High Cost

Trainings & Outreach

HC Reporter - November 2015

November 2015

In this issue...

Program Happenings   |   At the FCC   l   In the News


RBE Support Ready to Be Authorized

On September 29, 2015, the FCC released a Public Notice (DA 15-1092) announcing that Rural Broadband Experiment (RBE) support for three provisionally selected bids is ready to be authorized. The bids that are ready to be authorized cover 292 census blocks in two states for a total of $2,821,652.85 in support. Details of the bids can be found in the Notice. Read the Public Notice

Reminder: Carriers Must Use High Cost Program Support for Its Intended Purpose

On October 19, 2015, the FCC released a Public Notice (FCC 15-133) reminding all carriers that receive support from the High Cost Program (whether legacy support or Connect America Fund support) of their obligations to use such support only for its intended purpose of maintaining and extending communications service to rural, high-cost areas of the nation. Expenditure of legacy or Connect America Fund support for any other purpose is misuse and may subject the recipient to recovery of funding, suspension of funding, and enforcement action by the FCC's Enforcement Bureau. 
The Notice encourages state commissions to look carefully at the information provided to them in advance of the annual certification and to report any areas of concern to the FCC for further investigation and potential enforcement action. Read the Public Notice


FCC Takes Steps to Facilitate Mobile Broadband and Next Generation Wireless Technologies

On October 22, 2015, the FCC announced that it took steps to maintain the United States' leadership in wireless by proposing new rules for wireless broadband in wireless frequencies above 24 GHz. In the Notice of Proposed Rulemaking (FCC 15-138), the FCC continues their examination of higher frequency bands for mobile and other uses. They identify specific spectrum bands above 24 GHz that appear to be suitable for mobile service, and seek comment on proposed service rules that would authorize mobile and other operations in those bands. This development of service rules for mobile use of the millimeter wave (mmW) bands occurs in the context of the FCC's efforts to develop a regulatory framework that will help facilitate so-called Fifth Generation (5G) mobile services. Read the Notice of Proposed Rulemaking 


If a carrier has relinquished its ETC designation, send a copy of the relinquishment order to HC Orders within one week. If USAC does not receive a copy of the relinquishment order within one week, USAC will invoice the carrier for any support paid following the relinquishment. 


See a helpful list of common findings in High Cost Program audits. Avoid these and other common audit findings by 1) retaining appropriate and adequate documentation to support your filings, 2) reviewing all data thoroughly prior to submission, and 3) reporting data in a timely fashion. 



The High Cost Program team is here to help you! Visit the Contact Us page and let us know how we can help you.


FCC Claims VoIP Symmetry Rule Not Modified by 2015 Declaratory Ruling

On October 5, 2015, the FCC filed a Brief with the D.C. Circuit Court of the AT&T appeal of the 2015 Declaratory Ruling on the VoIP symmetry rule that was adopted in the USF/ICC Transformation Order. Read the Brief

FCC Announces OMB Approval of Revised RBE Form

On October 7, 2015, the FCC published a Notice in the Federal Register announcing it has received Office of Management and Budget approval for a revision of currently approved information collection associated with FCC Form 5620. This form will be used by provisionally selected winning bidders for Rural Broadband Experiments to demonstrate they have the technical and financial qualifications to successfully complete the proposed project within the required timeframes. Read the Notice

FCC Releases Alternative Connect America Cost Model and Results

On October 8, 2015, the FCC released the Alternative Connect America Cost Model (A-CAM) version 2.0 and illustrative results for potential use in rate-of-return areas. Read the Public Notice

FCC Approves Frontier Communications Compliance Plan

On October 9, 2015, the FCC released a Public Notice (DA 15-1162) approving Frontier Communications' compliance plan. Previously, the FCC conditionally granted forbearance to price cap carriers from the "Cost Assignment Rules" that generally require carriers to assign costs to build and maintain the network, and revenues from services provided, to specific categories, conditioned on FCC approval of the compliance plan. Read Public Notice

FCC Meeting: USTelecom, et al. Discuss FCC's Bifurcated Approach for RLEC Universal Service Fund Reform

On September 30, 2015, USTelecom, NTCA, ITTA, WTA, Moss Adams, and Alexicon met with FCC staff to discuss the September 25, 2015, letter filed by USTelecom, et al. and the status of industry efforts to develop technical assumptions for a bifurcated approach to current rate-of-return universal service support mechanisms. Read the summary

FCC Meeting: ATA and GVNW Discuss Alaska Plan for High Cost Program Support

On September 28-30, 2015, Alaska Telephone Association members and GVNW Consulting met with FCC staff to discuss the Consensus Alaska Plan for distributing High Cost Program support in Alaska over the next ten years. They provided maps (included in the summary) demonstrating the development of middle mile facilities in Alaska and said it is crucial to adopt the Alaska Plan to enable providers to take advantage of developing middle-mile facilities to deliver broadband to end users. Read the summary

Alaska Telephone Association, 9/8/2015


FCC Meeting: Windstream Discusses Connect America Fund Phase II Deployment Procedures 

On October 6, 2015, Windstream met with FCC staff to discuss the procedures, set forth in the FCC's December 2014 Connect America Fund Order, by which a price cap carrier may elect to deploy to at least 95 percent, but less than 100 percent, of the funded locations in a state in which the carrier has accepted model-based support. Read the summary

FCC Meeting: Gila River and NTTA Discuss Tribal Broadband Factor

On October 13, 2015, Gila River Telecommunications and the National Tribal Telecommunications Association met with FCC staff to discuss the inclusion of a Tribal Broadband Factor to target additional support to Tribal lands for infrastructure investment. Read the summary

FCC Meeting: FairPoint Discusses Connect America Fund Phase I and II Transition

On October 15, 2015, FairPoint spoke with FCC staff to discuss the transition from Connect America Fund Phase I to Connect America Fund Phase II. See the presentation

FCC Filing: USTelecom, et al Update Concepts on FCC Bifurcated Approach for Universal Service Fund Reform

On September 25, 2015, USTelecom, NTCA, ITTA, and WTA filed a letter revising and updating concepts outlined in their August 10, 2015, ex parte on the FCC's potential use of a bifurcated approach to cost recovery as part of universal service reforms. Read the letter

FCC Filing: ITTA, USTelecom, and WTA Update Broadband Build-Out Methodology for A-CAM

On October 2, 2015, ITTA, USTelecom, and WTA filed a letter updating the broadband build-out requirement methodology filed by ITTA on June 29, 2015. Read the letter

FCC Filing: ITTA, NTCA, USTelecom, and WTA Update Proposed Build-Out Milestones for A-CAM

On October 2, 2015, ITTA, NTCA, USTelecom, and WTA filed a letter providing their consensus recommendations on processes for implementing a voluntary model-based plan for rate-of-return carriers to deploy broadband to unserved customers. Read the letter

FCC Filing: NRECA and UTC Offer Suggestions on Connect America Fund Phase II Bidders Technical Qualifications

On October 5, 2015, the NRECA and the Utilities Telecom Council filed a letter on the Connect America Fund Phase II competitive bidding procedures. Read the letter

FCC Filing: FairPoint Seeks Clarification on Connect America Fund Phase I and II Transition Date

On October 7, 2015, FairPoint filed a letter seeking clarification of the FCC's intention on the transition from Connect America Fund Phase I to Connect America Fund Phase II. Read the letter

FCC Filing: Hughes Files Paper Exploring Universal Service Subsidies for Broadband

On October 9, 2015, Hughes Network Systems filed a letter attaching a draft paper entitled "The Economics of Universal Service: An Analysis of Entry Subsidies for High Speed Broadband" by Andre Boik of the University of California. Read the letter and academic paper

FCC Filing: NRECA Supports CFC Petition for Waiver of Bank Eligibility Requirement for RBE

On October 21, 2015, NRECA sent a letter to Chairman Wheeler to express support for the inclusion of the National Rural Utilities Cooperative Finance Corporation as a qualified provider of letters of credit for the Rural Broadband Experiments program and the planned Connect America Fund Phase II reverse auction. Read the letter

FCC Reply: Alteva Files Reply on RLEC Study Areas With 100 Percent Competitive Overlap

On September 28, 2015, Alteva filed a reply on the FCC's proposed methodology for determining rate-of-return carrier study areas subject to 100 percent overlap with unsubsidized competitors in a Public Notice (DA 15-868), released July 29, 2015. Alteva stated that the Comments, together with the additional information provided in this Reply, validates the FCC's concerns that the partial information available to it from FCC Form 477 filings provides insufficient evidence as to whether the FCC's Rules authorize the cessation of universal service support to certain carriers. Read the reply

Broadband Essential Infrastructure for Communities

On September 23, 2015, Jeff Hawn reported in RCR Wireless News that President Obama's Broadband Opportunity Council released its 40-page report that declares, "Today, broadband is taking its place alongside water, sewer and electricity as essential infrastructure for communities." Read the article

Universal Broadband: Whose Responsibility Is It?

On October 2, 2015, Colin Wood reported in Government Technology on who should be responsible for ensuring that every American has access to broadband internet, according to ten government, industry, and nonprofit representatives. Read the article

Grants Available in Eastern Kentucky for Broadband Expansion

On October 7, 2015, Brad Bowman reported in The State Journal that Kentucky's broadband initiative, KentuckyWired, should bring high-speed Internet access to every county in the state by 2018. In addition, eastern Kentucky's Appalachian region will get one of the first upgrades it’s had since its inception. Read the article

NASA Gets Ready to Test Broadband from Space

On October 13, 2015, David Nield reported in Tech Radar that NASA's compact CubeSats have phoned home to confirm they're in orbit and ready to start communicating with Earth. That means that the space agency can begin testing the viability of getting broadband to and from space. Read the article


High Cost Program


November 2015