On December 30, 2014, the Federal Communications Commission issued the last update of the year to its Frequently Asked Questions (FAQs) about its Special Access Data Collection. See our blogs dated 10/21/14, 11/5/14, 11/17/14, 11/25/14, 12/9/14, 12/15/14 and 12/22/14 . 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, the due dates are as follows:
- January 29, 2015, for large businesses with more than 1,500 employees as measured at the parent company level; and
- February 27, 2015, for other entities required to provide data and information in response to the data collection (i.e., entities with 1,500 or fewer employees).
The following are the new questions added December 30, 2014.
Competitive Provider Questions (Section II.A)
3. If I answer “no” to Questions II.A.2 or II.A.2.a, and therefore am not required to answer the remaining II.A and II.D questions, what should I upload to the remaining II.A. and II.D questions which populate the Essay Upload section of the web portal? (Question II.A.2)
If you answered “no” to question II.A.2 or II.A.2.a, then you are not required to respond to the remaining questions in II.A or the questions in II.D. See Question II.A.2. However, the Special Access Web Portal was designed to automatically populate the Essay Uploads with Questions II.A.5, 8, 10-11, 18-19, II.D.1-2. Filers will receive an error message if they do not upload a document to the Confidential and Highly Confidential areas of the “Essay Questions Upload Files” area. In this case, the filer must upload a document to the Confidential and Highly Confidential areas but these documents can simply state that the question is nonapplicable (N/A). In the web portal “Database Upload” area, the filer will upload their database container but only need to load data for Table II.A.1 and Table II.A.2 but not need for any other fields or tables.
5. Do I need to report “intermediate transport,” i.e. “middle mile” interoffice transport? (Questions II.A.3-5, II.A.12)
Questions II.A.3-4 capture “last mile” facilities so in response to these questions you would not need to report intermediate, i.e. “middle mile” transport. In Question II.A.5, non-cable Competitive Providers must show the fiber routes that constitute their network, including the “last-mile” and “middle-mile” transport fiber network, whereas Competitive Providers that are cable companies operating within their local franchise areas, must report their “middle mile” interoffice transport network but not “last mile” fiber routes. Question II.A.12 requests billing information for transmission paths that are sold for the provision of a standalone Dedicated Service. By using the term “transmission paths,” Question II.A.12 is not limited to Locations with Connections, i.e., “last-mile” facilities, reported in response to Question II.A.4 but also includes dedicated interoffice transport facilities, i.e. intermediate transport.
7. Latitude and longitude request asks for four digits after the period, but it should end in either a 0 or 5 versus using a more accurate ending digit? (Table II.A.4)
Enter values in decimal degrees to the nearest ±0.0005, i.e., each coordinate must end in #.###0 or #.###5. So if the latitude is 37.74195 you would enter this as 37.7420; if the latitude is 37.74112 you would enter this as 37.7410. See Instructions - Pages 12-13.
8. What should I enter in the bandwidth fields if the Location type is unknown? (Table II.A.4)
If the type of Location, i.e. “Loc_type field,” is “unknown” you will enter information for total bandwidth in the “Sold_bandwidth_total” field but you may enter “0” for the following fields:
Form 477 Filer Certification (Section II.G)
4. When do I need to submit my corporate letter identifying FRNs in ECFS if I am filing both a Streamlined Certification for certain FRNs and a Full Website submission for other FRNs?
You can submit two separate submission packages, one for your Affiliates filing Streamlined Certifications and one for your Affiliates filing Full Website submissions. As explained in the Instructions, the ultimate parent/holding company or controlling entity must separately file a letter in ECFS in WC Docket No. 05-25 identifying its FRN and the FRN and name of all of its subsidiaries that are separately filing responses to this data collection; send a copy of this letter via email to SPADCOutreach@fcc.gov. For the Streamlined Certifications, you should file the corporate letter identifying FRNs in ECFS for those filers covered by the submission by December 15, 2014. For Full Website submissions, you should file the corporate letter identifying FRNs in ECFS for those filers covered by the submission by the appropriate deadline, i.e. January 29, 2015 for businesses with more than 1,500 employees that are required to respond to the special access data collection and February 27, 2015 of businesses with 1,500 or fewer employees that are required to respond to the special access data collection. See Order Extending Deadlines for Special Access Data Collection.
5. How do I file at the parent/holding company-level if some of my Affiliates are filing Streamlined Certifications and others are filing Full Website submissions?
You can submit two separate submission packages for your Affiliates filing Streamlined Certifications and Full Website submissions. You will log in to the Special Access Web Portal under separate FRNs, one FRN for the Streamlined Certifications and one FRN for the Full Website submission. The corporate letters filed in ECFS for the Streamlined Certification and Full Website submission will link the ultimate parent/holding company or controlling entity FRN and the FRN and name of all of its subsidiaries that are separately filing responses to this data collection.
Special Access Web Portal
“Filer Identification” Page
14. Who do I address my letter identifying the parent/holding company or controlling entity FRN and subsidiary FRNs and names that are separately filing responses? (Instructions – Page 8)
Parties can either submit a single response reporting aggregate information at the ultimate parent/holding company level for all subsidiaries, affiliates, and intermediate holding companies or submit separate responses for individual subsidiaries, affiliates, and intermediate holding companies. If filing separate responses, identify the name and FRN of the filer’s ultimate parent/holding company or controlling entity (Instructions – Pages 7-8) The ultimate parent/holding company or controlling entity must separately file a letter in the Commission’s Electronic Comment Filing System (ECFS) in WC Docket No. 05-25 identifying its FRN and the FRN and name of all of its subsidiaries that are separately filing responses to this data collection; send a copy of this letter via email to Craig Glenn at Craig.Glenn@fcc.gov. Please address the letter to Marlene H. Dortch, Secretary, Federal Communications Commission, 445 12th Street, SW, Washington, D.C. 20554.
“Essay Uploads” Page
20. What should I file in the “Confidential” section for the fiber route maps? (Question II.A.5)
Consistent with the Protective Order, you may upload a document with the stamp “REDACTED – FOR PUBLIC INSPECTION.” You must upload a document in the Confidential and Highly Confidential sections or you will receive an error message.