Another FCC Required Filing is Due Today
Monday, July 02, 2012
Posted by: Andrea Haney
ETCs learned from their consultants late last week that the FCC requires all
ETCs to file certain intercarrier compensation information with their state
commissions by June 30th pursuant to revised FCC rule §54.304, Administration
of Connect America Fund Intercarrier Compensation Replacement.
The 54.304 requirement has not been widely publicized or discussed by USAC,
NECA or national organizations prior to very late last week.
Section 54.304 requires that all ETCs seeking CAF ICC support for the funding
period July 1, 2012 through June 30, 2013 must file data projecting eligibility
for CAF ICC funding with the FCC, USAC, and the relevant state commission by June 30, 2012.
Based on information ITA has received today from Jerry Burmeister at ITCI, and
Burnie Snoddy at Kiesling Associates, here are some key points:
1. NECA filed the appropriate data with USAC and the FCC for member ETCs. Each
ETC does need to make a filing with their state commission.
2. ITA has learned that Kiesling Associates, ITCI and Vantage Point are
preparing or have already prepared filings for their clients. If in doubt, you
should check with your consultant.
3. Because the June 30th filing deadline was on a Saturday, the filing deadline
is extended to July 2nd (today).
4. ITA talked with IUB’s Mike Balch today, and Balch agreed that ETCs need not
file the ICC data, and need not request confidential treatment of data.
Instead, ETCs can simply file a certification that it is not seeking
duplicative recovery in Iowa for any Eligible Recovery subject to the recovery
mechanism described in §51.917, and that if the IUB needs any additional
information it can contact the ETC. (see sample below).
5. The filing must be made via IUB’s Electronic Filing System at https://efs.iowa.gov/efs/LoginShow.do?toCreateFiling=true.
Use a docket number of M-2012-____(your telco ID number______). To find your
telco ID number that IUB has assigned to you, click here and enter your telco
name in the search box.
Here is a sample certification letter prepared by Burnie Snoddy at Kiesling
Annual Reporting Requirements for High‐Cost Recipients Pursuant to 47 C.F.R.
§51.917(d) (vii) and47 C.F.R. §54.304 (d) (1)
Dear Ms. Cooper:
The Federal Communications Commission’s (FCC) November 18, 2011 USF/ICC
Transformation Order,FCC 11‐161 (WC Docket No. 10‐90) requires carriers seeking to obtain recovery through
the federal mechanisms established in the Order to make certain certifications
to the FCC and to state commissions regarding their eligibility
for, and their compliance with the rules applicable to, such recovery.
Specifically, 47 C.F.R. §51.917 (d) (vii) requires Rate of Return Carriers to
certify annually to the FCC and to relevant state commissions that the carrier
is not seeking duplicative recovery in the state jurisdiction for any Eligible
Recovery subject to the federal recovery mechanisms. In compliance with that
requirement, Atkins Telephone Company, Inc. hereby states that it is not
seeking duplicative recovery in the state jurisdiction for any Eligible
Recovery subject to the recovery mechanism described in §51.917.
The FCC’s November 18, 2011 USF/ICC Transformation Order, FCC 11‐161 (WC Docket No. 10‐90) also requires rate of return
carriers seeking CAF ICC support to file data establishing
the amount of the rate of return carrier’s eligible CAF ICC funding per 47
C.F.R. §54.304 (d) (1). If additional support data is required, we will provide
it upon request.
Please contact your consultants and advisors for more information.