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Posted by Amy Gross on 11/25/14 7:46 AM

#SpecialAccessOn Friday, the Federal Communications Commission once again updated its Frequently Asked Questions (FAQs) about its Special Access Data Collection. See our blogs dated 10/21/14, 11/5/14 and 11/17/14. As before, the document does not indicate what changed. To assist our clients, we again 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 21, 2014.

 

General


10. Does the collection capture intrastate and interstate billing information?

Yes. The Commission has stated its intent to collect data on interstate and intrastate special access services and special access services offered via a state-level tariff or state approved contract. Data Collection Order, 27 FCC Rcd 16318, 16327, para. 19 (2012). For purposes of the collection, Revenues are defined as intrastate and interstate billed amounts and Tariff means intrastate or interstate rates filed by common carriers. See Data Collection Definitions.

 

Who must respond to the collection?

5. Am I required to respond to the collection if the ILEC operating in my study area

was not subject to price cap regulation until 2014?

No. The scope of the data collection covers price cap areas. Most of the questions in the data collection ask for data, e.g., Locations with Connections and billing information, for calendar 2013, giving the FCC a snapshot in time. Since 2013, the FCC has granted one petition to convert three ILECs to price cap regulation. See CenturyLink Petition for Conversion of Average Schedule Affiliates to Price Cap Regulation and for Limited Waiver Relief, WC Docket No. 14-23, Order, 29 FCC Rcd 5140 (WCB 2014). The three ILECs are affiliates of CenturyLink – i.e., CenturyTel of Chester, Inc., CenturyTel of Potsville, Inc., and CenturyTel of the Midwest-Wisconsin (Wayside), and collectively have less than 6,000 access lines. With respect to these converted price cap areas, Providers and Purchasers are not required to respond to the collection.

 

9. Am I required to report the U.S. portion of an international circuit?

Yes, filers are only asked to report the U.S. portion of a circuit, not the non-U.S. portion of the circuit.

 

Definitions

3. Does a Dedicated Service include mixed DS1s that include elements with a capacity below a DS1?

Filers are only asked to report the Dedicated Services component so you would not need to report information on elements with capacity below a DS1, i.e. that does not meet the capacity for Dedicated Services as defined in the collection. To the extent you can separately identify as part of a bundled service the Revenues or expenditures associated with the sale or purchase of a Dedicated Service, report those Revenues or expenditures.

 

4. Are entities that provide dark fiber considered Providers for purposes of the filing

requirement?

Yes. Entities that provide unlit dark fiber are captured by the collection as Providers. The definition of Competitive Provider includes entities that either provide a Dedicated Service or a Connection over which a Dedicated Service could be provided. 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. However, entities that provide dark fiber should not report Connections which they have leased pursuant to an IRU (unless there are separate fiber strands to the Location that the entity owns and has not leased as an IRU).

 

Competitive Provider Questions (Section II.A)

3. Which questions do I need to respond to if I own unlit dark fiber that terminates to a

Location? (Questions II.A.3-4)

Unlit dark fiber would be reported as a Location with Connection in response to Questions

II.A.3-4. However, you would not need to report billing information related to that facility

because it is not being used to provide a Dedicated Service. You must report the Location

but in the various bandwidth fields you may enter a null value of “0.”

 

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

2. Do the Purchaser questions capture Dedicated Services provided as Unbundled Network Elements (UNEs)? (Section II.E)

Yes. Dedicated Services include DS1s and DS3s, whether or not they are sold as UNEs. To the extent you can separately identify as part of a bundled service the expenditures associated with the purchase of a Dedicated Service, report those expenditures.

 

Purchasers – Other” Questions (Section II.F)

3. Do the Purchaser questions capture Dedicated Services provided as Unbundled

Network Elements (UNEs)? (Section II.F)

Yes. Dedicated Services include DS1s and DS3s, whether or not they are sold as UNEs. To the extent you can separately identify as part of a bundled service the expenditures associated with the purchase of a Dedicated Service, report those expenditures.

 

“Getting Started” Page

13. Why can’t I access the Full Website with my Internet Explorer browser?

The Full Website requires Internet Explorer (IE) 8 or higher. Users who have IE7 or lower should use a different web browser or upgrade to IE8 or higher in order to access the Full Website.

 

 

 

Download a Sample TMI Briefing

 

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Download a Sample Regulatory Digest

 

Topics: FCC, Special Access Data Collection, #specialaccess, UNEs

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