USF/ICC Reform Broadband ICC IP Transition USF Call Completion Misc. Upcoming Events November 18, 2013 HIGHLIGHTS • The Tenth Circuit issued an Order detailing the order of argument and allocated times for the November 19, 2013 oral argument in the case reviewing Petitions for Review of the FCC’s Transformation Order. • At the FCC’s November Open Meeting, the Wireline Competition and Wireless Telecommunications Bureaus, and the Office of Native Affairs and Policy presented an update on USF reform implementation. • NTCA sent a letter to Chairman Wheeler detailing policy initiatives it says will help rural carriers fulfill the nation’s broadband vision, including IP transition, CAF support for RLECs, QRA-based support caps, E-rate reform, spectrum auctions, and video access. • Silver Star Telephone discussed its findings on the accuracy of the data in the ESRI StreetMap and TigerLine databases with respect to road data in connection with its Application for Review of the QRA benchmarks. • GVNW and Arctic Slope Telephone provided an update on the Arctic Fiber Network project and the potential impacts of the QRA caps on the fiber network. • SBCA responded to NTCA’s filing that attached a paper authored by Vantage Point Solutions on the capabilities and limitations of satellite services to provide voice and broadband in high-cost areas. • South Park Telephone withdrew its Petition for Waiver of FCC rules limiting high-cost universal service support. The day before withdrawing the Petition, South Park spoke with the FCC on the impact the Petition had on its pending Section 214 Application. • Price cap carriers asked the FCC to release funding for those census blocks that were uncontested in the CAF Phase I Round 2 award process. Boycom responded to Windstream’s reply to its census block list challenge; Midstate responded to CenturyLink’s reply. • The ABC Coalition provided additional responses to Wireline Competition Bureau questions raised in the Cost Model Virtual Workshop. NRIC filed a letter on adjustments to the cost model, and asked the FCC to consider different thresholds for RoR carrier service areas where higher-cost-to-serve areas exist. • COMPTEL discussed its concerns that the FCC changed the small carrier exemption from call completion data retention and reporting requirements without notice to the industry or an opportunity to comment. • SDN discussed the benefits it says it brings to South Dakota as a centralized equal access and tandem transit provider, and argued bill and keep is not an appropriate compensation mechanism for SDN. • Level 3 filed a letter on its numbering trials, and asked the FCC to investigate its routing dispute with CenturyLink. Level 3 also filed its Third Report on its VoIP numbering trial. • Terral Telephone asked the FCC to resolve its Petition for Waiver of the Part 36 frozen category rules. • The FCC’s Office of Engineering and Technology gave a presentation on the release of the first public version of the FCC Broadband Speed Test app for Android smartphones. Editor: Teresa Evert | Assistant Editor: Shawn O'Brien November 18, 2013 Page 2 Transformation Order - USF/CAF • The Tenth Circuit issued an Order on November 12, 2013, detailing the order of argument and allocated times for the November 19, 2013 oral argument in the case reviewing Petitions for Review of the FCC’s Transformation Order. The court noted these allocations are not binding on the court and create no entitlements in the parties. The first session will address intercarrier compensation issues; the second will address universal service support issues; the third will address due process and constitutional violation issues as well as access stimulation and VoIP issues; and the final session will address rural CLEC issues, the ARC, access charges collected by VoIP providers; and the FCC’s use of end-user/common carrier definitions. • At the FCC’s November 14, 2013 Open Meeting, the Wireline Competition Bureau, Wireless Telecommunications Bureau, and Office of Native Affairs and Policy presented an update on USF reform implementation. The Bureaus discussed, among other things, the price cap carriers’ election of CAF Phase I Round 2 support; CAF Phase II support; the July 2013 QRA Benchmarks Order; study area boundary data collection; the pending survey of urban rates; and annual ETC reporting. The Bureaus indicated future activities include completing authorizations of funding for CAF Phase I Round 2, adopting a cost model, completing study area boundary reconciliation, and conducting the rate survey. Statements were issued by Chairman Wheeler and Commissioners Rosenworcel, Pai, and Clyburn. • NTCA sent a letter to Chairman Wheeler on November 12, 2013, detailing policy initiatives that will help rural carriers fulfill the nation’s broadband vision. NTCA said the FCC should promote and sustain the ongoing IP transition, noting its 2012 “IP Evolution” Petition to promote and sustain an orderly evolution to IP, and adopt a CAF support mechanism for RLEC broadband deployment. NTCA also said the FCC should address the current regulatory uncertainty, pointing out rural broadband deployment has stalled due to concerns about the volatility of QRA-based caps on highcost USF support. NTCA also said: the FCC should modernize the E-Rate program;the upcoming 600 MHz auctions present an opportunity to make advanced wireless services more widely available by licensing spectrum on the basis of Cellular Market Areas; and the FCC should reform outdated video access rules. • Silver Star Telephone spoke with staff members of the Wireline Competition Bureau on November 8, 2013, to explain the data in the ESRI StreetMap and TigerLine databases contain errors in road miles and road crossings for Silver Star’s study areas, suggesting the errors in ESRI, at least in part, occur because Silver Star’s study areas experienced significant new development prior to 2010 and ESRI was not updated. Silver Star asserted the TigerLine database more accurately reflects roads and road crossings associated with subdivisions, but said both databases are incorrect with respect to recreational roads. Silver Star filed an Application for Review in June 2013 of the WCB’s Order denying, in part, its request for waiver to correct data in the Quantile Regression Analysis model. • GVNW and Arctic Slope Telephone Cooperative Association met with Commissioner Pai’s Legal Advisor on November 12, 2013, to discuss the lack of reasonable comparability between satellite and fiber connectivity for communities in the North Slope Borough. They noted the Arctic Slope service area is larger than the state of Minnesota, creating extreme construction and maintenance challenges in the harsh Arctic environment. They also provided an update on ASTAC’s effort to realize the benefits of the Arctic Fiber Network project and discussed the potential impacts on the AFN in 2015 of the QRA caps on support. • The Satellite Broadcasting and Communications Association filed a letter on November 15, 2013, responding to NTCA’s filing that attached a paper authored by Vantage Point Solutions on the capabilities and limitations of satellite services to provide voice and broadband in high-cost areas. SBCA asserted the paper is an attempt by NTCA to forestall broadband competition in rural areas, and said the paper makes inaccurate claims about the quality of satellite broadband service in an effort to persuade the FCC to allow rural carriers to leverage and retain their incumbent status. SBCA also claimed the paper ignores the fact that broadband satellite service is the only infrastructure readily available even in the most remote areas. November 18, 2013 Page 3 • South Park Telephone filed a letter on November 14, 2013, withdrawing its Petition for Waiver of two Commission rules that limit high-cost universal service support. On November 13, 2013, South Park Telephone, Signal Telcom Partners, and JSI spoke with Wireline Competition Bureau staff regarding South Park’s Petition for Waiver and its domestic Section 214 application for transfer of control. • Adak Eagle Enterprises and Windy City Cellular sent a letter to Commissioner Clyburn on November 12, 2013, attaching two filings made by the Marine Exchange of Alaska and the Minority Media and Telecom Council that address the critical services provided by AEE and WCC, in support of their Application for Review of the Order denying their Petitions for Waiver of the $250 per line per month cap on high-cost USF support. They said the Marine Exchange of Alaska filing shows how the services and facilities provided by AEE and WCC played a critical role in supporting the rescue of fishermen off the coast of Adak Island. They also said MMTC similarly emphasizes how critical it is for the denial of AEE and WCC’s waiver petitions to be reversed so that the companies can continue providing essential services. • AT&T, CenturyLink, FairPoint, Windstream, and Frontier met with Wireline Competition Bureau staff on November 12, 2013, to urge the FCC to release funding for those census blocks that were uncontested in the CAF Phase I Round 2 award process. They also urged the Bureau to complete its examination of the challenged census blocks expeditiously, and asked the FCC not to consider any evidence submitted by a participant after the stated deadlines. • Midstate Communications filed a letter on November 15, 2013, to respond to CenturyLink’s reply to its challenge to CenturyLink’s CAF Phase I census block list. Midstate maintains it has built fiber within census blocks 460159732002037 and 460159732002043, and currently serves these areas with speeds up to 20 Mbps downstream and 2 Mbps upstream. Public Notice • Boycom Cablevision filed a letter on November 12, 2013, to respond to Windstream’s reply to Boycom’s challenge to Windstream’s CAF Phase I census block list. Boycom provided information it says supports its claim of providing the required broadband service in the relevant census blocks, including the officer certification, maps, and billing records. Public Notice • USTelecom, on behalf of the ABC Coalition, filed a letter on November 13, 2013, providing additional input to questions the Wireline Competition Bureau raised in the Cost Model Virtual Workshop. The Coalition said, among other things, it is reasonable to set aside $50 million from the $1.8 billion in support to recognize the average draw of approximately $50 million per yearfrom the CAF-ICC recovery mechanism. The Coalition also believes using a straight average when forecasting the price cap carrier draw from the CAF-ICC recovery mechanism is reasonable, which results in $1.75 billion of support being distributed through the model or competitive bidding. The Coalition also believes that using average revenue per user to develop benchmarks is inappropriate, saying it would be pure speculation as to the right ARPU to use over time. • NRIC filed a letter on November 13, 2013, in response to USTelecom’s letter on adjustments to the Connect America Cost Model. NRIC asserted issues identified by USTelecom raise the need for improvements to the CACM, and said it is concerned that without an appropriately tailored CACM for RoR ILECs, decisions made in the CAF II price cap proceeding may create precedents and disincentives for RoR ILECs to consider price cap and/or CACM-based federal USF disbursements. NRIC requested the FCC consider the need for different thresholds for RoR carrier service areas where higher-cost-to-serve areas exist. • NECA filed a letter on November 13, 2013, providing the latest view of Universal Service Fund data for 2011 and 2012 reporting periods, as requested by FCC staff, in connection with analyses related to USF reforms. • No comments were filed on NTUA Wireless’ Petition for Forbearance from the requirement that the service area of an ETC conform to the service area of any rural telephone company serving the same area in connection with a conditional ETC designation for participating in the Tribal Mobility Fund auction, Auction 902. Replies due November 22. Public Notice November 18, 2013 Page 4 • SDN Communications spoke with staff members of the Wireline Competition Bureau on November 8, 2013, to discuss the issues raised in AT&T’s September 18, 2013 ex parte on traffic pumping and centralized equal access rings, and to discuss the benefits SDN brings to South Dakota as a centralized equal access provider and tandem transit provider. SDN also discussed its comments filed on the USF/ICC Transformation FNPRM, in which SDN argued bill and keep is not an appropriate compensation mechanism for SDN because it does not have end users and it does not receive any federal or state universal service support. Back to Highlights Call Completion • COMPTEL spoke with Wireline Competition Bureau staff on November 14, 2013 to discuss the Report and Order and FNPRM on rural call completion. COMPTEL expressed concern that the FCC changed the small carrier exemption from the data retention and reporting requirements from carriers with 100,000 subscribers to carriers with 100,000 subscriber lines without notice to the industry or an opportunity to comment, and provided no explanation for the change. COMPTEL also noted two of the three examples given on page 12 of the Order to explain how the definition of “initial longdistance call path choice” would work in practice appear to conflict. Broadband • At the FCC’s November 14, 2013 Open Meeting, the Office of Engineering and Technology gave a presentation on the release of the first public version of the FCC Broadband Speed Test app for Android smartphones. The FCC Speed Test is an open-source, crowdsourcing program intended to assess mobile broadband performance nationwide, and will provide consumers with open, transparent information on their own mobile broadband speeds. The OET said the FCC plans to release interactive maps and other tools in 2014 to allow consumers to see meaningful information about mobile broadband network performance around the country based on aggregate data collected by the app. Statements were issued by Chairman Wheeler, and Commissioners Rosenworcel, Pai, and Clyburn. State Actions • The Maine PUC issued a Notice of Proceeding on November 1, 2013, to consider Fairpoint’s request for an increase in rates for Provider of Last Resort telephone service and Maine USF funds. The PUC stated the proposed rate change represents an annual increase of $700,368 or a 12.7% increase in revenues derived from the sale of POLR service. The PUC said Fairpoint also requested an annual disbursement from the Maine USF of $66.9 million that would increase the total annual amount collected from MUSF contributors from $8.32 million to $75.2 million. The PUC outlined the process for participation in the proceeding and noted an initial case conference in this matter will be held on November 22, 2013. Time Warner Cable Information Services and TWC Digital Phone filed a petition on November 15, 2013, to intervene, and claimed if Fairpoint’s request is granted, FairPoint will enjoy a competitive advantage in the areas in which they compete for customers. • Keystone Research Center issued a report on November 13, 2013, claiming PA bill HB 1608 will hurt rural access to broadband service and sharply increase telephone rates. The report argues “Pennsylvania needs next-generation broadband in all communities, not deregulation that locks in substandard rural service.” The report says, among other things, the bill abandons rural communities by permitting telephone carriers to eliminate service to consumers they do not want to serve; eliminates critical customer protections that allow customers to compare phone rates and quality of service requirements; and removes oversight of telecommunications company mergers and acquisitions. The proposal is scheduled for a House Consumer Affairs hearing next week. November 18, 2013 Page 5 • The Louisiana PSC staff issued a final recommendation on AT&T’s petition for deregulation in the state on November 4, 2013. The Staff recommended the PSC: eliminate AT&T’s COLR obligation; modify AT&T Louisiana’s price plan; provide for service and cost support parity; eliminate the requirement for certain administrative reports; and eliminate the rules and requirements applicable to technical and market trials. The Staff also recommended the PSC deny AT&T’s request to modernize various billing and collection rules and certain administrative rules, suggesting if the PSC wants to review current rules/orders on AT&T requests on billing and collection rules, it should do so in separate proceedings. • Great Lakes Communications filed a Supplemental Motion asking the Iowa Utilities Board to close its investigation, claiming it fulfilled the IUB’s requirements to demonstrate that it is providing adequate telephone service in its certificated exchanges. Great Lakes also said since it filed its original Motion on April 30, 2013, it has successfully resolved its dispute with CenturyLink. Back to Highlights USF • Masergy Communications filed a letter on November 13, 2013, asking the FCC to act on IVANS’ Request for Review and Petition for Declaratory Ruling of a USAC decision on applying USF assessments to enterprise services using MPLS and Frame Relay. Masergy asserted the confusion over proper regulatory classification of MPLS has been going on since 2009, and claimed the FCC has offered no formal guidance despite numerous requests for the FCC to provide some certainty on these services. Masergy continues to believe that MPLS and similar services should be classified as information services. • The FCC issued a Notice in the Federal Register on November 13, 2013, announcing the comment dates on the FCC’s proposed Lifeline Biennial Audit Plan. The proposed audit would be required of any carrier that receives more than $5 million annually from the low-income USF support program. Comments are due December 13; replies due December 30. Public Notice • TracFone filed a letter on November 14, 2013, in response to the Texas PUC’s letter that corrected errors in Texas-related information in TracFone’s State Database Fact Sheet on Lifeline programbased eligibility databases in various states. TracFone explained the misstatements were the result of a misunderstanding of information provided to them by the TPUC, and agreed with the corrections in the TPUC’s letter. • The Consortium for School Networking, Calcasieu Parish School System, and EducationCounsel met with staff members of the Wireline Competition Bureau and Office of Strategic Planning on November 8, 2013, to discuss the CoSN 2013 E-rate and Broadband Survey 2013. They presented data on district leaders' broadband capacity, needs, priorities, barriers, costs and use of the E-rate program, and recommended the FCC explore key improvements to the program, including increased funding for capital and ongoing expenses, model technology-neutral network designs, and incentives for consortia purchasing. • EducationCounsel, the National Public Education Support Fund, et al. met with Commissioner Rosenworcel and her staff on November 12, 2013, to discuss comments filed by the National Public Education Support Fund on E-rate reform. They urged the FCC to use the E-rate proceeding to promote digital equity for all students, establish minimum target connectivity speeds, raise the program cap to support new capital and ongoing investments, and simplify the program. • Additional replies were filed on November 8, 2013, on the NPRM seeking to modernize the E-rate program. The Alaska Rural Coalition agreed reforms to the E-rate program are necessary, but said the FCC must ensure these reforms do not disadvantage rural and remote areas, where schools and libraries have the greatest need for broadband technology and digital services. The Montana November 18, 2013 Page 6 Telecommunications Association said E-rate support should not fund expenditures that are not necessary, may duplicate investment, waste resources, compete against other programs, or otherwise divert funds from the program’s primary mission to promote affordability of broadband communications services for schools and libraries. COMPTEL said the FCC should strengthen the competitive bidding process, give schools and libraries more flexibility when choosing broadband solutions, improve the administrative efficiency of the program, and use the data from the special access proceeding to guide the E-rate program. List of all replies filed • Cordova Wireless filed a Petition on November 12, 2013, seeking a waiver of the September 30, 2013 high-cost line count data filing deadline. Cordova said it inadvertently missed the filing deadline, and filed one day late when it realized its error. Cordova said absent a waiver, it will lose $911,000 in USF support. • The FCC issued an Order on November 13, 2013, adopting a Consent Decree which terminated its investigation into whether U.S. Satellite violated certain FCC rules concerning regulatory fees, reporting obligations, and required contributions to the USF, TRS Fund, and North American Numbering Plan and Local Number Portability administration. The Order noted U.S. Satellite paid all invoiced amounts and will make a voluntary contribution to the U.S. Treasury in the amount of $500,000. Misc. • Level 3 filed a letter on November 12, 2013, on its numbering trials and what it claims is CenturyLink’s refusal to route traffic destined for telephone numbers associated with the Level 3 ES Operating Company Number over the existing CenturyLink-Level 3 LEC interconnection trunks. Level 3 recommended the FCC investigate this issue and seek information about the extent to which CenturyLink is enforcing its policies uniformly. Level 3 suggested the FCC investigate CenturyLink’s treatment of traffic associated with SBCIS, claiming SBCIS has for several years been permitted to obtain telephone numbers under its own OCN. • Level 3 filed a Third Report on its VoIP numbering trial on November 13, 2013, pursuant to the April 18, 2013 Order. Level 3 said it successfully tested call routing in five rate centers: Boston, Los Angeles, Charlotte, Dallas, and Rochester, and said native telephone numbers were released and the new LRNs were opened for porting in those cities beginning on October 21, 2013. Level 3 noted it has not been able to successfully test call routing in the Denver rate center, claiming CenturyLink demanded Level 3 obtain separate, dedicated trunks to carry traffic from CenturyLink to Level 3. Level 3 asked the FCC to investigate this matter and to clarify that CenturyLink may not require Level 3 to purchase unnecessary additional facilities in this manner. • Terral Telephone sent a letter to Chairman Wheeler on November 12, 2013, asking the FCC to resolve its pending Petition for Waiver of the Part 36 frozen category rules. Terral said a waiver is essential to its ability to continue to deploy broadband, to fulfill its carrier of last resort obligations, to keep its books in accordance with Part 36 and accurately account for its network investment, and said a waiver would reduce its need for federal USF support. Terral also noted the FCC has not acted on the Joint Board’s 2010 proposal on unfreezing category relationships. • The Ad Hoc Telecommunications Users Committee met with Wireline Competition Bureau staff on November 15, 2013, to discuss what it says are burdensome data collection requirements required by the Bureau’s Report and Order in the interstate special access proceeding. Ad Hoc said the data collection will apply to tens of thousands of entities subject to the FCC’s jurisdiction solely because they hold radio licenses used for private, internal communication, and urged the FCC to consider further clarifications and exclusions to avoid unreasonably burdensome reporting requirements on such entities. • The FCC issued a Public Notice on November 13, 2013, announcing that December 16, 2013 will be the next meeting of its Consumer Advisory Committee. Issues or questions to be considered by the November 18, 2013 Page 7 CAC may include: consumer protection and education; implementation of FCC rules and consumer participation in the FCC rulemaking process; access by people with disabilities; and the impact of new and emerging technologies. • Verizon filed a letter on November 15, 2013, to provide an update on its progress in restoring new fiber facilities to areas of Fire Island affected by Hurricane Sandy. Verizon said it has commenced its work to bring fiber to the western portion of Fire Island and is on track to meet its goal of deployment by May 2014. Verizon also said while the fiber deployment proceeds, voice customers whose facilities were destroyed or rendered inoperable by Hurricane Sandy will continue to be offered Verizon’s Voice Link services. • The FCC released a Public Notice on November 14, 2013, seeking comment on Sprint’s Petition for Reconsideration of certain rules adopted in the IP CTS Reform Order. Sprint asked the FCC to reconsider the rule prohibiting all providers from receiving compensation from the Interstate TRS Fund for minutes of use generated by consumers using IP CTS software and applications that consumers receive at no charge or purchase for less than $75 on or after the effective date of the rule. Sprint also asked the FCC to modify its registration and certification requirements to allow access to IP CTS phones in public places. Comments are due 15 days after publication in the Federal Register; replies due 25 days after publication. • The FCC released a Public Notice on November 14, 2013, seeking comment on AT&T’s Petition for clarification, or in the alternative a waiver, of the requirement for providers to offer speech-to-speech users the option to have their voices muted during an STS call. AT&T said it can meet this obligation for incoming calls to an STS user who has not pre-selected muting in his or her profile, and seeks clarification that this process complies with section 64.604(a)(1)(viii). Comments are due 15 days after publication in the Federal Register; replies due 25 days after publication. • Replies were filed on the FNPRM on whether and how to revise the current rate methodology for IP CTS, and other issues The Missouri PSC said if the FCC is seriously considering transferring IP CTS responsibilities to the states, then it should provide a better and more detailed explanation of the proposal and additional opportunity for input. The PSC also said jurisdictional issues need to be resolved, as well as the problem of IP CTS usage by people without a hearing loss. The National Association for State Relay Administration said the FCC must classify IP services as either a “telecommunications service” or an “information service,” and expressed concern that without historical data, they have no way to foresee the impact to their programs should the FCC transfer IP CTS responsibility to the states. The Arizona Commission for the Deaf and Hard of Hearing said it is premature to address issues in the framework of migrating IP CTS oversight, and said they have identified other more critical issues to address prior to further consideration of migrating oversight. Replies are due November 18. FR | List of all replies filed • The Massachusetts DTC filed comments on November 15, 2013, to refresh the record on cramming, the unlawful and fraudulent practice of placing unauthorized charges on telephone bills. The MDTC asserted the record on cramming supports expanding the FCC’s rules to require carriers to provide third-party bill blocking at no charge to all customers. MDTC said the FCC should extend its cramming protections to all voice communicating platforms and urged the FCC to consider implementing a Do-Not-Cram registry. Replies are due December 2. FR | Public Notice • The FCC announced on November 13, 2013, the effective date for rules adopted in the September 26, 2013 Report and Order on bringing high inmate calling services rates into compliance with the statutory mandate of being just, reasonable, and fair. The rules are effective February 11, 2014, except for section 64.6060 and Section III.I, which require approval by the Office of Management and Budget. The FCC also published a Notice in the Federal Register announcing the comment dates for the accompanying FNPRM on options to reform interstate ICS. Comments are due December 13; replies due December 30. Back to Highlights November 18, 2013 Page 8 Upcoming Filing Dates • Nov. 18 - Replies due on the FNPRM on whether and how to revise the current rate methodology for IP CTS, and other issues. FR • Nov. 18 - Comments due on seeking to refresh the record on cramming, the unlawful and fraudulent practice of placing unauthorized charges on telephone bills. Replies due December 2. FR | Public Notice • Nov. 18 - Replies due on petitions for limited designation as ETCs for the provision of wireless Lifeline service filed by Sage Telecom Communications, Blue Wireless, and i-wireless. Public Notice (extended per 10/17 PN) • Nov. 19 - Replies due on NECA’s 2014 Modification of the Average Schedule Universal Service High-Cost Loop Support Formula, which, if approved, would be scheduled to take effect on January 1, 2014, and remain in effect through December 31, 2014. Public Notice (extended per 10/17 PN) • Nov. 21 - Replies due on Intelafone’s Request for Review of a July 2013 USAC decision denying its request for a waiver of the late filing fees related to Intelafone’s 2010 and 2011 FCC forms 499-A. Public Notice (extended per 10/17 PN) • Nov. 22 - Replies due on NTUA Wireless’ Petition for Forbearance from the requirement that the service area of an ETC conform to the service area of any rural telephone company serving the same area in connection with a conditional ETC designation for participating in the Tribal Mobility Fund auction, Auction 902. Public Notice • Nov. 25 - PRA comments due on proposed revisions to FCC Forms 470 and 471, and the accompanying instructions (E-Rate), and FCC Forms 497, 481, 550, 555, and 560 (Lifeline). FR • Nov. 27 - Comments due on proposed changes to FCC Form 499-A (Annual Telecommunications Reporting Worksheet) and accompanying instructions, and Form 499-Q (quarterly worksheet) and accompanying instructions. Public Notice • Nov. 29 - Comments due on US Link’s Request for review and reversal of a USAC private line revenue audit finding. Replies due December 16. Public Notice • Dec. 2 - Comments due on Deltacom’s Request for Review and reversal of an audit finding associated with a USAC decision that reclassified private line revenues originally reported as intrastate as interstate. Replies due December 17. Public Notice • Dec. 2 - Comments due on EasyLink Services International’s Request for Review of an USAC decision that denied EasyLink’s request to reverse its outstanding account balance. Replies due December 17. Public Notice • Dec. 2 - Comments due on Navajo Pillars Telephone’s Petition seeking ETC designation in two regions of the Navajo Nation and seeking a waiver of certain USF and ICC rules. Replies due December 16. Public Notice • Dec. 4 - Replies due on the FNPRM on whether and how to revise the current rate methodology for IP CTS, and other issues. FR (extended per 10/17 PN) • Dec, 4 - Replies due on the FNPRM on whether and how to revise the current rate methodology for IP CTS, and other issues. FR (extended per 10/17 PN) • Dec. 5 - Comments due on American Teleconferencing Services’ Request for Review and reversal of a USAC decision that rejected its revised amended 2012 FCC Form 499-A. Replies due December November 18, 2013 Page 9 20. Public Notice • Dec. 9 - Comments due on Madison Telephone’s Petition for Waiver of sections 54.305(d)(2), 36.612(a)(2), and 54.305(f), to allow it to receive Safety Valve Support in connection with exchanges it acquired in 2001. Replies due December 24. Public Notice • Dec. 13 - Comments due on the FCC’s proposed Lifeline Biennial Audit Plan. The proposed audit would be required of any carrier that receives more than $5 million annually from the low-income USF support program. Replies due December 30. Public Notice | FR • Dec. 13 - Comments due on the FNPRM on options to reform interstate ICS. Replies due December 30. FR • Dec. 16 - Replies due on Navajo Pillars Telephone’s Petition seeking ETC designation in two regions of the Navajo Nation and seeking a waiver of certain USF and ICC rules. Public Notice • Dec. 17 - Replies due on Deltacom’s Request for Review and reversal of an audit finding associated with a USAC decision that reclassified private line revenues originally reported as intrastate as interstate. Public Notice • Dec. 17 - Replies due on EasyLink Services International’s Request for Review of an USAC decision that denied EasyLink’s request to reverse its outstanding account balance. Public Notice • Dec. 16 - Replies due on US Link’s Request for review and reversal of a USAC private line revenue audit finding. Public Notice • Dec. 20 - Replies due on American Teleconferencing Services’ Request for Review and reversal of a USAC decision that rejected its revised amended 2012 FCC Form 499-A. Public Notice • Dec. 23 - Comments due on the NPRM seeking comment on proposals to exempt certain iTRS and CTS providers permanently from certain mandatory minimum standards. Replies due January 21. FR • Dec. 23 - PRA comments due on the reporting requirements associated with the Electronic Tariff Filing System that ILECs and CLECs use to file their tariffs and associated documents. FR • Dec. 24 - Replies due on Madison Telephone’s Petition for Waiver of sections 54.305(d)(2), 36.612(a)(2), and 54.305(f), to allow it to receive Safety Valve Support in connection with exchanges it acquired in 2001. Public Notice • Dec. 30 - Replies due on the FCC’s proposed Lifeline Biennial Audit Plan. The proposed audit would be required of any carrier that receives more than $5 million annually from the low-income USF support program. Public Notice | FR • Dec. 30 - Replies due on the FNPRM on options to reform interstate ICS. Replies due December 30. FR • Jan. 6 - PRA comments due on the new information collection associated with the May 2013 Order granting forbearance from 126 of the approximately 141 rules and requirements covered by USTelecom’s Petition. This collection covers conditional forbearance relief granted by the FCC to price cap carriers from cost assignment rules, property record rules, ARMIS report 43–01, and structural separation requirements for Independent LECs. Notice • Jan. 7 - PRA comments due on new information collection requirements relating to reforms adopted in its June 2013 Order. Notice November 18, 2013 Page 10 • Mar. 19 - Comments due on Section IV.B in the Special Access FNPRM. Replies due April 30. Back to Highlights Editor: Teresa Evert | Assistant Editor: Shawn O'Brien
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