Skip Navigation

Federal Communications Commission

English Display Options

Commission Document

Study Area Boundary Reconsideration Order

Download Options

Released: February 26, 2013

Federal Communications Commission

DA 13-282

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of
)
)

Connect America Fund
)
WC Docket No. 10-90
)
High-Cost Universal Service Support
)
WC Docket No. 05-337

ORDER ON RECONSIDERATION

Adopted: February 26, 2013

Released: February 26, 2013

By the Chief, Wireline Competition Bureau:

I.

INTRODUCTION

1.
On November 6, 2012, the Wireline Competition Bureau (Bureau) released a Report and
Order1 adopting data specifications for the collection of study area boundary data to use in the
implementation of certain universal service reforms adopted as part of the USF/ICC Transformation
Order
.2 The Study Area Boundary Order required incumbent local exchange carriers (LECs) to submit
certified study area boundary data in esri shapefile format, and it allowed state commissions or state
telecommunications associations (state entities) voluntarily to submit such data on the LECs’ behalf.3
2.
In this Order on Reconsideration, the Bureau modifies on its own motion several aspects
of the rules adopted in the Study Area Boundary Order. First, we conclude that it is more appropriate for
state commissions to certify to the accuracy of the study area boundary data when they submit such data
on behalf of the incumbent LECs operating in their state. Second, we reconsider our decision to permit
state associations to submit data on behalf of incumbent LECs and instead require that the entity that will
certify to the accuracy of the data make the submission. Third, we permit incumbent LECs that are price
cap carriers to submit exchange-level study area boundary data by providing internal wire center
boundaries, if they choose, and indicating the exchange(s) associated with the wire center. Finally, we
provide some guidance as to our expectations regarding the certification requirement and clarify the
standards of accuracy laid out in the Study Area Boundary Order.


1 Connect America Fund; High-Cost Universal Service Support, WC Docket Nos. 10-90, 05-337, Report and Order,
27 FCC Rcd 13528 (Wireline Comp. Bur. 2012) (Study Area Boundary Order). The Study Area Boundary Order
was published in the Federal Register on January 28, 2013. See 78 FR 5750.
2 See Connect America Fund; A National Broadband Plan for Our Future; Establishing Just and Reasonable Rates
for Local Exchange Carriers; High-Cost Universal Service Support; Developing a Unified Intercarrier
Compensation Regime; Federal-State Joint Board on Universal Service; Lifeline and Link-Up; Universal Service
Reform—Mobility Fund
; WC Docket Nos. 10-90, 07-135, 05-337, 03-109, CC Docket Nos. 01-92, 96-45, GN
Docket No. 09-51, WT Docket No. 10-208, Report and Order and Further Notice of Proposed Rulemaking, 26 FCC
Rcd 17663 (2011) (USF/ICC Transformation Order), pets. for review pending sub nom. In re: FCC 11-161, No.
11-9900 (10th Cir. filed Dec. 8, 2011).
3 Study Area Boundary Order, 27 FCC Rcd at 13528, para. 1.

Federal Communications Commission

DA 13-282

II.

DISCUSSION

A.

State Entity Certification

3.
In the Study Area Boundary Order, we allowed state entities voluntarily to submit
shapefiles on behalf of any and/or all incumbent LECs within their states.4 The Bureau stated that state
commissions typically are the entities that establish incumbent LEC service areas and therefore are well
situated to assist incumbent LECs in preparing study area boundary data.5 The Study Area Boundary
Order
concluded, however, that even when states submit data on behalf of incumbent LECs, those
incumbent LECs remain responsible for reviewing and certifying to the accuracy of the state-submitted
data.6 With this Order on Reconsideration, we modify certain aspects of these requirements and conclude
that the entity submitting data to the Commission is the more appropriate entity to certify to the accuracy
of the study area boundaries; we continue to encourage states to submit data on behalf of their incumbent
LECs.
4.
Since release of the Study Area Boundary Order, some incumbent LECs have argued
that, because state commissions are the entities responsible for establishing study area boundaries, state
commissions should be responsible for submitting such boundaries and/or certifying that they are
accurate.7 In addition, certain state commissions have also asserted that they should be involved in or
responsible for certifying the accuracy of the study area boundaries in their state.8 We recognize that both
state commissions and this Commission have a role in overseeing study area boundaries.9 Therefore, we
now conclude upon reconsideration that it is appropriate for the state commissions that voluntarily
undertake the task of submitting boundary data to us to certify that these data are accurate and correct to
the best of their knowledge, information, and belief.10 In addition to acknowledging the states’ traditional
role in administering incumbent LEC study area boundaries, we also believe that it is most efficient and
direct for an entity submitting data to the Commission to be responsible for its accuracy, rather than
having data submitted by one party but verified by another. While state commissions were the entities


4 Id. at 13533, para. 17.
5 Id. The Bureau did not require all states to submit the study area boundaries on behalf of their incumbent LECs,
however, in part due to an expectation that some state commissions may not be prepared to undertake the necessary
reconciliation effort in the time frame contemplated for the data collection.
6 Id. at 13534, para. 18.
7 See Comments of United States Telecom Association, WC Docket Nos. 10-90, 05-337, OMB Control No. 3060-
1181, filed Jan. 3, 2013, at 4, 16 (USTelecom PRA Comments); Remarks of Jeff Lanning, VP-Federal Regulatory
Affairs, CenturyLink, at NARUC Winter Committee Meetings, Staff Subcommittee on Telecommunications – CAF-
Boundary Mapping, Feb. 3, 2013 (Lanning Feb. 3 Remarks).
8 Letter from Maurice Gene Hand, Director, Communications Department, Nebraska Public Service Commission, to
Chelsea Fallon, Assistant Chief, Industry Analysis and Technology Division, FCC, WC Docket Nos. 10-90, 05-337
(filed Feb. 21, 2013).
9 The Commission froze all study area boundaries effective November 15, 1984, to prevent the establishment of
high-cost exchanges within existing service territories merely to maximize high cost support. See MTS and WATS
Market Structure; Amendment of Part 67 of the Commission’s Rules and Establishment of a Joint Board
, CC Docket
Nos. 78-72, 80-286, Decision and Order, 50 Fed. Reg. 939 (1985) (Part 67 Order); see also 47 C.F.R. Part 36 App.
(“Study area boundaries shall be frozen as they are on November 15, 1984”). A carrier must therefore apply to the
Commission for a waiver of the study area boundary freeze if it wishes to acquire or transfer exchanges. Part 67
Order
, 50 Fed. Reg. at 939, para. 1. In the USF/ICC Transformation Order, the Commission streamlined its rules
governing study area waiver requests, creating a method similar to the Bureau’s processing of routine section 214
transfer of control applications. See USF/ICC Transformation Order, 26 FCC Rcd at 17763, paras. 266-67; 47
C.F.R. § 36.4. The Bureau considers whether the state commission objects to the proposed transfer of exchanges.
10 See infra para. 15 for a further discussion of certification.
2

Federal Communications Commission

DA 13-282

that originally established study area boundaries for the incumbent LECs in their state, we acknowledge
that certain states may not have the resources available to compile and submit study area boundary data in
the format requested for this data collection. We therefore will continue to rely on individual incumbent
LECs to submit data on the study areas they serve in cases where state commissions do not submit data
and invite state entities to participate in any necessary reconciliation of data submitted by ILECs.11
5.
State commissions wishing to submit and certify study area boundary data should notify
the Commission in writing of their intention to do so by filing a notification in WC Docket No. 10-90
using the Commission’s Electronic Comment Filing System (ECFS).12 In these notifications, states
should indicate which incumbent LEC study areas they plan to include in their submission. We will
release a Public Notice identifying the deadlines for these notices, as well as the deadlines for the
shapefile submissions and certifications, in the near future. States planning to submit data will be able to
file at a later date than incumbent LECs since the states will have already taken on the task of resolving
any disputes and ensuring the accuracy of the filing. State commissions should submit data based on the
specification in the Appendix attached hereto. We expect that the boundaries submitted and certified by
state commissions will have been verified and reconciled at the state level, and that minimal further
reconciliation will need to be done by Commission staff.13
6.
If a state commission does not notify the Commission that it intends to submit study area
boundary data for the incumbent LECs in its state, those incumbent LECs are required to submit and
certify their study area boundary data under the rules and procedures established in the Study Area
Boundary Order
and this Order on Reconsideration, as well as subsequent Public Notices providing filing
deadlines and instructions.14
7.
On reconsideration, we no longer provide an option for state associations to submit data
on behalf of incumbent LECs in their state. Consistent with our decision above that state commissions
making submissions should certify as to the accuracy of the data, we conclude in general that the party
submitting the data should also certify as to its accuracy, consistent with the certification standard as
explained below. We do not believe that the state associations are likely to have the necessary
information to be able to certify as to the accuracy of incumbent LECs’ data; we therefore reconsider our
earlier decision to provide the option for state associations to submit data on behalf of incumbent LECs.
However, state associations can assist state commissions and incumbent LECs in preparing boundary data
and in the reconciliation of data submitted by incumbent LECs. In those states where the state
commission chooses not to submit data on behalf of all incumbents, we encourage state commissions and
state telecommunications associations to participate in the process of reconciling data submitted by the
incumbent LECs and will share such data with them to assist in that function.15 For instance, we plan to
provide state entities with a map of the LEC-submitted boundaries for their review and comment. If


11 See infra paras. 5-7.
12 ECFS is available at <http://apps.fcc.gov/ecfs/>;.
13 Commission staff will review data submitted by state commissions to ensure its completeness and to confirm that
it follows the data specification and mapping standards set forth in the Appendix to this Order on Reconsideration.
14 As stated in the Study Area Boundary Order, we will contact any incumbent LEC that does not submit study area
boundary data in the format requested by the required date and request that the data be submitted within 30 days,
unless the state commission has filed a notification indicating that it plans to submit study area boundary data on
behalf of that incumbent LEC. We will also contact any incumbent LEC that has not certified the accuracy of the
required study area data, and request that the incumbent LEC certify the data, or submit corrected data, within 30
days. Study Area Boundary Order, 27 FCC Rcd at 13535, para. 22.
15 For instance, state telecommunications associations can assist incumbent LECs in preparing boundary data and, in
cases where the associations maintain such data in their own records, can provide that data to the incumbent LECs
for them to submit.
3

Federal Communications Commission

DA 13-282

boundary overlaps, void areas, or disputes occur in data submitted by incumbent LECs, we will seek input
from the relevant state entities and incumbent LECs to help resolve such issues. If a state commission
chooses not to participate in the reconciliation process, we will resolve the matter based on the
information before us.
8.
We emphasize that we need to complete the initial data collection with sufficient time to
allow for its use in developing revised high cost loop support (HCLS) benchmarks that will determine
support levels beginning January 1, 2014. If neither an incumbent LEC nor the relevant state commission
submits or certifies boundary data for particular study areas, the Bureau will determine the boundaries of
such study areas, using its own analysis and data sources, for purposes of establishing the HCLS
benchmarks that will be used to deliver support in 2014.16 If state commissions or incumbent LECs make
refinements or corrections to study area boundary data after the required deadlines in 2013, those
modifications cannot be considered until the next time the Bureau updates the HCLS benchmarks.17

B.

Submissions by Price Cap Carriers

9.
The Study Area Boundary Order required all incumbent LECs to submit study area
boundary data at the exchange level, with the shapefile for each study area depicting each internal
exchange as a closed, non-overlapping polygon.18 It is important to collect exchange-level data from rate-
of-return carriers because the Bureau, when conducting the analysis used to implement the HCLS
benchmarking rule, must be able to distinguish those exchanges that are subject to “frozen” support levels
from those that are not, and track and account for exchanges that are transferred from one incumbent LEC
to another.19 However, because the HCLS benchmarking rule does not apply to price cap carriers, certain
parties have argued that it may not be necessary or practical to collect study area boundary data at the
exchange level from price cap carriers.20
10.
The study area boundaries of price cap carriers are needed to “complete the puzzle” for
HCLS implementation – to verify the accuracy of adjacent rate-of-return carrier study areas. In addition,
data on exchanges is useful for tracking the sale or transfer of exchanges between price cap and rate-of-
return carriers. Knowing which exchanges have been transferred from a price cap carrier is important for
HCLS implementation because it allows the Bureau to account for whether and how a rate-of-return
carrier’s study area boundary has changed as a result of the sale or purchase of an exchange. We
therefore believe that exchange-level data from price cap carriers is necessary to ensure ongoing accurate
HCLS implementation and will provide information generally useful for ongoing policy implementation
at the Commission.
11.
While exchange-level data from rate-of-return carriers are essential to HCLS
implementation, and the benefits of collecting these data fully exceed the burdens involved in submitting
them, we recognize that the benefits of obtaining similar data from price cap carriers—while
substantial—are more removed, and that submitting data at that level of detail involves time and effort on


16 Study Area Boundary Order, 27 FCC Rcd at 13529, para. 4 (discussing HCLS implementation).
17 As stated in the Study Area Boundary Order, incumbent LECs (or state commissions) must submit updated study
area boundary data by March 15 of each year showing any changes made by December 31 of the previous year. Id.
at 13535, para. 23. When the Bureau updates the HCLS benchmarks, it will use the most recent data available.
18 Each exchange-area polygon would constitute one record in the shapefile and contain associated data with certain
attributes used to identify the exchange, such as the exchange name and CLLI (Common Language Location
Identifier) code. Id. at 13530, para. 8.
19 Id. at 13530-31, para. 8.
20 See USTelecom PRA Comments at 5-6, 9-10; Lanning Feb. 3 Remarks.
4

Federal Communications Commission

DA 13-282

the part of the incumbent LECs or state commissions.21 We therefore reconsider our decision to require
exchange-level data for price cap areas and will allow price cap carriers – or state commissions – to
submit the boundaries of component wire centers, which may be less burdensome to compile in a
shapefile format,22 when submitting price cap study area boundary data, as long as the filer indicates the
exchange or exchanges associated with each wire center.23 In addition, the filer should submit both a
polygon of the outer boundary of the price cap study area, as well as polygons for the individual interior
wire center boundaries, as part of the same shapefile or map layer.24 We expect this change to provide the
Commission with adequate data for HCLS implementation while reducing the filing burden on incumbent
LECs and state commissions.

C.

Accuracy Requirements

12.
In the Study Area Boundary Order, we required that the submitted shapefiles conform to
the 1:24,000 scale, which is the standard used by the U.S Geological Survey (USGS) National Map and
which claims to produce a horizontal accuracy of +/- 40 feet. Certain parties have voiced concerns about
certifying that the study area boundary data they submit have a horizontal accuracy of +/- 40 feet.25 This
requirement stems from the need to have boundaries conform to a common base map, rather than an
accuracy requirement per se. If two adjoining study areas are bound by a road, stream, or other
geographic or topographic feature, basing the maps of these areas on a standard scale of 1:24,000 will
produce a more accurate set of boundaries and will greatly improve the reconciliation process.26
13.
We clarify in this Order on Reconsideration that in the initial year of implementation of
this data collection, we will take a flexible approach in administering the requirement that shapefiles
conform to the 1:24,000 topographic scale of the USGS National Map or that have an accuracy level of
+/- 40 feet. In particular, we emphasize that we do not intend to penalize filers who undertake reasonable,
good faith efforts to submit information within the necessary time frames, even if that information
subsequently is adjusted or corrected in future years.
14.
We also acknowledge that even after incumbent LECs or state commissions certify to the
accuracy of their submitted data, overlap and void areas can occur, and, in such cases, we will seek input
from the relevant parties (incumbent LECs and/or state commissions) to resolve such issues during the
reconciliation process. There may be disputes in particular instances as to the precise location of a
boundary, and in this first year of implementation, we ask all parties to undertake best efforts to work
with us to develop a coherent national data set. We recognize that the initial implementation of this data


21 See USTelecom PRA Comments at 5-6, 9-10; Lanning Feb. 3 Remarks; Letter from Jonathan Banks, Senior Vice
President, Law & Policy, USTelecom, to Marlene Dortch, Secretary, FCC, WC Docket Nos. 10-90, 05-337 (filed
Feb. 25, 2013) (USTelecom Feb. 25 ex parte).
22 See USTelecom PRA Comments at 5-6, 9-10; Lanning Feb. 3 Remarks; USTelecom Feb. 25 ex parte.
23 See infra Appendix for further detail. In some states and for some incumbent LECs, exchange boundaries and
wire center boundaries are identical; in other cases, a wire center can contain multiple exchanges, or an exchange
can contain multiple wire centers. Data on the wire center boundaries of price cap carriers will be useful for other
purposes, including informing the work of the Commission’s Technology Transitions Policy Task Force, which is
developing recommendations on how the Commission can modernize policies to encourage technological transition,
empower consumers, promote competition, and ensure network reliability. FCC Chairman Julius Genachowski
Announces Formation of ‘Technology Transitions Policy Task Force,’
News Release, FCC, Dec. 10, 2012, available
at
http://www.fcc.gov/document/fcc-chairman-announces-technology-transitions-policy-task-force.
24 See infra Appendix for further detail.
25 See USTelecom PRA Comments at 4, 16; Comments of Texas Statewide Telephone Cooperative, Inc., WC
Docket Nos. 10-90, 05-337, OMB Control No. 3060-1181, filed Jan. 7, 2013; Lanning Feb. 3 Remarks.
26 See Study Area Boundary Order, 27 FCC Rcd at 13532, para. 14 n.33.
5

Federal Communications Commission

DA 13-282

collection may be more challenging for some states than others, and we encourage all states to participate
in this important effort.
15.
Finally, we provide guidance regarding the requirement that an official certify that the
information provided is accurate and correct to the best of his or her knowledge, information, and belief.
Such certifications should be based on the information before the official making the certification and on
a reasonable, good faith effort to confirm the accuracy of submitted boundaries. For incumbent LECs in
states where the state commission is unable, for whatever reason, to undertake this important task, it is
necessary to have some party indicate that it has made a reasonable, good faith effort to verify the
information in question, even though the incumbent LEC is not the ultimate decision maker regarding the
location of the boundary. The certification from an official of an incumbent LEC regarding the location
of the boundary to the best of that individual’s knowledge, information, and belief will represent just that
– the individual’s or company’s reasonable, good faith efforts.

III.

PROCEDURAL MATTERS

16.
Regulatory Flexibility Certification. As required by the Regulatory Flexibility Act of
1980 (RFA),27 the Commission prepared a Final Regulatory Flexibility Analysis (FRFA) for the Study
Area Boundary Order
. In accordance with the RFA,28 we certify that the modifications adopted herein
“will not have a significant economic impact on a substantial number of small entities.”29 The rules
modified in this Order on Reconsideration will reduce the burden on small entities relative to the impact
of the rules adopted in the Study Area Boundary Order. We have eased the burden on small incumbent
LECs by allowing state entities to certify to the accuracy of the data they (the states) submit, rather than
requiring incumbent LECs to make the certification. We have also reduced the burden on small entities
that are price cap carriers by allowing them the option to submit boundary data at the wire center rather
than exchange level.
17.
The Commission will send a copy of this Order on Reconsideration, including this
certification, to the Chief Counsel for Advocacy of the Small Business Administration.30 In addition, the
Order on Reconsideration (or a summary thereof) and certification will be published in the Federal
Register.31
18.
Paperwork Reduction Act. The Study Area Boundary Order contained new information
collection requirements subject to the Paperwork Reduction Act of 1995 (PRA), Public Law No. 104-13.
The Bureau submitted a request for emergency PRA approval for this new data collection to the Office of
Management and Budget (OMB) in December 2012,32 and OMB approved the Bureau’s request on
January 23, 2013.33 The emergency PRA approval expires on July 31, 2013. The Bureau will explain the
modifications adopted in this Order on Reconsideration when it submits its request for extension of the
currently-approved collection to OMB. When that PRA request is published in the Federal Register,
OMB, the general public, and other Federal agencies will be invited to comment on all aspects of the
study area boundary information collection requirements.


27 See 5 U.S.C. § 603. The RFA, see 5 U.S.C. § 601 et seq., has been amended by the Contract With America
Advancement Act of 1996, Pub. L. No. 104-121, 110 Stat. 847 (1996) (CWAAA). Title II of the CWAAA is the
Small Business Regulatory Enforcement Fairness Act of 1996.
28 See 5 U.S.C. § 604.
29 5 U.S.C. § 605(b).
30 Id.
31 Id.
32 77 FR 75159-01.
33 78 FR 5750.
6

Federal Communications Commission

DA 13-282

19.
Congressional Review Act. The Commission will send a copy of this Order on
Reconsideration to Congress and the Government Accountability Office, pursuant to the Congressional
Review Act.34
20.
Effective Date. We conclude that good cause exists to make the effective date of the
modifications adopted in this Order on Reconsideration effective immediately upon publication in the
Federal Register or on February 27, 2013, whichever is later, pursuant to section 553(d)(3) of the
Administrative Procedure Act.35 Agencies determining whether there is good cause to make a rule
revision take effect less than 30 days after Federal Register publication must balance the necessity for
immediate implementation against principles of fundamental fairness that require that all affected persons
be afforded a reasonable time to prepare for the effective date of a new rule.36 The rules in the Study Area
Boundary Order
were duly published in the Federal Register and will take effect on February 27, 2013.
The changes adopted in this Order on Reconsideration provide the affected parties with additional options
for complying with the requirements in the Study Area Boundary Order. Given the need to collect this
information and the lack of any additional burden imposed by this Order on Reconsideration, there is
good cause to make these amendments effective immediately upon Federal Register publication or on
February 27, 2013, whichever is later.
21.
Accordingly, IT IS ORDERED, pursuant to sections 1, 2, 4(i), 201-205, 218-220, 254,
303(r), and 403 of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 152, 154(i), 201-205,
218-220, 254, 303(r), and 403, sections 0.91, 0.201(d), 0.291, 1.108, and 1.427 of the Commission’s
rules, 47 C.F.R. §§ 0.91, 0.201(d), 0.291, 1.108, 1.427, and the delegations of authority in paragraphs
157, 184, 187, 192, 217 of the USF/ICC Transformation Order, FCC 11-161, that this Order on
Reconsideration IS ADOPTED.
22.
IT IS FURTHER ORDERED that this Order on Reconsideration SHALL BE
EFFECTIVE immediately upon publication in the Federal Register or on February 27, 2013, whichever is
later.
23.
IT IS FURTHER ORDERED that the Commission’s Consumer and Governmental
Affairs Bureau, Reference Information Center, SHALL SEND a copy of this Order on Reconsideration to
the Chief Counsel for Advocacy of the Small Business Administration.


34 See 5 U.S.C. § 801(a)(1)(A). The Congressional Review Act is contained in Title II, § 251, of the CWAAA; see
Pub. L. No. 104-121, Title II, § 251, 110 Stat. 868.
35 5 U.S.C. § 553(d)(3).
36 Omnipoint Corporation v. FCC, 78 F.3d 620, 630 (D.C. Cir. 1996), citing United States v. Gavrilovic, 551 F.2d
1099, 1105 (8th Cir. 1977).
7

Federal Communications Commission

DA 13-282

24.
IT IS FURTHER ORDERED that the Commission SHALL SEND a copy of this Order
on Reconsideration to Congress and the Government Accountability Office pursuant to the Congressional
Review Act, see 5 U.S.C. § 801(a)(1)(A).
FEDERAL COMMUNICATIONS COMMISSION
Julie A. Veach
Chief
Wireline Competition Bureau
8

Federal Communications Commission

DA 13-282

APPENDIX

Specification for Study Area Boundary Submission

I.

General

Incumbent local exchange carriers (LECs) or state commissions must submit study area boundaries in esri
shapefile format.1 Incumbent LECs should submit each study area served in a separate shapefile. Since
shapefiles typically consist of 3 to 9 individual files, the shapefile for the study area should be submitted
as a single, zipped file containing all of the component files. The shapefile and encapsulating zip file
names must contain the company name and the 6-digit study area code. Shapefile templates are available
at http://www/fcc/gpv/wcb/iatd/neca.html.
State commissions may submit shapefiles comprised of multiple study areas, and may submit zip files
that contain multiple study areas. The encapsulating zip file should contain the state name.
Study area boundaries for rate-of-return carriers must be submitted at the exchange level, while study
areas for price cap carriers can be submitted at the exchange or wire center level. The shapefile must
contain one data record for each exchange or wire center within the study area. Each exchange or wire
center should be represented as a closed, non-overlapping polygon with the associated feature attributes
listed below in the accompanying metadata.
In cases where a carrier or state submits price cap study areas at the wire center level, the shapefile must
contain both a polygon representing the outer study area boundary as well as polygons representing the
internal wire centers. In the attributes associated with the polygon representing the outer study area
boundary, fields 4, 5, and 6 (in Section II.B below) can be left blank or null. In addition, the attributes
associated with each wire center polygon should include the exchange name(s) associated with the wire
center. If there are multiple exchanges, list them all in the field separated by a comma.
After submitting the study area boundaries, an officer of the LEC, or an individual authorized by the state
commission, must certify that the information provided is accurate and correct to the best of his/her
knowledge, information, and belief, based the individual’s or company’s reasonable, good faith efforts.2

II.

Shapefile

A shapefile template is available at http://www.fcc.gov/wcb/iatd/neca.html. Submitted shapefiles must:
A. contain one closed, non-overlapping polygon for each exchange or wire center in the study area.
The polygon should represent the area served from that exchange or wire center.
B. have associated with each exchange or wire center polygon the following identifying feature
attributes (or fields):


1 The Commission will be using these data as a general map base for universal service and other analyses for which
these data are useful. For the purposes of this collection, boundary does not refer to an architectural or engineering
drawing, meets and bounds descriptions, or other surveyed body of work. Boundary does refer to the general extent
of the incumbent LEC’s exchange or wire center which can be identified on a base map scale of 1:24,000. If
appropriate, the boundary should be consistent with or snapped to existing political, geographic, or physical features
(e.g., county, road, river, etc.) at or below 1:24,000. 1:24K national mapping standards are available at
http://egsc.usgs.gov/isb/pubs/factsheets/fs17199.html.
2 See supra para. 15 for a discussion of the certification requirement.
9

Federal Communications Commission

DA 13-282

1. OCN – NECA-assigned operating company number as in the LERG
2. Company Name
3. Boundary Type – Exchange, Wire Center, or Outer Study Area
4. Exchange Name3
5. Wire Center Name (leave blank if submitting exchange-level data)
6. Was the Exchange acquired subject to section 54.305 of the Commission’s rules?4
7. Study Area Code (6-digit)
8. State
C. have an assigned projection w/accompanying .prj file
D. use unprojected (geographic) WGS84 geographic coordinate system
E. conforming to 1:24K national mapping standards or have a minimum horizontal accuracy of +/-
40 feet or less
F. be submitted as a WinZip archive with a name containing the company name and study area code
(e.g., CompanyName_123456.zip).

III.

CLLI Codes

In conjunction with the shapefile attributes listed above, incumbent LECs or state entities should submit,
within the zip file, a .csv file listing all of the 11-digit CLLI codes (for switches) associated with each
exchange or wire center boundary. Because multiple CLLI codes can be associated with an exchange, it
is easiest to capture these data in a separate table rather than include them in the shapefile attributes listed
above. The .csv file should contain the three fields listed below, and each CLLI code should be listed in a
separate row. This is a .csv file only; the locations of the switches associated with the CLLI codes do not
need to be mapped.
1. Boundary Type – Exchange, Wire Center, or Outer Study Area
2. Exchange or Wire Center Name
3. CLLI Code (11-digit)

IV.

Cover Page Information

In addition to the shapefile data described above, we also will collect electronically the following
information:
A. Company Name
B. FRN (please use the FRN used for the 477 filing in the state)
C. Contact person name
D. Contact person address
E. Contact person phone number
F. Contact person email address
G. Date created/revised
H. Methodology – process steps to create the data


3 If a price cap carrier or state commission is submitting wire center-level data, it should provide the name of the
exchange associated with the wire center boundary.
4 See 47 C.F.R. § 54.305; see also Connect America Fund; High-Cost Universal Service Support; WC Docket Nos.
10-90, 05-337, Order, 27 FCC Rcd 4235, 4255, App. A n.2. (Wireline Comp. Bur. 2012). Rural incumbent LECs
that incorporate acquired exchanges into an existing study area provide NECA with separate cost data for the
acquired portions of the study area. Submitted shapefiles must include separate polygons for portions of exchanges
subject to section 54.305.
10

Federal Communications Commission

DA 13-282

I.
Certifying official name
J. Certifying official address
K. Certifying official phone number
L. Certifying official email address
11

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.