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FCC Request for Extension regarding Form 477

Submission Date: 
02/10/2009

I. Introduction

The American Cable Association urges the Commission to expeditiously adopt a short 120-day extension for broadband and VoIP providers to complete and file the new Form 477. An extension is warranted for the following reasons:

(i) The new form obligates filers to submit a substantial amount of increased data and information. At the same time, the new form has only recently been approved by OMB, and is still not available on the FCC website. Due to these delays, many ACA members lack the administrative resources, both financial and administrative, to timely submit the new Form 477 by March 2, 2009.

(ii) An extension would have substantial public interest benefits, including permitting the Commission to amass a complete and well-developed record and ensuring accurate submissions.

For these reasons, the Commission should expeditiously adopt an extension.

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ACA Request for Extension -Form 477 -090210 Final (2).pdf343.26 KB

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