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Version 4.0 of Connect America Phase II Cost Model Available

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Released: December 2, 2013


Federal Communications Commission

News Media Information 202 / 418-0513

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 13-2304

Released: December 2, 2013




WC Docket No. 10-90

Comment Date: January 7, 2014

Today, the Wireline Competition Bureau (Bureau) announces that version four of the
Connect America Cost Model (CAM v4.0), which incorporates a number of modifications, including
additional adjustments to address the unique circumstances and operating conditions in the non-
contiguous areas of the United States, will be available shortly.1 We seek comment on whether the
Bureau should adopt this version of CAM and the default inputs for purposes of calculating costs in
price cap areas for implementing Connect America Phase II.
Overview of Changes in CAM v4.0. As described in more detail below, CAM v4.0 includes
a number of modifications to address the unique circumstances and operating conditions in the non-
contiguous areas of the United States. In particular, CAM v4.0 calculates the cost of submarine
cables used for middle mile connections between intra-state points in non-contiguous areas. It also
updates the plant mix values for the non-contiguous carriers, and assumes that buried plant is placed

1 Including Version 4.0, the Bureau has released nine versions of the model. See Wireline Competition Bureau
Announces Availability of Version One of the Connect America Fund Phase II Cost Model
, WC Docket Nos.
10-90, 05-337, Public Notice, 27 FCC Rcd 15356 (Wireline Comp. Bur. 2012); Wireline Competition Bureau
Announces Availability of Version Two of the Connect America Fund Phase II Cost Model
, WC Docket No.
10-90, Public Notice, 28 FCC Rcd 280 (Wireline Comp. Bur. 2013); Wireline Competition Bureau Announces
Availability of Version Three of the Connect America Fund Phase II Cost Model
, WC Docket No. 10-90,
Public Notice, 28 FCC Rcd 2316 (Wireline Comp. Bur. 2013); Wireline Competition Bureau Announces
Availability of Version 3.1 of the Connect America Fund Phase II Cost Model
, WC Docket No. 10-90, Public
Notice, 28 FCC Rcd 5707 (Wireline Comp. Bur. 2013); Wireline Competition Bureau Announces Availability
of Version 3.1.2 of the Connect America Fund Phase II Cost Model and Adds Additional Discussion Topics to
Connect America Cost Model Virtual Workshop
, WC Docket No. 10-90, Public Notice, 28 FCC Rcd 7293
(Wireline Comp. Bur. 2013); Wireline Competition Bureau Announces Availability of Version 3.1.3 of the
Connect America Fund Phase II Cost Model,
WC Docket No. 10-90, Public Notice, 28 FCC Rcd 8339
(Wireline Comp. Bur. 2013); Wireline Competition Bureau Announces Availability of Version 3.1.4 of the
Connect America Fund Phase II Cost Model, Illustrative Results, and Updated Methodology Documentation
WC Docket No. 10-90, Public Notice, 28 FCC Rcd 9049 (Wireline Comp. Bur. 2013); Wireline Competition
Bureau Announces Availability of Version 3.2 of the Connect America Fund Phase II Cost Model, and
Illustrative Results; Seeks Comment on Several Modifications for Non-Contiguous Areas
, WC Docket No. 10-
90, Public Notice, 28 FCC Rcd 12833 (Wireline Comp. Bur. 2013) (Version 3.2 Public Notice).

in conduit in non-contiguous areas to provide additional protection from harsh weather. This version
modifies the prior methodology used for determining input values for terrain in non-contiguous
areas, and it treats Alaska Communications Systems (ACS) as a small carrier for purposes of
calculating its operating expenses. It also uses state-specific values for certain capital expense inputs
for Virgin Islands Telephone Corporation d/b/a Innovative Telephone (Vitelco). CAM v4.0
incorporates several modifications to CostQuestLandLine (CQLL) and CostQuestMiddleMile
(CQMM), the proprietary applications that CAM relies on to develop the network topology for the
CAM.2 In CQLL, the national demand location data and the terrain data were updated, and the
clustering code was modified. CQMM was modified to route middle-mile connections along roads,
consistent with the treatment of last mile plant in prior versions. CAM v4.0 includes inputs for
submarine cable and other costs specific to non-contiguous areas, and it also adjusts the default input
for the cost of money to 8.5 percent. CAM v4.0 also incorporates updated broadband coverage data.
Middle Mile Submarine Routes in Non-Contiguous Areas. CAM v4.0 includes the capability
to model the cost of submarine cable used for middle mile connections in non-contiguous areas.
Previous versions of the model did not distinguish between terrestrial routes and the submarine
portions of middle mile routes in determining middle mile investment in the non-contiguous areas of
the United States. The model was modified to identify middle mile routes requiring an undersea
connection, including those connecting the islands in Hawaii, Puerto Rico, the U.S. Virgin Islands,
and the Northern Mariana Islands, and to connect Anchorage to Juneau and the Kenai Peninsula.3
The Capital Expenditures (Capex) workbook was modified to include submarine cable costs and the
cost for two beach manholes on each intrastate middle mile submarine route.4 This submarine cable
is part of the middle-mile network in each area; it connects central offices just like wholly land-
based middle-mile cable does. Each beach manhole is connected to a nearby central office that
provides multiplexing, routing and co-location. We assume that there is no need for duplicative
facilities to provide multiplexing, routing or co-location between central offices and therefore do not
assume a full landing station at each submarine landing site.5 To the extent that parties disagree with
that assumption, they should provide a detailed analysis in support of their position.

2 The CQLL develops a wireline network topology from the demand point back to the central office, while the
CQMM develops the network middle mile topologies between each central office in a state. CQLL and
CQMM-derived databases are loaded into the CAM, along with other data, to create a solution set.
3 See, e.g., Letter from Greg J. Vogt, Counsel for Hawaiian Telcom, Inc., to Marlene H. Dortch, Secretary,
FCC, WC Docket Nos. 10-90, 05-337, Enc. at 3-5 (dated Sept. 11, 2013) (enclosing letter from Steven P.
Golden, Hawaiian Telcom, Inc.) (HTI Sept. 11, 2013 Letter); Letter from Karen Brinkmann, Counsel for ACS,
to Marlene H. Dortch, Secretary, FCC, WC Docket No. 10-90, at 7-9 (filed Sept. 12, 2013) (ACS Sept. 12,
2013 Letter).
4 A beach manhole provides a means to connect undersea cable with a land-based cable. It includes a vault at
the beach landing point to accommodate this splice point as well as the facilities to ensure the submarine cable
comes ashore without being subject to surf and tides (typically by boring underneath the sea floor out to a
point where surf and tides are no longer likely to be problematic).
5 ACS argues that it requires two additional landing stations in Juneau and two additional landing stations on
the Kenai Peninsula. See ACS Sept. 12, 2013 Letter at 7-8.

The table below shows middle mile route distances for terrestrial and submarine routes in
non-contiguous areas.
Total MM
Land MM

63,620,956 74
63,620,956 54,717,162 8,903,794




Plant Mix. CAM v4.0 includes state-specific plant mix values for the price cap carriers
serving the non-contiguous United States: ACS, Puerto Rico Telephone Company (PRTC),
Hawaiian Telcom, Inc. (HTI), Vitelco, and the Micronesian Telecommunications Corporation d/b/a
IT&E (MTC). The plant mix values for price cap carriers serving the contiguous United States were
largely based on values that reflect an inventory of existing plant mix.6 Several of the non-
contiguous carriers have suggested that the model should use “forward-looking” plant mix values for
their areas that are significantly different than their current plant mix values and the national average
plant mix values in CAM v3.2.7
Rather than use current values or the proposed forward-looking values submitted by these
carriers, CAM v4.0 incorporates a hybrid approach that recognizes that there may be good reasons in
non-contiguous areas to reduce the amount of aerial plant in the future, but that an efficient carrier

6 See, e.g., Letter from Henry Hultquist, AT&T, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 10-90
(filed May 23, 2013); Letter from Craig J. Brown, CenturyLink, to Marlene H. Dortch, Secretary, FCC, WC
Docket No. 10-90 (filed May 24, 2013).
7 See Letter from Richard Cameron, ACS, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 10-90, at 6-
9 (filed July 30, 2013) (ACS July 30, 2013 Letter). CAM v3.2 included plant mix values submitted by ACS.
See Version 3.2 Public Notice, 28 FCC Rcd at 12839-40. See also Letter from Russell M. Blau, Counsel to
Vitelco, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 10-90, Exh. A (filed Sept. 17, 2013) (Vitelco
Sept. 17, 2013 Letter); Comments of PRTC, WC Docket No. 10-90 (filed Sept. 12, 2013) (PRTC Sept. 12,
2013 Comments); HTI Sept. 11, 2013 Letter, Enc. at 10. We note that these non-contiguous carriers also have
suggested that they are unable to differentiate between underground and buried plant, and therefore assume a
high percentage of underground plant. See ACS July 30, 2013 Letter at 7; Vitelco Sept. 17, 2013 Letter at
Exh. A, 1-2; PRTC Sept. 12, 2013 Comments at 17; HTI Sept. 11, 2013 Letter, Enc. at 8-10. As discussed
below, CAM was modified to allow buried plant to be placed in conduit systems.

would likely replace aerial plant with a mixture of buried and underground plant. CAM v4.0
recognizes that buried and underground plant both provide the benefits of below-ground plant, and
that an efficient carrier would choose to bury plant rather than build underground plant where
technically and legally permitted, as underground plant is typically three to five times more costly
than buried plant.8 CAM v4.0 therefore assumes the amount of underground plant would not exceed
a carrier’s current amount of underground plant; to the extent the carrier-submitted proposed values
for underground plant are higher than current values, the excess is moved into buried plant.9 The
table below illustrates a hypothetical example of this approach.
Current values
Forward-looking values


By utilizing a greater amount of buried plant than current buried plant, the hybrid approach reflects
the fact that there may be some locations where it is more efficient to decrease the amount of aerial
plant in favor of buried plant. We do recognize, however, that there may be some instances when
deploying underground plant may be technically or legally required. To the extent any party
contends that the approach to plant mix taken in CAM v4.0 does not adequately reflect a forward-
looking network, they should supply data that demonstrates what percentage of plant in the state
must specifically be placed underground, as opposed to buried, due to local ordinances or for
technical reasons.
Buried Plant in Conduit. In response to comments submitted by some carriers serving non-
contiguous areas, CAM v4.0 also was modified to allow buried plant to be placed in conduit
systems. Traditionally, underground plant is placed within conduit for added support and protection
and with access points via manholes, while buried plant is placed directly into the ground, without
any conduit. Some non-contiguous carriers have suggested that the model should include an
additional approach to plant deployment that would combine aspects of both traditional underground
and buried plant.10 Such an approach combines buried plant techniques with conduit for added
protection. The logic modification contained in CAM 4.0 allows for these “buried in conduit”
systems and is used for buried plant in the non-contiguous United States.
Terrain. The methodology for determining whether a census block group is identified as
having hard rock was modified for the non-contiguous areas of the United States. Several carriers
serving the non-contiguous areas, ACS, PRTC, and HTI, requested that the model treat 100 percent

8 See Connect America Cost Model Overview at 20 (Sept. 12, 2013), available at Even if the
Bureau were to adjust the CAM to account for size 1 manholes and add duct to buried plant, as discussed
below, the cost per foot for underground plant would still be roughly twice the cost of buried plant, based on
current sharing assumptions.
9 100 – (Current underground plant + Forward-looking aerial plant) = Hybrid buried plant.
10 Letter from Thomas J. Navin, Counsel for PRTC, to Marlene H. Dortch, Secretary, FCC, Attach. at A-8,
WC Docket No. 10-90 (filed Oct. 30, 2013) (PRTC Oct. 30, 2013 Letter); ACS July 30, 2013 Letter at 7.

of their terrain as “hard rock,” the most expensive terrain in which to place plant.11 This approach
would significantly over-estimate the actual amount of hard rock in these areas.
CAM v4.0 modifies the approach for determining whether a census block group is
considered to consist of hard rock in non-contiguous areas. Terrain factors for the entire country
were developed for each census block group using data from the Natural Resources Conservations
Service (NRCS) STATSGO data, where available.12 The rock hardness used in the contiguous
United States for a given census block group is whichever type of rock is listed most frequently for
the list of STATSGO map units in the census block group, regardless of the geographic area of those
map units.13 The revised methodology now considers the entire census block group in non-
contiguous areas, where terrain data are available, to be hard rock if at least fifty percent of the area
is identified as hard rock.14
ACS Treated as Small Carrier. CAM v4.0 shifts ACS from the “medium” carrier category,
which encompasses carriers that serve between 100,000 and 1 million access lines, to the “small”
carrier category, for carriers that serve fewer than 100,000 access lines. Given the other changes
made in CAM v4.0, we tentatively believe that it would be reasonable to treat ACS as a “small”
carrier rather than a “medium” carrier category for the purposes of calculating its operating expense
(opex) in the CAM v4.0.15
Vitelco Capex Inputs. CAM v4.0 also includes state-specific values for certain inputs in the
Capex workbook for the Virgin Islands. Vitelco submitted several proposed modifications to the
Capex workbook. CAM v4.0 includes the modifications to the material costs, but not to the labor
costs. We tentatively believe it would be reasonable to assume that certain materials would be more
expensive in the Virgin Islands, but we are not convinced that labor costs should be adjusted upward
as proposed by Vitelco.
Other Changes Proposed by Non-Contiguous Carriers. CAM v4.0 does not include all the
changes submitted into the record by carriers serving the non-contiguous United States. In analyzing
the impact of the requested changes and assessing the reasonableness of the modelled costs, we

11 See, e.g., Letter from Richard Cameron, ACS, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 10-
90, at 5-6 (filed July 9, 2013) (ACS July 9, 2013 Letter); HTI Sept. 11, 2013 Letter, Enc. at 7-8; PRTC Oct.
30, 2013 Letter, Attach. at A-9 to A-11.
12 STATSGO data do not include terrain data for the Virgin Islands or the Northern Mariana Islands.
13 Thus, prior versions of the model would treat a census block group as soft if three values in the STASTGO
database for a particular census block group were listed as soft and one value was listed as hard, even if actual
physical territory of the area listed as hard represented 80 percent of the geographic area of the census block
14 Taking this approach for non-contiguous areas addresses the fact that the size of some of the block groups
and the STATSGO map units in these areas, particularly in Alaska, are much larger than in the contiguous
United States. For example, in Alaska you could have a substantial fraction of an area described as hard rock
in the STATSGO database, but because of multiple map units within the census block group, the block group
may not have hard rock as the most commonly occurring value. Therefore, we use an area-based measure
outside the contiguous United States.
15 Opex is calculated as a weight on the amount of investment, so any increase in capex leads to an increase in
opex. Therefore, any change in assumptions from those used in CAM v4.0 may lead to opex levels that are
unreasonably high. In such an instance, the Bureau would have to reconsider the treatment of ACS as a small
carrier for these purposes.

compared the costs calculated in CAM v4.0 with the embedded costs reported by the carriers.16 To
the extent parties believe that additional modifications should be made to CAM v4.0 prior to
adopting the cost model, they should provide a detailed analysis in support of their position and
specify which inputs should be adjusted upwards or downwards.
CQLL Demand Locations. CAM v4.0 also incorporates modifications designed to ensure
that the growth in demand locations for a given county are appropriately placed in areas with other
residential locations. This modification does not alter the demand data sources, but modifies the
methodology for random placement of housing units to prevent anomalous and potentially
misleading results. Specifically, beginning with CAM v3.0, the overall increase or decrease of
residential housing units in a specific county in 2011, as compared to the 2010 census counts, was
randomly dispersed to census blocks based on the amount of livable roads in each census block of
the county. This process may have resulted in residential housing units being assigned to census
blocks for which 2010 census records showed no residential locations. CAM v4.0 uses both 2010
census block information and 2011 GeoResults geocoded residential data to identify census blocks
that have no residential locations and removes housing units that previously had been placed in these
census blocks to reflect 2011 county growth. Instead, CAM v4.0 randomly places those housing
units into census blocks that already contain residential locations. This random placement follows
the same methods used beginning in v3.0, but improves on these methods by removing roads in
census blocks without residential locations to prevent their use as possible targets for random
placement. This modification impacts only about 0.1 percent of all residential demand locations, but
results in a net increase in demand of approximately 3,500 Node4 locations, which had been
previously excluded due to their assignment to census blocks that had no roads or fell outside of
defined service areas.
CQLL Terrain Data. The CQLL terrain database was modified to correct an inversion in
some rows impacting the rock hardness and soil texture values.
CQLL Clustering Code and Node3 Creator. The CQLL clustering code was modified to
improve feeder path branching in areas with multiple roads. The code for the feeder allocation
formulas was updated consistent with changes described in CAM v3.2 release notes that previously
were addressed via an update to CQLL output. The calculations for accumulating feeder fibers of
Gigabit passive optical network (GPON) splitters and special access services were modified. The
fiber service terminal (i.e., pedestal) cost values used to determine the placement of Node3s (i.e.,
pedestals) was modified to use the installed value of a fiber service terminal; the previous value
understated the cost.
CQMM Updates. CQMM was modified to use road distance in calculating terrestrial middle
mile route distances, in most instances, and includes the capability to model the cost of submarine
cable used for middle mile connections in non-contiguous areas. CQMM calculates connections
between nodes using a minimum spanning tree approach. For CAM v3.2, and earlier versions of the
model, distance was calculated using airline distance multiplied by 1.2 (i.e., an estimated conversion
factor of airline to road distance). For CAM v4.0, distance is calculated using either airline distance

16 In comparing embedded cost to modeled cost, Bureau staff looked at NECA data reflecting embedded loop
cost for each non-contiguous carrier over thirteen years. We looked at reported costs over such a lengthy time
period because embedded costs can vary over time, unlike the levelized costs estimated by the model.
Because NECA data includes only loop costs, we excluded middle mile and undersea cable costs from the
model results, and used an assumed 11.25 percent cost of money, in order to make a like-to-like comparison.

or road distance. In the non-contiguous areas of the United States, middle mile distances that
include submarine routes are calculated using airline distance (x1.2). In the contiguous United
States and for middle mile distances in non-contiguous areas of the United States that do not contain
submarine routes, most distances are calculated using road distance.17 Where the ratio of road
distance to airline distance is greater than 3.04, which represents the 99th percentile of the road
distance to airline distance ratios for all routes used in CQMM, the distance is the airline distance
multiplied by 3.04.18 Each route with any submarine cable is assigned two beach manholes.
Submarine investment is not shared with other utilities, and is not impacted by the regional cost
CQMM also was modified so that a regional tandem will no longer be able to serve a central
office of a different state when states are in the same Local Access and Transport Area (LATA). For
example, Minnesota and North Dakota share a LATA. With the modification, North Dakota central
offices are served only by regional tandems in North Dakota. In addition, CQMM was modified to
remove duplicate key values that could lead to an infinite processing loop, to remove three
duplicative regional tandem locations, and to trigger repeater investment based on route distance
between nodes rather than total route distance.
Cost of Money. In prior versions of the model, the default input values reflected a 9 percent
cost of money. The previously released model outputs for CAM v3.2 used the model’s default input
values, but allowed Commission staff and interested parties to see how support amounts varied using
both an 8 percent and 9 percent cost of money. CAM v4.0 reflects an 8.5 percent cost of money.
CAM Broadband Coverage. CAMv4.0 incorporates updated broadband coverage to reflect
State Broadband Initiative (SBI) Round 7 data.19 Consistent with the process for updating
broadband coverage in prior versions of the CAM, the new coverage table removes from the SBI
data Cable and Fixed Wireless providers receiving subsidies, as well as those not providing voice
services as reported on FCC Form 477.
CAM Capex. CAM v4.0 includes in the undersea tab of the Capex workbook inputs for
submarine cable and beach manholes on intrastate middle mile submarine cable routes in non-
contiguous areas of the United States, described above.20 The cable investment is based on the same
input used for undersea cabling; each beach manhole investment is estimated at $1 million; and
submarine costs are calculated using the underground fiber Annual Charge Factor.
CAM v4.0 also includes logic to support a “buried in conduit” method of plant placement,
which allows buried plant to be placed in conduit systems.21 The Plant Mix Buried Conduit
workbook was added, and the percentage of buried in conduit placements is an input in that
workbook. Buried excavation costs are used. A toggle allows the user to exclude manholes (the

17 Where there is no route distance, the airline distance is multiplied by 1.2.
18 This limitation applies to all-terrestrial routes in non-contiguous areas, as well as in the contiguous United
19 SBI Round 7 reflects data as of December 2012. See CAM v4.0 Methodology at Sec. 6.
20 See supra at 3.
21 As discussed above, this capability is used for buried plant in the non-contiguous United States.

current default) or to specify access points via size one manholes.22 Another toggle selects the type
of conduit used for the buried trench; duct without inner-duct is the default.
In addition, CAM v4.0 includes modifications to the buried and underground formulas’ use
of the Structure Sharing table (in the Plant Sharing Tables tab) and to the Engineering Rules to allow
control over sizing for manholes in rural, suburban, and rural areas.
State Specific Capex. A State Specific Capex table and toggle were added to provide an
input source for situations in which a state-specific capex input is required. When the State Specific
Capex toggle is set to yes, the state-specific capex information will be taken from the State Specific
Capex workbook. That is, the state specified in the State Specific Capex workbook will become the
active capex values, for the specified state only, in the input collection.
CAM Processing Logic. When running a single state solution set, CAM previously
identified the service areas to process based on the fifth and sixth characters of the service area code,
but excluded those census blocks served in neighboring states. CAM v4.0 was modified to retain all
census blocks, including neighboring states, associated with service areas in which the fifth and sixth
characters of the service area code match the state that is processed. This change aligns the state
definition between single and multi-state solution sets, where states are defined as collections of
service areas; there is no impact on investment calculations.
Access to CAM v4.0. Parties should follow the same procedures to access CAM v4.0 as
announced for previous versions. In particular, parties may access CAM v4.0 at or Additionally,
authorized users who have signed the relevant attachments to the protective order will have access to
a system evaluator package that provides a test environment populated with a sample database,
allowing users to view database structures, observe the processing steps of CAM for a subset of the
country, and see changes in the database. In addition, authorized uses will receive a digital rights
management protected PDC format file (a form of secure PDF) containing the processing source
code for CQLL and CQMM.
Updated Documentation. In conjunction with the release of CAM v4.0, the Bureau will
shortly be posting updated methodology documentation for CAM v4.0, which provides more detail
on the current model architecture, processing steps, and data sources.24 Additionally, the Bureau
will be making available the input tables used in the CAM. The methodology documentation and
the input tables will be available at

22 A size 1 manhole (handhole) will typically accommodate one or two 4” openings, each capable of
accommodating three inner ducts. In total, each manhole can accommodate three to six fiber cables (more
than 1000 total strands) in each direction (e.g., N-S or E-W). Though there is no additional labor or excavation
cost associated with “buried in conduit” plant, the material cost of the conduit and manhole results in a slightly
increased cost when compared to traditional buried plant.
23 In order to access any version of the model, parties must execute the relevant acknowledgement of
confidentiality, licensing, and nondisclosure documents released as attachments to a Third Supplemental
Protective Order. See Connect America Fund, WC Docket No. 10-90, Third Supplemental Protective Order,
27 FCC Rcd 15277 (Wireline Comp. Bur. 2012).
24 The methodology documentation has been, and will continue to be, revised to reflect any changes made in
the CAM. This documentation will replace the version 3.2 methodology documentation that was posted in
August 2013.

Illustrative Results. The Bureau also will shortly be releasing a new set of illustrative model
outputs for CAM v4.0. The Bureau emphasizes, however, that it has not yet finalized the funding
thresholds, and therefore these illustrative results do not represent final support amounts.25


A. Initial Regulatory Flexibility Act Analysis

The Non-Contiguous Areas PN included an Initial Regulatory Flexibility Analysis (IRFA)
pursuant to 5 U.S.C. § 603, exploring the possible significant economic impact on small entities of
the policies and rules proposed therein.26 We invite parties to file comments on the IRFA in light of
this additional Public Notice.

B. Paperwork Reduction Act

This document does not contain proposed information collections subject to the Paperwork
Reduction Act of 1995 (PRA), Public Law 104-13. In addition, therefore, it does not contain any
new or modified information collection burden for small business concerns with fewer than 25
employees, pursuant to the Small Business Paperwork Relief Act of 2002, Public Law 107-198.27

C. Filing Requirements

Pursuant to sections 1.415 and 1.419 of the Commission’s rules,28 interested parties may file
comments and reply comments on or before the dates indicated on the first page of this document.
Comments are to reference

WC Docket No. 10-90 and DA 13-2304,

and may be filed by paper or
by using the Commission’s Electronic Comment Filing System (ECFS).29
 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. 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.

25 The Bureau released an order adopting key engineering assumptions for the Connect America Cost Model
earlier this year. See Connect America Fund; High-Cost Universal Service Support, WC Docket Nos. 10-90,
05-337, Report and Order, 28 FCC Rcd 5301 (Wireline Comp. Bur. 2013). The Bureau has not yet selected
final input values, nor has it adopted the funding and extremely high-cost thresholds that will determine
support amounts to be offered to price cap carriers.
26 See Wireline Competition Bureau Seeks Comment on Connect America Phase II Support for Price Cap
Areas Outside of the Contiguous United States
, WC Docket No. 10-90, Public Notice, 28 FCC Rcd 1030,
1038-46, App. (Wireline Comp. Bur. 2013) (Non-Contiguous Areas PN).
27 See 44 U.S.C. § 3506(c)(4).
28 47 C.F.R. §§ 1.415, 1.419.
29 See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998).

o 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.
o 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
o U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445
12th Street, SW, Washington DC 20554.
In addition, we request that one copy of each pleading be sent to each of the following:
(1) Katie King, Telecommunications Access Policy Division, Wireline Competition Bureau, 445
12th Street, SW, Room 6-A322, Washington, DC 20554; e-mail:;
(2) Charles Tyler, Telecommunications Access Policy Division, Wireline Competition Bureau, 445
12th Street, SW, Room 5-A452, Washington, DC 20554; e-mail:
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).
The proceeding this Notice initiates shall be treated as a “permit-but-disclose” proceeding in
accordance with the Commission’s ex parte rules.30 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
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 parte rules.
For additional information on this proceeding, contact Katie King ( of
the Wireline Competition Bureau, Telecommunications Access Policy Division, (202) 418-7400.
- FCC -

30 47 C.F.R. §§ 1.1200 et seq.

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