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On August 10, 2016, the FCC released a Public Notice announcing a preliminary list and map of census blocks that have been deemed initially eligible for the Connect America Fund (CAF) Phase II auction. The list and the map are on the FCC website. Notifications of additional coverage data are due by August 31, 2016.
FCC Issues Compliance Guide for RoR USF Obligations, Reporting
On August 11, 2016, the FCC issued a Small Entity Compliance Guide describing the service and reporting obligations for rate-of-return (RoR) carriers that voluntarily elect, on a state-level basis, to receive CAF A-CAM model-based support or that choose to remain on legacy mechanisms. The guide details various performance, deployment, and reporting obligations for all RoR carriers receiving High Cost Program support, including speed, latency, data usage, buildout, reporting, certification, recordkeeping, interconnection, and pricing.
FCC Releases Minor Corrections to A-CAM
On August 15, 2016, the FCC released a Public Notice with minor changes to the reports showing the model-based Connect America Fund support amounts offered to rate-of-return carriers originally released on August 3, 2016. Specifically, the report now includes a revised support amount for Fremont Telecom and corrections to the short names previously assigned to seven study areas. No other changes were made and all other companies’ support amounts remain the same.
Please stay up to date with your regulatory filings. USAC reminds rate-of-return carriers that it will withhold funding from carriers that do not submit data needed to calculate High Cost Program support.
In the Rate of Return Reform Order released on March 30, 2016, the FCC created a model-based funding mechanism for rate-of-return carriers and is asking carriers to choose between the new cost model and a modified version of the existing support system.
Carriers that elect the new Alternative Connect America Model (A-CAM) will receive a set amount of monthly support over 10 years and will need to meet defined build-out obligations. Carriers that choose to stick with the modified legacy funding mechanism, Connect America Fund Broadband Loop Support (CAF-BLS), will receive funding - and be required to meet deployment obligations – that are calculated using data submitted by carriers.
Specifically, the FCC and USAC will use FCC Form 477 data to conduct competitive overlap analysis and calculate deployment obligations; study area boundary data to calculate study area density and set operating expense limitations; and data to determine the capital investment allowance. Without this information, USAC will be unable to calculate carrier support, including support for carriers that elect the CAF-BLS path, and will withhold funding until this information is submitted.
Carriers should therefore be certain that all data filed with the FCC, including FCC Form 477 data and study area boundary data, are up-to-date and accurate. Any data revisions should be filed as soon as possible. These filings are in addition to the FCC Form 481 (54.313), the annual use certification (54.314) and deployment data (54.316) that carriers are required to submit in order to receive High Cost Program support (as specified in 54.903).
As announced in a Public Notice (DA 16-601), released on May 31, 2016, the FCC Form 481 has been OMB-approved. As such, the certify button and bulk certification options are now active and carriers can make their final certifications.
This filing is required for all ETCs participating in the High Cost and/or Lifeline programs with the exception of participants in Phase I Mobility Fund [section 54.313(k)]. FCC Form 481 is due Friday, July 1, 2016.
FCC Form 481 Templates and Resources
Eligible telecommunications carriers (ETCs) can log into E-File and access the FCC Form 481. USAC has also posted the FCC Form 481 Template (PDF version), filing instructions, and all necessary upload templates to our website.
While the names of these files on our website have been updated to reflect the approval of the form, the content has not changed as a result of the approval. These can all be found on the High Cost Forms and Lifeline Forms pages.
In addition, a recording of the webinar held about this year's FCC Form 481 submission may be accessed on the USAC website.
On June 3, 2016, the FCC released a Public Notice (DA 16-618) providing guidance to price cap carriers that accepted Connect America Fund (CAF) Phase I incremental support regarding upcoming validation of compliance for Phase I incremental support. In response to informal inquiries from CAF Phase I incremental support recipients, the FCC provided guidance about the types of documentation that recipients should be prepared to produce upon request. Examples of potentially relevant documentation would include, but not be limited to:
• Engineering studies,
• Construction schedules,
• Records of plant placed in service,
• Network maps,
• Advertising materials, and/or
• Customer subscription records.
Carriers should be prepared to produce their capital improvement plan from the time period immediately pre-dating the acceptance of CAF Phase I incremental support for either round. Carriers also should be prepared to produce documentation demonstrating the steps taken to determine an area was not already served according to the then-current National Broadband Map or slated to become served as a BIP or BTOP project, to the best of their knowledge. Carriers that accepted funding in the second round to deploy to locations shown on the then current National Broadband Map as already served by them with 3 Mbps/768 kbps should be prepared to produce documentation that those locations were served at the time of acceptance through a copper-fed digital subscriber line access multiplexer.