April, 2015 - Miller Isar

NO. 15-04
APRIL 30, 2015
Regulatory Review
The Miller Isar, Inc. Regulatory Review is a monthly report designed to provide clients with information regarding
regulatory and policy matters that may impact their business operations. The Regulatory Review is provided for
informational purposes only and does not constitute legal opinion or counsel. Comments and suggestions are
welcome.
FEDERAL REGULATORY NEWS
COMMISSION SEEKS COMMENT ON 911 CALL FORWARDING FOR NON-SERVICE-INITIALIZED
PHONES
On April 1, 2015, the Commission issued a Notice of Proposed Rulemaking regarding whether the
obligation to transmit 911 calls from “non-service-initialized” (NSI) devices to Public Safety Answering
Points (PSAPs) continues to serve an important public safety objective. An NSI device is a mobile device for which there is
no valid service contract with any CMRS provider. The Commission explained that a primary rationale for the initial
adoption of the Commission’s rule in the late 1990s was to expedite wireless calls to 911 that would otherwise have been
delayed due to lengthy call validation processes for unidentified callers that were commonly used at the time. According to
the Commission, these call validation methods are no longer in use. Further, the availability of low-cost options for wireless
services has increased. These trends suggest that the NSI component of the requirement is no longer necessary to ensure that
wireless callers have continued access to emergency services. The Commission proposes to sunset the NSI component of the
rule after a six-month transition period that will allow for public outreach and education. Comment is also requested on
alternative approaches to addressing the issue of fraudulent calls from NSI devices. Comments are due 30 days following
publication in the Federal Register; reply comments are due 60 days following publication. (FCC No. 15-43)( PS Docket No.
08-51)
WHEELER SAYS COMCAST ABANDONMENT OF TIME WARNER CABLE MERGER IS IN CONSUMERS’ BEST INTEREST
On April 24, 2015, Commission Chairman Wheeler released a statement on Comcast’s announcement that it would abandon
the cable company’s $45 billion dollar bid to acquire Time Warner Cable. “Comcast and Time Warner Cable’s decision to
end Comcast’s proposed acquisition of Time Warner Cable is in the best interests of consumers,” Wheeler noted. “The
proposed transaction would have created a company with the most broadband and video subscribers in the nation alongside
the ownership of significant programming interests,” he continued. Wheeler concluded, “I am proud of our close working
relationship throughout the review process with the Antitrust Division of the Department of Justice. Our collaboration
provided both agencies with a deeper understanding of the important issues of innovation and competition that the proposed
transaction raised.”
NECA AVERAGE SCHEDULE FORMULA REVISIONS APPROVED
On April 29, 2015, the The Wireline Competition Bureau issued an Order approving the National Exchange Carriers
Association’s (NECA) December 23, 2014 proposed modification of average schedule formulas for interstate settlements, for
the period beginning July 1, 2015, through June 30, 2016.
IN THE COURTS
COMMISSION OPPOSES SUPREME COURT USF/ICC TRANSFORMATION ORDER REVIEW
In late March the Commission filed a Brief with the U.S. Supreme Court asking the Court to deny
NARUC, Cellular South, et al. and Allband Petitions for Writs of Certiorari that sought Court review
the U.S. Court of Appeals for the Tenth Circuit’s 2014 Opinion denying all petitions for review of the
Commission’s 2011 USF/ICC Transformation Order. The Commission argued that Allband’s claims regarding a $250 perline cap on universal service fund (USF) subsidies do not warrant further review because Allband is not, and is not
anticipated to be, subject to the $250 cap. The Commission said Cellular South, et al.’s claim that the Commission lacked
authority to impose broadband conditions on USF subsidies also does not warrant review because petitioners’ arguments are
based on the Commission’s classification of broadband Internet access as an information service rather than as a
telecommunications service, and the Commission already reversed that classification. Regarding the National Association of
Regulatory Utility Commissioners (NARUC) appeal, the Commission argued that the Tenth Circuit already rejected
NARUC’s argument that the Commission lacked authority to establish bill-and-keep as the default method of intercarrier
compensation for all telecommunications traffic exchanged with local exchange carriers.
USTELECOM FILES SUPPLEMENTAL OPEN INTERNET ORDER REVIEW PETITION – OTHER PETITIONS FILED
On April 13, 2015, USTelecom filed a Supplemental Petition for Review of the Commission’s March 12, 2015 Open Internet
Report and Order on Remand, Declaratory Ruling and Order with the U.S. Court of Appeals for the D.C. Circuit. In its
pleading, USTelecom states that its Petition supplements its March 23, 2015 Petition for Review. USTelecom said that the
Petition for Review had been filed out of an abundance of caution in the event that the Commission’s Order, or the
Declaratory Ruling part of the Order, had been construed to be final on the date it was issued rather than after Federal
Register publication. On April 14, 2015 additional petitions for reconsideration of the Commission’s Open Internet Order
were filed by the American Cable Association, NCTA, CTIA and AT&T with the D.C. Circuit Court. CenturyLink filed a
Petition for Review with the D.C. Circuit on April 17, 2015. See List of petitions for review available to date. On April 23,
2015, USTelecom filed a Statement of Issues to be Raised with the D.C. Circuit Court. USTelecom said the issues include:
the Commission’s reclassification of broadband Internet access service as a telecommunications service subject to common
carrier regulation under Title II, and the FCC’s assertion of authority over the terms on which broadband Internet access
providers interconnect with other IP networks.
CALIFORNIA DISTRICT COURT DENIES AT&T DISMISSAL MOTION ON FTC MOBILE DATA THROTTLING COMPLAINT
On March 31, 1025, U.S. District Court for the Northern California district denied an AT&T motion to dismiss the Federal
Trade Commission’s (FTC) Complaint against AT&T for violation of a federal statutory prohibition against unfair or
deceptive acts or practices under Section 45(a), title 15, U.S. Code. The Complaint maintains that AT&T violated federal
law through adoption of a mobile data throttling program when it had advertised unlimited mobile data plans for smart phone
users. AT&T argued it could not be held liable for a violation of Section 45(a) because it is exempted under the statute as a
common carrier. The FTC countered that the motion is appropriate because AT&T is challenging only “the scope of the
FTC’s statutory authority.” The Court found that “Contrary to what AT&T argues, the common carrier exception applies
only where the entity has the status of common carrier and is actually engaging in common carrier activity. When this suit
was filed, AT&T’s mobile data service was not regulated as common carrier activity by the Federal Communications
Commission.” “Once the Reclassification Order of the Federal Communications Commission (which now treats mobile data
serve as common carrier activity) goes into effect that will not deprive the FTC of any jurisdiction over past alleged
misconduct as asserted in this pending action,” the Court noted.
THREE FCC TRANSPARENCY BILLS INTRODUCED
On April 21, 2015, the The House Energy and Commerce Committee issued a Press Release announcing that
Communications and Technology Subcommittee members have introduced three draft proposals to improve Commission
transparency. The draft bills will be the focus of the Subcommittee’s April 30, 2015 FCC Reauthorization: Improving
Commission Transparency hearing. A draft bill by Bob Latta (R-OH) would require the Commission to publish a list of
items that are placed on delegated, bureau level authority in lieu of a Commission vote. A draft bill by Adam Kinzinger (RIL) would require the Commission to publish the draft of a rulemaking, order, report or any other action when it is circulated
to the Commissioners for a vote, and the draft bill by Renee Ellmers (R-NC) would require the Commission to publish new
rules on the same day that they are adopted. Commissioner Pai issued a statement on the bills.
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IN CONGRESS
WHEELER RESPONDS TO CONGRESSIONAL INQUIRIES INTO OPEN INTERNET ORDER
On March 25, 2015, Commission Chairman Wheeler, responded to a letter from Representative Rod Blum (R-IA) in which
Congressman Blum had expressed concern that the Commission’s Open Internet Order would disproportionately impact
small and medium-sized Internet Service Providers (ISPs) and jeopardize their ability to make future network investments.
Chairman Wheeler said the Order included a temporary exemption for small providers from the enhanced transparency rule.
The Order directed the Consumer and Governmental Affairs Bureau to adopt an order on whether to make the exception for
small providers permanent by December 15, 2015, Wheeler said. Chairman Wheeler also responded to letters from
Representative Niki Tsongas (D-MA(response), Senator Edward Markey (D-MA), et al. (response), and Representative
Maxine Waters (D-CA), et al. (response), all of whom had urged the Commission to reclassify broadband under Title II.
Chairman Wheeler said, based on the input of all stakeholders, the FCC adopted the strongest possible open Internet
protections in the Order. On April 9, 2015, Chairman Wheeler responded to Senator Dianne Feinstein’s (D-CA) February
2015 letter. Senator Feinstein had urged the Commission to include provisions in the Open Internet Order to preserve the
ability of ISPs to block access to material that endangers public safety, violates intellectual property protections, or threatens
national security. Chairman Wheeler said the Open Internet rules were not intended to expand or contract broadband
providers' rights or obligations with respect to other laws or safety and security considerations, including the needs of
emergency communications and law enforcement, public safety and national security authorities. Further, he noted that the
open Internet rules protect only lawful content and are not intended to impede efforts by broadband providers to address
unlawful transfers of content or transfers of unlawful content.
REPUBLICANS INTRODUCE RESOLUTION TO EXPEDITE INVALIDATION OF OPEN INTERNET RULES
Several Republican Congresspersons led by Representative Doug Collins (R-GA) have introduced a “resolution of
disapproval that would allow Congress to review new federal regulations including those adopted under the Commission’s
Open Internet Order, using an expedited legislative process. The measure is intended to invalidate the Commission’s open
Internet rules. Thirteen Republican representatives, including Bob Goodlatte of Virginia and Bob Latta of Ohio, co-sponsored
Collins' resolution.
BILL EXEMPTING BROADBAND PROVIDERS FROM UNIVERSAL SERVICE FUND CONTRIBUTIONS INTRODUCED
On March 26, 2015, Representative Alexander Mooney (R-WV) introduced H.B. 1712, the Freedom from Internet Tax Act,
which proposes an amend the Communications Act of 1934 to exempt broadband Internet access service providers from
Federal universal service fund contributions. A broadband Internet access providers is defined as a “person engaged in the
provision of broadband Internet access service (as defined in the rules adopted in the Report and Order on Remand,
Declaratory Ruling, and Order that was adopted by the Commission on February 26, 2015(FCC 15–24)”
HOUSE REPUBLICANS REQUEST ADDITIONAL INFORMATION ON FCC FIELD OFFICE CLOSURES
House Energy and Commerce Committee leaders have requested that the Commission provide additional information on the
proposed closure of 16 of the 24 FCC field offices. In a letter to Chairman Wheeler, Committee Chairman Fred Upton (RMI), communications and technology subcommittee Chairman Greg Walden (R-OR), oversight and investigations
subcommittee Chairman Tim Murphy (R-PA), and Rep. Mike Pompeo (R-KS) said the Commission has only provided the
panel with a two-page memo and a 35-page slide presentation on a consultant's report concerning the proposal to close the
field offices. “These cannot be the sole basis upon which you concluded to close the field offices,” the lawmakers said. The
legislators state that the proposal raises significant challenges and concerns in the face of Commission statements that it is
taking action on 99 percent of interference to public safety communications complaints within one day. The lawmakers have
requested all documents, the final report by the outside consultants and other communications related to the field office
closure proposal prepared by the FCC's Enforcement Bureau and Office of Managing Director by May 7.
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STATE REGULATORY NEWS
CALIFORNIA – Comcast-Time Warner Cable Merger Would be Rejected Under Alternative
Proposed Decision
Prior to the withdrawal of the ill-fated Comcast Corp. – Time Warner Cable, Inc. merger, California
Public Utilities Commissioner Mike Florio released an alternative proposed decision in which the merger would be denied as
being contrary to the public interest. Under the alternative proposed decision, the Commission would have found that the
“negative effects of the merger cannot be mitigated effectively.” The proposed alternate decision would have found that the
merger would have a negative effect on local telecommunications competition and create barriers to network infrastructure
investment, concluding that the merger would create “an effective monopoly on providing broadband services within its local
geographic area.” Communications Division's California Broadband Availability Index data reflects that Comcast would have
a monopoly on speed tiers of 25 Mbps and above in some 78 percent of California census blocks, with only one competitor in
the remaining areas. The alternative proposed decision would have found that the merger would result in a single company
capable of serving more than 84 percent of the homes in California. The alternate proposed decision took antitrust and
competitive considerations, safety, consumer benefits, and broadband-related issues into consideration among others. On
February 13, 2015, a proposed assigned administrative law judge’s decision was released approving the merger with 25
conditions intended to promote broadband deployment, expand Comcast’s Internet Essentials program, provide for
broadband service upgrades and customer service improvements. (Applications 14-04-013, 14-06-012)
COLORADO – Emergency Service Rulemaking Initiated
The Colorado Public Utilities Commission has initiated a rulemaking to review amendments to its basic emergency service
rules. The rulemaking follows a grant of a petition filed by several 911 authorities to amend rules relating to the selective
911 database. The Petition requests narrow rule changes to Rules 2136(d) and (e); 2138(b), (c), and (f); 2140; and 2141 of the
Rules Regulating Telecommunications Providers, Services, and Products, Code of Colorado Regulations 723-2. According
to the Commission, “The 911 Authorities state that the purpose of the proposed rules is to bring the enhanced 911 rules into
conformity with existing tariffs and practices, particularly with respect to how governing bodies and public service answering
points pay for basic emergency service from a basic emergency service provider, and for purposes of remitting emergency
telephone service fees pursuant to § 29-11-100.5, et seq., C.R.S.” (Docket 15M-0122T)
DELAWARE– Commission Eliminates Bonding, Certain Reporting Requirements
On March 23, 2015 the Delaware Public Service Commission informed telecommunications service providers that they are
no longer required to maintain performance bonds, following enactment of House Bill No. 96, which became effective
February 11, 2015. Providers were advised that they could cancel their bonds immediately. Providers whose bonds were
about to lapse were told that it was unnecessary to inform the Commission if not renewing a bond. The Commission also
informed providers that they are no longer required to file annual reports and assessments, and no longer required to submit
retail tariffs or tariff amendments. Companies wishing to retain tariffs were asked to inform the Commission if the providers
wanted the Commission to retain a link to the provider’s tariff on the Commission’s web site. Switched access tariffs are
unaffected and must still be filed. The new law also eliminated the Commission’s jurisdiction over mergers.
FLORIDA – New 786 Area Code Slated for Implementation in Keys by June 1
The Florida Public Service Commission has ordered that the new 786 area code be fully implemented in the Keys by June 1,
on an overlay basis with the existing 305 are code. Mandatory ten-digit dialing in the 305 area code began April 18.
Neustar, Inc., the North American Numbering Plan administrator, had informed the Commission that the 305 area code
projected to reach exhaustion in the second quarter of 2015. The Commission noted it had completed initial area code relief
work for the Keys in 2000 and that number conservation measures had delayed the need for another area code until 2014.
IDAHO – TRS Surcharge Remains Unchanged; Telephone Assistance Surcharge Decreased
The Idaho Public Utilities Commission has ordered that the current Telecommunications Relay Service surcharge of $0.02
per month per access line on local service providers and $0.0002 per intrastate MTS/WATS minute are to remain unchanged
to meet projected funding levels. Hamilton Telecommunications remains the current default relay services provider. (Case
GNR-T-15-02) Separately, the Commission approved a reduction in the Idaho Telecommunications Service Assistance
Program (ITSAP) will decrease to $0.01 a month from $0.03 cents a month, to reflect a reduction in recipients. The average
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number of reported ITSAP recipients per month in 2014 (10,674) decreased by 25% from 2013 (17,626). The reduced
surcharge becomes effective on June 1. (Docket GNR-T-15-03).
INDIANA – New Area Code Slated for 317 NPA
The Indiana Utility Regulatory Commission has ordered deployment of a new area code in the current 317 area to preclude
projected number exhaustion by 2017. The new area code is to be implemented as an overlay, which the Commission found
to minimize inconvenience, cost, and burdens on consumers and service providers. A new 463 area code overlay is to go into
effect in late spring 2016. An implementation committee is to develop a 13-month implementation plan to be submitted to the
Commission and Office of Utility Consumer Counselor within 60 days from the date of the order. The Committee is also to
develop a customer education plan, focusing on mandatory ten digit dialing. (Case 44513)
INDIANA – Internet Tax Prohibition Enacted
Governor Mike Pence (R) has signed SB 80, a bill that would prohibit any state government or agency from imposing,
assessing, collecting, or attempting to collect a tax on Internet access or the use of Internet access, into law. Under the new
law a tax on Internet access, or any use of Internet access, regardless of whether the tax is imposed on a provider of Internet
access or a buyer of Internet access and regardless of the technology used to describe the tax is prohibited “Internet access”
is defined as a “service that enables users to connect to the Internet to access content, information, or other services offered
over the Internet, without regard to whether the service is referred to telecommunications, communications, transmission, or
similar services, and without regard to whether a provider of the service is subject to regulation by the Federal
Communications Commission as a common carrier under 47 U.S.C. 201 et seq.” The federal Internet Tax Freedom Act
prohibits states from taxing Internet access, but the moratorium on Internet taxation is set to expire on Oct. 1, 2015, if not
extended. The new state law takes effect July 1, 2015.
MARYLAND – Multi-Location 911 Legislation Enacted
Maryland Governor Larry Hogan (R) has signed HB 1080/SB 576, bills requiring direct access to 911 from multi-line
telephone systems (MLTS) in hotels and businesses, into law. Under the new law, MLTS equipment installations made on or
before December 31, 2017 must ensure that the system is “connected to the public switched telephone network in such a way
that an individual dialing 911 is connected to the public safety answering point without requiring the individual to dial any
other number or set of numbers.”
MARYLAND – Streamlined Telecommunications Regulation Bill Passes House
The Maryland House of Delegates has passed HB 472, a bill that would streamline the State’s telecommunications
regulations and limit Public Service Commission authority. The bill alters the definition of “telephone company,” defined as
“a public service company that owns telephone lines to receive, transmit, or communicate local exchange telephone services,
exchange access telephone services, or teletype communications; leases, licenses, or sells local exchange telephone services,
exchange access telephone services, or teletype communications; or owns telephone lines to receive, transmit, or
communicate telephone services to inmate facilities.” The bill would authorize the Public Service Commission to allow a
telephone company that has 20,000 or fewer subscribers to provide a regulated service without requiring the company to file
a tariff schedule if the Commission finds that it is in the public interest. A telephone company that provides discretionary
regulated retail services and/or competitive regulated retail services would not have to file a tariff schedule of its rates and
charges for these services with the Commission. Specified merger and acquisition requirements would no longer apply to a
merger or transfer of stock or other ownership interest between a telephone company and another entity with a greater than
50% ownership in common with the telephone company. And a telephone company would be exempt from specified
requirements related to financial transactions. The bill requires Commission to conduct specified studies and develop a report
to the legislature. The bill’s provisions related to tariffs take effect September 1, 2015. The bill’s other provisions take effect
July 1, 2015. SB 207, the Senate version of the bill, already passed the Senate.
NEW MEXICO – CenturyLink Meets Reduced Regulation Qualifications
The New Mexico Public Regulation Commission has voted 4 to 1 to approve a hearing examiner’s February 2015
recommendation that CenturyLink qualifies for reduced regulation under New Mexico law. The hearing examiner found that
Century served less than 375.000 access lines, as defined by law, and met the statutory criterion for qualification as a midsized carrier subject to reduced regulation under a 2004 New Mexico law. CenturyLink was found to serve 351,938 access
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lines as of June 30, 2014, down from the more than 850,000 lines service eight years ago. CenturyLink “will be subject to
rules to ensure service quality, consumer protection, and pricing flexibility up to a cap” consistent with the level of regulation
currently applicable to Windstream, the second largest local exchange carrier in the State. Several parties, including staff,
had urged the Commission to also make a public interest consideration, but the Commission elected to focus solely on the
statutory threshold. Commissioner Valerie Espinoza, who cast the dissenting vote, expressed concerns over insufficient
consumer protections resulting from reduced regulation. A proceeding is to be initiated to implement the decision. (Case 1400068-UT)
NORTH DAKOTA – Application Fee Bill Signed Into Law
Governor Jack Dalrymple (R) has signed SB 2123, a bill authorizing the Public Service Commission to impose an application
fee to process applications submitted by certain utilities, including telephone companies, for certificates of public
convenience and operating authority, into law. Fees of up to $10,000 will be assessed on new applications. The fee will be
deposited into a special fund and held to cover the cost of processing an application.
WASHINGTON – Amended Telecommunications Regulations Adopted
On March 30, 2015, the Washington Utilities and Transportation Commission adopted amendments to existing
telecommunications rules intended to streamline state regulation of providers and reduce reporting and tariffing requirements
for certain carriers to reflect an increasingly competitive market place. The Commission amended rules in several areas
including registration and competitive company classifications; the Washington Telephone Assistance Program and universal
service; and the transfer of property. Under the amended rules “competitively classified” carriers are no longer required to
file tariffs, although the Commission adopted detariffing following changes in state law enacted in 2006. The amended also
rules reduce certain service quality reporting requirements and eliminate certain reporting requirements, as well as the filing
of annual certification and other reports with the Commission. (Docket UT-140680)
WEST VIRGINIA – VoIP Deregulation Bill Enacted
SB 576, a bill that prohibiting the Public Service Commission from asserting jurisdiction over Internet Protocol enabled or
voice over Internet Protocol (VoIP) has been enacted by Governor Earl Ray Tomblin (D). Under the new law, an “Internet
protocol-enabled service” is defined as “any service, capability, functionality or application provided using internet protocol,
or any successor protocol, that enables an end user to send or receive a communication in internet protocol format, or any
successor format, regardless of whether the communication is voice, data or video.” VoIP is defined as a service that
“enables real-time two-way voice communications that originate or terminate from the user's location using internet protocol
or a successor protocol; and uses a broadband connection from the user's location.” The new law also prohibits the
Commission from regulation of transactions involving telephone company entities under common ownership.
COMPLIANCE REPORTING MAY
The following report listing has been compiled from past reporting requirements and is provided exclusively for
informational purposes. Reporting requirements are subject to change and should be verified by filers.
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FEDERAL REPORTS DUE IN MAY
FCC Form 499-Q Telecommunications Reporting Worksheet and de minimis notification due May 1.
ALL REPORTS DUE IN MAY
Due
May
May
Jurisdiction
Alaska
Alaska
Report
Access Minutes Report
Carrier and Area Specific Bulk
Billed Report
May
Missouri
Relay Missouri Statement
May
Rhode Island Telecommunication Education
Access Fund
May
Rhode Island Telecommunications Relay Service
Report
May 1 California
Affiliate Transaction Report
May 1 Federal
499Q de minimis determination
notice
(ad hoc as may apply)
May 1 Federal
FCC Form 499-Q
Telecommunications Reporting
Worksheet (Quarterly)
May 1 Federal
Geographic Rate Averaging and
Rate Integration Certification
May 1 Idaho
ID Universal Service Fund Form
May 1 Indiana
Indiana Utility Regulatory
Commission Telecommunications
Public Utility Fee Report
May 1 Kansas
Interexchange Carrier/Competitive
Local Exchange Carrier/And
Operator Service Providers Annual
Report to the Kansas Corporation
Commission
May 1 Minnesota
Alternative Operator Service
Annual Report
May 1 Minnesota
Telecommunications Carrier
Annual Report
May 1 North Dakota North Dakota Telecommunications
Gross Receipt Tax
May 1 Ohio
Competitive Telecommunications
Service Providers Annual Report
May 1 Oklahoma
Annual Report of Competitive
Telecommunications Carriers
May 1 Oklahoma
Local Service Provider Annual
Report
May 1 Washington Telecommunications Companies
Annual Report
May 10 Alaska
Alaska Telecommunications Relay
Services Fund - Remittance of
Surcharges Collected
May 10 Arkansas
State of Arkansas Universal Service
Fund
Due
Jurisdiction
May 10 California
May 10
May 10
May 10
May 10
May 15
May 15
May 15
May 15
May 15
May 15
May 15
May 15
May 15
May 15
May 15
May 15
May 15
May 15
May 15
May 15
May 15
Report
Combined California PUC
Telephone Surcharge Transmittal
California
Employee Compensation, Dues,
and Subscriptions
Georgia
Local Service Indicators Data
Requests
New York
Service Quality Performance
Oregon
Oregon Universal Service
Contribution Worksheet
Alabama
Revised Survey of Competitive
Local Exchange Carriers
Florida
Florida Telecommunications Relay,
Inc. (FTRI) Monthly Surcharge
Collection Report
Georgia
Georgia Telecommunications Relay
Service (TRS) Monthly Surcharge
Collection Report
Kansas
Kansas Universal Service Fund
2004/2005 Wireless and Wireline
Carrier Remittance Worksheet
Kentucky
Commonwealth of Kentucky
Telecommunications Relay Service
Fund Telecommunications Devices
for the Deaf Distribution Fund
Kentucky
Commonwealth of Kentucky
Universal Service Fund
Maine
Maine Telecommunications
Education Access Fund
Maine
Maine Universal Service Fund
Missouri
Quarterly Quality of Service Report
Nebraska
Nebraska USF & E911 Remittance
Worksheet
Nevada
Annual Report
North
North Carolina Access Line Report
Carolina
- Rule 17-2(K)
North
Public Utility Regulatory Fee
Carolina
Report
North
Questions for Competing Carriers
Carolina
Report
Oklahoma
State of Oklahoma Universal
Service Fund Carrier Remittance
Worksheet
Oklahoma
Utility Assessment Fee
Pennsylvania Pennsylvania Universal Service
Fund, FY2004 Carrier Remittance
Monthly Worksheet
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Due
Jurisdiction
May 15 Puerto Rico
May 15 Rhode Island
May 15 South
Carolina
May 15 Texas
May 15 Utah
May 15 Vermont
May 15 Virginia
May 20 Alaska
May 20 Arizona
May 20 Colorado
May 20 Idaho
Report
Puerto Rico Universal Service Fund
July 2004 - December 2004 Carrier
Remittance Worksheet
E911
The Public Service Commission of
South Carolina SC Dual Party
Relay System Invoice
CTP (Certified
Telecommunications Provider)
Quarterly Reporting pursuant to HB
1777
Hearing and/or Speech Impaired
Relay Report
Vermont Universal Service Fund
Carrier Remittance Worksheet
Telecommunications Relay Service
Monthly Report
State of Alaska Universal Service
Fund Monthly Carrier Remittance
Worksheet
Arizona Universal Service Fund
Carrier Remittance Worksheet
CO Telecommunications Relay
Service Surcharge
Idaho Telecommunications Service
Assistance Plan (ITSAP)
May 20 New York
Simplified Telecommunications
Annual Report
May 20 New
Hampshire
Telecommunications Relay Service
Remittance
Due
Jurisdiction
May 20 Utah
May 20 Washington
May 21 New York
May 21 New York
May 21 Oregon
May 22 Arkansas
May 25 Minnesota
May 25 Texas
May 30 Mississippi
May 30 Nebraska
May 30 Tennessee
May 30 Vermont
May 30 Vermont
May 30 Virginia
May 30 Wyoming
May 31 Federal
Report
Utah Universal Service Fund
Surcharge Remittal Statement
Telecommunications Relay Service,
Washington Telecommunications
Assistance Program, and E911
TAF Adjustment Input Form
Targeted Accessibility Fund
Monthly Online Reporting Form
Residential Services Protection
Fund Surcharge Remittance Form
Arkansas Intrastate Carrier
Common Line Pool Report
Minnesota Annual 911/TAM/TAP
Fees Report Form
Texas Universal Service Fund
Worksheet
Mississippi Dual Party Fund
Statement of Revenues
State of Nebraska Dual Party Relay
Surcharge Form
Wireline Activity Tennesse-CCN
Authority
Monthly Disconnect Report
Vermont Service Quality
Performance Index Report
Service Quality Report
Telecommunication Companies
Revenue & Assessment Report
(Wyoming Universal Service Fund)
FCC Form 395 - Common Carrier
Annual Employment Report and
Discrimination Complaint Report
May 20 Pennsylvania Remittance Form for Monthly
Telecommunications Relay Service
(TRS) Surcharge Collections
MILLER ISAR, INC. NEWS
Access billing disputes continue to plague competitive local exchange carriers. Miller Isar, Inc. has been active in
supporting dispute resolutions in April through review of incumbent and client access tariffs, interconnection agreements,
and regulatory decisions. The firm has also initiated client plans for compliance with the July 1, 2015 switched exchange
access end office rate element reductions ordered under the 2011 FCC USF/ICC Transformation Order and begun providing
courtesy compliance notifications in anticipation of the large number of compliance filings to be made in May and early June.
MILLER ISAR, INC. DAILY NEWS
Miller Isar, Inc. offers a daily news service on regulatory and industry issues and separately, on VoIP developments. For
subscription information, contact Andrew Isar at 253.851.6700 or [email protected] .
MILLER ISAR, INC. ONLINE
Miller Isar, Inc.’s web site has been redesigned and is available to provide clients and the public with access to important
regulatory information. Please visit us at www.millerisar.com.
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For additional information, please contact Andrew Isar at aisar@ millerisar.com, or 253.851.6700.
The following articles are reprinted with the expressed consent of the author and CCMI. The author and CCMI have
authorized reprinting of these and future articles by Mr. Regitsky as a regular Regulatory Review feature.
UNIVERSAL SERVICE FUND EXEMPTION FOR BROADBAND INTERNET ACCESS PROVIDERS WILL NOT LAST LONG
By Andrew Regitsky, Apr 3, 2015 9:43:29 AM In its recently released Open Internet Order, the FCC congratulated itself on
forbearing from the telecommunications requirement that broadband Internet access services immediately begin contributing
to the universal service Connect America Fund. This self-congratulation has become a habit. Read more »
COMBINATION ILEC/CLEC COMPANY STRESSES NEED FOR COST-EFFECTIVE, IP-BASED WHOLESALE SERVICES
By Andrew Regitsky, Apr 10, 2015 9:30:00 AM There is an important battle currently being waged between ILECs and
CLECs regarding the continuing need for ILECs to provide cost-effective wholesale services to replace special access during
the transition from the copper circuit switched network to one based on fiber and Internet protocol. The FCC finally waded
into this battle in November, when it released a Notice of Proposed Rulemaking (NPRM) in Docket 14-174, tentatively
concluding that to receive authority to discontinue, reduce, or impair a legacy copper service that is used as a wholesale input
by CLECs, an ILEC must commit to providing CLECs equivalent wholesale access on equivalent rates, terms, and
conditions. For more details on this NPRM, please see our December 5, 2014 blog. Read more »
A POSSIBLE WAY OUT OF THE NET NEUTRALITY CHAOS
By Andrew Regitsky, Apr 17, 2015 9:52:56 AM Watching unfold after the FCC’s March 12, 2015 Order is like watching the
plucky heroine enter the deserted house in a horror movie. We know nothing good is going to happen. Unlike our heroine,
however, who can usually make quick work of the demons hiding inside the house, the net neutrality dispute is only the
beginning of a horror movie that will continue for years. Here are the latest developments: Read more »
THE EVER-EXPANDING UNIVERSAL SERVICE FUND
By Andrew Regitsky, Apr 24, 2015 9:16:00 AM, While the industry waits to see if the Federal-State Joint Board will
recommend that broadband Internet access service providers must contribute to the Universal Service Fund (it will), and
whether that recommendation is accepted by the FCC (it will be), it appears that the Commission is in search of even more
ways to increase the flow of universal service dollars. Its latest effort is a back door attempt through the Universal Service
Administrative Company (USAC) to require VoIP providers to contribute to the Fund based on their revenues from ancillary
services such as call forwarding and call waiting. Read more »
LIGHT READING FROM CORPORATE COUNSEL DAILY UPDATE
LOOK ON THE BRIGHT SIDE OF COMPLIANCE, SAYS LAWYER
A little oversight never hurt anyone, he says. And it's actually led to a better job for him and his colleagues. READ
MORE »
UNLOCKING THE VALUE OF AN INFORMATION GOVERNANCE STRATEGY
A clear understanding of the underlying value of all of your electronically stored assets will allow you to reduce
information-related... READ MORE »
NO DOJ RULES FOR ADA-COMPLIANT WEBSITES? DO IT ANYWAY
Right now is the perfect time to make websites and mobile applications accessible, regardless of when the U.S. Department...
READ MORE »
WHEN EX-EMPLOYEES LEAVE WITH SOCIAL MEDIA PASSWORDS
An Illinois company sued a former employee for misappropriation of trade secrets when he refused to hand over its
LinkedIn... READ MORE »
BROWSE, CLICK, SIGN, ENFORCE
Signing, dating and keeping a record of a paper contract are standard practices that do not easily translate to online... READ
MORE »
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THE $11M LESSON IN TELEPHONE CONSUMER PROTECTION COMPLIANCE
Want to let your customers know with a phone call or text that the items they need are ready for pickup? Think twice.. .
READ MORE »
MICROSOFT: UNMASKING EMAILS RISKS 'OUTRAGE' OVERSEAS
Internet users are secondarily liable third parties for negligence when they fail to incorporate reasonable security... READ
MORE »
EMPLOYEE WELLNESS PROGRAMS: FINALLY, SOME GUIDANCE
The U.S. Equal Employment Opportunity Commission is giving companies some direction for implementing wellness
programs... READ MORE »
CAN EMPLOYEES SECRETLY RECORD WORKPLACE CONVERSATIONS?
It's likely that almost every employee in your company has a smartphone that can be used as a clandestine recording... READ
MORE »
THE ETHICS AND COMPLIANCE RISK ASSESSMENT CHECKLIST
The term "risk assessment" is thrown around early and often in ethics and compliance circles, but it often is hard to... READ
MORE »
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