1892).