Documentation / Certification Requirements

Eligible telecommunications carriers (ETCs) using high cost support in a flexible manner to assist in disaster restoration must retain documentation sufficient to justify the alternate flexible use of high-cost support.

Sufficient documentation is required as ETCs shall be subject to audit or investigation by the FCC’s Office of Inspector General (OIG) where an ETC uses the temporary rules.  Furthermore, any ETC receiving more than $1 million under the new temporary rules shall be subject to an automatic audit, investigation, or other review by the FCC OIG or USAC working under the OIG’s oversight to ensure the temporary support is used for its intended purposes.

Certification Requirements

ETCs seeking the flexibility to use some of their high-cost support to assist in disaster restoration must file a certification consistent with the Katrina Order.  The certification can be in the form of a letter and must state that: (1) the carrier is serving in the area; and (2) the carrier incurred substantial damage as a result of Hurricane Katrina.  USAC has prepared a sample Katrina certification letter for your use.  USAC also asks that ETCs provide an estimate of support to be used in disaster restoration efforts so that the scope of support required for recovery can be better determined.