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Bureau Seeks Comment on Mobile Line Count Reporting Issues

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Released: July 10, 2013


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


TTY: 1-888-835-5322

Washington, D.C. 20554

DA 13-1557

Released: July 10, 2013

Wireline Competition Bureau Seeks Comment on Requests for Review of Administrator Decisions

Regarding Mobile Line Count Reporting

CC Docket No. 96-45, WC Docket No. 05-337

Comment Date: August 9, 2013
Reply Date: August 26, 2013

The Wireline Competition Bureau seeks comment on three separate Requests for Review of
Decisions by the Universal Service Administrative Company (USAC). Two requests were filed by
AT&T, Inc. on behalf of its affiliates,1 and the third request was made by Cordova Wireless
Communications, LLC.2 The three filings request of review of USAC determinations that certain mobile
lines were not eligible for universal service support under section 54.307(b) of the Commission's rules
due primarily to issues with the reporting of customer billing addresses.3
In its two filings, AT&T requests review of USAC's decision that, in determining the location of
a customer using a P.O. Box, a carrier must use the physical address of the relevant post office.4
According to the petition, AT&T's current practice is to assign a P.O. Box customer based on the centroid

1 Request for Review by AT&T of Decision of the Universal Service Administrator, CC Docket No. 96-45 et al.
(filed June 22, 2012) (AT&T June 22 Filing); Request for Review by AT&T of Decision of the Universal Service
Administrator, CC Docket No. 96-45 et al. (filed Apr. 16, 2013) (AT&T April 16 Filing).
2 Request for Review by Cordova Wireless Communications, LLC of a Decision of Universal Service
Administrator, CC Docket No. 96-45 et al. (filed July 5, 2013) (Cordova Filing).
3 47 C.F.R. 54.307(b). Several other petitions regarding mobile line count and customer billing address issues are
also currently pending before the Commission. ACS Wireless Request for Review and Petition for Waiver, CC
Docket No. 96-45, WC Docket No. 05-337 (filed Jan. 17, 2012); Request for Review by PR Wireless, Inc., of a
Decision of the Universal Service Administrator, CC Docket Nos. 96-45, 03-109 (filed Apr. 5, 2010); ASTAC
Wireless LLC Petition for Waiver of Section 54.307(b) of the Commission's Rules, CC Docket No. 96-45 (filed Jan.
31, 2008); Letter from John T. Nakahata, General Counsel, GCI, to Dana Shaffer, Bureau Chief, Wireline
Competition Bureau, FCC, CC Docket No. 96-45 (filed Jan. 26, 2009); Mobi PCS, Inc. and Cricket
Communications, Inc. Petition Requesting the Federal Communications Commission to Provide Guidance to the
Universal Service Administrative Company, CC Docket 96-45 (filed May 29, 2009).
4 AT&T June 22 Filing at 2-3; AT&T April 16 Filing at 2-3.

of the customer's ZIP codes, and AT&T contends that cataloging and reporting the addresses of all the
relevant post offices would be a burdensome undertaking.5
Cordova requests review of USAC's determination that certain lines were ineligible for support
because the initially submitted customer billing addresses were outside Cordova's service area, even
though the customers also receive bills at local addresses within Cordova's service area.6 Cordova argues
that, for customers who receive bills at multiple addresses, USAC should rely upon the local addresses
where the customers reside and use the service.7 Cordova also seeks review of a USAC decision that
certain lines were ineligible for support because they showed no activity.8
Pursuant to sections 1.415 and 1.419 of the Commission's rules, interested parties may file comments or
reply comments on or before the dates indicated above.9 Comments may be filed using the Commission's
Electronic Comment Filing System (ECFS).10

Electronic Filers: Comments may be filed electronically using the Internet by accessing the

Paper Filers: Parties who choose to file by paper must file an original and one copy of each
filing. If more than one docket or rulemaking number appears in the caption of this proceeding,
filers must submit two additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission's Secretary,
Office of the Secretary, Federal Communications Commission.

All hand-delivered or messenger-delivered paper filings for the Commission's Secretary must be
delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325, Washington, DC 20554.
The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held together with rubber
bands or fasteners. Any envelopes and boxes must be disposed of before entering the building.

Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must
be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.

U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street,
SW, Washington DC 20554.
People with Disabilities: To request materials in accessible formats for people with disabilities
(Braille, large print, electronic files, audio format), send an e-mail to or call the
Consumer & Governmental Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (tty).

5 AT&T June 22 Filing at 7-9; AT&T April 16 Filing at 7-9.
6 Cordova Filing at i.
7 Id. at 5-6.
8 Id. at 11-14.
9 47 C.F.R. 1.415, 1.419.
10 See Electronic Filing of Documents in Rulemaking Proceedings, GC Docket No. 97-113, Report and Order, 13
FCC Rcd 11322 (1998).

In addition, we request that one copy of each pleading be sent to each of the following:

(1) Ryan J. Yates, Telecommunications Access Policy Division, Wireline Competition Bureau, 445 12th
Street, S.W., Room 5-B510, Washington, DC 20554; e-mail:; and
(2) Charles Tyler, Telecommunications Access Policy Division, Wireline Competition Bureau, 445 12th
Street, S.W., Room 5-A452, Washington, DC 20554; e-mail:
The proceeding this Notice initiates shall be treated as a "permit-but-disclose" proceeding in
accordance with the Commission's ex parte rules.11 Persons making ex parte presentations must file a
copy of any written presentation or a memorandum summarizing any oral presentation within two
business days after the presentation (unless a different deadline applicable to the Sunshine period applies).
Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation
must (1) list all persons attending or otherwise participating in the meeting at which the ex parte
presentation was made, and (2) summarize all data presented and arguments made during the
presentation. If the presentation consisted in whole or in part of the presentation of data or arguments
already reflected in the presenter's written comments, memoranda or other filings in the proceeding, the
presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or
other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be
found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission
staff during ex parte meetings are deemed to be written ex parte presentations and must be filed
consistent with rule 1.1206(b). In proceedings governed by rule 1.49(f) or for which the Commission has
made available a method of electronic filing, written ex parte presentations and memoranda summarizing
oral ex parte presentations, and all attachments thereto, must be filed through the electronic comment
filing system available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt,
searchable .pdf). Participants in this proceeding should familiarize themselves with the Commission's ex
For further information, please contact Ryan Yates, Telecommunications Access Policy Division,
Wireline Competition Bureau at (202) 418-0886 or TTY (202) 418-0484.
- FCC -

11 47 C.F.R. 1.1200 et seq.

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