Hurricane Katrina Questions for High Cost Support

Q. What entities may participate in High Cost relief related to Hurricane Katrina?

A. Federally or state designated eligible telecommunications carriers, or ETCs, (competitive carriers or incumbent carriers) with hurricane-damaged facilities in Alabama, Mississippi, and Louisiana may participate in Katrina-related High Cost relief necessary to reconstruct hurricane-damaged facilities.

A. Yes. Carriers received a waiver of USF deadlines for High Cost for the following filings:

a. Mandatory quarterly line count filings for High Cost Model (“HCM”) support and Interstate Access Support (“IAS”) for incumbent local exchange carriers (“LECs”) and competitive LECs.

b. Mandatory quarterly line counts filings for all High Cost components received by competitive LECs.

c. Mandatory quarterly line count filings for High Cost Loop (“HCL”), Local Switching Support (“LSS”), and Interstate Common Line Support (“ICLS”) for incumbent LECs.

d. Voluntary quarterly updated line count and data filings for all other incumbent LECs.

e. Use certifications for HCL support, Safety Net Additive (“SNA”) support, Safety Valve Support (“SVS”), LSS, and HCM support.

f. FCC Forms LSSc and LSSa – Projected LSS data for 2006 payments.

g. FCC Form 509 – ICLS annual true-up data filing.

h. FCC Forms LSSc and LSSa – 2004 LSS true-up data.

Filing deadlines for the above information were waived for 150 days beginning August 29, 2005. To receive High Cost support, however, carriers must make all missed filings no later than January 26, 2006. For further information please consult DA 05-2484.

Q. As an ETC, can I use my High Cost funds received in another state to meet the needs in one of the states where I had Hurricane Katrina damage?

A. No. Per FCC order (FCC 05-178) concerning Hurricane Katrina relief, carriers are not permitted to use high-cost support disbursed to one state to meet the needs in another state.

Q. Is additional High Cost support available due to the impact of Hurricane Katrina?

A. No. No additional High Cost support will be available for Hurricane Katrina relief. Existing High Cost support may, however, be used to repair and rebuild facilities and services damaged by Hurricane Katrina. The FCC expects that rural and non-rural carriers operating throughout the disaster area will be able to use their more than $240 million in estimated annual High Cost support to assist in the restoration efforts.

Q. As an ETC, what additional steps must be taken in order to use my High Cost funds for disaster restoration?

A. Each ETC must file a certification letter according to the new FCC order, FCC 05-178. Carriers using their High Cost support to assist in disaster restoration must file a letter that certifies that: (1) the carrier is serving in the area; and (2) the carrier incurred substantial damage as a result of Hurricane Katrina. A signed letter containing this preceding certification will suffice. The certification should be filed with both the FCC and USAC at the following addresses:

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

Karen Majcher
Vice President – High Cost and Low Income Division
Universal Service Administrative Company
2000 L Street, NW, Suite 200
Washington, DC 20036

For your convenience, USAC has developed a sample letter at the following link, Katrina Certification Letter.

Q. Can a carrier with a “temporary” ETC designation for purposes of receiving Lifeline support under the Low Income Program apply for High Cost support?

A. No. Any carrier receiving temporary ETC status consistent with the Katrina relief Order may only use the ETC status for participation in Lifeline support for low income consumers affected by Hurricane Katrina.