Skip Navigation

Federal Communications Commission

English Display Options

Commission Document

Commission Concludes Investigation of Certain 2012 Annual Access Tariff

Download Options

Released: December 3, 2012

Federal Communications Commission

FCC 12-147

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of
)
)

WC Docket No. 12-233
Investigation of Certain 2012 Annual
)
Access Tariffs
)
WCB/Pricing No. 12-09
)
)

ORDER

Adopted: November 30, 2012

Released: December 3, 2012

By the Commission:

I. INTRODUCTION

1.
Last year the Commission adopted the USF/ICC Transformation Order,1 which created
an incentive-based, market-driven approach to the intercarrier compensation (ICC) systems designed to
reduce arbitrage and competitive distortions by phasing down byzantine per-minute and geography-based
charges. During the past year, the Commission, the states and the carriers have been working to
implement the first phase of the transition. This Order, which concludes the annual access tariff filing
investigation initiated this summer, represents the next step in that process. By resolving the issues
involved in the vast majority of tariff filings, the Commission is well on its way to implementing the
reforms adopted last year. As we have stated previously, we estimate, based on conservative
assumptions, that once our ICC reform is complete, mobile and wireline phone consumers stand to gain
benefits worth over $1.5 billion dollars per year.2
2.
Specifically, in this Order, we conclude the investigation regarding the Access Recovery
Charge (ARC) rates contained in the 2012 Annual Access Tariff Filings of all issuing local exchange
carriers (Designated LECs) that were suspended by the Wireline Competition Bureau (Bureau) on July 2,
2012 and were subject to the subsequent Designation Order.3 These carriers fall into two groups: issuing


1 Connect America Fund et al., WC Docket No. 10-90 et al., Report and Order and Further Notice of Proposed
Rulemaking, 26 FCC Rcd 17663 (USF/ICC Transformation Order or Order), pets. for review pending sub nom. In
re: FCC 11-161
, No. 11-9900 (10th Cir. filed Dec. 8, 2011).
2 USF/ICC Transformation Order, 26 FCC Rcd at 17873, para. 654.
3 July 3, 2012 Annual Access Tariff Filings, WCB/Pricing No. 12-09, Order, 27 FCC Rcd 7322 (Wireline Comp.
Bur. 2012) (2012 Annual Access Tariff Suspension Order or 2012 Suspension Order). Some of the suspensions
were reconsidered by the Bureau. See WCB/Pricing File No. 12-09, July 3, 2012 Annual Access Tariff Filings,
Order on Reconsideration, 27 FCC Rcd 8948 (Wireline Comp. Bur. 2012) (2012 Annual Access Tariff Suspension
Reconsideration Order
or Reconsideration Order); see also Investigation of Certain 2012 Annual Access Tariffs,
WC Docket No. 12-233, WCB/Pricing No. 12-09, Order Designating Issues for Investigation, 27 FCC Rcd 10311
(Wireline Comp. Bur. 2012) (Designation Order).

Federal Communications Commission

FCC 12-147

carriers in the National Exchange Carrier Association’s (NECA) Tariff F.C.C. No. 5 (NECA Issuing
Carriers), and rate-of-return carriers that issue their own tariffs or are issuing carriers in other group
tariffs (Other Designated LECs). Based on additional filings by NECA and changes in some rates, we
conclude that most NECA Issuing Carrier ARC rates are now just and reasonable, and therefore lawful.
Based on other additional filings and rate adjustment, we also now conclude that the ARC rates of the
Other Designated LECs are just and reasonable, and therefore lawful. As discussed below, however, we
conclude that the ARC rates for certain NECA Issuing Carriers still have not been properly justified.
Those NECA Issuing Carriers are listed in Appendices A and B. We therefore find that the ARC rates
for these NECA Issuing Carriers are unlawful, and we require NECA, on behalf of these carriers, to make
further compliance filings with the Commission. Although we will allow the problematic rates to
temporarily remain effective pending resolution of the compliance filing, refunds may be required at that
time.

II.

BACKGROUND

A.

Overview of Intercarrier Compensation Reform

3.
On November 18, 2011, the Commission released the USF/ICC Transformation Order,
which established a number of new rules requiring carriers to adjust, over a period of years, many of their
switched access charges effective on July 1 of each of those years, as part of a transition to a bill-and-
keep regime.4 As an initial matter, the Commission capped the vast majority of interstate and intrastate
switched access rates as of December 29, 2011.5 Next, carriers were required, by July 2012, to reduce
certain intrastate switched access rates by 50 percent of the differential between the carriers’ relevant
intrastate access rates and interstate access rates, provided that the aggregate intrastate revenues were
above the aggregate interstate revenues.6 The reductions to intrastate rates were implemented at the state
level via intrastate tariffs and related state proceedings.
4.
The Commission also adopted a recovery mechanism to mitigate the impact of reduced
intercarrier revenues on carriers and to facilitate continued investment in broadband infrastructure, while
providing greater certainty and predictability going forward than the status quo.7 As part of the recovery


4 See USF/ICC Transformation Order, 26 FCC Rcd at at 17934-35, para. 801 and Figure 9 (although many of the
switched access rate elements are subject to the transition adopted, other rates are not being specifically reduced at
this time). See also id. at 18109-115, paras. 1297-1314 (seeking comment on the appropriate transition for rate
elements not reduced in the USF/ICC Transformation Order).
5 Id. at 17934-35, para. 801 and Figure 9. For price cap carriers, all intrastate rates are capped as of the effective
date, while for rate-of-return carriers, only terminating intrastate access rates are capped. Id.
6 Id. The transition also required carriers to reduce reciprocal compensation rates, if above the carrier’s interstate
access rates, by 50% of the differential between the reciprocal compensation rate and the carrier’s interstate access
rate. See id. The rules defining the rate transition did not specify required reductions based on rate levels, but
compared certain intrastate revenues resulting from switched demand for Fiscal Year 2011 to the same demand
priced at corresponding interstate rates for the same period. See 47 C.F.R. § 51.909(b); see also Connect America
Fund et al.
, WC Docket No. 10-90 et al., Order, 27 FCC Rcd 5986, 5989-90, at paras. 8-9 (Wireline Comp. Bur.
2012).
7 USF/ICC Transformation Order, 26 FCC Rcd at 17677, para. 36. In adopting the recovery mechanism, the
Commission explained that it did so in large part “to provide predictability to incumbent carriers that had been
receiving implicit ICC subsidies [and] to mitigate marketplace disruption during the reform transition.” Id. at
17962-63, para. 858.
2

Federal Communications Commission

FCC 12-147

mechanism, the Commission defined as “Eligible Recovery” the amount of intercarrier compensation
revenue reductions that incumbent LECs would be eligible to recover through a combination of end-user
charges (the ARC) and, where eligible and if a carrier elects to receive it, Connect America Fund
support.8 A carrier’s Eligible Recovery is based on a percentage of the reduction in revenue each year
resulting from the intercarrier compensation reform transition.
5.
Incumbent LECs with Eligible Recovery may assess an ARC on consumers in the form
of a monthly fixed charge.9 The Commission took steps to ensure that any increases to the monthly ARC
consumer charge did not impact rate affordability, including limiting the annual residential ARC rate
increase to $0.50 and establishing a Residential Rate Ceiling that prohibits carriers from imposing an
ARC on any consumer paying an inclusive local monthly phone rate of $30 or more for basic service.10
If an incumbent LEC cannot recover its entire Eligible Recovery through ARCs and is otherwise eligible,
it may opt to receive the remainder from Connect America Fund support.11
6.
The Commission’s rules require incumbent LECs that choose to participate in the
recovery mechanism to determine their Base Period Revenues to be used in calculating their Eligible
Recovery in the 2012 Annual Access Tariff Filing.12 This initial calculation of Eligible Recovery is
critical because it establishes the amount that carriers are able to recover through their ARC charges and
potential recovery from the Connect America Fund.13 The Commission must ensure that carriers
correctly calculate their Eligible Recovery in their Tariff Review Plan spreadsheets (TRPs)14 for
implementation of the USF/ICC Transformation Order throughout the transitional period.

B.

History of the Proceeding

7.
On June 18, 2012, incumbent LECs filed their 2012 Annual Access Tariff Filings to
become effective on July 3, 2012. On July 2, 2012, the Bureau released an Order that suspended for one
day and set for investigation the ARC rates contained in the 2012 Annual Access Tariff Filings of all
issuing carriers that charged an ARC pursuant to the new rules established in the USF/ICC


8 Id. at 17957, para. 850. In creating the recovery mechanism, the Commission concluded that “it is appropriate to
first look to customers paying lower rates for some limited, reasonable recovery, and adopt[ed] a number of
safeguards to ensure that rates remain affordable and that consumers are not required to contribute an inequitable
share of lost intercarrier revenues.” Id. at 17987-88, para. 906.
9 Id. at 17988, para. 908
10 Id.
11 Id. at 17990, para. 910.
12 See 47 C.F.R. §§ 51.915, 51.917.
13 See id. §§ 51.907, 51.909, 51.915, 51.917.
14 In coordination with interested parties, the Commission created a number of new tariff worksheets to be
submitted as supporting documentation to demonstrate compliance. The April 19, 2012 TRP Order set forth the
revised TRPs for all incumbent LECs to use to support the annual revisions to their interstate access service tariffs.
See Material to be Filed in Support of 2012 Annual Access Tariff Filings, WCB/Pricing File No. 12-08, Order, 27
FCC Rcd 3960, 3960, para. 1 (Wireline Comp. Bur. 2012) (TRP Order), citing 47 C.F.R. §§ 61.41-.49, 51.700-
.715, and 51.901-.919. For both price cap and rate-of-return incumbent LECs, the Commission added new ARC,
Access Reduction, and Reciprocal Compensation spreadsheets to address the new regulations adopted in the
USF/ICC Transformation Order. Id. at 3963-66, paras. 9-11, 26-27.
3

Federal Communications Commission

FCC 12-147

Transformation Order.15 The Bureau concluded that substantial questions of lawfulness warranted
further investigation of these tariffs, and imposed an accounting order requiring the affected carriers to
keep accurate account of all received amounts associated with the rates subject to this investigation.16
8.
On August 1, 2012, the Bureau reconsidered, on its own motion, its decision to suspend
and investigate the tariffs and associated transmittals of several incumbent LECs.17 The Bureau
concluded that, following additional review and analysis, these carriers either reasonably calculated their
Fiscal Year 2011 revenues and Eligible Recovery amounts in their initial tariff filings or corrected such
calculations, and if necessary, their ARC rates in subsequent amendments to their tariff filings.18 The
Bureau therefore terminated the investigations as to those carriers that demonstrated that their Eligible
Recovery calculations were consistent with the new rules.19
9.
On August 31, 2012, the Pricing Policy Division (Division) of the Wireline Competition
Bureau designated for investigation five issues related to the 2012 Annual Access Tariff Filings.20
Specifically, the Division designated for investigation the following issues that impact carrier recovery:
(1) whether each Designated LEC reasonably determined the amount of its Base Period Revenue; (2)
whether each Designated LEC reasonably calculated its required intrastate rate reductions; (3) whether
each Designated LEC reasonably estimated its projected interstate and intrastate switched access
demand; (4) whether NECA’s allocation of projected pool interstate switched access revenues based on
projected switched access billed revenues was reasonable; and (5) whether the suspended ARC rates
were just and reasonable and, if not, the process for requiring refunds.21
10.
Direct cases for all other Designated LECs were filed on September 27, 2012. NECA’s
direct case was filed on October 4, 2012. An opposition to NECA’s direct case was filed by Emery
Telecom on October 18, 2012. No carriers submitted rebuttal filings. We now address the specific
issues that were investigated pursuant to the Designation Order.


15 See 2012 Annual Access Tariff Suspension Order, 27 FCC Rcd at 7323-24, 7325, paras. 3-4, 8.
16 See id. at 7325, para. 8; see also Letter from Sharon E. Gillett, Chief, Wireline Competition Bureau, to Regina
McNeil, Vice President and General Counsel, NECA, WC Docket Nos. 10-90 et al., 27 FCC Rcd 5801 (2012)
(Bureau May 30, 2012 Letter).
17 See Reconsideration Order, 27 FCC Rcd at 8948, para 2. Subsequent to the release of the Reconsideration
Order
, the Bureau determined that several LECs’ suspended tariff filings are reasonable (including all price cap
LECs that were not addressed in the Reconsideration Order). No issues were designated for investigation with
respect to those LECs. As a procedural matter, the suspended rates remained suspended until the conclusion of this
investigation, and we now find that they are just and reasonable, and therefore, lawful.
18 Id. at 8949, para. 4.
19 Id.
20 See 47 U.S.C. § 204.
21 See Designation Order, 27 FCC Rcd at 10311-12, 10326, para. 1 and App. A. The Designation Order also
asked each responding LEC to include, as part of its direct case, information regarding the appropriate timing and
procedures for making any necessary tariff filings or revisions to the amount of Connect America Fund support a
LEC may be eligible to receive. Id. at 10312, 10322-23, paras. 2, 33-35.
4

Federal Communications Commission

FCC 12-147

III.

DISCUSSION

A.

Whether Each Designated LEC Reasonably Determined the Amount of Its Base
Period Revenue

11.
The first issue designated for investigation was whether each Designated LEC
reasonably determined the amount of its Base Period Revenue to be used as the starting point for
calculating its Eligible Recovery.22 Each Designated LEC was required to file, as part of its direct case, a
revised description and justification document that clearly and fully explained the procedures it used to
determine its “collected revenue,” defined as Fiscal Year 2011 revenues that were received by March 31,
2012, and one of the components that comprises Base Period Revenue.23 Each Designated LEC was
directed to ensure that several aspects of determining Fiscal Year 2011 revenues for services provided
during Fiscal Year 2011 were addressed in a revised description and justification document. Further,
each Designated LEC was instructed to describe the derivation of the initial amounts, including any non-
recurring revenues, and any adjustments made in arriving at its collected revenue amount. If any Base
Period Revenue amount was modified as a result of this review of the methodology for determining
collected revenues, the Designated LEC was directed to revise its TRP filing accordingly. Designated
LECs were also invited to file any additional materials related to the appropriate procedure or
methodology to determine Base Period Revenue that would comply with the Commission’s rules.
Finally, for each NECA Issuing Carrier charging an ARC rate in its interstate switched access tariff,
NECA was directed to provide an explanation of the procedure for determining Fiscal Year 2011
revenues that were received by March 31, 2012, in compliance with the preceding requirements.24
12.
We conclude that the NECA Issuing Carriers listed in Appendix A have not
demonstrated that they reasonably determined the amount of their Base Period Revenue to be used as the
starting point for calculating their Eligible Recovery. For example, contrary to the specific requirements
set out in the Designation Order, some NECA Issuing Carriers provided no explanation at all for how
they calculated collected revenue amounts. Others stated that they used billed revenue, rather than the
amount of revenue actually collected for services provided between October 1, 2010 and September 30,
2011, and collected by March 31, 2012, as required by the Commission’s rules.25 In light of the failure of
each of the NECA Issuing Carriers listed in Appendix A to adequately justify its ARC rates, we find the
ARC rates unreasonable and we direct NECA, on behalf of each of these carriers, to make a compliance
filing with the Commission within sixty (60) days of this Order’s adoption. This compliance filing must
include a certified statement by an officer of each carrier of the amount of revenue the carrier collected
for services provided during FY 2011, as specified in the Designation Order.26 Additionally, in cases in


22 See Designation Order, 27 FCC Rcd at 10314-16, 10326, paras. 8-12 and App. A; see also 47 C.F.R. §
51.917(d).
23 See Designation Order, 27 FCC Rcd at 10315, para. 9. The relevant revenues include revenues from interstate
rate elements, rate elements included in the definition of Transitional Intrastate Access services and net reciprocal
compensation revenue for services provided during Fiscal Year 2011. See 47 C.F.R. §§ 51.903(j), 51.917(c).
Carriers may use unadjusted billed revenue only if they received payment for all relevant FY 2011 bills by March
31, 2012, and affirmatively state that they collected all relevant billed revenues in their description and justification
document. See Designation Order, 27 FCC Rcd at 10315, para. 9 n.29.
24 See Designation Order, 27 FCC Rcd at 10316, paras. 10-12.
25 See 47 C.F.R. 51.917(c).
26 See Designation Order, 27 FCC Rcd at 10315-16, paras. 9-11. Our decision to require a certified statement by
(continued….)
5

Federal Communications Commission

FCC 12-147

which the amount of collected revenue changes any Base Period Revenue amount in the filed TRP, we
direct NECA to file a revised TRP on behalf of each NECA Issuing Carrier listed in Appendix A that
reflects the carrier’s revised Base Period Revenue in all of the TRP calculations where Base Period
Revenue is used. We extend the accounting order for the NECA Issuing Carriers listed in Appendix A
and will require refunds if modifications to a NECA Issuing Carrier’s Base Period Revenues result in
lower allowed ARC rate(s) for a carrier than the rate(s) contained in the revised NECA tariff.
13.
We find that each of the Other Designated LECs, as well as the NECA Issuing Carriers
not listed in Appendix A, complied with this portion of the Designation Order, and we conclude that
those carriers have reasonably determined the amount of their Base Period Revenue to be used as the
starting point for calculating their Eligible Recovery.

B.

Whether Each Designated LEC Reasonably Calculated Its Required Intrastate
Rate Reductions

14.
The second issue designated for investigation was whether each Designated LEC
reasonably calculated its reduction in intrastate rates required by section 51.909(b) of the Commission’s
rules.27 That section requires each rate-of-return LECs to compare total revenue it would have received if
it had provided Transitional Intrastate Access Service at its interstate access rates in effect on December
29, 2011, using its Fiscal Year 2011 intrastate switched access demand for each rate element, with total
revenue from the rate elements included in the definition of Transitional Intrastate Access Service at such
carrier's intrastate access rates in effect on December 29, 2011, using its Fiscal Year 2011 intrastate
switched access demand for each rate element.28 These calculations were required to include any non-
recurring revenues and associated demand included in the Base Period Revenue. If the calculated
intrastate revenues were larger, the carrier was required to reduce its intrastate rates.29 The specific
calculation required for such rate reductions were incorporated in the 2012 RoR ILEC Intrastate Rates
Worksheet of the rate-of-return TRP.
15.
As part of its direct case, each Designated LEC was directed to file the 2012 RoR ILEC
Intrastate Rates Worksheet from its TRP with intrastate demand mapped to the interstate rate structure to
calculate the revenue that would have been generated if the intrastate demand had been priced at
interstate rates.30 Designated LECs were then instructed to make the necessary revenue comparison
between this amount and the relevant intrastate revenues and, if the required intrastate rate reduction
amount is different from the amount filed in its TRP, to refile its entire TRP to reflect the revised
intrastate rate reduction amount.31 In addition, NECA Issuing Carriers were directed to file comparable
data reflecting the calculation of the amount of required intrastate rate reductions.32
(Continued from previous page)


an officer at this time is necessary due to the insufficiency of the information submitted by each carrier identified in
Appendix A in its direct case. It is our expectation that the requested certifications will provide additional
assurance that the carriers listed in Appendix A reasonably determined the amount of their Base Period Revenue.
27 See id. at 10316-17, 10326, paras. 13-16 and App. A; see also 47 C.F.R. § 51.909(b).
28 47 C.F.R. § 51.909(b)(2)(i) and (ii).
29 47 C.F.R. § 51.909 (b)(2)(iii).
30 See Designation Order, 27 FCC Rcd at 10317, para. 15.
31 See id. Each carrier was directed to maintain records documenting the procedures used to map the intrastate
demand to the interstate rate structure, and to provide those records to the Commission on request. Id. Carriers
(continued….)
6

Federal Communications Commission

FCC 12-147

16.
We find that the Designated LECs’ revised TRP filings meet the Designation Order
requirements. The NECA Issuing Carriers’ June 18, 2012 Annual Access Tariff Filing contained
intrastate rate reductions for pooling carriers that were calculated using a methodology that improperly
failed to include intrastate rate information as part of the required aggregate revenue calculation.33 The
Bureau informed NECA that its methodology did not comply with the Commission’s rules.34 The
Designation Order identified this failure to comply with our rules as one of the reasons for suspension of
NECA Issuing Carriers’ tariffed ARC rates, and directed NECA to file revised intrastate rate reductions
for the first step of the intercarrier compensation transition for each NECA Issuing Carrier in compliance
with section 51.909(b) of the Commission’s rules.35 Our analysis of NECA’s direct case shows that this
defect in the NECA Issuing Carriers’ June 18, 2012 Annual Access Tariff Filing has been remedied by
the inclusion of intrastate demand information as required by the Commission’s intercarrier
compensation rate transition rules.36 We also note that the intrastate demand information used to
calculate the intrastate rate reductions required by the Commission’s intercarrier compensation rate
transition rules was reviewed by states in state tariff proceedings, and that interested parties had the
opportunity to participate in these proceedings.37 Because of this correction in the rate calculation
methodology, we find that the NECA Issuing Carriers’ intrastate rate reduction calculations are
reasonable for purposes of calculating Eligible Recovery and establishing ARC rates.
17.
We further conclude that TRPs filed by the Other Designated LECs reasonably reflect
the revised intrastate rate reduction amount, and we therefore conclude that these carriers have
reasonably calculated intrastate rate reductions.

C.

Whether Each Designated LEC Reasonably Estimated its Projected Interstate and
Intrastate Switched Access Demand

18.
The third issue designated for investigation was whether each Designated LEC
reasonably estimated its projected interstate and intrastate switched access demand for the 2012-13 tariff
filing year.38 As part of its direct case, each carrier was instructed to provide additional detail for certain
cells on the TRP worksheets, including the amount of local switching support (LSS) reflected in cell F7
on the 2012 RoR ILEC Interstate Rates Worksheet, and the projected annual percentage rate of demand
(Continued from previous page)


were also invited to file any additional materials or arguments that address or demonstrate the calculation of the
appropriate intrastate rate reduction in compliance with the Commission’s rules. Id.
32 See id. at 10317, para. 16.
33 See Designation Order, 27 FCC Rcd at 10316-17, para. 14.
34 See Bureau May 30, 2012 Letter.
35 See Designation Order, 27 FCC Rcd at 10316-17, paras. 13-16 (“Typically, the LEC improperly used a
composite rate for the interstate rate of the comparison, using interstate rates and interstate demand in lieu of
utilizing the methodology required by the Commission’s rules”) (emphasis in original).
36 47 C.F.R. § 51.909(b).
37 See USF/ICC Transformation Order, 26 FCC Rcd at 17929, para. 790 (noting that states will help implement the
bill-and-keep methodology, and will continue to oversee the tariffing of intrastate rate reductions during the
transition period). We note that some of these 2012 state tariff proceedings may still be ongoing and notify
carriers that they are required to file with us any updated TRPs should their state intrastate access rates increase as
a result of a state proceeding.
38 See Designation Order, 27 FCC Rcd at 10317-18, 10326, paras. 17-21 and App. A.
7

Federal Communications Commission

FCC 12-147

change reflected in the calculation of the amount in cell F10 on the 2012 RoR ILEC Interstate Rates
Worksheet and in cell G9 on the 2012 RoR ILEC Intrastate Rates Worksheet.39 Further, Designated
LECs whose projected interstate and/or intrastate demand loss exceeded an annualized rate of 15 percent
were instructed to, as part of their direct case, either: (1) file a detailed explanation of how they derived
their loss factor, or (2) utilize an annualized projection of 15 percent projected demand loss, in which
case the LEC was not required to file additional justification for its projected demand loss, but was
required to file a revised TRP reflecting an annualized 15 percent demand loss.40
19.
NECA was directed to review the TRP calculations for each of its Tariff Participants.41
For those NECA Issuing Carriers whose projected demand loss exceeded an annual rate of 15 percent,
NECA was directed to file a detailed explanation of the derivation of each issuing carrier’s loss factor as
part of its direct case.42 For those NECA Issuing Carriers whose projected demand loss exceeded 15
percent but who utilized an annualized projected demand loss of 15 percent, the Designation Order
specified that the NECA Issuing Carriers were not required to file additional justification for their
projected demand loss, but were required to file a TRP reflecting an annualized 15 percent demand loss.43
20.
With regard to the NECA Issuing Carriers, we note that 42 carriers filed TRPs that
reflected annualized intrastate demand loss of greater than 15 percent.44 We find that the NECA Issuing
Carriers listed in Appendix B provided insufficient justification for their intrastate demand loss in excess
of 15 percent. For example, a number of these carriers just provided the numbers showing a greater than
15 percent demand loss, but failed to provide any explanation as to the cause of that demand loss and
others failed to provide information sufficient for the Commission to determine if the projection was
reasonable. Because we believe that a 15 percent demand loss is a generous allowance for demand loss
notwithstanding special circumstances, which these carriers failed to provide, we find these projections
unreasonable.45 We note that carriers with actual intrastate demand loss in excess of 15 percent will be
made whole through the true-up process. 46 Accordingly, we direct NECA to refile, within sixty (60)


39 See id. at 10318, para. 19.
40 See id. at 10318, para. 20. This provision did not authorize a LEC to increase its demand loss projection to an
annualized rate of 15% if its projection in its June TRP was less than that amount.
41 See id. at 10318, para. 21.
42 See id.
43 See id. This provision did not authorize a LEC to increase its demand loss projection to an annualized rate of
15% if the projection amount in its June TRP was less than that amount.
44 As noted, the Designation Order also required justification of interstate demand losses greater than 15%, given,
in part, NECA’s methodology for allocating projected revenues. Id. at 10318, para. 21. Because NECA adopted
the proposed pooling allocation of projected revenues addressed in Section III.D, individual carrier projections are
less significant. We find that the administrative cost of revising the pool allocation of projected revenue to reflect
the small number of carriers with unsupported interstate demand losses greater than 15% would exceed any
benefits from requiring NECA to reallocate what would likely be a de minimis reduction in projected revenues. In
any event, the demand projections will be trued-up in 2014.
45 The Division established a threshold of 15% to focus its review of demand projections to those exceeding our
anticipated range. See id at 10318, para. 20. We note that approximately 95% of carriers included demand
projections of 15% or less in their direct cases, suggesting that the approach adopted in the Designation Order was
reasonable.
46 The USF/ICC Transformation Order permits true-ups for a carrier’s recovery based upon a carrier’s actual
(continued….)
8

Federal Communications Commission

FCC 12-147

days from the date of this Order, new TRPs reflecting an annualized projected intrastate demand loss of
no greater than 15 percent for each of the NECA Issuing Carriers listed in Appendix B. We extend the
accounting order established in the 2012 Annual Access Tariff Suspension Order for these NECA Issuing
Carriers and will require refunds to the extent that carriers’ demand adjustments result in lower ARC
rates. The remaining NECA Issuing Carriers either used a 15 percent or less annualized intrastate
demand loss or provided an adequate justification as to how they derived a demand loss factor that
exceeds 15 percent. We conclude that these NECA Issuing Carriers have reasonably estimated their
projected intrastate switched access demand.
21.
We find that the Other Designated LECs either reasonably demonstrated how they
derived a demand loss factor that exceeds 15 percent, or utilized an annual demand loss projection no
greater than 15 percent. We conclude that those carriers have reasonably estimated their projected
interstate and intrastate switched access demand.

D.

Whether NECA’s Allocation of Projected Pool Interstate Switched Access Revenues
Based on Projected Switched Access Billed Revenues Was Reasonable

22.
The fourth issue designated for investigation was whether it was reasonable for NECA to
use each pooling carrier’s projection of billed 2012-13 interstate switched access revenues as the means
of allocating projected pool switched access revenues among pool participants in calculating issuing
carriers’ Eligible Recovery.47 In the TRPs supporting its annual access tariff filing, NECA identified, as
each Pooling LEC’s projected 2012-13 interstate switched access revenues the revenue the carrier was
projected to receive from its individual billing of access services at the relevant NECA rates. NECA’s
use of individual carrier switched access service revenue, rather than pool settlement revenue, as the
projected interstate switched access revenue amount for the purpose of calculating a carrier’s Eligible
Recovery effectively eliminated interstate switched access pooling for the rate elements involved. This
elimination of pooling resulted in each Pooling LEC’s Eligible Recovery increasing or decreasing
depending on whether it was a net recipient or a net contributor to the pool.48 This approach resulted in
approximately 40 Pooling LECs (a subset of the Pooling LEC’s who would otherwise have been net
contributors to the pool) having projected switched access revenues for 2012-13 above their adjusted
base period revenue.49 And, because any switched access service revenues received that were above a
carrier’s adjusted base period revenue would not have been redistributed among Pooling LECs, the ARC
and/or Connect America funding needed for the remaining Pooling LECs would have been
correspondingly increased. This approach also changed the distribution of how carriers would have
(Continued from previous page)


minutes of use (MOUs). Therefore, if a NECA Issuing Carrier does actually incur intrastate demand losses in
excess of 15%, it will be able to recover that Eligible Recovery pursuant to the true-up. See USF/ICC
Transformation Order
, 26 FCC Rcd at 17982-83, para. 899. However, we also note that the Commission will
review whether carriers significantly overstated their demand loss at the end of the true-up period. The
Commission may revisit what constitutes a reasonable demand loss estimate if its review of the true-up process
establishes carriers are consistently overestimating their actual rate of demand loss.
47 See Designation Order, 27 FCC Rcd at 10319-20, 10326, paras. 22-27 and App. A. See also 47 C.F.R. §
69.600 et seq.
48 Notwithstanding NECA’s interpretation of the interstate pooling requirements, we note that NECA used pool
settlement revenues, rather than individually billed revenues, for purposes of determining projected revenue for
LECs participating in intrastate pools.
49 We use the term “adjusted base period revenue” here to describe the amount of money each carrier would need
to receive from switched access revenues to achieve their Base Period Revenue amount reduced by 5%.
9

Federal Communications Commission

FCC 12-147

recovered their Eligible Recovery, as it would have impacted the amounts received through ARC rates
and the Connect America Fund.
23.
The Division explained in the Designation Order that NECA’s approach to projecting
interstate received switched access revenue for each pooling LEC appeared to be inconsistent with the
intent of the USF/ICC Transformation Order to permit LECs to elect whether to participate in the NECA
pooling process.50 Moreover, the Designation Order noted that the USF/ICC Transformation Order
contemplated a continuation of the pooling process for switched access services and that the results of
that pooling process should be the basis for allocating projected 2012-13 switched access revenues.51
24.
Pursuant to that analysis, the Division stated in the Designation Order that it would be
reasonable to allocate projected revenues for purposes of determining each pooling carrier’s projected
2012-13 interstate switched access revenues by allocating the projected revenues in relation to each
carrier’s interstate Base Period Revenue divided by the projected pool Base Period Revenue.52 NECA
was directed to employ this pooling approach in its direct case, if it found the methodology to be
acceptable, by filing revised TRPs supporting each of its tariff participants’ calculation of Eligible
Recovery.53 If NECA chose not to employ this pooling approach it was invited to file additional
materials that address the proper development of Eligible Recovery for pooling LECs, including
arguments supporting the approach used by NECA and any adjustments needed to address any potential
windfall for some carriers.54
25.
On October 4, 2012, NECA filed its direct cases, including support for the development
of each pooling carrier’s Eligible Recovery, which employed the pooling approach outlined in the
Designation Order.55 An opposition to NECA’s direct case was filed by Emery Telecom on October 18,
2012, which we reject herein as inconsistent with the USF/ICC Transformation Order.56 Accordingly,


50 Designation Order, 27 FCC Rcd at 10320, para. 24.
51 Id. at 10320, para. 25.
52 See id.
53 See id. at 10320, para. 26. NECA Issuing Carriers were further instructed to include in the revised TRPs any
additional adjustments that may be necessary because of other aspects of the Designation Order. Id.
54 See id. at 10320, para. 27.
55 See id. at 10319-20, paras. 22-26.
56 We reject Emery’s argument that the USF/ICC Transformation Order and the Commission’s rules do not
support the interpretation that settlement revenues must be pooled when calculating a carrier’s Eligible Recovery.
See Emery Telecom Comments on Direct Case of NECA, WC Docket No. 10-90 et al., at 1-3 (filed Oct. 18,
2012). Emery urges the Commission to reinstate NECA’s original calculation of Eligible Recovery, thereby not
requiring Emery to assess an ARC on its end users. Id. As the Designation Order made clear, the Commission
intended that NECA pooling continue. See Designation Order, 27 FCC Rcd at 10320, para. 25. The pooling
process has historically included the development of averaged pool rates reflecting the costs of the pooling LECs
and the distribution of revenues in a manner that reflected each carrier’s costs. See id. at 10319-20, paras. 22-23.
Nothing in the USF/ICC Transformation Order indicated that these procedures should be abandoned. To do as
Emery Telecom suggests would be inconsistent with the recovery mechanism adopted in the USF/ICC
Transformation Order
by making the assessment of an ARC by some carriers dependent on whether they were a
significant net contributor to the NECA pool. See id. at 10319-20, paras. 23-24.
10

Federal Communications Commission

FCC 12-147

we conclude that the approach utilized by the NECA Issuing Carriers in their direct cases constitutes
pooling in a manner that is consistent with the approach set forth in the USF/ICC Transformation Order.

E.

Modifications to Access Recovery Charge Rates as a Result of this Investigation

26.
The fifth issue designated for investigation was the reasonableness of the ARC rates of
the Designated LECs, and, if the rates are unjust and unreasonable, the process for requiring refunds,
which will be discussed in Section III.F of this order.57 Only certain of the NECA Issuing Carriers’ ARC
rates changed as a result of the revised calculations required by the direct case.
27.
First, we deny the Application for Review filed by the Public Service Commission of the
District of Columbia (DC PSC).58 The DC PSC Application seeks review of the Wireline Competition
Bureau’s Reconsideration Order, arguing that allowing Verizon’s ARC rates to become effective permits
Verizon to charge residential customers in states in which the Residential Rate Ceiling is not reached a
higher and unfair ARC.59 Because the tariff complies with section 51.915(e)(3) of the Commission’s
rules,60 we conclude that the Bureau acted properly in permitting Verizon’s ARC rates to become
effective.61 Second, we dismiss the DC PSC’s Application insofar as the DC PSC does not assert that the
Verizon ARC rate at issue violates Commission rules; it argues instead that we should change the rules to
prohibit such a rate. As noted in the Reconsideration Order, the DC PSC’s petition requesting
reconsideration of section 51.915(e)(3) of the Commission’s rules remains pending and is the appropriate
vehicle for the Commission to address whether the rules should be changed.62


57 See Designation Order, 27 FCC Rcd at 10321-22, 10326, paras. 28-32 and App. A. This issue also includes
consideration of any ARC rate later suspended and rolled into this investigation. See National Exchange Carrier
Association Revisions to Tariff F.C.C. No. 5
, WCB/Pricing File No. 12-09, Transmittal No. 1350, Order, 27 FCC
Rcd 8148 (2012).
58 Application for Review of the Wireline Competition Bureau’s Order on Reconsideration, DA 12-1231 of Betty
Ann Kane, Chairman of the Public Service Commission of the District Of Columbia, WCB/Pricing File No. 12-09
(filed Aug. 31, 2012) (DC PSC Application).
59 DC PSC Application at 6.
60 Section 51.915(e)(3) provides that a price cap carrier holding company “may recover the eligible recovery
attributable to any price cap study areas operated by its wholly-owned operating companies through assessments of
the Access Recovery Charge on end users in any price cap study areas operated by its wholly owned operating
companies that are price cap incumbent local exchange carriers.” 47 C.F.R. § 51.915(e)(3). As a price cap
holding company, Verizon is permitted to assess its ARC charges on end users in any price cap study areas
operated by its wholly owned price cap regulated operating companies. Thus, Verizon’s assessment of the ARC
charges in the manner provided in its tariff did not violate this Commission rule.
61 Id.
62 Reconsideration Order, 27 FCC Rcd at 8949, para. 4 n.10. We plan to act on the DC PSC’s Petition
expeditiously, and in order to ensure that we have a complete record on these issues, we incorporate the record
developed in this proceeding into the record associated with the DC PSC’s Petition for Reconsideration. See
Petition for Reconsideration of the Public Service Commission of the District of Columbia, WC Docket Nos. 10-90
et al. (filed Dec. 29, 2011). In addition, on October 4, 2012, the Commission received, from the Pennsylvania
Public Utility Commission (PA PUC), a document captioned “Petition For Clarification of the Pennsylvania Public
Utility Commission and Application for Review of Wireline Competition Bureau’s Order on Reconsideration, DA
12-1231, of Betty Ann Kane, Chairman of the Public Service Commission of the District of Columbia.” This
document was filed pursuant to sections 1.2, 1.41, and 1.429 of the Commission’s rules. To the extent that this
(continued….)
11

Federal Communications Commission

FCC 12-147

28.
The Designation Order directed NECA to provide four tables as part of its direct case.
Specifically, it directed NECA to provide a table (Table 1), showing the LECs that filed a residential
ARC of $0.50, a single-line business ARC of $0.50, and a multi-line business ARC of $1.00 that remain
eligible to charge those rates under the revised TRP for each NECA Tariff Participant. NECA was
directed to provide a second table (Table 2), showing the LECs that filed a residential ARC capped by
the Residential Rate Ceiling, a single-line business ARC of $0.50, and a multi-line business ARC of
$1.00 that remain eligible to charge the same rates under the revised TRP. NECA was directed to
provide a third table (Table 3) listing each LEC that the direct case shows would be eligible to charge
one or more higher ARC rate(s) than those currently in effect. For each LEC listed in Table 3, NECA
was directed to provide the currently effective ARC rates and the comparable ARC rates determined in
the direct case. NECA was directed to provide a fourth table (Table 4), listing each LEC that has one or
more currently effective ARC rate(s) that the direct case shows exceed the allowed ARC rate(s). For
each LEC listed in Table 4, NECA was directed to provide the currently effective ARC rates and the
comparable ARC rates determined in NECA’s direct case. NECA was also required to submit a proposal
for filing revised ARC rates which included, for each LEC listed in Table 4, the proposed rates to be filed
to provide the required refund and the length of time such rates shall be in effect.63
29.
We have reviewed the direct cases filed in response to the Designation Order, as
discussed above in sections III.A–D of this Order. Based on this review, with the exception of the
carriers listed in Appendices A and B, we find that the ARC rates of all carriers for whom the
reasonableness of the ARC rates was set for investigation are just and reasonable, and thus lawful.64
30.
Further, in the Designation Order we noted that some price cap carrier rates were not
being designated for investigation even though their suspensions had not been reconsidered in the
Reconsideration Order. Since the release of the Reconsideration Order, we determined that those
carriers had sufficiently addressed all concerns with their filings prior to the release of the Designation
Order
and we decided not to designate any issues with regard to those LECs.65 We hereby affirm that the
ARC rates of those carriers are determined to be just and reasonable, and thus lawful.
31.
As noted above with respect to issues discussed in Sections III.A and C, we are requiring
certain carriers to make a compliance filing that may result in revised Eligible Recovery amounts and
thus potentially different allowable ARC rates. Accordingly, as part of its compliance filing, we direct
(Continued from previous page)


filing is a petition for reconsideration of the Bureau’s Reconsideration Order, we dismiss it on procedural grounds
because it was not filed within 30 days, as required under the Commission’s rules. See 47 C.F.R § 1.429(d).
Likewise, to the extent the PA PUC filing is an application for review of the Bureau’s Reconsideration Order, we
dismiss it on procedural grounds because it was not filed within 30 days, as required under the Commission’s rules.
See 47 C.F.R. § 1.115. However, to the extent that the PA PUC filing is a request for a declaratory ruling or a
request for clarification, it involves questions regarding how the Commission has interpreted or applied its rules,
and is therefore more appropriately considered in the context of the DC PSC’s pending Petition for
Reconsideration of section 51.915(e)(3) of the Commission’s rules. Accordingly, we also incorporate the PA PUC
filing into the record associated with the DC PSC’s Petition for Reconsideration.
63 See Designation Order, 27 FCC Rcd at 10321-22, para. 30.
64 See supra para. 12 (explaining that carriers listed in Appendix A failed to reasonably determine the amount of
their base period revenue) and para. 20 (explaining that carriers listed in Appendix B failed to reasonably estimate
their interstate and intrastate switched access demand).
65 Designation Order, 27 FCC Rcd at 10311, para. 1 n.2.
12

Federal Communications Commission

FCC 12-147

NECA to refile, within sixty (60) days from the date of this Order, updated tables 1-4 reflecting changes
that result from implementation of this Order. We note that no comments were received on refund
procedures for NECA Issuing Carriers, and we address the refund process in Section III(F). Though
currently not justified on the evidence here, we anticipate that ARC charges at some rate level ultimately
will be just and reasonable, and thus find it equitable, until the compliance filings and refund processes
are resolved, to temporarily allow those carriers to continue to charge the ARC rates currently filed.66
We note that NECA will be directed to file new tariffs to implement the changes reflected in the revised
tables 1-4 submitted with the compliance filing.

F.

Implementation Procedures

32.
Finally, the Designation Order raised the question of what further procedures may be
necessary to implement the instant Order terminating this investigation.67 Such issues include comment
on what procedures should be specified to address changes to the amount of Connect America Fund
support a carrier may be eligible to receive and/or may have already received.68 For NECA pooling
carriers, the Designation Order sought comment on the Division’s proposal that NECA and USAC
establish a process within 21 days of the release of this Order to implement the required revisions in a
coordinated manner.69 For Other Designated LECs, the Designation Order sought comment on the
Division’s proposal that each carrier file a revised TRP with the Universal Service Administrative
Company (USAC) within 30 days of this Order, after which USAC would process the revised filings and
make the necessary adjustments consistent with the process it uses to address other submissions of
revised data.70
33.
No carriers filed comments either opposing the Division’s proposal or suggesting a
different method to address changes to the amount of Connect America Fund support a carrier may be
eligible to receive or may have already received.71 Accordingly, we require each NECA Issuing Carrier
and Other Designated LEC not listed in Appendices A and B whose replacement Connect America Fund
support has changed as a result of this proceeding to file a revised TRP with USAC within thirty (30)
days of the date of this Order, and USAC will process the revised filings and make the necessary
adjustments to the carrier’s Connect America Fund support using its normal procedure for processing


66 See, e.g., American Telephone and Telegraph Company, 85 F.C.C.2d 549, 556-57, paras. 17-18 (1981)
(discussing MCI v. FCC, 627 F. 2d 322, 338 (D.C. Cir. 1980), and concluding that where the Commission had held
rates to be unlawful – and indeed, even unjust and unreasonable, as well – it nonetheless had leeway to allow those
rates to temporarily continue in effect where its decision was based on insufficient data and “not based upon a
substantive assessment of the rates on their merits”).
67 See Designation Order, 27 FCC Rcd at 10322-23, paras. 33-35.
68 See id. at 10322-23, para. 33.
69 See id. at 10323, para. 35.
70 See id. at 10323, para. 34.
71 We note that both Union Telephone Company (Union) and the Chillicothe Telephone Company (Chillicothe)
suggest that “major recalculations of Eligible Recovery that reduce CAF ICC support or require repayment of prior
disbursements of CAF ICC support be extended over a reasonable and appropriate transition period to minimize
disruptions to the operations and finances of affected small businesses.” See Union Direct Case at 10-11;
Chillicothe Direct Case at 18. Since neither Union nor Chillicothe cites any specific instance where this transition
period should apply, we decline to act on their requests at this time.
13

Federal Communications Commission

FCC 12-147

data revisions. To avoid any carrier receiving a cash flow shock from differences in the timing of the
USAC adjustments and the NECA pooling adjustments, we direct USAC and NECA to coordinate the
timing of their adjustments to minimize cash flow disruptions.
34.
With regard to carriers required to make compliance filings and potentially submit
revised TRPs, the Bureau will review them when filed. For those filings that contain Base Period
Revenue figures and revised intrastate demand projections at 15 percent that implement the directives of
this Order in a reasonable manner, the Bureau will direct USAC to process the TRP filings as necessary
to make adjustments to the carrier’s Connect America Fund support.
35.
Carriers whose compliance filings or revised TRPs do not reasonably implement the
directives of this Order may continue to be subject to refunds of amounts collected under tariffed charges
subject to the accounting order in this proceeding. We delegate authority to the Wireline Competition
Bureau, as appropriate, to review the compliance filings required by this Order and to take any further
action necessary to ensure that the directives contained in this Order are carried out.

IV.

ORDERING CLAUSES

36.
ACCORDINGLY, IT IS ORDERED that, pursuant to sections 201-204, and 251 of the
Communications Act of 1934, as amended, 47 U.S.C. §§ 201-204, 251, the tariff investigation initiated in
WCB/Pricing Docket No. 12-09 IS TERMINATED.
37.
IT IS FURTHER ORDERED that the Access Recovery Charge rates filed by the
National Exchange Carrier Association on behalf of the NECA Issuing Carriers listed in Appendices A
and B are unlawful. However, the Access Recovery Charge rates of those carriers may continue to be
assessed pending the outcome of the compliance plan filings.
38.
IT IS FURTHER ORDERED that the NECA Issuing Carriers listed in Appendices A and
B within sixty (60) days from the date of this order SHALL FILE compliance filings consistent with this
Order.
39.
IT IS FURTHER ORDERED that the National Exchange Carrier Association, within
sixty (60) days from the release date of this order, SHALL FILE a compliance filing consistent with this
Order.
40.
IT IS FURTHER ORDERED that the accounting order applicable to the NECA Issuing
Carriers REMAINS EFFECTIVE with respect to the carriers listed in Appendices A and B.
41.
IT IS FURTHER ORDERED that the rates of the Designated LECs that are not listed in
Appendices A and B are just and reasonable, and therefore lawful.
42.
IT IS FURTHER ORDERED that the accounting order applicable to Designated LECs
that are not listed in Appendices A and B IS TERMINATED.
43.
IT IS FURTHER ORDERED that each Designated LEC not listed in Appendices A and
B whose ICC replacement Connect America Fund recovery amount has changed as a result of this
proceeding, within thirty (30) days from the release date of this Order, SHALL FILE a revised Tariff
Review Plan with USAC, and USAC will process the revised filings and make the necessary adjustments
to the carrier’s Connect America Fund support.
44.
IT IS FURTHER ORDERED that the Application for Review filed by the Public Service
14

Federal Communications Commission

FCC 12-147

Commission of the District of Columbia IS DENIED to the extent described above, and otherwise IS
DISMISSED.
45.
IT IS FURTHER ORDERED that, to the extent the Pennsylvania Public Utility
Commission filing referenced above contains an Application for Review or a Petition for
Reconsideration, the Petition or Application IS DISMISSED.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary
15

Federal Communications Commission

FCC 12-147

APPENDIX A

STUDY AREA ID

ISSUING CARRIER NAME

120042
DIXVILLE TELEPHONE COMPANY
140053
FRANKLIN TELEPHONE COMPANY
170171
HICKORY TELEPHONE COMPANY
170215
YUKON-WALTZ TELEPHONE COMPANY
190248
SCOTT COUNTY TELEPHONE COOPERATIVE, INC.
270432
KAPLAN TELEPHONE COMPANY
290562
DEKALB TELEPHONE COOPERATIVE, INC.
WEST KENTUCKY RURAL TELEPHONE COOPERATIVE
290598
CORPORATION, INC.
310688
CLIMAX TELEPHONE COMPANY
310703
KALEVA TELEPHONE COMPANY
310704
ACE TEL. CO. OF MICHIGAN INC.
310725
SAND CREEK TELEPHONE COMPANY
330971
WEST WISCONSIN TELCOM COOP., INC.
431977
CENTRAL OKLAHOMA TELEPHONE COMPANY
431979
CHEROKEE TELEPHONE COMPANY
462188
FARMERS TELEPHONE COMPANY, INC.
462201
RICO TELEPHONE COMPANY
492262
E.N.M.R. TEL. COOPERATIVE, INC.-NM
502279
GUNNISON TELEPHONE COMPANY
16

Federal Communications Commission

FCC 12-147

APPENDIX B

STUDY AREA ID

ISSUING CARRIER NAME

522419
HOOD CANAL TELEPHONE CO.
613013
KETCHIKAN PUBLIC UTILITIES TELEPHONE DIVISION
140069
WAITSFIELD/FAYSTON TELEPHONE CO., INC.
190239
NEW HOPE TELEPHONE COOPERATIVE
220381
PUBLIC SERVICE TELEPHONE COMPANY
230491
NORTH STATE TELEPHONE COMPANY. D/B/A NORTH
STATE COMMUNICATIONS
250283
BRINDLEE MOUNTAIN TELEPHONE LLC
250290
FARMERS TELECOMUNICATIONS COOPERATIVE, INC.
250300
HOPPER TELECOMMUNICATIONS LLC
250322
UNION SPRINGS TELEPHONE COMPANY, INC.
270433
LAFOURCHE TELEPHONE COMPANY, L.L.C.
290565
HIGHLAND TELEPHONE COMPANY, INC.
300606
CONNEAUT TELEPHONE COMPANY
300634
MINFORD TELEPHONE COMPANY
310777
ACE TELEPHONE COMPANY OF MICHIGAN, INC. - OLD
MISSION
330920
NIAGARA TELEPHONE COMPANY
341025
SHAWNEE TELEPHONE. COMPANY
341060
MOULTRIE INDEPENDENT TELEPHONE COMPANY
341062
NEW WINDSOR TELEPHONE COMPANY
351346
ACE TELEPHONE ASSOCIATION-IA
361346
ACE TELEPHONE ASSOCIATION-MN
371537
DALTON TELEPHONE COMPANY
452176
VALLEY TELEPHONE COOPERATIVE, INC.-AZ
482242
INTERBEL TEL. COOP., INC.
482244
LINCOLN TELEPHONE COMPANY, INC.
532364
COLTON TELEPHONE COMPANY
532371
CASCADE UTILIITES, INC.
532378
TRANS-CASCADE TELEPHONE COMPANY
532388
NORTH STATE TELEPHONE COMPANY
542338
SIERRA TELEPHONE COMPANY, INC.
552351
LINCOLN COUNTY TELEPHONE SYSTEM, INC.
432016
PANHANDLE TELEPHONE COOPERATIVE, INC.
472423
INLAND TELEPHONE COMPANY-ID
17

Note: We are currently transitioning our documents into web compatible formats for easier reading. We have done our best to supply this content to you in a presentable form, but there may be some formatting issues while we improve the technology. The original version of the document is available as a PDF, Word Document, or as plain text.

close
FCC

You are leaving the FCC website

You are about to leave the FCC website and visit a third-party, non-governmental website that the FCC does not maintain or control. The FCC does not endorse any product or service, and is not responsible for, nor can it guarantee the validity or timeliness of the content on the page you are about to visit. Additionally, the privacy policies of this third-party page may differ from those of the FCC.