Quarterly Line Count Filings are Due in December

All Eligible Telecommunications Carriers (ETCs) who have a Competitive Eligible Telecommunications Carrier (CETC) filing line counts in their service area(s) are required to file line counts with the Universal Service Administrative Company (USAC) on a quarterly basis.  In addition, all CETCs are required to file required line counts with USAC on a quarterly basis. In order to qualify for high cost support, you must report your line counts as follows:

• High Cost Loop, Local Switching Support, and Long Term Support:  Your next line count filing is due on December 30, 2002 for the number of lines you served as of June 30, 2002.  For ETCs, your lines must be reported consistent with the disaggregation path you selected.  For CETCs, your lines must be reported consistent with the disaggregation path selected by the incumbent carrier(s) in whose service area(s) you serve lines.  You may obtain copies of the appropriate disaggregation plans by calling USAC (202-776-0200).
• Interstate Common Line Support:  Your next line count filing is due on December 30, 2002 for the number of lines you served as of June 30, 2002.  You, or your agent, must report your lines using FCC Form 507, which is available on the Forms Section of USAC's website. Your lines must be reported by customer class. (Residential and single line business lines are reported separately from multi-line business lines.)  For ETCs, your lines must be reported consistent with the disaggregation path you selected.  For CETCs, your lines must be reported consistent with the disaggregation path selected by the incumbent carrier(s) in whose service area(s) you serve lines
• High Cost Model Support:  Your next line count filing is due no later than December 30, 2002 for the number of lines you served as of June 30, 2002.  For both ETCs and CETCs, your lines must be reported by wire center.
• Interstate Access Support:  Your next line count filing is due by the last business day of the quarter, December 31, 2002, for the number of lines you served as of September 30, 2002.  For both ETCs and CETCs, your lines must be reported by UNE zone and customer class. (Residential and single line business lines are reported separately from multi-line business lines.) 

Remember:  Line count filings for all High Cost support mechanisms except IAS must be received by USAC on December 30, 2002.  IAS must be received by USAC by December 31, 2002.  If the line count filing is received after the filing date, a petition for waiver will need to be filed with the FCC.  Because USAC is not authorized to waive filing deadlines, only the FCC's grant of a waiver will permit USAC to use your December line counts to calculate high cost support.

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Draft Forms for Interstate Common Line Support Mechanism Data Collections Are Available for Download and Review

Drafts of proposed new information collection forms and accompanying draft instructions for the Interstate Common Line Support (ICLS) mechanism are available for download and review.  USAC developed these forms with FCC oversight and review.

FCC Form 508, "Projected Annual Common Line Revenue Requirement Form," proposes to collect the same 13 pieces of information from each rate-of-return incumbent local exchange carrier that was collected for the first year's operation of the program.  USAC, the universal service administrator of the ICLS mechanism, will use this information to compute the amount of each carrier's ICLS payments. 

Download Draft FCC Form 508 [Excel Format, 52kb] and its accompanying draft instructions [PDF Format, 53kb].

FCC Form 509, "Annual Common Line Actual Cost Data Collection Form," proposes to collect the same 13 pieces of information that each carrier initially projected on its FCC Form 508.  USAC will use the carrier's actual cost data to make adjustments to true-up each carrier's projected and actual ICLS payments, if appropriate.

Download Draft FCC Form 509 [Excel Format, 48kb] and its accompanying draft instructions [PDF Format, 56kb].

Carriers or carriers' agents may file FCC Form 508 and FCC Form 509, consistent with the approach used with the FCC Form 507, "Interstate Common Line Support Mechanism Line Count Report."  Carriers and their agents must certify that the information reported on the forms is accurate to the best of their knowledge.

Please note that FCC Form 508 and FCC Form 509 are available only in draft and must first undergo Office of Management and Budget review and approval before they may be finalized and used by carriers to report their ICLS cost information.  Please do not complete or submit these forms to USAC.

Interested persons may submit questions and/or comments concerning the draft forms and draft instructions to iclsquestions@universalservice.org.

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October 1 Certifications

All carriers, rural, as well as all non-rural carriers eligible to receive high cost loop, local switching, high cost model or hold harmless support, are subject to a certification requirement that has a direct impact on those carriers' receipt of high cost universal service support. The certification for both rural and non-rural carriers is due on or before October 1, 2002. Without that certification, carriers will not be eligible for the first quarter 2003 high cost support for which they would otherwise be qualified. Provided below is a summary of the components of this certification requirement.

What must be contained in the certification?

• The certification must state that all federal high cost support (which includes high cost loop support, local switching support, high cost support received pursuant to the purchase of exchanges, high cost model support, and hold harmless support) will be used only for the provision, maintenance, and upgrading of facilities and services for which the support is intended, consistent with section 254(e) of the Communications Act.
• The certification may be in the form of a letter from the appropriate state regulatory authority, or authorized corporate officer where the state lacks jurisdiction.
• The certification must clearly reference CC Docket No. 96-45.
• The certification should list rural carriers separately from non-rural carriers, in those states in which non-rural carriers are certified.
• The certification should include each carrier's study area code, the six-digit number assigned to each carrier by the National Exchange Carrier Association (NECA).
  

Who must submit the certification?

• If a carrier is subject to state jurisdiction, the certification must come from the appropriate state regulatory authority. In states in which the commission has limited jurisdiction, the state commission need not initiate the process. Rather, the carriers may initiate the process, formulate plans to comply with section 254(e), and present them to the state commission, which may then in turn certify the carriers.
• If the carrier is not subject to state jurisdiction, the carrier may certify directly to the FCC and USAC. The certification may be in the form of a sworn affidavit executed by a corporate officer, attesting to the use of the support only for the provision, maintenance, and upgrading of the facilities and services for which the support is intended.
• Carriers are encouraged to work closely with their state commissions.
  

What carriers are covered by this certification requirement?

All carriers seeking support from the following components of the high cost universal service support mechanism are subject to this certification requirement: High Cost Loop Support; Local Switching Support; High Cost Model Support; and interim hold harmless support. That is, all rural carriers and all competitive ETCs seeking high cost support in the service area of a rural LEC are subject to the rural certification requirement contained in section 54.314 of the FCC's rules. In addition, all non-rural carriers that are eligible to receive either forward-looking support under the high cost model or hold harmless support, as well as all competitive ETCs seeking high cost support in the service area of such a non-rural carrier, are subject to the non-rural certification requirement contained in section 54.313 of the FCC's rules.

Where should certifications be filed?

Certifications must be filed with both the FCC and USAC at the following addresses:

FCC:

Marlene H. Dortch
Office of the Secretary
Federal Communications Commission
445 - 12th Street, SW
Washington, DC 20554

USAC:

Irene Flannery
Universal Service Administrative Company
2120 L Street, NW - Suite 600
Washington, DC 20037

When must certifications be filed?

In order to receive first quarter 2003 high cost support, certifications must be submitted on or before October 1, 2002. The certifications must be received by the FCC and USAC on or before October 1. The consequence of failing to file is loss of first quarter 2003 support, absent a waiver from the FCC. If a state commission or a carrier misses the October 1 deadline, the following schedule applies:

• Certify by January 1, 2003: the carrier may receive support for the second, third, and fourth quarters of 2003.
• Certify by April 1, 2003: the carrier may receive support for the third and fourth quarters of 2003.
• Certify by July 1, 2003: the carrier may receive support for the fourth quarter of 2003.
• Fail to certify by July 1, 2003: the carrier may not receive any high cost support for 2003.

Has your certification been received by USAC?

To see if USAC has received your October 1 certification, please visit our October 1 certification checklist.

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LINE COUNT FILINGS ARE DUE ON JULY 31, 2002.

YOU MUST FILE YOUR LINE COUNTS CONSISTENT WITH THE DISAGGREGATION PATH YOU SELECTED. IF YOU ARE A COMPETITIVE CARRIER, YOU MUST FILE LINE COUNTS CONSISTENT WITH THE DISAGGREGATION PATH SELECTED BY THE INCUMBENT CARRIER(S) IN WHOSE SERVICE AREA(S) YOU SERVE LINES.

FCC rules require all rural incumbent carriers to file annual line counts for High Cost Loop support (HCL), Long Term Support (LTS), and Local Switching Support (LSS) on July 31, 2002. You must report the lines consistent with the disaggregation path you selected. In addition, the rules require all rate-of-return incumbent carriers to file annual line counts for Interstate Common line Support (ICLS) on July 31, 2002. You must use FCC Form 507 to report lines for ICLS. Again, you must report lines consistent with the disaggregation path you selected.

FCC rules require all non-rural incumbent carriers to file quarterly line counts for High Cost Model (HCM) support on July 31, 2002. For HCM support, you must report lines by wire center.

If you are a competitive eligible telecommunications carrier that serves lines in an incumbent carrier's service area, FCC rules require you to file line counts on a quarterly basis. Your next line count filing is due no later than July 31, 2002. For HCL, LTS, and LSS, you must report lines consistent with the disaggregation plan selected by the incumbent carrier(s) in whose service area you serve lines. For ICLS, you must report lines using FCC Form 507 and consistent with the disaggregation plan selected by the incumbent carrier(s) in whose service area(s) you serve lines. For HCM, you must report lines by wire centers.

Remember: Your line count filings must be received by USAC by July 31, 2002. If your line count filing is received after that date, you will need to file a petition with the FCC for a waiver of the line count filing rule in order for USAC to be permitted to use your line counts to calculate high cost support.

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FCC Form 507, Interstate Common Line Support (ICLS) Mechanism Line Count Form, Is Now Available for Downloading

FCC Form 507, Interstate Common Line Support (ICLS) Mechanism Line Count Form, Is Now Available for Downloading (6/21/02)

FCC Form 507, the ICLS Line Counts Form, and its accompanying instructions are now available for downloading from USAC's website.  Carriers must use Form 507 to submit their ICLS line counts to USAC, the universal service Administrator, beginning with the July 31, 2002 ICLS line count submission.   Please access Form 507 and the accompanying instructions on our high cost forms web page.

Rate-of-return incumbent carriers and competitive eligible telecommunications carriers (CETCs) that have initiated service in the rate-of-return incumbent carrier's service area are required to submit line count information to USAC by July 31, 2002 and on that date each year thereafter, in order to qualify for ICLS.   Additionally, if a CETC has initiated service and reported line count data to USAC in the rate-of-return incumbent carrier's service area, the rate-of-return incumbent carrier must submit line count information to USAC on a quarterly basis.    

Please note that you are encouraged to submit your completed form in electronic format by the due date.  You must also mail signed copies of the certifications that are required components of Form 507 to the address listed in the instructions.  The form is not considered complete until we receive the line count data collection sheet and the certifications.  All components of the completed Form 507 must be received by the July 31, 2002 due date.  If you have additional questions once you have reviewed the form and instructions, please contact the ICLS Customer Service Bureau via e-mail at iclsquestions@universalservice.org, via toll free number at 866-204-ICLS (4257), or at 512-835-1585.

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FCC Waives June 30, 2002, Use Certification Requirement for Interstate Common Line Support (ICLS)

On June 13, 2002, the FCC released an Order waiving the requirement that carriers file an annual use certification on June 30, 2002, in order to receive ICLS. The FCC found that the requirement was unnecessary because carriers filed use certifications on April 18, 2002, for the ICLS funding year beginning on July 1, 2002. The FCC determined that the June 30th filing would merely duplicate the earlier filing on April 18, 2002, which covers the same certification period. The FCC, therefore, concluded that special circumstances warrant a waiver of the June 30, 2002 filing requirement. Carriers will need to file their next ICLS use certification on June 30, 2003, and each year thereafter, in order to receive ICLS after the initial funding year. If a carrier has not yet filed a use certification for ICLS and is eligible or becomes eligible to receive ICLS, it should file its annual certification on the date it first files its line count information. For more information on ICLS, please visit the ICLS section of this web site.

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May 15, 2002 Is an Important Deadline for All Rural and Rate-of-Return Carriers!

All rural and rate-of-return incumbent LECs must choose a disaggregation path for the distribution of federal high cost universal service support on or before May 15, 2002. If you fail to select a disaggregation path by the May 15th deadline, you will default to Path 1 (no disaggregation) and will lose the flexibility to request disaggregation at some future time. You will only be permitted to disaggregate if the state commission orders you to do so. On the other hand, if you elect Path 1 by the May 15th deadline, then decide at a later time that you wish to disaggregate, you retain the flexibility to petition your state commission and request that your chosen disaggregation plan be approved.

As you may know, the FCC first announced that incumbent rural carriers may choose to disaggregate their high cost support in the Rural Task Force Order (FCC 01-157) that was issued in July of 2001. This Order reformed the high cost universal service support mechanism for rural carriers. In November of 2001, the FCC released the MAG Order (FCC 01-304), in which it extended the disaggregation provisions to the newly established Interstate Common Line Support (ICLS) universal service mechanism, which applies to all rate-of-return carriers, both rural and non-rural. The FCC established May 15, 2002 as the due date by which all rate-of-return carriers and all rural carriers must select the manner in which they intend to disaggregate their high cost support.

To assist you in determining which path your company would prefer, we have posted a brief summary of the three disaggregation paths, as well as the disaggregation information filing requirements under each of the three paths, on our Disaggregation website. Once you have selected a disaggregation path, you must send the appropriate documents to your state regulatory commission or the FCC, if you are not governed by a state regulatory commission. The same information that you file with your state commission or the FCC, if you are not governed by a state regulatory commission, must be submitted to and received by USAC on or before the May 15th deadline.

After you have submitted your disaggregation plan to USAC, you may check on-line to see if your disaggregation plan has been received. Please look on the High Cost web page under Disaggregation and select Disaggregation Checklist. The disaggregation plans are compiled by state. Just select your state and a Microsoft Excel file will appear for the rural and rate-of-return incumbent LECs in that state. If there is an "X" in the Disaggregation column, then USAC has received your disaggregation plan. This data is updated once a day in the late afternoon. Please be sure to visit the Disaggregation Checklist.

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Check to See If Your Self-Certification Has Been Received By USAC!

You now have the capability to check on-line to see if your self-certification for the Interstate Common Line Support and Long Term Support mechanisms has been received by USAC. Remember: the filing date for self-certifications has been extended to April 18, 2002.

Please look on the High Cost web page under ICLS Mechanism, and select ICLS Checklist. The self-certifications are compiled by state. Just select your state and a Microsoft Excel file will appear for the carriers in that state. If there is an "X" in the Use Certification column, then USAC has received your self-certification. Please note that this data is updated once a day in the late afternoon. In the near future, you will also be able to check on-line to see if your disaggregation plan has been received by USAC. Please be sure to visit the ICLS Checklist.

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Modifications to the Initial Implementation of Interstate Common Line Support Mechanism

On March 22,2002, the Federal Communications Commission (FCC) released an order modifying some aspects of the initial implementation of the Interstate Common Line Support (ICLS) mechanism.  In its role as neutral universal service administrator, USAC will be implementing the new ICLS order as directed by the FCC.

The order provides as follows:

• Extension of Deadline.  The deadline for submission of information necessary to qualify for ICLS has been extended to April 18, 2002.  The information that must be submitted includes projected revenue requirement data, line count information, and a use certification.  A further explanation of what needs to be filed and how it should be filed appears below.

• Data.  For this initial implementation period, rate-of-return carriers must file with USAC the following data by study area for the period July 1, 2002 to June 30, 2003: 

Projected common line revenue requirement Projected subscriber line charge (SLC) revenues Projected transitional carrier common line (CCL) charge revenues Projected special access surcharges Projected line port costs in excess of basic analog service Projected long term support (LTS) The deadline for submitting corrections to the projected common line revenue requirement data has been extended to April 29, 2002.

• Line Count Information.  Rate-of-return carriers must file actual line count data by customer class (residential/single-line business and multi-line business) as of September 30, 2001.  For this initial filing period, carriers should file their line count data on a study area basis.

• Use Certification.  Rate-of-return carriers must file a self-certification with the FCC and with USAC stating that all ICLS and LTS provided to such carrier will be used only for the provision, maintenance, and upgrading of facilities and services for which the support is intended, as required by section 54.904 of the FCC's rules.

• Submission of Data and Line Count Information.  

• Pooling carriers.  For this initial implementation period, the FCC has authorized the National Exchange Carrier Association (NECA) to submit projected revenue requirement and actual line count information on behalf of rate-of-return carriers participating in the NECA common line pool.  The FCC also stated that a pooling company may opt to either submit the data itself or have another consultant submit the information on its behalf, in which case USAC would use the data submitted by the carrier to calculate its ICLS.


• Non-pooling carriers.  A non-pooling carrier may either file its projected revenue requirement data and actual line count data or authorize an agent to submit the data on its behalf.  For a sample letter for the required submission, click here [PDF document, 8kb].


• Competitive carriers.  Competitive eligible telecommunications carriers must file actual line count data by customer class as of September 30, 2001.  For a sample letter for the required submission, click here [PDF document, 17kb].

• Other Certifications.  In addition to the use certification discussed above, the following certifications must also be submitted:

• Pooling carriers.  For the pooling carriers for which it submits data, NECA must certify the following: (1) that the projections are accurate to the best of its knowledge and belief; (2) that the line count data are accurate to the best of its knowledge and belief and represent actual data supplied to NECA by the carrier; and (3) that it has notified each carrier of the filing and will provide each carrier with a copy of the part of the filing relevant to the individual carrier within 15 days. 


• Non-pooling and competitive carriers.  Non-pooling carriers and competitive carriers must certify that the data submitted to USAC are accurate to the best of their knowledge and ability and that the line count data are accurate.  For a sample letter for non-pooling carriers click here [PDF document, 8kb].  For a sample letter for competitive carriers click here [PDF document, 17kb].


• Request for Confidential Treatment of Filed Data. Carriers may request confidential treatment of some or all of the data filed to obtain ICLS by complying with the requirements set forth in 47 C.F.R. §0.459 and by requesting confidential treatment in the cover letter submitted with the data.

If you have any questions, please do not hesitate to contact our ICLS Customer Service Bureau by phone at 512-835-1585, toll free at 866-204-ICLS (4257), or via e-mail at iclsquestions@universalservice.org. 

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Change to Important Filing Date for the Interstate Common Line Support and Long Term Support Self-Certification

On April 18 2002, all rate-of-return carriers eligible to receive Interstate Common Line Support (ICLS) and Long Term Support (LTS) must file a self-certification with the FCC and with USAC stating that all ICLS and LTS provided to such carrier will be used only for the provision, maintenance, and upgrading of facilities and services for which the support is intended, as required by section 54.904 of the FCC's rules. Previously, the deadline was March 31, 2002; however, on March 22, the FCC released an Order (FCC 02-89) extending the deadline for submission of the self-certification until April 18, 2002 for the initial implementation filing. 

The certification may be in the form of a letter from an authorized representative for the carrier and must clearly reference CC Docket No. 96-45. On June 30, 2002, the certification must be filed again for the annual certification filing, and it must be filed on June 30 of each year thereafter. In addition, competitive eligible telecommunications carriers (CETCs) must file a certification the first time they file line count information for the purpose of receiving ICLS and LTS, pursuant to section 54.903 of the FCC's rules, and they must also file a certification annually on each June 30 thereafter.

For a sample self-certification letter click here.

Failure to file a certification will preclude a carrier from receiving ICLS and LTS, absent a waiver from the FCC. If the certification is filed late, the carrier will not become eligible for support until the second calendar quarter after the certification is filed. Certifications must be filed with both the FCC and USAC at the following addresses:

FCC (by mail):

William F. Caton
Office of the Secretary Federal Communications Commission
445 - 12th Street, SW
Washington, DC 20554

For filing by hand, see the FCC's website for new filing locations.

For electronic filing, see the FCC's website for instructions.

USAC:

Irene M. Flannery
Vice President - High Cost & Low Income Division
Universal Service Administrative Company
2120 L Street, NW - Suite 600
Washington, DC 20037

If you have additional questions, please contact the ICLS Customer Service Bureau at the following:

Via email: iclsquestions@universalservice.org
Telephone: (512) 835-1585 or Toll Free (866) 204-ICLS (4257)

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