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Posted by Amy Gross on 11/18/14 8:41 AM

Special Access Data Collection

On Friday, the Federal Communications Commission updated its Frequently Asked Questions (FAQs) about its Special Access Data Collection. See our previous Blogs posted 10/21/14 and 11/5/14. As before, the document does not indicate what has changed. We compared the documents and identified the items below as “new.” We’ve included the name of the FAQ section that changed as well as the number of the specific new question(s).

 

As a reminder, although the secure web portal interface, Version 1.0, at https://specialaccessfiling.fcc.gov/spadc/login has been activated, as of the date of this blog only the essay portions of the data collection can be viewed and completed at this time. The database container that parties will download from the web portal and use to load and deliver certain other data, e.g., location and pricing data, is undergoing final testing and is not yet available.

 

The following are the new questions added November 14, 2014:

 

Exemptions from Responding

2. Are small Providers of Dedicated Services exempted from responding to the collection?

No.

 

5. How is the $5 million threshold calculated for determining whether a filer is a Purchaser for purposes of the collection (e.g., when dealing with a holding company consisting of various subsidiaries)?

Parties can either submit a single response reporting aggregate information at the ultimate parent/holding company level for all subsidiaries and intermediate holding companies or submit separate responses for individual subsidiaries, and intermediate holding companies. When dealing with a holding company consisting of subsidiaries, the $5 million threshold is calculated at the holding company level even if the parent decides to file separate responses for each subsidiary or operating unit. For example, ultimate Parent Company A directly owns Subsidiary A and Subsidiary B, each subsidiary purchased $2.6 million in Dedicated Services in price cap areas for 2013. The company as a whole is considered a Purchaser for purposes of the collection because its expenditures in the aggregate exceed $5 million. The company can either submit one response at the parent company level or file two separate responses, one for Subsidiary A and one for Subsidiary B. For additional information, see the data collection Instructions – Pages 7-8. Additionally, the FCC has prepared a decisional tree diagram to help you determine whether you are required to respond to the collection which is available by clicking here.

 

Definitions

2. Does the definition of Connection include unlit dark fiber?

A Connection merely has to have the capability of being used to provide a Dedicated Service for purposes of the data collection, which captures Connections using unlit dark fiber.

 

3. Are Synchronous Optical NETwork (SONET), Automatic Teller Machine (ATM) and frame relay services considered a Circuit Based Dedicated Service (CBDS) or a Packet Based Dedicated Service (PBDS) for purposes of the collection?

For purposes of the data collection, SONET, ATM and frame relay services are treated as PBDS.

 

Competitive Provider Questions (Section II.A)

1. Are companies that access dark fiber pursuant to a non-IRU agreement but provide Dedicated Services to End Users and do not own or use UNEs have to respond to Section II.A?

The respondent is only required to respond to Questions II.A.1-2.

 

3. How do we report Locations that do not have U.S. Postal Service addresses or where we FCC Special Accessdo not know the geocode (i.e., latitude and longitude) to the requisite degree of accuracy? (Questions II.A.4(b)-(c), II.A.7)

If you have entered the geocode for the Location (i.e., latitude and longitude), then you do not need to provide the situs address for the Location. If you do not know the actual address for the Location or the geocode with the requisite degree of accuracy, then you may either enter the closest nearby address to the Location and/or estimate the geocode for the Location.

 

6. What do I need to report in the database container if I have submitted only loosing or unsuccessful bids for Requests for Proposals (RFPs)? (Question II.A.11)

In Question II.A.11, if you have only submitted loosing or unsuccessful bids for RFPs, in order to complete II.A.11 for the data container to avoid an error message, type “Not Applicable” in each field following “RFP_Number,” and provide an explanation in the Explanatory Attachment.

 

7. For the circuit ID, who is the entity that purchased the elements in common for a

particular circuit? (Question II.A.12(d))

The circuit ID common to all elements purchased in common for a particular circuit refers to what was purchased by the Competitive Provider’s customer.

 

8. How do we report bundled billing components? (Question II.A.14)

Question II.A.14 does not require you to use the ILEC-centric diagram and descriptions to assign billing codes. As set forth in Question II.A.14(c), “[i]f none of the possible entries describes the circuit element, enter a short description.” This allows you to create your own unique billing codes and provide your own description as to what a particular code relates to.

 

9. Does a company that sells unlit dark fiber have to report the associated Revenue?

(Questions II.A.15-17)

No, only Revenues from the provision of Dedicated Services.

 

ILEC Questions (Section II.B)

1. How do we report Locations that do not have U.S. Postal Service addresses or where we do not know the geocode (i.e., latitude and longitude) to the requisite degree of accuracy? (Questions II.B.4(b)-(c))

If you have entered the geocode for the Location (i.e., latitude and longitude), then you do not need to provide the situs address for the Location. If you do not know the actual address for the Location or the geocode with the requisite degree of accuracy, then you may either enter the closest nearby address to the Location and/or estimate the geocode for the Location.

 

2. How do I report “past due” billing balances on invoices? (Table II.B.4)

To the extent “past due” balances can be separated from the bills, they can be excluded from Table II.B.4. If the amounts cannot be excluded from the bill, but can be identified, they should be identified as such using a “Billing_Code” field that links to Table II.B.6.

 

3. How do I report “monthly prorated” billing information? (Table II.B.4)

To the extent that the billed amount can be separated and identified (using Billing Codes that link to Table II.B.6) as “prior-month prorated” charges, you may do so using separate line items under the unique Circuit ID. If these charges cannot be separately broken out from the billed amount, they may all be included as a single amount under the “Billed” amount.

 

4. How do I report billing information for customers in arrears? (Table II.B.4)

To the extent that the billed amount can be separated and identified (using Billing Codes that link to Table II.B.6) as “arrears” charges, you may do so using separate line items under the unique Circuit ID. If these charges cannot be separately broken out from the billed amount, they may all be included as a single amount under the “Billed” amount.

 

5. How do I report in-cycle adjustments as line items on customer’s bill? (Table II.B.4)

Companies are only required to report in-cycle adjustments as line items on the bill if they were originally billed as such. The adjustments should appear in Table II.B.4 as a separate observation with the corresponding Circuit ID for which the adjustment applies. The observation in the table containing the information on the adjustment should also include a Billing Code describing it as such and linking it to Table II.B.6. If the adjustments were not billed as separate line items, or if the adjustments apply to multiple Circuit IDs, the adjustments should be reported in Table II.B.5.

 

6. In creating a separate observation for the same circuit identifier common to all circuit elements purchased in common for a particular circuit (“Circuit_ID” field), what field do we place the in-cycle adjustment for a monthly recurring charge? (Table II.B.4)

You may enter the in-cycle adjustments for monthly recurring charges in the “Initial_NRC” and “Initial_MRC” fields and the “Total_Billed” fields for that same, newly-created observation, such that once all the “Total_Billed” amounts are summed over all observations (i.e., circuit elements) with the same “Circuit_ID,” the summed amount should equal the total end charge for the circuit in that month, including all in-cycle adjustments. If you prefer, you can simply put the charges in the “Billed” and “Total_Billed” fields and place zeros in the “Initial_NRC” and “Initial_MRC” for those observations.

 

Purchasers – mobile wireless service provider” Questions (Section II.E)

1. How do we report Locations that do not have U.S. Postal Service addresses or where we do not know the geocode (i.e., latitude and longitude) to the requisite degree of accuracy? (Questions II.E.2(b)-(c))

If you have entered the geocode for the Location (i.e., latitude and longitude), then you do not need to provide the situs address for the Location. If you do not know the actual address for the Location or the geocode with the requisite degree of accuracy, then you may either enter the closest nearby address to the Location and/or estimate the geocode for the Location.

 

Form 477 Filer Certification (Section II.G)

3. Can I certify at the holding company level or do I need to break it out by subsidiaries?

You have the option of filing the certification at the holding company-level or individually by subsidiary.

 

Special Access Web Portal

5. Does the parent company of a subsidiary or affiliate that is otherwise required to respond to the collection need to apply for an FRN is they do not have one?

Yes, the parent company will need to register for an FRN in order to respond to the collection.

 

 

Topics: FCC, wireless, special access, featured post, form 477

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