Special Access for Price Cap LECs R&O WC 05-25 DA 13-1909

Federal Communications Commission

DA 13-1909

Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Special Access for Price Cap Local Exchange
Carriers;
AT&T Corporation Petition for Rulemaking to
Reform Regulation of Incumbent Local Exchange
Carrier Rates for Interstate Special Access
Services

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WC Docket No. 05-25
RM-10593

REPORT AND ORDER
Adopted: September 18, 2013

Released: September 18, 2013

By the Chief, Wireline Competition Bureau:
TABLE OF CONTENTS
Heading

Paragraph #

I. INTRODUCTION.................................................................................................................................. 1
II. BACKGROUND.................................................................................................................................... 2
III. DISCUSSION ........................................................................................................................................ 8
A. Clarifying the Scope of the Data Collection .................................................................................... 8
1. Purchasers Subject to the Commission’s Jurisdiction ............................................................. 10
2. Price Cap Areas....................................................................................................................... 15
3. FCC Form 477 Filers Reporting Broadband Connections ...................................................... 16
B. Instructions – Data Specifications ................................................................................................. 19
1. Locations with Connections .................................................................................................... 20
a. Guidance on Capable Connections for Competitive Providers ........................................ 23
b. Guidance on Capable Connections for ILECs .................................................................. 28
2. Location Data .......................................................................................................................... 32
3. Mapping Requirements ........................................................................................................... 34
4. Billing Information.................................................................................................................. 46
5. Headquarters Information........................................................................................................ 47
6. Certain Questions Requiring Narrative Responses from Purchasers ...................................... 51
C. Modifications and Amendments to the Data Collection ................................................................ 53
D. Other Requests for Clarifications and Changes ............................................................................. 54
IV. PROCEDURAL MATTERS................................................................................................................ 55
V. ORDERING CLAUSES....................................................................................................................... 63
APPENDIX A – Instructions for Data Collection
APPENDIX B – Revised Data Collection

Federal Communications Commission
I.

DA 13-1909

INTRODUCTION

1.
On December 11, 2012, the Commission adopted the Special Access Data Collection
Order, requiring providers and purchasers of special access and certain entities providing “best efforts”
service to submit data, information and documents for a comprehensive evaluation of competition in the
special access market.1 In this Report and Order, we move forward in our efforts to review and ensure
that our special access rules work to promote access, competition and investment by finalizing the
comprehensive data collection. Specifically, pursuant to authority delegated by the Commission, we (1)
clarify the scope of the collection to reduce burden where doing so is consistent with our delegated
authority and will not impact the Commission’s ability to analyze the data; (2) provide instructions and
record format specifications for submitting information; and (3) modify and amend questions and
definitions contained in the collection. We will subsequently issue a public notice announcing the
deadline for submissions once approval for the collection is obtained as required by the Paperwork
Reduction Act of 1995 (PRA) from the Office of Management and Budget (OMB).2
II.

BACKGROUND

2.
On August 15, 2012, the Commission suspended, on an interim basis, its rules allowing
the grant of pricing flexibility for special access services in areas subject to price cap regulation.3 The
Commission took this step based on “significant evidence that these rules, adopted in 1999, are not
working as predicted, and widespread agreement across industry sectors that these rules fail to accurately
reflect competition in today’s special access markets.”4 To identify a replacement framework, the
Commission detailed a plan to collect data and information for a robust market analysis to gauge actual
and potential competition for special access services. There was ample support in the record for
“collecting additional data to inform our future actions.”5
1

See Special Access for Price Cap Local Exchange Carriers; AT&T Corporation Petition for Rulemaking to Reform
Regulation of Incumbent Local Exchange Carrier Rates for Interstate Special Access Services, WC Docket No. 0525, RM-10593, Report and Order and Further Notice of Proposed Rulemaking, 27 FCC Rcd 16318 (2012) (referred
to herein as either Special Access Data Collection Order or Special Access Data Collection FNPRM); AT&T Inc.
and BellSouth Corporation Application for Transfer of Control, WC Docket No. 06-74, Memorandum Opinion and
Order, 22 FCC Rcd 5662, 5677, para. 28 (2007) (AT&T/BellSouth Order) (“[S]pecial access is a dedicated
transmission link between two locations, most often provisioned via high-capacity circuits.”). The data collection
uses the term Dedicated Service, which is defined as a service that “transports data between two or more designated
points, e.g., between an End User’s premises and a point-of-presence, between the central office of a local exchange
carrier (LEC) and a point-of-presence, or between two End User premises, at a rate of at least 1.5 Mbps in both
directions (upstream/downstream) with prescribed performance requirements that include bandwidth-, latency-, or
error-rate guarantees or other parameters that define delivery under a Tariff or in a service-level agreement.” See
Appendix B, Definition of Dedicated Service. Dedicated Service includes regulated and unregulated “special
access” service and its functional equivalents. See Special Access Data Collection Order, 27 FCC Rcd at 16319,
para. 1 n.1 (defining special access). Dedicated Service does not include “best efforts” services, which are handled
separately in the data collection. See Appendix B, Definitions for Dedicated Service and Best Efforts Business
Broadband Internet Access Service. Unless stated otherwise, capitalized and italicized terms used in this Report and
Order refer to the defined terms in the data collection attached hereto. See id.
2

Public Law 104-13 (codified at 44 U.S.C. §§ 3501-3520).

3

Special Access for Price Cap Local Exchange Carriers; AT&T Corporation Petition for Rulemaking to Reform
Regulation of Incumbent Local Exchange Carrier Rates for Interstate Special Access Services, WC Docket No. 0525, RM-10593, Report and Order, 27 FCC Rcd 10557 (2012) (Pricing Flexibility Suspension Order).
4

Id. at 10558, para. 1.

5

See id. at 10605, para. 85.

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3.
On December 18, 2012, the Commission released the Special Access Data Collection
Order, outlining the data collection.6 Services covered by the collection include traditional special access
service (including DS1s and DS3s), Packet-Based Dedicated Service (PBDS) such as Ethernet, and Best
Efforts Business Broadband Internet Access Service to ensure a “clear picture of all competition in the
marketplace.”7 Those required to respond to the data collection include Providers and Purchasers of
special access services8 and certain entities providing Best Efforts Business Broadband Internet Access
Service.9 The geographic and temporal scope includes data on a nationwide basis for areas where the
Incumbent Local Exchange Carrier (ILEC) is subject to price cap regulation (i.e., price cap areas) with
the majority of the data from calendar years 2010 and 2012.10
4.
The general categories of data and information identified by the Commission for
collection are: market structure, pricing, demand, terms and conditions, and competition and pricing
decisions.11 Under each category, most of which would be collected from Providers, the Commission
highlighted the types of data and information covered. For example, market structure included, among
other things, data exclusively from Providers on facilities used to provide Dedicated Service, non-price
factors affecting deployment, collocations, and network maps.12 The pricing information included data
exclusively from Providers on the “quantities sold and prices charged for special access services, by
circuit element” and required ILECs to “list the form of price regulation that applies . . . on a wire-centerby-wire-center basis.”13 The demand data included not only information on the bandwidth of special
access sold and revenues earned by Providers but also on the expenditures made by Purchasers.14 The
terms and conditions section called for information and data from both Providers and Purchasers, seeking
details on topics such as the discounts and benefits associated with Tariff plans and the business rationale
for those plans.15 The Commission also sought information on Requests for Proposals and advertised and
marketed services to help evaluate competition and pricing decisions for special access services. Lastly,
the Commission described the coverage area and price information it sought to collect from entities
providing Best Efforts Business Broadband Internet Access Service.16 The Commission provided an
“initial version” of the questions and definitions for the collection as an appendix to the order.17
6

See Special Access Data Collection Order, 27 FCC Rcd at 16360, App. A.

7

Id. at 16326-27, paras. 16-19.

8

The Commission found “it necessary to obtain data from special access providers and purchasers of all sizes.” Id.
at 16327-28, para. 22. In reaching this conclusion, the Commission focused on how small providers could be a
“significant competitor in smaller areas,” citing filings by AT&T Inc. (AT&T) and Verizon in the proceeding. Id. at
16328, para. 22 n.51. The Commission said that “[c]ompetition in the provision of special access appears to occur at
a very granular level—perhaps as low as the building/tower” and so even a provider with at least fifty channel
terminations to end users could be significant. Id. at 16327-28, para. 22. Accordingly, the Commission declined to
exempt smaller providers of Dedicated Service from the collection.
9

Id. at 16327-28, para. 22 (exempting those entities with fewer than 15,000 customers and fewer than 1,500
business broadband customers).
10

Id. at 16328-31, paras. 23-29.

11

Id. at 16331, para. 30.

12

Id. at 16331-33, paras. 31-35.

13

Id. at 16333, paras. 36-37.

14

Id. at 16333-34, para. 38.

15

Id. at 16334, para. 39.

16

Id. at 16335-37, paras. 40-46.

17

Id. at 16331, para. 30.

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5.
The Commission plans to use the data collected for a one-time, multi-faceted market
analysis.18 The analysis will evaluate “how the intensity of competition (or lack thereof), whether actual
or potential, affects prices, controlling for all other factors that affect prices.”19 The analysis will include
“econometrically sound panel regressions . . . of the prices for special access on characteristics such as 1)
the number of facilities-based competitors (both actual and potential); 2) the availability of, pricing of,
and demand for best efforts business broadband Internet access services; 3) the characteristics of the
purchased service; and 4) other factors that influence the pricing decisions of special access providers,
including cost determinants (e.g., density of sales) and factors that deliver economies of scale and scope
(e.g., level of sales).”20 The Commission also plans to assess the reasonableness of terms and conditions
offered by ILECs for special access service.21 Once the data are obtained and analyzed, the Commission
will evaluate whether it is appropriate to make changes to its existing pricing flexibility rules to better
target regulatory relief in competitive areas and evaluate whether remedies are appropriate to address any
potentially unreasonable terms and conditions.22
6.
The Commission delegated authority to the Wireline Competition Bureau (Bureau) to
implement the data collection. The Commission’s delegation gives the Bureau authority to: “(a) draft
instructions to the data collection and modify the data collection based on public feedback; (b) amend the
data collection based on feedback received through the PRA process; (c) make corrections to the data
collection to ensure it reflects the Commission’s needs as expressed in [the Special Access Data
Collection Order]; . . . (d) issue Bureau-level orders and Public Notices specifying the production of
specific types of data, specifying a collection mechanism (including necessary forms or formats), and
set[] deadlines for response to ensure that data collections are complied with in a timely manner; and (e)
take other such actions as are necessary to implement [the Special Access Data Collection Order]. . .
consistent with the terms of [the Special Access Data Collection Order].”23
7.
After the release of the Special Access Data Collection Order, we received several
requests for clarifications and changes to the initial version of the data collection definitions and
questions; received comments through the PRA process; and met with several potential respondents to
discuss the data collection.24 We also reviewed the collection for improvements to achieve the robust
analysis proposed in the Special Access Data Collection FNPRM.25 In this Report and Order, consistent
with our delegated authority, we clarify the scope of the collection; provide instructions on how to

18

Special Access Data Collection FNPRM, 27 FCC Rcd at 16343-49, paras. 66-71.

19

Id. at 16346-47, paras. 68-69.

20

Id. at 16346, para. 68.

21

Id. at 16354-56, paras. 91-93.

22

Id. at 16352-56, paras. 80-93.

23

Special Access Data Collection Order, 27 FCC Rcd at 16340, para. 52.

24

See Information Collection(s) Being Reviewed by the Federal Communications Commission, Comments
Requested, 78 Fed. Reg. 9911 (Feb. 12, 2013) (announcing a 60-day period for to comment on the collection as part
of the PRA process). A list of the filings received is available in the Commission’s Electronic Comment Filing
System (ECFS) in WC Docket No. 05-25 and RM-10593. Consistent with our delegated authority, we reference the
PRA comments in making modifications, amendments, and clarifications to the data collection in this Report and
Order. See Special Access Data Collection Order, 27 FCC Rcd at 16340, para. 52. Allegations as to whether the
collection complies with the PRA are not addressed here however. We will address those allegations as part of the
PRA approval process.
25

See Special Access Data Collection FNPRM, 27 FCC Rcd at 16345-49, paras. 66-71.

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respond to the data collection questions; and provide a list of all modifications and amendments to the
data collection questions and definitions based on the feedback received and our further internal review.26
III.

DISCUSSION
A.

Clarifying the Scope of the Data Collection

8.
As established by the Special Access Data Collection Order, Providers and Purchasers
of special access services are required to respond to the data collection if they are subject to the
Commission’s jurisdiction under the Communications Act of 1934, as amended.27 In addition, the
Commission required entities providing Best Efforts Business Broadband Internet Access Services to
respond unless they have fewer than 15,000 customers and fewer than 1,500 business broadband
customers.28 The Commission limited the geographic scope of the collection to services provided and
purchased in price cap territories.29
9.
We have received several questions about the scope of the data collection. Parties have
asked: (1) who is required to file; (2) whether entities in rate-of-return areas must respond; and (3) how
the reference to FCC Form 477 (Form 477) filers reporting broadband connections in Section II.G of the
data collection affects the pool of respondents.30 We address these questions below.
1.

Purchasers Subject to the Commission’s Jurisdiction

10.
The Special Access Data Collection Order stated that Purchasers of Dedicated Service
must supply certain information as part of the data collection.31 A Purchaser is a Competitive Provider or
an End User, which is defined as a “business, institutional, or government entity that purchases a
communications service for its own purposes and does not resell such service.”32 In the collection,
Purchasers are generally required to report their expenditures for Dedicated Service under Tariff and nonTariff plans and provide details on the terms and conditions associated with those plans.33 This
information is useful in evaluating allegations of harmful, anticompetitive conduct and cross-checking the
information reported by Providers.34
11.
The term Purchasers is broadly defined in the Special Access Data Collection Order to
include “any entity subject to the Commission’s jurisdiction . . . that purchases special access services.”35
Read literally, that term encompasses a very broad range of entities that are consumers of Dedicated
26

See Appendices A (Instructions) and B (Revised Data Collection).

27

See Special Access Data Collection Order, 27 FCC Rcd at 16327, para. 20.

28

Id. at 16327, para. 22.

29

Id. at 16328, para. 23 (“If, however, a provider or purchaser prefers to provide data for all areas without
distinguishing between areas served by price cap LECs and rate-of-return LECs, it may do so.”).
30

Section II.G of the data collection adopted by the Commission states that if an entity is required to respond
because it reported broadband connections to end user locations in the Form 477 but is outside the scope of the
collection, then the entity must certify as such. See id. at App. A § II.G.
31

Special Access Data Collection Order, 27 FCC Rcd at 16327, para. 20.

32

See Appendix B, § I Definitions.

33

See id. § II.F. Purchasers that are mobile wireless service providers will provide additional information on their
cell site locations. Id. § II.E.1-2.
34

See Special Access Data Collection FNPRM, 27 FCC Rcd at 16355-56, paras. 92-93.

35

Special Access Data Collection Order, 27 FCC Rcd at 16327, para. 20.

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Services and, in that regard, are no different from consumers of Dedicated Services that are not subject to
our jurisdiction. For example, a package delivery service that purchases a DS-1 to operate its business
would be required to comply with the collection if it holds a private radio license for communications
with its drivers (and is therefore “subject to the Commission’s jurisdiction”). But if instead of holding its
own wireless license the same company purchases a commercial mobile radio service (CMRS) for those
communications, and does not otherwise engage in an activity that would cause it to fall within the
Commission’s jurisdiction, it would not be required to comply with the data collection. There are
potentially hundreds of thousands of license and authorization holders, information service providers, or
others that are “subject to the Commission’s jurisdiction” but otherwise are simply consumers of
Dedicated Services and are unfamiliar with, and perhaps completely unaware of, the Commission’s
requirements and proceedings involving the regulation of ILECs in price cap areas.
12.
For several reasons, we do not believe the Commission intended to capture these
consumers. First, including literally all entities subject to the Commission’s jurisdiction would result in
the non-uniform treatment of certain consumer categories; responses from manufacturers, banks, or
package delivery service providers that purchase Dedicated Service would turn on whether an entity in
that category just happened to engage in an unrelated activity that subjects it to the Commission’s
jurisdiction. Second, in describing the entities required to submit data in its Final Regulatory Flexibility
Analysis (FRFA), the Commission noted that Providers and Purchasers required to respond may include
“price cap regulated incumbent LECs, competitive LECs, interexchange carriers, cable operators, and
companies that provide fixed wireless communications services” in addition to some entities providing
“best efforts” services.36 We believe this statement largely describes the categories of entities from which
responses were anticipated by the Commission; this is also consistent with the Commission’s estimated
respondent pool of about 6,500—far fewer than the potentially hundreds of thousands of entities if the
definition of Purchasers were interpreted more broadly.37 Third, defining Purchasers more broadly will
not contribute substantially to the economic analysis. As proposed in the Special Access Data Collection
FNPRM, the analysis of the collected data will rely more heavily on the data obtained from Providers,
e.g., Locations served and prices charged at the circuit-level, than the limited information on terms and
conditions obtained from Purchasers.38 Although the data obtained from Purchasers will help to identify
harmful, anticompetitive conduct in the sale of Dedicated Service, it need not, and indeed cannot, be
comprehensive to serve this purpose.39 Finally, these consumers of Dedicated Service are unlikely to
respond with any additional information on terms and conditions that we would not otherwise obtain from
a smaller respondent pool and so the benefit of having a broader array of Purchasers respond is
outweighed by the burden. Clarifying the scope of Purchaser respondents is therefore appropriate.40
13.
Consistent with the Commission’s overall intent, we clarify that the definition of
Purchasers excludes from the collection entities that are subject to the Commission’s jurisdiction only
36

Id. at 16408-09, App. B, para. 70.

37

See Information Collection(s) Being Reviewed by the Federal Communications Commission, Comments
Requested, 78 Fed. Reg. 9911 (Feb. 12, 2013) (providing an initial estimate of 6,386 respondents).
38

See, e.g., Special Access Data Collection FNPRM, 27 FCC Rcd at 16346, para. 68 (proposing to undertake
econometric modeling to develop panel regressions on special access prices by taking into account, among other
things, the number of facilities-based competitors and the characteristics of purchased service).
39

See id. at 16355-56, paras. 92-93. Even though the mandatory collection does not comprehensively cover all
purchasers of special access, purchasers not subject to the collection will have an opportunity to provide data and
information, on a voluntary basis, to highlight for the Commission’s consideration any harmful, anticompetitive
conduct experienced in their purchase and use of special access services.
40

We note the Commission similarly excluded those “best efforts” providers with a small number of subscribers
from the collection because the excluded data “would not diminish the rigor of [the Commission’s] analysis.” See
Special Access Data Collection Order, 27 FCC Rcd at 16335-36, para. 44.

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because they fall within one or more of the categories listed below.41 These exclusions do not apply to
entities that hold licenses, authorizations or registrations under any other Part of the Commission’s rules
not listed below, or that provide a Dedicated Service or a Best Efforts Business Broadband Internet
Access Service in a price cap area.42


End Users that provide an information service;



Equipment authorization holders regulated under Parts 2 and 15 of the Commission’s
rules;



Accounting authorization holders in the maritime and maritime mobile-satellite radio
services regulated under Part 3 of the Commission’s rules;



Experimental radio authorization holders regulated under Part 5 of the Commission’s
rules;



Commercial radio operators regulated under Part 13 of the Commission’s rules;



Antenna structure registration holders regulated under Part 17 of the Commission’s rules;



Television and radio broadcasters regulated under Part 73 of the Commission’s rules;



Holders of authorizations issued pursuant to Part 74 of the Commission’s rules such as
experimental radio, auxiliary, special broadcast and other program distribution service
authorizations;



Maritime service authorization holders regulated under Part 80 of the Commission’s
rules;



Aviation service authorization holders regulated under Part 87 of the Commission’s rules;



Private land mobile radio service authorization holders regulated under Part 90 of the
Commission’s rules except for holders of authorizations under Part 90 for the provision
of point-to-point fixed microwave services and authorizations in the Wireless Broadband
Services frequency band, 3650-3700 MHz;



Personal radio service authorization holders regulated under Part 95 of the Commission’s
rules; and



Amateur radio service authorization holders regulated under Part 97 of the Commission’s
rules.

41

While we clarify the narrower scope of Purchasers, we decline to adopt the suggestions of Smith Bagley et al.
and NTCA—The Rural Broadband Association (NTCA) to exempt all small carriers, over which the Commission’s
jurisdiction extends completely, from the collection if they spend less than $5 million annually on special access or
purchase fewer than 50 special access connections in a relevant geographic area. See Smith Bagley PRA Comments
of Smith Bagley, Inc. et al, WC Docket No. 05-25, at 7 (filed Apr. 15, 2013) (Smith Bagley PRA Comments);
NTCA PRA Comments, WC Docket No. 05-25, at 12 (filed Apr. 15, 2013) (NTCA PRA Comments). The
Commission has already included Providers and Purchasers of “all sizes” in the collection. Special Access Data
Collection Order, 27 FCC Rcd at 16327-28, para. 22. The Bureau cannot therefore create a de minimis exception
for smaller Purchasers that is clearly inconsistent with the terms of the Commission’s order.
42

For example, an entity holding an earth station license issued under Part 25 of the Commission’s rules that also
has an experimental license issued under Part 15 (a listed exclusion category), is not excluded from the collection if
it purchased Dedicated Service in a price cap area during the relevant reporting periods. Likewise, an entity holding
an antenna structure registration under Part 17 (a listed exclusion category) is not excluded from the collection if it
provided a covered Best Efforts Business Broadband Internet Access Service in a price cap area.

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14.
These exclusions only apply to the categorically excluded entity and do not extend to
other entities within the same corporate structure or entities that are otherwise affiliated with the excluded
entity. For example, if an entity holding a television broadcast authorization is affiliated with a cable
company that provides Dedicated Service, the affiliated cable company must still respond to the data
collection even though the television broadcasting entity is not required to respond. In addition, for
clarity, we point out that these categorical exclusions do not include common carriers (wired or wireless),
mobile wireless service providers, cable system operators even if they only provide video program
services, international service providers, satellite service providers, or entities that hold authorizations
issued by the Federal Communications Commission (FCC) for the provision of fixed point-to-point
microwave services.
2.

Price Cap Areas

15.
The Commission is seeking data and information on the provision and purchase of
services in price cap areas “[b]ecause the focus of this proceeding is on the regulation of special access
services in price-cap territories.”43 While certain language in the Special Access Data Collection Order
has led to confusion on whether carriers in rate-of-return areas must respond, we clarify that entities
providing or purchasing Dedicated Service only in areas where the ILEC is subject to interstate rate-ofreturn regulation are not required to provide data and information in response to the data collection.
Likewise, we clarify that an entity providing Best Efforts Business Broadband Internet Access Service
only in areas where the ILEC is subject to interstate rate-of-return regulation is not required to submit
data in response.44 A map depicting the study areas where the ILECs are subject to price cap and rate-ofreturn regulation is available on the Commission’s website; the map will assist entities in determining
whether or not they are providing or purchasing services in price cap areas.45 In addition, we recognize
that over the years some ILECs have converted to price cap regulation and further clarify that the data
collection covers Dedicated Service provided or purchased and Best Efforts Business Broadband Internet
Access Service provided if the ILEC was subject to price cap regulation in the area at any point during the
relevant reporting periods, 2010 or 2012.46

43

See Special Access Data Collection Order, 27 FCC Rcd at 16328, para. 23 (discussing the geographic scope of the
collection). Carriers currently subject to price cap regulation are the ACS Companies; the Ameritech Operating
Companies; BellSouth Telecommunications, Inc.; CenturyTel Operating Companies; Cincinnati Bell Telephone;
Consolidated Communications; Embarq Local Telephone Companies; Frontier Telephone Companies; Hawaiian
Telecom, Inc.; Illinois Consolidated Telephone Company; Micronesian Telecommunications, Corp.; Nevada Bell
Telephone Company; Pacific Bell Telephone Company; Puerto Rico Telephone Company; Qwest Corporation;
Southern New England Telephone; Southwestern Bell Telephone; SureWest Telephone; The Fairpoint Telephone
Companies; The Verizon Telephone Companies; Virgin Islands Telephone Company and Windstream Telephone
System.
44

If an entity provides or purchases Dedicated Service in both price cap and rate-of return areas, then it must only
report data and information relevant to the areas where the ILEC is subject to price cap regulation. However, for
administrative ease, Providers and Purchasers may submit data that include both price cap and non-price cap areas
if they prefer. See Special Access Data Collection Order, 27 FCC Rcd at 16328, para. 23.
45

See Map: Regulatory Type at the Holding Company Level by Study Area, FCC,
http://www.fcc.gov/maps/regulatory-type-holding-company-level-study-area (last visited Sept. 9, 2013). We note
that we are currently updating this map based on a collection of study area boundaries. If the new study area
boundary data are not available to respondents in time for them to take into account in formulating responses to the
special access data collection, we will consider reliance on the currently available study area boundary data to be
reasonable.
46

A Provider must report data on its operations for the entire year for both 2010 and 2012 if the ILEC was subject to
price cap regulation at any point during 2010 or 2012.

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FCC Form 477 Filers Reporting Broadband Connections

16.
In delegating authority to the Bureau, the Commission noted that “[t]he delegation
includes the authority to require entities subject to the Commission’s jurisdiction to certify whether or not
they are special access providers, entities that provide best efforts business services, or purchasers for the
purposes of this data collection.”47 In Section II.G of the initial version of the data collection attached to
the Special Access Data Collection Order, the Commission stated that “[i]f you must respond to this data
collection because you filed the FCC Form 477 in 2012 to report the provision of ‘broadband connections
to end user locations’ but are not covered by the scope of the collection “then indicate as such . . . and
complete the certification accompanying this data collection.”48
17.
Smith Bagley et al. in their joint comments to the Commission as part of the PRA process
highlighted the reference to the Form 477 in Section II.G and requested a clarification as to which entities
must submit data and which entities must only certify that they are not required to submit data and
information in response to the collection.49 We therefore clarify that all entities required to submit the
Form 477 because they provide broadband connections to end user locations in price cap areas must—at a
minimum—submit a certification in this special access data collection. Specifically, entities required to
report broadband connections to end user locations on the Form 477 must certify whether they are a
Provider, Purchaser, a covered entity providing Best Efforts Business Broadband Internet Access Service,
or none of the above as part of this data collection.50 If the Form 477 filer is also a Provider, Purchaser,
or a covered entity providing Best Efforts Business Broadband Internet Access Service as defined in this
collection, then it must also respond to all the relevant questions for that category of entity. If the Form
477 filer does not fall within any of those categories, e.g., an entity only providing Best Efforts Business
Broadband Internet Access Service in interstate rate-of-return areas and not purchasing Dedicated
Service, then the Form 477 filer need not submit any information or data beyond its certification.51
18.
The intent of this certification is to ensure the subsequent market analysis of the collected
data comprehensively includes all Providers with Connections to Locations that are owned, leased under
an Indefeasible Right of Use (IRU) agreement, or in the case of Competitive Providers, obtained as an
Unbundled Network Element (UNE) to provide a Dedicated Service, and covered entities providing Best
Efforts Business Broadband Internet Access Service.52 We estimate that most, if not all, of these
Providers and covered entities providing “best efforts” services are required to file the Form 477 based on
that form’s reporting criteria.53 Therefore, we can use the list of Form 477 filers as a point of reference to
47

See Special Access Data Collection Order, 27 FCC Rcd at 16381-82, para. 52 n.111.

48

See id. at 16381-82, App. A § II.G. In this Report and Order, we are further modifying this language so that more
specifically, filers who were required to report broadband connections to end user locations on the Form 477 due on
March 1, 2013, must, at a minimum, file a certification in response to the data collection. See infra Section III.C;
Appendix B § II.G.
49

See Smith Bagley PRA Comments at 12-13.

50

This clarification merely implements the process provided in the data collection adopted by the Commission and
is otherwise consistent with the Bureau’s delegation of authority. See Special Access Data Collection Order, 27
FCC Rcd at 16318, para. 52 n.111.
51

More details on the electronic certification process are provided in the attached instructions. See Appendix A.

52

See Special Access Data Collection FNPRM, 27 FCC Rcd at 16345-49, paras. 66-71 (proposing a one-time, multifaceted market analysis of the collected data).
53

For example, entities reporting broadband connections on the Form 477 are “incumbent and competitive local
exchange carriers (LECs), cable system operators, fixed wireless service providers (including “wireless ISPs”),
terrestrial and satellite mobile wireless service providers, BRS providers, electric utilities, municipalities, and other
entities.” The Form 477 filers include providers of broadband connections to non-residential locations. The transfer
rate covered by the Form 477, exceeding 200 kbps in at least one direction, captures the minimum bandwidth
(continued….)

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ensure that appropriate Providers respond to the collection. For example, if an entity filed the Form 477
but did not respond to the collection, there is a strong likelihood it has data and information relevant to the
collection. Moreover, to the extent Form 477 filers not covered by the scope of the collection have to
certify as such, this burden is minimal.54 Thus, the Form 477 certification requirement furthers the
Commission’s goal of conducting a comprehensive data collection in a minimally burdensome way.
B.

Instructions – Data Specifications

19.
Attached to this Report and Order is a comprehensive set of instructions with format
specifications for responding to the data collection.55 These instructions address many requests for
clarification received from parties since the release of the Special Access Data Collection Order. The
more significant clarifications contained in the instructions are discussed below.
1.

Locations with Connections

20.
Providers are required to report Locations with Connections to help the Commission
identify: (1) facilities that can, or could, be used to provide a Dedicated Service; and (2) the demand for
Dedicated Service.56 Regardless of what market analysis we adopt, this information is critical in
determining how and where competition for special access services exists or is likely to develop.57
21.
A Connection is defined as a communication path between a Location and a Provider’s
network that provides a Dedicated Service or is “capable” of providing a Dedicated Service.58 By design,
only Connections to non-residential Locations are reported.59 Special access services are used by
businesses, schools, libraries, and other institutions of state and local government.60 Including facilities
and services provided to residences will not help, and may distort, our analysis of the special access
market. Therefore, Providers do not report Connections to residential locations.
(Continued from previous page)
connections at issue in this collection, i.e., at least 1.5 megabits per second (Mbps) in both directions. The Form 477
filers also include providers using the same types of connections sought in the collection, e.g., connections to end
user locations that are owned, obtained as UNEs, or leased as special access lines. See Instructions for Local
Telephone Competition and Broadband Reporting (FCC Form 477), Filing due 9/1/2013 (reporting data as of
06/30/2013) at 2 (Form 477 Instructions); Special Access Data Collection Order, 27 FCC Rcd at 16318, App. A., § I
Definitions, Questions II.A.3-4; II.B.2-3.
54

The Commission included the potential burden associated with this certification for Form 477 filers in its
published estimate for the proposed information collection. See Information Collection(s) Being Reviewed by the
Federal Communications Commission, Comments Requested, 78 Fed. Reg. 9911 (Feb. 12, 2013).
55

See Appendix A. While the attached instructions are largely in final form, we may make further adjustments, as
necessary, to implement the data collection. We will make the final version of the instructions available on the
Commission’s website well in advance of the deadline for responding to the collection.
56

See Appendix B. Questions II.A.3-4, II.B.2-3.

57

See Special Access Data Collection FNPRM, 27 FCC Rcd at 16345-51, paras. 66-79 (proposing a one-time, multifaceted market analysis using the data collected).
58

See Appendix B (“Connection means a wired ‘line’ or wireless ‘channel’ that provides a dedicated
communication path between a Location and the first Node on a Provider’s network. . . . A Connection must have
the capability of being used to provide one or more Dedicated Services; however a Connection can be used to
provide other services as well. For example, a dedicated communication path that is currently being used to provide
a mass market broadband service but has the capability to provide a Dedicated Service is considered a Connection
for the purpose of this data collection.”).
59

A Location is where an End User is connected; an End User means a business, institutional, or government entity
that purchases service for its own use, not for resale. See Appendix B, § I Definitions.
60

See Pricing Flexibility Suspension Order, 27 FCC Rcd at 10559, para. 3.

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22.
We have received several questions about the meaning of “capable” within the definition
of Connection for purposes of the data collection.61 In response, we provide the following guidance on
what Locations with Connections to report, which varies depending on the Provider type.
a.

Guidance on Capable Connections for Competitive Providers

23.
Non-Cable Competitive Providers. Competitive Providers other than cable system
operators must report all Locations with idle and in-service Connections that they own or lease as an IRU,
regardless of the type of service provided over the Connection.62 This subcategory of Competitive
Providers must report all of their Connections because these entities typically target their service
offerings to businesses and other higher-capacity users where sufficient demand exists to justify the
investment. They do not typically deploy their facilities (or lease IRUs) to blanket an entire area and
instead deploy (or lease IRUs) to particular Locations within a local geographic area.63 That is, they are
likely to only have built such Connections to a particular Location based on strong expectations of
sufficient demand. Both the information about the facilities and the demand leading to the deployment of
those facilities are relevant to our analysis.64
24.
In addition, Competitive Providers must report Locations with Connections obtained as a
UNE to provide a Dedicated Service.65 This includes those UNEs obtained to provide a service that
incorporates a Dedicated Service within the offering as part of a managed solution or bundle of services
sold to the customer. Examples of services incorporating a Dedicated Service could include: the
Converged Business Network solution offered by Level 3 Communications, Inc. (Level 3); the HighSpeed Dedicated Internet Access service from XO Communications, LLC (XO); or the business Ethernet
61

See Letter from Jay Bennett, AT&T, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-25, at 1 (filed
Jan. 15, 2013) (AT&T Letter); Letter from Paul Margie, Counsel for Sprint Nextel Corporation (Sprint), to Marlene
H. Dortch, Secretary, FCC, WC Docket No. 05-25, at 1 (filed Jan. 9, 2013) (Sprint Letter); Letter from Maggie
McCready, Verizon, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-25, at 1 (filed Jan. 15, 2013)
(Verizon Letter).
62

This clarification addresses the concerns raised by AT&T and Verizon on the need to collect data on both idle and
in-service Connections from Competitive Providers to evaluate potential competition. See AT&T Letter at 1;
Verizon Letter at 1. In addition, we also revise the questions directed at Competitive Providers on Locations with
Connections, Questions II.A.3-4, to include Locations with Connections during 2010 or 2012 instead of Locations
with provisioned Connections to further effectuate this clarification. See infra Section III.C. Lastly, while a cable
system operator may technically operate as a competitive local exchange carrier (CLEC), for the purposes of this
order and the data collection, we refer to cable system operators as a category separate and apart from other CLECs
that are Competitive Providers.
63

See Pricing Flexibility Suspension Order, 27 FCC Rcd at 10587-88, para. 54 (citing comments filed by CLECs)
(“[I]t is not economical for competitors to deploy their own facilities to serve all special access demand . . . . [Costs]
are typically too large to justify provisioning a building with relatively low levels of demand”); see also XO
Holdings Inc., Annual Report (Form 10-K) at 2, 6 (Mar. 31, 2011) (touting itself as a leading alternative for
businesses and large enterprises with 42 metropolitan fiber networks with approximately 3,000 on-network
buildings, i.e., an average of about 71 connected buildings per metropolitan network); TW Telecom, Inc. (TW
Telecom), Annual Report (Form 10-K) at 4 (Feb. 15, 2013) (providing service to “enterprise organizations” and
serving 75 metropolitan markets with about 18,000 buildings connected by its local fiber facilities, i.e., an average
of about 240 connected buildings per metropolitan market).
64

This guidance also responds to the clarifications sought by AT&T and Verizon. See AT&T Letter at 1 (urging the
Commission “to make clear that the definition of Connections include both facilities that are in-service and facilities
that are in-place but not in-service, so as to capture data on potential competition.”); Verizon Letter at 1 (asking for
clarification that Connection includes connections capable of providing a Dedicated Service “and is not limited to
paths on which there actually is a Dedicated Service being sold”).
65

See Appendix B, Questions II.A.2-3.

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solution offered by TW Telecom.66 This information will further help us identify the demand for special
access service.
25.
Competitive Providers Who Are Cable System Operators. Outside their Franchise Areas
(FAs), cable operators must follow the same reporting guidance on all Locations with Connections, for
the same reasons, as the non-cable Competitive Providers described above.67 However, we require cable
system operators to report Locations in their FAs with Connections they own or lease as an IRU
differently.68
26.
Cable system operators within their FAs report Locations based on the type of
Connection. They must report those Locations with Connections owned or leased as an IRU that are
connected to a Node (i.e., headend) that has been upgraded or was built to provide Metro Ethernet (or its
equivalent) service.69 They must report Locations with these Connections regardless of the service
provided over the Connection or whether the Connection is idle or in-service. Historically, cable
companies deployed facilities widely in their FAs to serve primarily residential customers and other
community needs,70 and have more recently expanded their service offerings to customers that are likely
to buy Dedicated Service.71 We are therefore particularly interested in Connections that have been
66

See Converged Business Network, Level 3, http://www.level3.com/en/products-and-services/data-andinternet/converged-business-network/ (discussing Level 3’s Converged Business Network offering that combines
Internet, data and voice services over a single access circuit) (last visited Sept. 9, 2013); Dedicated Internet Access,
XO, http://www.xo.com/services/network/dia/Pages/overview.aspx (discussing dedicated Internet access) (last
visited Sept. 9, 2013); Business Ethernet, TW Telecom, http://www.twtelecom.com/telecom-solutions/voicesolutions/business-ethernet-services/ (discussing business Ethernet services) (last visited Sept. 10, 2013).
67

See Implementation of Sections of the Cable Television Consumer Protection and Competition Act of 1992 Rate
Regulation, MM Docket No. 92-266, First Order on Reconsideration, 29 FCC Rcd 1164, 1180, para. 24 (1993) (“A
franchise area is the area a system operator is granted authority to serve in its franchise.”).
68

Within their FAs, cable system operators will also report Locations with Connections obtained as a UNE to
provide a Dedicated Service in the same manner as other Competitive Providers.
69

Metro Ethernet is an Ethernet metropolitan area network service offering that involves centrally positioning one or
more gigabit Ethernet (GbE) or 10 gigabit Ethernet (10 GbE) switches in a metro area. It offers the advantage of
carrying all traffic in native Ethernet format, with no requirement for introducing SDH/SONET, frame relay, ATM
or other Physical Layer or Data Link Layer protocols that can increase both complexity and cost, while adding
overhead. See Webster’s New World Telecom Dictionary (2010); see also Ralph Santitoro, Metro Ethernet Forum
White Paper, Metro Ethernet Services – A Technical Overview (2006), available at
http://metroethernetforum.org/Assets/White_Papers /Metro-Ethernet-Services.pdf (providing a comprehensive
technical overview of Ethernet services) (last visited Sept. 9, 2013).
70

Cable companies typically must obtain a franchise from the local franchising authority to provide cable service in
order to operate in that area. In many instances, franchising authorities imposed build-out requirements as a
condition to granting the franchise to the cable system operator. As a result, cable system operators are subject to
outside factors in decisions to deploy, in contrast to their non-cable Competitive Providers. See, e.g., 47 U.S.C. §
541(a)(4)(A) (“In awarding a franchise, the franchising authority shall allow the applicant’s cable system a
reasonable period of time to become capable of providing cable service to all households in the franchise area. . . .”);
Comcast Cable Communications, 23 FCC Rcd 10073, 10075, para. 6 (Media Bur. Pol. Div. 2008) (noting that
franchisee is obligated to build-out its service to “‘substantially all residential households’ served by the town’s
‘aerial plant . . . within twelve (12) months’ and ‘to all residential areas of the Service Area, within four (4) years’”).
71

See Comcast Corp. (Comcast), Press Release, Comcast Introduces Metro Ethernet Services to Address
Bandwidth, Application and Reliability Requirements of Mid-Sized Businesses (rel. May 16, 2011) (Comcast May
2011 Press Release), available at http://business.comcast.com/enterprise/aboutus/pressroom/PressReleaseDetails?NewsItemID=24ce4591-e857-40af-8b5e-7ebec7d80fc4&IsPremium=False (last
visited Sept. 9, 2013); Letter from Glenn Reynolds, USTelecom—The Broadband Assoc. (USTelecom), to Marlene
H. Dortch, Secretary, FCC, WC Docket No. 05-25, Exhibit – Cable Companies Continue to Grow their Competitive
Presence (filed Aug. 21, 2013).

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upgraded to business class Metro Ethernet (or its equivalent)—whether or not those Connections are in
service and regardless of the type of service provided—because it is reasonable to assume that such
upgrades were made based on strong expectations as to the likelihood of sufficient demand for Dedicated
Service and are sources of potential competition.72
27.
For Locations with facilities that are not linked to a Node capable of providing Metro
Ethernet (or its equivalent), cable system operators must report in-service Connections that were used
during the relevant reporting period to provide a Dedicated Service or a service that incorporates a
Dedicated Service within the offering as part of a managed solution or bundle of services sold to the
customer.73 Cable system operators do not report Locations with facilities used to provide a service that is
substantially similar to the services provided to residential customers, e.g., one or two line telephone
service or best-efforts Internet access and subscription television services.74 We exclude these facilities
because they were most likely built to provide residential-type services instead of high-capacity services
to non-residential customers based on the historical deployment of cable systems; their inclusion could
thus skew our assessment of demand for special access service.75 We can still account for the potential
competition from these facilities by referencing data provided elsewhere in the collection, e.g., we can
refer to the fiber maps filed by cable system operators, the location of Nodes upgraded to provide Metro
Ethernet (or its equivalent), and the information provided showing those census blocks within the FAs
where the cable system operator reports making broadband service available with a bandwidth rate of at
least 1.5 Mbps in both directions (upstream/downstream).76 Accordingly, this clarification will aid the
Commission by focusing the collection on Locations with Connections relevant to our inquiry, thus aiding
the analysis, and has the benefit of reducing the reporting burden for cable system operators.
b.

Guidance on Capable Connections for ILECs

28.
In addition to the guidance provided to Competitive Providers on the meaning of
“capable” for the reporting of Locations with Connections, we provide ILECs with this additional
clarification. ILECs are not required to report copper loops that were unable to provide a bandwidth
connection of at least 1.5 Mbps in both directions (upstream/downstream) “as provisioned” during the
relevant reporting periods, e.g., bare copper loops not upgraded with the necessary equipment. These
copper loops are not considered Connections capable of providing a Dedicated Service for the purposes of
this data collection. This clarification addresses a concern raised by Verizon on their inability “to
distinguish between UNEs that CLECs use to serve mass-market locations and those that they use to
serve business locations.”77
72

See, e.g., Comcast May 20111 Press Release (announcing “Metro Ethernet services as part of an ongoing strategy
to expand its portfolio of business services to meet the requirements of larger customers”).
73

See supra para. 24, note 66 (providing examples of a service that could incorporate a Dedicated Service).

74

Examples of a service that is substantially similar to the services provided to residential customers could include
the following: Business Internet + Voice, Comcast, http://business.comcast.com/smb/bundle (discussing a Comcast
Business Class bundled service offering that includes business voice, web hosting, email, and Internet access at
monthly rates) (last visited Sept. 9, 2013) or similar offerings from Cox Business Internet, Cox Communications,
Inc. (Cox), http://ww2.cox.com/business/oklahomacity/data/business-internet.cox?campcode=gntile_b_data_internet
(last visited Sept. 9, 2013); Business Internet, Bright House Networks, http://business.brighthouse.com/productsand-services/data-and-internet/broadband-internet.html (last visited Sept. 9, 2013); and Optimum: TV, Phone and
Internet Services for your Business, Cablevision Systems Corp., http://www.optimumbusiness.com/ (last visited
Sept. 9, 2013).
75

See supra note 70.

76

See Appendix B, Question II.C.1.

77

See Letter from Frederick Moacdieh, Verizon, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-25, at 1
(filed Oct. 25, 2012).

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29.
We are collecting data to analyze the special access market to help inform our analysis of
the appropriate regulatory treatment of special access services. Special access services subject to
dominant carrier regulation largely consist of DS1s and DS3s, which have a symmetrical bandwidth of
about 1.5 Mbps and 44 Mbps, respectively.78 Therefore, for the collection, we do not intend to collect
data from ILECs on copper loops that “as provisioned” are unable to provide a bandwidth of at least 1.5
Mbps in both directions.79
30.
This exclusion will significantly decrease the reporting burden for ILECs while not
adversely affecting our analysis. Information on each and every copper loop an ILEC has with a
bandwidth of less than 1.5 Mbps in both directions is unnecessary for the Commission to assess potential
competition. We can instead assume that the ILEC has deployed facilities of some kind throughout its
study area and has at least one transmission link, albeit a bare copper loop, to every Location within its
study area even when the ILEC does not report having a Location with a Connection. We do recognize,
however, that copper loops can be modified to provide higher capacity services and will continue to
collect information from Competitive Providers on the loops they obtain as UNEs and later modify to
provide a bandwidth connection of at least 1.5 Mbps in both directions.80
31.
In addition to excluding certain copper loops, ILECs are prohibited from reporting
facilities to Locations used to provide services substantially similar to the services provided to residential
customers, e.g., one or two line telephone service or best-efforts Internet access and subscription
television services such as AT&T’s U-verse or Verizon’s FiOS service (even if the facility is technically
capable of providing a Dedicated Service).81 This exclusion is again aimed at limiting the data reported to
only Locations where the End Users are demanding services relevant to our inquiry (i.e., buying
Dedicated Services). In these areas, as with the exclusion for certain copper loops, we can assume that
the ILEC has a capable facility connecting every Location in its study area even when it did not provide a
Dedicated Service to the Location during the relevant reporting period.
2.

Location Data

32.
Several parties are concerned about the Location information sought in the data
collection, namely the requirement that the Provider (1) indicate whether the connected Location is a
78

The Commission has granted forbearance from dominant carrier regulation of certain packet-based and optical
transmission services to the largest ILECs. See Petition of the Verizon Telephone Companies for Forbearance under
47 U.S.C. § 160(c) from Title II and Computer Inquiry Rules with Respect to Their Broadband Services, WC
Docket No. 04-440 (filed Dec. 20, 2004); Letter from Edward Shakin, Vice President and Associate General
Counsel, Verizon, to Marlene H. Dortch, Secretary, FCC, WC Docket. No. 04-440, at 2-3 (filed Feb. 7, 2006); FCC
News Release, Verizon Telephone Companies’ Petition for Forbearance from Title II and Computer Inquiry Rules
with Respect to their Broadband Services Is Granted by Operation of Law (rel. Mar. 20, 2006); Petition of AT&T
Inc. for Forbearance Under 47 U.S.C. § 160(c) from Title II and Computer Inquiry Rules with Respect to Its
Broadband Services, Petition of BellSouth Corporation for Forbearance Under Section 47 U.S.C. § 160(c) from
Title II and Computer Inquiry Rules with Respect to Its Broadband Services, Memorandum Opinion and Order, 22
FCC Rcd 18705 (2007); Petition of the Embarq Local Operating Companies for Forbearance Under 47 U.S.C. §
160(c) from Application of Computer Inquiry and Certain Title II Common-Carriage Requirements, et al.,
Memorandum Opinion and Order, 22 FCC Rcd 19478 (2007); Qwest Petition for Forbearance Under 47 U.S.C. §
160(c) from Title II and Computer Inquiry Rules with Respect to Broadband Services, Memorandum Opinion and
Order, 23 FCC Rcd 12260 (2008).
79

For this reason, we are revising Questions II.B.2-3 to no longer require ILECs to report Unbundled Copper Loops.
See infra Section III.C (discussing changes to questions).
80

See Appendix B, Questions II.A.3-4 (requiring the reporting of Locations with Connections obtained as a UNE,
which includes Unbundled Copper Loops used to provide a Dedicated Service).
81

See also supra note 74 (providing additional examples of a service that is substantially similar to the services
provided to residential customers).

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building, cell site, or other man-made structure, i.e., reporting the location type and (2) report the geocode
(latitude and longitude) for each Location.82 On location type, Comcast and Cox said “that they do not
necessarily know or record the type of structure . . . and that recreating such data (e.g., through site visits
or requests to the customer) could be quite a burdensome exercise.”83 In addition, Alaska
Communications Systems (ACS), Cincinnati Bell Inc. (Cincinnati Bell), and members of the American
Cable Association (ACA) reported difficulty with determining not only the location type but also the
geocode.84
33.
In response, we clarify in the instructions that if the filer does not know the location type,
it can report the type as “unknown.”85 While we intend to use the location type to further understand the
demand segments for Dedicated Services, we can utilize information reported elsewhere in the collection
for this purpose.86 Therefore, while this clarification will significantly reduce the reporting burden on
Providers, it will not adversely affect the Commission’s analysis. As for the location geocode, we
understand that Providers are more likely to have coordinate information for connected cell sites than for
connected buildings. Providers do typically have, however, at least the street address for a connected
building.87 We therefore clarify in the instructions that Providers can report a location geocode derived
from a postal address through use of a geocoding platform.88 This clarification will significantly reduce
the reporting burden by eliminating the need for site visits to obtain coordinate information.
3.

Mapping Requirements

34.
The Special Access Data Collection Order required Competitive Providers to file maps
showing: (1) the fiber routes constituting their network and connecting their networks to Locations;89 and
82

While we do not discuss the rationale behind each and every instruction in this Report and Order, the instructions
do contain additional clarifications on how to calculate sold bandwidth and the accuracy level for location data. See
Appendix A, Instructions at 13-14, 38-39.
83

See Letter from Steven F. Morris, National Cable and Telecommunications Assoc. (NCTA), to Marlene H.
Dortch, Secretary, FCC, WC Docket No. 05-25, at 3 (filed Feb. 28, 2013) (NCTA Feb. 28 Letter).
84

See ACS, PRA Comments, WC Docket No. 05-25, at 5 (filed Apr. 15, 2013) (ACS PRA Comments) (“ACS does
not keep records of the geocode for each location where special access services are deployed, nor does the company
maintain records on the location type.”); Cincinnati Bell, PRA Comments, WC Docket No. 05-25, at 4 (filed Apr.
15, 2013) (“Existing records do not contain this information, so a site visit may be required to each location to
ascertain the Location type. . . . The cost and burden of complying with the geocoding requirements are excessive
and should be eliminated.”); ACA, PRA Comments, WC Docket No. 05-25, at 11-12 (filed Apr. 15, 2013) (“Of the
ACA members surveyed, all maintain information about their customers’ addresses, but, with one exception, none
had geocode (longitude/latitude) information for these locations.”) (ACA PRA Comments).
85

See Appendix A, Instructions at Tables II.A.4 and II.B.3.

86

For example, mobile wireless service providers are required to report the connections to their cell sites and the
providers supplying those connections. See Appendix B, Question II.E.2. This will help the Commission evaluate
the demand for cell site backhaul.
87

See ACA PRA Comments at 12; see also Cincinnati Bell PRA Comments at 3 (“[T]he location of individual
buildings is easily captured by using service addresses that are readily available.”).
88

We will allow parties to derive the coordinate fields for the location address from a known geocoding platform
such as Bing maps, Google, Yahoo, batchgeo.com, Texas A&M Geoservices or other geocoding solution. See, e.g.,
Texas A&M Geoservices, http://geoservices.tamu.edu/Services/Geocode/ (last visited May 2, 2013) (providing a
free platform for the conversion of postal addresses into geographic coordinates).
89

See Special Access Data Collection Order, 27 FCC Rcd at 16360, App. A, Question II.A.5. The question
originally required the submission of two separate maps – one for the transport network and one just showing the
fiber routes to Locations. As discussed in Section III.C of this Report and Order, we have revised the question to
require only one map. See Appendix B, Question II.A.5.

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(2) the Nodes used to interconnect with other providers and the year each Node went live.90 The maps
showing fiber routes help the Commission identify where Competitive Providers can or potentially could
provide Dedicated Service.91 The location of the interconnection Nodes helps the Commission understand
the “non-price factors that may impact where special access providers build facilities or expand their
network via UNEs.”92
35.
Several parties raised concerns about the burden of producing maps and verifying
interconnection Nodes. Cable companies, for example, stated they do not keep maps at this level of detail
in the normal course of business and would have to conduct site visits and create them at considerable
expense.93 NTCA also expressed concern explaining that while its members generally have maps
showing “middle-mile” facilities, they do not keep maps with “last mile” facilities.94
36.
NCTA and ACA alternatively propose that the Commission: (1) allow companies to
simply submit whatever network maps they have or “a list or ‘airline’ map showing the network footprint
(headend locations and customer locations served by those headends)” and (2) eliminate the Node
identification requirements.95 USTelecom opposes this proposal, arguing this alternative will not provide
the Commission with the necessary detail “to determine how both actual and potential competition
provide competitive discipline in the high-capacity marketplace.”96 As discussed below, although we do
not eliminate the obligations as proposed by NCTA and ACA, we do make certain clarifications to reduce
the burdens while ensuring the Commission has sufficient data for its analysis.
37.
Fiber Maps. The Commission required Competitive Providers to submit maps showing
their fiber routes, including fiber Connections to Locations, for an analysis of potential competition.97
While we understand the burdens of providing these comprehensive maps, the Commission has found that
competition for Dedicated Service “appears to occur at a very granular level—perhaps as low as the

90

The collection defines a Node as “an aggregation point, a branch point, or a point of interconnection on a
Provider’s network, including a point of interconnection to other Provider networks. Examples include LEC central
offices, remote terminal locations, splice points (including, for example, at manholes), controlled environmental
vaults, cable system headends, cable modem termination system (CMTS) locations, and facility hubs.” See
Appendix B, Definitions. As further clarified in the instructions, we do not expect filers to provide the “went live”
date if it occurred prior to 1995; the filer can instead simply answer “1000.” See Appendix A, Instructions at 16.
91

See Special Access Data Collection Order, 27 FCC Rcd at 16333, para. 35 (“These maps will indicate where
competitive providers can provide, or could potentially provide, special access services.”).
92

See id. at 16332, para. 33.

93

See NCTA Feb. 28 Letter at 3; NCTA, PRA Comments, WC Docket No. 05-25, at 7 (filed Apr. 15, 2013) (NCTA
PRA Comments); ACA PRA Comments at 11; Chariton Valley, PRA Comments, WC Docket No. 05-25, at 1 (filed
Apr. 15, 2013). One cable company estimated a cost of $4 million to produce a map for one large city and at least
$50 million for all its FAs. See NCTA Feb. 28 Letter at 3; NCTA PRA Comments at 7.
94

See Letter from Michael R. Romano, NTCA, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-25, at 2
(filed May 13, 2013) (NTCA Letter).
95

See Letter from Steven F. Morris, NCTA, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-25, at 2,
Attachment, at 1 (filed Mar. 22, 2013) (NCTA Mar. 22 Letter); ACA PRA Comments at 6.
96

See Letter from Glenn Reynolds, USTelecom, to Marlene Dortch, Secretary, FCC, WC Docket No. 05-25, at 2
(filed Apr. 11, 2013).
97

In addition, as part of the Special Access Data Collection FNPRM, the Commission is considering whether it can
use distances to fiber and demand for evaluating petitions for pricing flexibility. See 27 FCC Rcd at 16351 para. 78
n.173.

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building/tower.”98 The Commission therefore needs to collect information at an equally granular level,
i.e., the level of the connected Location.
38.
The mapping obligation is already limited by focusing solely on fiber routes and not
requiring the mapping of other transmission mediums. Relative to copper or coaxial cable, a Competitive
Provider can easily add additional Dedicated Services or other managed services to a fiber line. The
presence of fiber down a street is thus a good indicator of a Competitive Provider’s ability to serve nearby
Locations.99 To further reduce the burdens, we clarify in the instructions that the scale used for shapefile
mapping data is 1:24,000, which is the standard used by the U.S. Geological Survey National Map and
the same scale used by the Bureau for the study area boundary (SAB) map collection.100 This standard
will give the Commission sufficient data on the streets and paths traversed by fiber while eliminating the
need to report the exact location of fiber on the street. We expect that Competitive Providers would know
the streets and routes where their fiber runs without having to conduct site surveys so this clarification
should significantly reduce the reporting burden for Competitive Providers while still giving the
Commission data on fiber routes to a sufficient level of accuracy for its analysis.101
39.
We reject the alternative proposed by NCTA and ACA of requiring “whatever network
maps” a Competitive Provider has or “a list or ‘airline’ map showing a network footprint” for two
reasons.102 First, this approach will produce non-uniform and less granular data and will thus affect the
Commission’s analysis. Maps would vary by respondent with some simply showing the boundaries of
their network coverage and others providing details on some fiber routes but unlikely to the level of the
connected Location. Even a “list or ‘airline’ map showing the network footprint” would not necessarily
give the Commission the fiber routes to Locations, at least not to a sufficient level of accuracy. Second,
the variability of the maps would substantially increase the burden on Commission staff. For example,
the Commission would have to create a base map from the non-uniform data and offset gaps with
information collected elsewhere or through third-party data sets. Even if the Commission could somehow
fill any data gaps, the result would not be as detailed, uniform, or accurate as with having Competitive
Providers submit maps showing their fiber facilities to each Location. It would also divert Commission
resources from analyzing the data to create data necessary to begin the analysis.
40.
Nodes. NCTA and ACA have also asked the Commission to eliminate the requirement to
include Nodes used for interconnecting. One NCTA member said it “cannot reasonably identify every
node on the network used to interconnect . . . and the year that each node ‘went live,’” asserting that it
“would have to walk portions of the route to check for all splice points and/or interview local personnel”
to determine the location of interconnecting Nodes.103 An ACA member stated it would have to review
many end user agreements to determine this information, while another member stated that reporting the
98

See Special Access Data Collection Order, 27 FCC Rcd at 16327-28, para. 22.

99

The Department of Justice has also used distances to fiber when evaluating the effect of transactions on
competition. See Special Access Data Collection FNPRM, 27 FCC Rcd at 16351 para. 78 n.173 (citing AT&T Inc.
and BellSouth Corporation Application for Transfer of Control, WC Docket No. 06-74, Memorandum Opinion and
Order, 22 FCC Rcd 5662, 5682, para.42 (2007).
100

See Connect America Fund; High-Cost Universal Service Support, WC Docket Nos. 10-90, 05-337, Report and
Order, 27 FCC Rcd 13528, 13532, para. 14 (Wireline Comp. Bur. 2012); Order on Reconsideration, 28 FCC Rcd
1489 (Wireline Comp. Bur. 2013); Appendix A, Instructions at 15.
101

See, e.g., NCTA PRA Comments at 7 (“As Cox explains, it maintains fiber maps that show both backbone fiber
routes as well as lateral connections.”). We do not intend to penalize filers who undertake reasonable, good faith
efforts to identify the routes and paths traversed by fiber. See Order on Reconsideration, 28 FCC Rcd at 1493, para.
13.
102

See NCTA PRA Comments at 7; ACA PRA Comments at 6.

103

See NCTA PRA Comments, Exh. A, Decl. of Robert Hattori, Cox, at 5.

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“live” date for each interconnecting Node is “the most difficult and time-consuming aspect of creating the
maps.”104
41.
Although we retain the requirement to provide fiber maps, we clarify the obligations for
identifying interconnection Nodes in the instructions to reduce burdens. First, we clarify that Competitive
Providers can provide information reported to the Central Location Online Entry System (CLONES)
database on their interconnection points in lieu of reporting information from their own internal
records.105 Competitive Providers electing this option must certify that their CLONES data are current
and accurately identify their points of interconnection and the associated “live” dates to the best of their
knowledge.106 Second, we clarify in the instructions that Node locations need only be accurate to the
nearest ±0.0005 decimal degrees. Third, respondents do not have to report the year the Node went “live”
if it occurred before 1995 and is unknown.107
42.
These clarifications will not adversely affect the data needed for the Commission’s
analysis but will reduce burdens. The Commission intends to gather data on interconnection points to
understand whether the decision to deploy in an area is in response to the demand for Dedicated Service.
Based on the responses received from non-cable Competitive Providers to an earlier voluntary data
request, we believe the deployment and interconnecting decisions of non-cable Competitive Providers are
largely driven by the demand for high-capacity, business services. 108 The reporting of interconnection
points by these entities is thus valuable to the Commission.109
43.
The CLONES database is widely used by industry to create, update, and maintain codes
to uniquely identify the location of geographic places and certain equipment. It also contains historical
data on interconnection points as reported by the service providers. Competitive Providers can therefore
provide the information reported to CLONES without affecting the analysis provided they certify to the
best of their knowledge that the data accurately reflect their interconnecting points and “live” dates.110
44.
As for the location accuracy level for those Nodes identified, the Commission needs to
know the neighborhood of the interconnection point. Clarifying the accuracy level for Nodes to the
nearest ±0.0005 decimal degrees accomplishes this. In addition, reporting the year a Node went “live”
going as far back as 1995 will help the Commission understand decisions to deploy facilities to meet the
demand for Dedicated Service. After 1995, significant competitive entry and merger activity occurred
following the enactment of the Telecommunications Act of 1996.111 This timeframe will capture that
104

ACA PRA Comments at 10.

105

The CLONES database is managed by Telcordia Technologies, Inc. d/b/a Iconectiv, a wholly owned subsidiary
of Ericsson. See Systems and Tools, Iconectiv, https://codecenter.commonlanguage.com/systems.asp?#clones
(providing information about CLONES) (last visited Sept. 9, 2013).
106

See Appendix A, Instructions at 14.

107

See id. at 17.

108

See Data Requested in Special Access NPRM, WC Docket No. 05-25, RM-10593, Public Notice, 25 FCC Rcd
15146 (Wireline Comp. Bur. 2010).
109

In contrast, a cable system operator’s incentives for deploying and interconnecting its facilities, unlike those of
non-cable Competitive Providers, were historically driven by the demand for residential services. Cf. infra note 112.
Given these unique incentives, the Bureau considered only requiring cable firms to submit those Nodes that had
been upgraded to Metro Ethernet (or its equivalent) service. However, given concerns about the Bureau’s delegated
authority, we do not deviate from the approach in the Commission’s order. See Special Access Data Collection
Order, 27 FCC Rcd at 16340, para. 52 and note 112.
110

See Appendix A, Instructions at 14.

111

The number of reported Competitive Access Providers/CLECs increased substantially from 20 in 1993 to 109 in
1996 with an annual average growth rate of 76 percent during that timeframe. See Trends in Telephone Service,
(continued….)

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activity along with those headends recently upgraded by cable operators to provide Metro Ethernet (or its
equivalent) service.112 Accordingly, we will not adversely affect the Commission’s analysis by allowing
respondents to only report “live” dates prior to 1995 if available.
45.
These clarifications will ease the reporting burden for Competitive Providers while
ensuring that the Commission has sufficient data for its analysis. Entities do not always retain historical
data on interconnection points, so allowing for the submission of CLONES data and for the reporting of
“live” dates prior to 1995 only if available will ease the burden on these respondents. These clarifications
will also reduce, or completely eliminate, the need to conduct walkouts or surveys at the street or manhole
level.
4.

Billing Information

46.
The collection contains a section of questions asking for data on the Dedicated Services
billed to customers by Competitive Providers and ILECs.113 The billing section consists of three
interrelated questions: (1) reporting monthly billing information, billed at the level of the rate element,
but tied to the circuit;114 (2) identifying adjustment codes; and (3) identifying billing codes.115 In addition
to making minor revisions to the billing questions – discussed in Section III.C below, the instructions
contain a detailed breakdown of how to interpret and respond to each required data field for these
questions. The instructions address many of the requests for clarification on what is required. For
example, some parties interpreted the ILEC-centric diagram of billed circuit elements contained in
Question II.A.14 as a mandatory method of assigning billing codes.116 As clarified in the instructions,
there are two options for describing billing codes for circuit elements. A filer can either use the diagram
(Continued from previous page)
FCC, Common Carrier Bur., Industry Analysis Div. at Table 8.1 (July 1998). In addition, from 1995-1999, the
number of telecom mergers filed for governmental approval increased almost 50 percent. Mergers in the Telecomm.
Indus.: Hearing before the Senate Comm. on Commerce, Science, and Transp., 106th Cong. 2 (1999) (opening
statement of John McCain, U.S. Senator from Arizona). Further, between 1996 and 2001, 42 mergers between
telecom providers were consummated, 33 of which occurred in 1997 and 1998 alone. See Mark N. Cooper et al.,
Successes and Failures of the 1996 Telecommunications Act: Telecom Mergers (1996-2001), available at
http://www.civilrights.org/publications/1996_telecommunications/telecom-mergers.html (last visited Sept. 9, 2013).
112

See supra note 71 (listing press releases from cable firms that have expanded their service offerings to customers
that are likely to buy Dedicated Services). A cable company’s decision to upgrade headends to provide Metro
Ethernet (or its equivalent) service is relevant to the demand for Dedicated Services because these upgrades reflect
areas in which the cable system operator anticipated that sufficient demand was likely to exist for Dedicated
Services. We therefore also clarify in the instructions that cable system operators must separately indicate those
Nodes that have been upgraded to provide a Metro Ethernet (or its equivalent) service. See Appendix A,
Instructions at 15.
113

The billing data are only for Dedicated Services provided using facilities that are owned or leased as an IRU and,
in the context of a Competitive Provider, facilities obtained as a UNE to provide a Dedicated Service. See Appendix
B, Questions II.A.12, II.B.4.
114

In the data collection questions on billing, the term “circuit element” is used, which is intended to capture billing
information at whatever level of granularity billed to customers, e.g., rate elements, circuit elements, billed
elements, circuit components, etc.
115

See Appendix B, Questions II.A.12-14, II.B.4-6. The monthly billing information question, inter alia, requires
the filer to reference adjustment codes, where applicable, and billing codes.
116

See NCTA PRA Comments, Exh. A, Hattori Decl. at 8 (“The data request would appear to require Cox to attempt
to match Cox’s unique billing codes with a long list of rate elements that incumbent local exchange carriers use but
Cox does not.”); Letter from Thomas Jones, Counsel to tw telecom inc. (TW Telecom), to Marlene H. Dortch,
Secretary, FCC, WC Docket No. 05-25, at 1 (filed Jan. 10, 2013) (“[T]he Commission should account for the fact
that competitive providers do not bill separately for the same special access rate elements as incumbent LEC
providers.”) (TW Telecom Letter).

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and descriptions provided to describe the billed circuit element or create its own descriptions for the billed
elements, e.g., a party could assign a billing code to a circuit element described as “private line end-toend service.”117 Parties also questioned whether they can use Uniform Service Order Codes (USOCs) for
their unique billing code IDs.118 The instructions clarify that providers can use any unique billing code,
including USOCs.119 These and other clarifications are provided in the instructions.
5.

Headquarters Information

47.
Question II.A.9 asks Competitive Providers to report the locations of their U.S.
headquarters and the headquarters of certain affiliates, going as far back as 1995.120 NCTA questions the
need for this information and asks the Commission to eliminate this requirement or limit the years
covered to 2010 and 2012.121
48.
Like the data sought on interconnection points, the purpose of this question is to assess
certain non-price factors that may be relevant to where Competitive Providers build or expand their
network.122 The question asks for the locations of a Competitive Provider’s current and prior U.S.
headquarters, going as far back as 1995. In addition, Competitive Providers must identify the
headquarters of affiliated entities and entities acquired through merger that no longer exist123 if the
affiliated or acquired entity owned (or leased under an IRU agreement) Connections to five or more
Locations in a given MSA at the time of affiliation/acquisition, going as far back as 1995.124 We use 1995
as the cutoff because significant competitive entry and merger activity occurred after 1995.125 The longer
period thus helps us understand why a competitor chose to expand its facilities in certain areas over time.
49.
For certain Competitive Providers, namely cable system operators, the decision of where
to deploy Dedicated Service facilities is significantly influenced by the FAs awarded to the cable
operator, which are often unrelated to the location of its headquarters. For example, the headquarters for
Cox, the third largest cable provider in the United States, is located in Atlanta but Cox has no cable
network in that metropolitan area.126 In addition, cable operators have only recently upgraded systems in
their FAs to provide Dedicated Service. With this in mind, we question the benefits of obtaining
information on headquarters going as far back as 1995 from cable companies because while this question
is not particularly burdensome, it is unlikely to help us understand why a cable company deployed

117

See Appendix A, Instructions at 34, 52-53; Appendix B, Questions II.A.14.c, II.B.6.c.

118

See Cincinnati Bell PRA Comments at 7.

119

See Appendix A, Instructions at 34, 52-53.

120

See Appendix B, Question II.A.9. In addition, as discussed in Section III.C of this Report and Order, we have
revised the question to include the reporting of headquarters for acquired entities at the time of acquisition.
121

See NCTA Mar. 22 Letter, Attach. at 3.

122

See Special Access Data Collection Order, 27 FCC Rcd at 16332, para. 33.

123

As discussed in Section III.C of this Report and Order, we have revised the question to ask for headquarters
location information in those instances when the entity is acquired and merged out of existence – i.e., when the
Competitive Provider (or its subsidiary) responding to the data request was the surviving entity.
124

See Appendix B, Question II.A.9 and the Instructions for further information.

125

See supra note 111.

126

See Our Story, Cox, http://ww2.cox.com/aboutus/our-story.cox?campcode=gnf_r_aboutus_ourstory (last visited
Sept. 9, 2013), Atlanta Headquarters, Cox, http://ww2.cox.com/aboutus/our-story/headquarters.cox (last visited
Sept. 9, 2013).

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facilities in an area to provide Dedicated Service. We will therefore allow cable operators to respond to
this question by indicating “Not Applicable.”127
50.
The rationale for treating cable system operators differently does not apply, however, to
other Competitive Providers who do not deploy facilities according to designated FAs.128 We therefore
continue to find value and intend to collect headquarters information from non-cable Competitive
Providers for the analysis.
6.

Certain Questions Requiring Narrative Responses from Purchasers

51.
The data collection requires Purchasers to provide a narrative response to certain
questions. For example, Questions II.F.8-10 and 12 ask for information about any problems experienced
with terms and conditions, switching of Providers, or having to pay One Month Term Only Rates.129
Smith Bagley et al. objects to the mandatory submission of this “qualitative” information because it is not
quantitative or verifiable and asks for the voluntary submission of responses to these types of questions.130
52.
Questions II.F.8-10 and 12 give Purchasers an opportunity to provide factual details to
highlight any problems experienced in their dealings with Providers of Dedicated Service. The
Commission plans to use the information to help identify and document problems previously alleged by
Competitive Providers in this proceeding. While these questions are not particularly burdensome, and are
instead an opportunity, we have clarified in the instructions that if a Purchaser does not need, or want, to
provide a response, i.e., the Purchaser is not experiencing or does not want to highlight any alleged
problems, then the Purchaser can simply respond stating as much.131
C.

Modifications and Amendments to the Data Collection

53.
The following is a list of the modifications and amendments to the data collection
definitions and questions based on the received feedback and our further internal review.132 These
changes are consistent with the terms of the Special Access Data Collection Order.133


Affiliated Company. Definition revised to include not only affiliations with Providers but
also Purchasers. This revision will assist the Commission with internally linking
information on sales and purchases reported by filers to entities that have common
ownership. In addition, we have changed the ownership interest for determining an
affiliation from 25 to 10 percent. Use of the lower percentage is consistent with the
definition of affiliate used for the Form 499-A “Telecommunications Reporting

127

See Appendix A, Instructions at 18-19.

128

See supra, para. 23 (discussing incentives for deployment for non-cable Competitive Providers).

129

As discussed in Section III.C of this Report and Order, these identical questions also now appear in Section II.E
of the data collection for Purchasers who are mobile wireless services providers. See Appendix B, Questions II.E.911, 13.
130

See Smith Bagley PRA Comments at 11-12; NCTA Mar. 22 Letter at 5.

131

The same clarification is in the instructions for the identical questions directed at Purchasers who are mobile
wireless service providers, i.e., Questions II.E.9-11, 13. See Appendix A, Instructions at 66-67.
132

The revised data collection is attached in Appendix B. Many of the clarifications sought by parties that are not
reflected in the revised data collection are addressed separately in the instructions included in Appendix A as
discussed in Section III.B herein.
133

See 27 FCC Rcd at 16340, para. 52 (delegating authority to the Bureau to “modify the data collection based on
public feedback;…amend the data collection based on feedback;…make corrections to the data collection;…
and…take other such actions as are necessary to implement this Report and Order…consistent with the terms of this
Report and Order”).

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Worksheet,” which is based on the statutory definition of “affiliate” in Section 153(2) of
the Communications Act of 1934, as amended.134


Best Efforts Business Broadband Internet Access Service. Term modified to clarify that
only best efforts services with a minimum advertised bandwidth connection of at least 1.5
Mbps in both directions (upstream/downstream) must be reported.135 The addition of
“advertised bandwidth” also provides a clearer standard for respondents than the prior
language that suggested an actual capacity, which could vary depending on case-specific
variables such as time of day, traffic congestion, etc.



Circuit-Based Dedicated Service (CBDS). Term modified to clarify the Commission’s
intent of only capturing those categories of time-division multiplexing-based services,
such as DS1s and DS3s, which largely remain subject to dominant carrier regulation.136



Collocation. Definition deleted because the term is not used in the data collection.



Connection. We modified the definition to eliminate potential confusion over the
reference to “end user’s location,” which was a combination of two defined terms, End
User and Location.137 As modified, the term now drops the modifier “End User’s” and
just references Location, which is already defined as a point where the End User is
connected. We have also changed subsequent references to end user location in the
collection to Location. In addition, consistent with our clarification of “capable”
Connections in the instructions, we have modified the definition to clarify that an
Unbundled Copper Loop is only considered a Connection once modified to provide a
Dedicated Service.”138



Dedicated Service. Changed reference in definition from megabytes to megabits. In
addition, we clarified that the minimum bandwidth rate of 1.5 Mbps applies in both
directions, upstream and downstream.



End User. Revised this term to include not just entities that purchase Dedicated Service
for their own use and not for resale but also entities that more broadly purchase
communications services for their own use and not for resale.



Indefeasible Right of Use (IRU). The definition for this term previously included a list of
elements typically found in IRU agreements, including a substantial upfront fee, a
minimum term of ten years and no unreasonable limit on the grantee’s right to use the
asset. The definition gave respondents considerable discretion to determine whether a
lease is an IRU agreement. Sprint is concerned the definition will result in the over

134

See Instructions to the 2013 Telecommunications Reporting Worksheet (Form 499-A) at 10 (citing 47 U.S.C. §
153(2)), available at http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-319222A1.pdf.
135

See Verizon Letter at 1; see also FCC, Office of Engineering Technology and Consumer and Governmental
Affairs Bureau, A Report on Consumer Wireline Broadband Performance in the U.S. – February 2013 (“On average,
during peak periods DSL-based services delivered download speeds that were 85 percent of advertised speeds,
cable-based services delivered 99 percent of advertised speeds, fiber-to-the-home services delivered 115 percent of
advertised speeds, and satellite delivered 137% of advertised speeds.”), available at http://www.fcc.gov/measuringbroadband-america/2013/February (last visited Sept. 9, 2013).
136

See AT&T Letter at 1 (noting a potential issue with the placement of SONET and OCN in the definition of
CBDS).
137

See Verizon Letter at 1 (noting the Connection definition includes the undefined term “End User’s Location” and
requesting that the Bureau define the term to avoid confusion).
138

See supra Section III.B.1; Appendix B § Definitions.

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inclusion of contracts that are effectively service level agreements but called IRUs by the
parties.139 Conversely, AT&T said the term could be read to exclude IRUs with shorter
terms and with upfront payments of less than 25 percent.140
The definition is intended to capture facilities where the grantee effectively has an
ownership interest in the Connection and has the right to use the asset for an extended
period of time to provide a competitive service of its choosing. While IRUs of less than
ten years in total duration and with minimal upfront payments may indeed exist, for
purposes of our analysis of facilities-based competition, we will focus on IRUs with a
total term of at least ten years where the grantee has a right to access and exclusively use
the Connection absent unreasonable limits.141 We have modified the definition as
suggested by AT&T to clarify that the duration period of the IRU agreement need not
equal the remaining economic life of the asset.142


Packet-Based Dedicated Service (PBDS). Modified this definition to capture those types
of services for which the Commission has largely granted relief from dominant carrier
regulation.143



Prior Purchase-Based Commitment. Term revised to include commitments based on a
dollar amount of revenues in addition to a percentage of revenues.144



Revenues. Deleted second sentence in definition to eliminate confusion over the billed
revenue amounts to report.145



Tariff. Revised definition to clarify that term broadly includes both Tariff Plans and
Contract-Based Tariffs.



Transport Service. Definition revised to clarify intent of including dedicated transport
and special access services other than End User Channel Terminations.146



Question II.A.1: Affiliated Company. Expanded the types of affiliated entities reported
to Providers and Purchasers, not just Providers, to internally track commonly-owned
entities and rephrased question to simplify electronic filing, i.e., deleted yes/no response.



Questions II.A.3-4: Locations Data for Competitive Providers. Consistent with our
guidance on capable Connections in Section III.B.1.a of this Report and Order, we
revised these questions to include not only facilities in-use, i.e., provisioned Connections

139

See Sprint Letter at 1.

140

See AT&T Letter at 1.

141

This approach is consistent with the Commission’s prior treatment of IRUs. See, e.g., SBC Communications Inc.
and AT&T Corp. Applications for Approval of Transfer of Control, 20 FCC Rcd 18290, 18305, para. 24 (2005)
(noting that the consent decree with the Dept. of Justice, calling for certain divestitures in the form of IRUs with a
minimum term of 10 years for loops and transport, should remedy any likely anticompetitive effects on the
provisioning and pricing of wholesale special access services).
142

See AT&T Letter at 1.

143

See id.

144

See Letter from Eric Branfman, Counsel to Level 3, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 0525, at 1-2 (filed Jan. 9, 2013) (Level 3 Letter).
145

See Cincinnati Bell PRA Comments at 7 (noting confusion over billed amounts that are subsequently
discounted).
146

See Sprint Letter at 1.

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to Locations, but also idle Connections to capture data on potential competition.147 In
addition, to match the reported month-to-month billing information, filers will report
connected Locations during 2010 and 2012 instead of Locations as of year-end. The
wording of Question II.A.3 is also changed to clarify that Competitive Providers need
only report Locations with Connections in total and not separately by the enumerated
categories.148 We also added Question II.A.4.k to obtain the total bandwidth provided
over the Connection for the respondents’ own internal use or the internal use of an
Affiliated Company. This last piece of information will help us evaluate whether
Competitive Providers are self-providing service as an alternative to buying Dedicated
Service.

147



Question II.A.5: Fiber Network Map(s). We received inquiries from parties requesting
clarification of the mapping question requirements and have revised the question to only
require a single map showing the fiber routes of a Competitive Provider’s network that
are owned or leased under an IRU agreement.149



Question II.A.8: Business Rules for Deployment. Clarified question to remove
ambiguities and to help develop competition proxy variables for the Commission’s
econometric analysis.



Question II.A.9: Headquarters. As mentioned in Section III.B.5 above, question revised
to facilitate responses for proxy variables for competition, i.e., filers must now also report
the headquarters of entities acquired through merger where the filer or its subsidiary was
the surviving entity.



Questions II.A.12-14: Billing Information from Competitive Providers. Based on
feedback, we revised these questions so they now refer to circuit element instead of rate
element.150 Question II.A.12 is also amended to require the reporting of the customer’s
name in addition to the Form 499-A Filer ID, where applicable, or other unique identifier
(ID), and Question II.A.13 is amended to require the reporting of a unique ID to link
adjustments to a particular Tariff or contract. These changes to Questions II.A.12-13 will
help the Commission identify and internally track purchases by commonly-owned
customers and link billing adjustments to particular plans. Lastly, we added a new
Question II.A.12.l to capture the per unit charge for the circuit element in addition to the
total billed amount; modified former Question II.A.12.l to remove redundant language;
and deleted the requirement to report whether the circuit element is owned or leased as an

See supra Section III.B.1.a.

148

The clarification addresses the concerns of Cox and TW Telecom about differentiating between Locations
connected by owned facilities and Locations connected by leased IRU facilities. See NCTA PRA Comments, Exh.
A, Hattori Decl. at 4, para. 13 (“The most time-consuming aspect of this specific data collection for Cox, however,
is identifying and separately counting locations that Cox serves using circuits leased under IRU agreements.”); TW
Telecom Letter at 1 (“[T]he Commission should not require respondents to report separately special access
connections utilizing facilities owned by the provider and facilities obtained via indefeasible rights of use.”). A
clarification in the instructions for Question II.A.4 addresses this concern as well by allowing filers to alternatively
report the general percentage of IRU leasing arrangements with particular lessor types in total.
149

See also supra Section III.B.3 (providing additional clarifications on the information reported in response to this
question).
150

See Level 3 Letter at 3 (noting confusion between information reported in Questions II.A.12 and 14). As further
explained in the instructions, Questions II.A.12-14 are interrelated and link billing information to locations
identified elsewhere in the collection, adjustment IDs, and billing codes. See also supra note 114 (discussing the
reference to “circuit element”).

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IRU in former Question II.A.12.o to address concerns over differentiating between owned
and leased facilities.


Question II.A.19: Justification for Term and Volume Commitments. Question amended
to include Tariffs and agreements in effect with a customer, in addition to those
offered.151



Question II.B.1: Affiliated Company. As with the parallel question for Competitive
Providers, we expanded the types of affiliated entities reported to Providers and
Purchasers, not just Providers, to assist with the internal tracking of commonly owned
entities and modified the phrasing of this question to simplify electronic filing, i.e.,
deleted the yes/no response.



Questions II.B.2-3: Locations Data for ILECs. We revised these questions to eliminate
the reporting of Connections sold as an Unbundled Copper Loop by the ILEC. As
explained in Section III.B.1.b of this Report and Order, we do not intend to collect data
on copper loops with a bandwidth of less than 1.5 Mbps. If a Competitive Provider has
obtained an Unbundled Copper Loop from the ILEC as a UNE and modified the loop to
provide a Dedicated Service, we will get that data directly from the Competitive
Provider. This change will greatly reduce the reporting burden for ILECs.
In addition, like the Competitive Provider questions on connected Locations, we have
revised these questions to require the reporting of Locations connected during 2010 and
2012 instead of Locations as of year-end; this change is necessary to match the reported
month-to-month billing information. Question II.B.2, similar to its counterpart question
for Competitive Providers, is clarified so that ILECs report Locations in total and not
separately by the enumerated categories.152



Question II.B.4-6: Billing Information from ILECs. Similar to the questions on billing
for Competitive Providers, we revised these questions based on feedback to reference
circuit element instead of rate element. In addition, we made the following changes: (1)
amended Question II.B.4.b to require the reporting of the customer’s name to identify and
internally track purchases by commonly-owned customers; (2) removed the reference to
Unbundled Copper Loops in Question II.B.4 because Locations connected with
Unbundled Copper Loops are no longer reported by ILECs; (3) revised Question II.B.5.gh to refer to “contract or Tariff” and not just contract; (4) deleted references to accuracy
levels in Question II.B.4.h-k;153 (5) added a new Question II.B.4.t to capture the per unit
charge for the circuit element in addition to the total billed amount; (6) modified former
Question II.B.4.t to remove redundant language; (7) deleted former Question II.B.4.w
because a revenue commitment is included in the definition of Volume Commitment
referenced in a subsequent part of this question; (8) deleted the requirement to report
whether the circuit element is owned or leased as an IRU in II.B.4.y;154 and (9) deleted

151

See Level 3 Letter at 3 (“[I]f the agreement is in effect at the current time, it has an effect on the market whether
or not the Provider is currently offering the arrangement to new customers.”).
152

We also eliminated the reference to UNEs sold as it was already included by the reporting of provisioned
Connections to Locations that are owned. The ILEC will still indicate the bandwidth sold on the Connection to the
Location as a UNE in the form of a DS1 or DS3 in response to Question II.B.3.
153

We will separately address accuracy levels in the instructions consistent with the reporting of Locations, i.e.,
values in decimal degrees to the nearest ±0.0005 decimal degrees. This change is in response to the concerns raised
by Cincinnati Bell. See Cincinnati Bell PRA Comments at 3.
154

This particular change addresses concerns raised by parties on the burden of differentiating between owned and
leased facilities. See supra note 148.

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former II.B.4.aa because the burden outweighed the benefit of linking the billing
information for a circuit to a particular tariff name and section number.


Question II.B.12: All Tariffs. Deleted “available” from the initial sentence to capture not
only available tariffs but also tariffs currently in effect for the purchase of DS1, DS3, and
PBDS services; this change enables us to obtain information on all Tariffs that are
currently used, or could be used, to purchase Dedicated Service from ILECs. We
amended Question II.B.12.g to obtain additional information on the geographic areas
covered by the identified plans to help the Commission differentiate between urban and
rural areas. Added new Question II.B.12.k-l to indicate whether purchases in areas where
pricing flexibility has been granted count towards meeting a Volume Commitment.
Added new Question II.B.12.n to indicate whether tariffed purchases of PBDS count
towards meeting a Volume Commitment. Revised former Question II.B.12.n (now
Question II.B.12.q) to only require the reporting of Revenues in total and not separately
by additional categories, and deleted former Question II.B.12.o-p because the burden of
reporting outweighed the potential benefit of collecting the information. Lastly, we
amended former Question II.B.12.r (now Question II.B.12.s) to address concerns raised
by Level 3 about plans that effectively contain Prior Purchase-Based Commitments
without explicitly containing such provisions.155



Question II.B.13: Non-Tariffed Agreements. Rephrased language to simplify electronic
filing, i.e., eliminated the need for a yes/no response.



Question II.C.1-2: Entities Providing Best Efforts Services. Condensed Questions
II.C.1-2 into one question and rephrased so that only covered entities, i.e., those not
exempted, must answer. Modified former Question II.C.2.c.ii and d.ii to require
reporting for areas where service is offered, instead of where service is provided.156 This
is consistent with how data are reported for the State Broadband Initiative (SBI)
program.157

155

See Level 3 at 1-2.

156

See Verizon Letter at 2.

157

See American Recovery and Reinvestment Act of 2009 § 6001(l), 123 Stat. 115, 118, 128 (2009). The data filed
as part of the SBI program either includes a list of all addresses at which broadband service is available to end users
in the facilities-based provider’s service area or “a list of all census blocks of no greater than two square miles in
area in which broadband service is available.” See NTIA, State Broadband Data and Development Program, Notice
of Funds Availability, 72 Fed. Reg. 3545, App. F (July 8, 2009) (Technical Appendix); NTIA, State Broadband Data
and Development Grant Program, Notice of Funds Availability Clarification, 74 Fed. Reg. 40569, Technical
Appendix Clarification (Aug. 12, 2009). A broadband service is considered available “at an address if the provider
does, or could, within a typical service interval (7 to 10 business days) without an extraordinary commitment of
resources, provision two-way data transmission to and from the Internet with advertised speeds of at least 768 kbps
downstream and greater than 200 kbps upstream to end users at that address.” See Technical Appendix. The SBI
data also includes information on the available speed tiers (downstream/upstream). Id. The SBI program is nearing
its scheduled end; sometime in 2014, broadband providers will be required to file data on broadband deployment as
part of the Commission’s Form 477 program. However, providers will continue to participate in the SBI program
through 2014 and nothing in the transition from SBI to Form 477 should affect this data collection. See
Modernizing the FCC Form 477 Data Program, WC Docket No. 11-10, Report and Order, FCC 13-87, para. 25 (rel.
June 27, 2013).

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

Question II.D.3: Procedures when Changing Transport Providers. We are deleting this
question and will instead rely on information obtained from similar questions directed at
Purchasers and follow-up as necessary with Providers based on those responses.158



Sections II.E-F: Questions for Purchasers. To differentiate information from
Purchasers that are mobile wireless service providers from other Purchasers, we have
duplicated Questions II.F.2-14 and added them to Section II.E. Purchasers that are
mobile wireless service providers will now only answer the questions on purchases in
Section II.E. All other Purchasers will answer the questions in Section II.F.



Question II.E.2: Cell Site Locations. Revised Question II.E.2.g-h to clarify that the total
bandwidth is reported.



Questions II.F.3-4 (II.E.4-5): Added subpart asking Purchasers to identify the percentage
of expenditures made pursuant to purchases under a Tariff in 2012 that were subject to a
Term Commitment of five or more years. This will help us gauge the scope of
expenditures tied to longer-term plans.



Question II.F.8 (II.E.9): Terms and Conditions Constraints. As suggested by parties, we
clarified this question to give Purchasers an opportunity to highlight alleged problems
with terms and conditions not otherwise captured by the collection.159



Question II.F.9 (II.E.10): Changing Transport Providers. Revised language to clarify
intent of obtaining information in those instances where a Purchaser buys both Transport
Service and End User Channel Terminations from one Provider and then subsequently
switches Transport Providers while continuing to purchase the “last-mile” facilities from
the original Provider.160



Question II.F.10 (II.E.11): Purchases Solely for the Purpose of Meeting a Prior
Purchase-Based Commitment. Modified language to cover purchases that would not
have been made but for the commitment instead of purchases not utilized to meet a
commitment.161 We further amended the question to obtain additional details on such
purchases where applicable.



Question II.F.11 (II.E.12): Switching Providers. Modified question based on feedback
from parties asking about the scope of the question.162



Question II.F.13 (II.E.14): Tariffs under which you Purchase Service. Deleted
“available” from the initial sentence to capture all Tariffs used by the Purchaser to obtain
DS1, DS3, and PBDS services; made minor improvements to the language in subparts
(k.ii), (m.ii), (n.ii), and (o.ii) as to the geographic areas identified and added the reporting
of the Provider’s name; and separated subpart (m) into two questions – one for purchases
in areas where the Commission has granted Phase I Pricing Flexibility and the other for
Phase II Pricing Flexibility areas.



Question II.F.14 (II.E.15): Non-Tariffed Agreements. Rephrased language to simplify
electronic filing, i.e., eliminated the need for a yes/no response.

158

See Appendix B, Questions II.E.10 and II.F.9.

159

See AT&T Letter at 1; Level 3 Letter at 3.

160

Clarification addresses issues raised by Sprint. See Sprint Letter at 1.

161

Level 3 at 3.

162

See Level 3 at 3; Sprint Letter at 1; TW Telecom Letter at 1.

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

Question II.G.1: Revised question so that entities providing Best Efforts Business
Internet Access Services that are exempt from providing data and information in response
to the data collection can certify as such and clarified language to cover entities required
to report broadband connections to end user locations on the Form 477 for 2012.

D.

Other Requests for Clarifications and Changes

54.
We have reviewed all of the requests for changes and clarifications to the data collection
and have addressed many of the requests in the revised questions described in Section III.C or in the
attached instructions. Clarifications or changes not made as requested were because the benefit of
collecting the information outweighed the burden or because the requested clarification or change is
inconsistent with the terms of the Special Access Data Collection Order, outside the scope of our
delegated authority, or because the Commission previously considered and rejected the requested relief.163
IV.

PROCEDURAL MATTERS

55.
Deadline for Responding. Once OMB has approved the data collection, we will publish
notice of such approval in the Federal Register and issue a public notice announcing the deadline for
responding.
56.
Responding to the Data Collection. In addition to the attached instructions discussing the
data specifications, we will post additional instructions on the submission process on the Commission’s
website. The Commission will create an electronic interface for the submission of information.
Submissions will involve the uploading of documents in response to various questions and interrogatories
and the electronic delivery of data. We will provide a data container file for submitting data that will
include validation scripts to verify that the filer is providing the data in the appropriate format.164
57.
Confidential Information. The data collection seeks information on facilities, billing,
revenue, and expenditure that is considered confidential by businesses. The Bureau will release
separately a Protective Order outlining procedures for designating and accessing information deemed
confidential and highly confidential.165
58.
Paperwork Reduction Act Analysis. This Report and Order further implements the
information collection requirement adopted by the Commission in the Special Access Data Collection
Order. The Commission is in the process of seeking approval for the collection from OMB pursuant to
the PRA, Public Law 104-13. The actions taken in the Report and Order are based on comments received
during the initial 60-day PRA comment period, meetings with industry, and our own internal further
review to enhance the quality, utility, and clarity of the collection.166

163

Compare Special Access Data Collection Order, 27 FCC Rcd at 16327-28, para. 22 (declining to exempt small
special access providers and purchasers from the data collection) with Smith Bagley PRA Comments at 5-6 (seeking
a de minimis exemption for small purchasers and providers); NTCA PRA Comments at 12 (requesting a de minimis
exception for providers and purchasers of less than fifty special access connections in a relevant geographic area);
see also Level 3 Letter at 2 (asking the FCC to require ILECs to report data on their rate of return on the sale of
special access circuits).
164

Responses must conform to the specifications provided in the templates. We will submit the instructions and
data format specifications to OMB as part of the application package seeking PRA approval for the information
collection.
165

See Wireline Competition Bureau Seeks Comment on Protective Order for Special Access Data Collection, WC
Docket No. 05-25, RM-10593, Public Notice, DA 13-1470 (Wireline Comp. Bur. rel. June 28, 2013).
166

See 5 C.F.R. § 1320.8(d)(1); Information Collection(s) Being Reviewed by the Federal Communications
Commission, Comments Requested, 78 Fed. Reg. 9911 (Feb. 12, 2013).

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59.
Final Regulatory Flexibility Act. The Regulatory Flexibility Act of 1980, as amended
(RFA) requires that a regulatory flexibility analysis be prepared for rulemaking proceedings, unless the
agency certifies that “the rule will not have a significant economic impact on a substantial number of
small entities.”167 The RFA generally defines “small entity” as having the same meaning as the terms
“small business,” “small organization,” and “small governmental jurisdiction.”168 In addition, the term
“small business” has the same meaning as the term “small business concern” under the Small Business
Act.169 A small business concern is one which: (1) is independently owned and operated; (2) is not
dominant in its field of operation; and (3) satisfies any additional criteria established by the Small
Business Administration.170
60.
The Special Access Data Collection Order contains a Final Regulatory Flexibility
Analysis (FRFA) that can be found at Appendix B of that Order. We incorporate the FRFA contained in
the Special Access Data Collection Order into this Report and Order. The actions taken in this Report
and Order do not create any burdens, benefits, or requirements that were not addressed by the FRFA
attached to the Special Access Data Collection Order.
61.
Congressional Review Act. As required by the Congressional Review Act (CRA), the
Commission previously sent a copy of the Special Access Data Collection Order to Congress and the
Government Accountability Office. The Commission will send a copy of this Report and Order to
Congress and the Government Accountability Office pursuant to the CRA.171
62.
Ex Parte Presentations. This is a permit-but-disclose proceeding and subject to the
requirements of section 1.1206(b) of the rules.172 Persons making oral ex parte presentations are
reminded that memoranda summarizing the presentations must contain a summary of the substance of the
presentation and not merely a listing of the subjects discussed. More than a one-sentence or two-sentence
173
description of the views and arguments presented is generally required.

167

5 U.S.C. § 605(b).

168

5 U.S.C. § 601(6).

169

5 U.S.C. § 601(3) (incorporating by reference the definition of “small business concern” in the Small Business
Act, 15 U.S.C. § 632). Pursuant to 5 U.S.C. § 601(3), the statutory definition of a small business applies “unless an
agency, after consultation with the Office of Advocacy of the Small Business Administration and after opportunity
for public comment, establishes one or more definitions of such term which are appropriate to the activities of the
agency and publishes such definition(s) in the Federal Register.”
170

Small Business Act, 15 U.S.C. § 632.

171

See 5 U.S.C. § 801(a)(1)(A).

172

47 C.F.R. § 1.1206(b).

173

Id.

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ORDERING CLAUSES

63.
ACCORDINGLY, IT IS ORDERED pursuant to sections 1, 4(i), 4(j), 5, 201-205, 211,
215, 218, 219, 303(r), 332, 403, and 503 of the Communications Act of 1934, as amended, 47 U.S.C. §§
151, 154(i), 154(j), 155, 201, 202, 203, 204, 205, 211, 215, 218, 219, 303(r), 332, 403, 503, and section
706 of the Telecommunications Act of 1996, 47 U.S.C. § 1302, sections 0.91 and 0.291 of the
Commission’s rules, 47 C.F.R. §§ 0.91 and 0.291, and the authority delegated to the Bureau in the Special
Access Data Collection Order, that this Report and Order is ADOPTED.
64.
IT IS FURTHER ORDERED that, pursuant to section 1.102(b)(1) of the Commission’s
rules, 47 C.F.R. § 1.102(b)(1), this Report and Order SHALL BE effective 30 days after publication in the
Federal Register.
FEDERAL COMMUNICATIONS COMMISSION

Julie A. Veach
Chief
Wireline Competition Bureau

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APPENDIX A
INSTRUCTIONS FOR DATA COLLECTION
FOR SPECIAL ACCESS PROCEEDING
WC DOCKET NO. 05-25, RM-10593
TABLE OF CONTENTS

Page #

I.

INTRODUCTION .............................................................................................................. 1

II.

FILING REQUIREMENTS AND GENERAL INSTRUCTIONS..................................... 1
A.
B.
C.
D.
E.
F.
G.
H.
I.
J.

III.

Purpose of Data Collection .................................................................................... 1
Authority for Data Collection ................................................................................ 1
Who Must Respond to this Data Collection?......................................................... 2
Responding to the Data Collection ........................................................................ 4
Geographic Scope of Submitted Data and Information ......................................... 5
When to File........................................................................................................... 5
Certification of Filing Accuracy ............................................................................ 5
Confidentiality ....................................................................................................... 5
Retention of Records ............................................................................................. 5
Paperwork Reduction Act Notices......................................................................... 6

ADDITIONAL INSTRUCTIONS AND DATA TABLE SPECIFICATIONS.................. 6
EXPLANATORY ATTACHMENT .................................................................................. 9
QUESTIONS DIRECTED AT COMPETITIVE PROVIDERS......................................... 9
Question II.A.1: Affiliated Company ................................................................................ 9
Question II.A.2: Facilities Requiring Additional Information......................................... 10
Facilities Information........................................................................................................ 10
Question II.A.3: Locations Data for Competitive Providers............................................ 10
Question II.A.4: Locations Data for Competitive Providers............................................ 12
Question II.A.5: Fiber Network Map............................................................................... 14
Question II.A.6: Sampling History of Competitive Connections by Location ................ 16
Question II.A.7: Collocations by Wire Center................................................................. 17
Question II.A.8: Business Rules for Deployment............................................................ 18
Question II.A.9: Headquarters ......................................................................................... 18
Question II.A.10: Marketing Plans .................................................................................. 20
Question II.A.11: Information on Requests for Proposals (RFPs)................................... 21
Billing Information ........................................................................................................... 22
Question II.A.12-14: Billing Information Overview ....................................................... 22
Question II.A.12: Prices by Circuit Element from Competitive Provider ....................... 22
Question II.A.13: Billing Adjustments ............................................................................ 30

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Question II.A.14: Billing Code Descriptions................................................................... 33
Revenues, Terms and Conditions Information ................................................................. 34
Question II.A.15: Sales Revenues for CBDS .................................................................. 34
Question II.A.16: Sales Revenues for PBDS................................................................... 35
Question II.A.17: Percentage of Revenues Generated from Agreement or Tariff
Containing a Prior Purchase-Based Commitment ............................................... 35
Question II.A.18: How do your terms and conditions compare with ILEC offerings? ... 35
Question II.A.19: Business Justification for Term and Volume Commitments .............. 35
QUESTIONS DIRECTED AT ILECS ............................................................................. 36
Question II.B.1: Affiliated Company............................................................................... 36
Facilities Information........................................................................................................ 36
Question II.B.2: ILEC Locations Data for ILECs ........................................................... 36
Question II.B.3: Locations Data for ILECs ..................................................................... 38
Billing Information ........................................................................................................... 39
Question II.B.4-6: Billing Information Overview ........................................................... 39
Question II.B.4: Prices by Circuit Element from ILECs ................................................. 39
Question II.B.5: Billing Adjustments .............................................................................. 48
Question II.B.6: Billing Code Descriptions..................................................................... 52
Question II.B.7: Wire Centers - CLLI Codes - Regulatory Treatment ............................ 53
Revenues, Terms and Conditions Information ................................................................. 53
Question II.B.8: Sales Revenues for CBDS..................................................................... 53
Question II.B.9: Sales Revenues for PBDS ..................................................................... 54
Question II.B.10: Revenues from One Month Term Only Rates..................................... 54
Question II.B.11: Number of Customers with One Month Term Only Rates ................. 54
Question II.B.12: All Applicable Tariff Plans and Contract-Based Tariffs..................... 55
Question II.B.13: Non-Tariffed Agreements ................................................................... 57
QUESTIONS DIRECTED AT ENTITIES PROVIDING BEST EFFORTS ................... 58
Question II.C.1: Census Blocks and Price Lists for 2010 and 2012 ................................ 58
QUESTIONS DIRECTED AT ALL PROVIDERS ......................................................... 60
Question II.D.1: Short Term and Long-Range Strategies................................................ 61
Question II.D.2: Location of Recorded Policies .............................................................. 61
QUESTIONS DIRECTED AT PURCHASERS THAT ARE MOBILE WIRELESS
SERVICE PROVIDERS................................................................................................... 61
Question II.E.1: Total Number of Cell Sites.................................................................... 61
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Question II.E.2: Cell Site Locations ................................................................................ 61
Expenditures Information ................................................................................................. 63
Question II.E.3: Total Expenditures on Dedicated Services............................................ 63
Question II.E.4: Expenditures with ILECs under Tariffs ................................................ 63
Question II.E.5: Expenditures with Competitive Providers under Tariffs....................... 64
Question II.E.6: Expenditures with ILECs and Competitive Providers Pursuant to NonTariffs................................................................................................................... 65
Question II.E.7: Expenditures under Tariffs for PBDS ................................................... 65
Question II.E.8: Expenditures under Non-Tariffs for PBDS ........................................... 66
Terms and Conditions Information................................................................................... 66
Question II.E.9: Terms and Conditions Constraints ........................................................ 66
Question II.E.10: Changing Transport Providers............................................................. 66
Question II.E.11: Purchases Solely for the Purpose of Meeting a Prior Purchase-Based
Commitment ........................................................................................................ 66
Question II.E.12: Switching Providers ............................................................................ 66
Question II.E.13: Paying One Month Term Only Rates .................................................. 66
Question II.E.14: Tariffs under which you Purchase Service.......................................... 67
Question II.E.15: Non-Tariffed Agreements ................................................................... 70
QUESTIONS DIRECTED AT OTHER PURCHASERS ................................................ 71
Question II.F.1: Principal Nature of Business ................................................................. 71
Expenditures Information ................................................................................................. 71
Question II.F.2: Total Expenditures on Dedicated Services ............................................ 71
Question II.F.3: Expenditures with ILECs under Tariffs................................................. 71
Question II.F.4: Expenditures with Competitive Providers under Tariffs ....................... 72
Question II.F.5: Expenditures with ILECs and Competitive Providers Pursuant to NonTariffs................................................................................................................... 73
Question II.F.6: Expenditures under Tariffs for PBDS ................................................... 73
Question II.F.7: Expenditures under Non-Tariffs for PBDS ........................................... 74
Terms and Conditions Information................................................................................... 74
Question II.F.8: Terms and Conditions Constraints ........................................................ 74
Question II.F.9: Changing Transport Providers............................................................... 74
Question II.F.10: Purchases Solely for the Purpose of Meeting a Prior Purchase-Based
Commitment ........................................................................................................ 74
Question II.F.11: Switching Providers............................................................................. 74
Question II.F.12: Paying One Month Term Only Rates .................................................. 74
Question II.F.13: Tariffs under which you Purchase Service .......................................... 75
Question II.F.14: Non-Tariffed Agreements.................................................................... 78
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QUESTION DIRECTED AT NON-PROVIDERS, NON-PURCHASERS, AND OTHER
ENTITIES NOT COVERED BY THE DATA COLLECTION....................................... 79
Question II.G.1: Not Required to Submit Data................................................................ 79

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I.

INTRODUCTION

On December 18, 2012, the Commission released an Order calling for the mandatory collection of data,
information and documents from entities that provide and purchase special access services in price cap
areas.1 Larger entities providing best efforts business broadband Internet access services are also required
to respond to the data collection. With the data, the Commission will conduct a comprehensive analysis
of special access markets to determine where relief from special access regulation is appropriate and
otherwise update its rules to ensure that they reflect the state of competition today and promote
competition. Italicized terms in these instructions are defined in Section I of the Mandatory Data
Collection, which is available on the FCC’s website.2
II.

FILING REQUIREMENTS AND GENERAL INSTRUCTIONS
A.

Purpose of Data Collection

This collection will enable the Commission to obtain the data, information, and documents needed to
conduct a comprehensive evaluation of competition in the special access market. In conjunction with the
market analysis proposed by the Commission in the Further Notice, the data, information, and documents
acquired through this collection will aid the Commission in “evaluating whether the pricing flexibility
rules result in just and reasonable special access rates and what regulatory changes may be needed.”3
B.

Authority for Data Collection

This collection of information stems from the Commission’s authority under sections 1, 4(i), 4(j), 5, 201205, 211, 215, 218, 219, 303(r), 332, 403, and 503 of the Communications Act of 1934, as amended, 47
U.S.C. §§ 151, 154(i), 154(j), 155, 201, 202, 203, 204, 205, 211, 215, 218, 219, 303(r), 332, 403, 503, and
section 706 of the Telecommunications Act of 1996, 47 U.S.C. § 1302.

1

See Special Access for Price Cap Local Exchange Carriers, WC Docket No. 05-25; AT&T Corporation Petition
for Rulemaking to Reform Regulation of Incumbent Local Exchange Carrier Rates for Interstate Special Access
Services, WC Docket No. 05-25, RM-10593, Report and Order and Further Notice of Proposed Rulemaking, 27
FCC Rcd 16318 (2012) (Special Access Data Collection Order). For purposes of these Instructions, our use of the
term “data” includes data and information.
2

See Special Access for Price Cap Local Exchange Carriers, WC Docket No. 05-25; AT&T Corporation Petition
for Rulemaking to Reform Regulation of Incumbent Local Exchange Carrier Rates for Interstate Special Access
Services, WC Docket No. 05-25, RM-10593, Order, DA 13-1909, App. B (WCB rel. Sept. 18, 2013) (Data
Collection Implementation Order).
3

See Special Access Data Collection Order, 27 FCC Rcd at 16341, para. 56.

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C.

Who Must Respond to this Data Collection?

All Providers and Purchasers of Dedicated Service in areas where the incumbent local exchange carrier
(ILEC) is subject to price cap regulation (i.e., price cap areas)4 must respond to this data collection unless
specifically excluded.5 By Providers, we mean any entity subject to the Commission’s jurisdiction under
the Communications Act of 1934, as amended, that provides Dedicated Service in a price cap area or
provides a Connection that is capable of providing a Dedicated Service in a price cap area. By
Purchasers, we mean any entity subject to the Commission’s jurisdiction that purchases Dedicated
Service in a price cap area. Entities that provide Best Efforts Business Broadband Internet Access
Services in an area where the ILEC is subject to price cap regulation are also required to respond to this
data collection unless they have fewer than 15,000 customers and fewer than 1,500 business broadband
customers as of December 18, 2012.6
Covered Providers. Types of Providers that must respond if they provide a Dedicated Service or have
Connections with the capability of providing a Dedicated Service could include, but are not limited to,
incumbent local exchange carriers, competitive local exchange carriers, interexchange carriers, cable
system operators, fixed wireless service providers (including wireless Internet service providers
(WISPs)), terrestrial and satellite mobile wireless service providers, electric utilities, local government
entities, certain providers of information services and third party network providers.
To help ensure that our analysis includes all Providers that have Connections capable of providing a
Dedicated Service, any entity required to report broadband connections to end user locations on the FCC
Form 477 (“Local Telephone Competition and Broadband Reporting”) for 2012 must respond to this
collection, i.e., required to file the FCC Form 477 on March 1, 2013, to report connections as of
December 31, 2012. If a FCC Form 477 filer does not (i) provide a Dedicated Service in a price cap area;
(ii) provide a Connection capable of providing a Dedicated Service in a price cap area; or (iii) provide a
Best Efforts Business Broadband Internet Access Service, then it will only need to certify as such when
responding to this data collection.
For example, a carrier providing or purchasing a Dedicated Service in an interstate rate-of-return area and
that reported broadband connections to end user locations in the Form 477 for Year 2012 would have to
4

A map depicting the study areas where an incumbent local exchange carrier (ILEC) subject to price cap regulation
is located is available on the FCC’s website. See Map: Regulatory Type at the Holding Company Level by Study
Area, FCC, http://www.fcc.gov/maps/regulatory-type-holding-company-level-study-area (last visited Sept. 9, 2013).
The Commission is currently updating this map based on a collection of study area boundaries. If the new study
area boundary data are not available to respondents in time for them to take into account in formulating responses to
the special access data collection, we will consider reliance on the currently available study area boundary data to be
reasonable.
5

Special Access Data Collection Order, 27 FCC Rcd at 16327, para. 20; see also Instructions at 3-4 (discussing
“Entities Specifically Excluded from the Data Collection”).
6

Special Access Data Collection Order, 27 FCC Rcd at 16327-28, para. 22 n.52 (“For purposes of this exemption,
the number of customers and business broadband customers shall be determined as of the date of release of this
Report and Order.”).

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respond to this data collection only to indicate that it is not a Provider, Purchaser, or entity that provides
Best Efforts Business Broadband Internet Access Services in a price cap area.
For guidance on determining whether you are a Provider with Connections “capable” of providing
Dedicated Service, see the additional instructions provided for identifying reportable Locations with
Connections in “Section III. Additional Instructions and Data Table Specifications,” Question II.A.3
(directed at Competitive Providers) and Question II.B.2 (directed at ILECs).
Covered Purchasers. Types of Purchasers that must respond if they buy a Dedicated Service in a price
cap area include, but are not limited to, ILECs, competitive local exchange carriers, interexchange carriers
(CLECs), cable system operators, wireless providers, satellite service providers, international service
providers to and from points in the United States, interconnected and non-interconnected VoIP providers,
and certain information service providers such as Internet access providers.
Responses are mandatory for covered Purchasers and Providers and covered entities providing Best
Efforts Business Broadband Internet Access Service. Failure to respond to this collection may result in
monetary penalties.7
Entities Specifically Excluded from the Data Collection. Entities falling into only one or more of the
categories listed below are specifically excluded from the collection even if they purchase Dedicated
Service in a price cap area. These exclusions do not apply, however, to entities that hold licenses,
authorizations or registrations under any other Part of the Commission’s rules not listed below, or that
provide a Dedicated Service or a Best Efforts Business Broadband Internet Access Service in a price cap
area.8


End Users that provide an information service;



Equipment authorization holders regulated under Parts 2 and 15 of the Commission’s rules;



Accounting authorization holders in the maritime and maritime mobile-satellite radio services
regulated under Part 3 of the Commission’s rules;



Experimental radio authorization holders regulated under Part 5 of the Commission’s rules;



Commercial radio operators regulated under Part 13 of the Commission’s rules;



Antenna structure registration holders regulated under Part 17 of the Commission’s rules;



Television and radio broadcasters regulated under Part 73 of the Commission’s rules;

7

47 U.S.C. § 503(b)(2); 47 C.F.R. § 1.80(b); Amendment of Section 1.80(b) of the Commission’s Rules, Adjustment
of Forfeiture Maxima to Reflect Inflation, Order, 23 FCC Rcd 9845 (2008).
8

For example, an entity holding an earth station license issued under Part 25 of the Commission’s rules that also has
an experimental license issued under Part 15 (a listed exclusion category), is not excluded from the collection if it
purchased Dedicated Service in a price cap area during the relevant reporting periods. Likewise, an entity holding
an antenna structure registration under Part 17 (a listed exclusion category) is not excluded from the collection if it
provided a covered Best Efforts Business Broadband Internet Access Service in a price cap area.

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

Holders of authorizations issued pursuant to Part 74 of the Commission’s rules such as
experimental radio, auxiliary, special broadcast and other program distribution service
authorizations;



Maritime service authorization holders regulated under Part 80 of the Commission’s rules;



Aviation service authorization holders regulated under Part 87 of the Commission’s rules;



Private land mobile radio service authorization holders regulated under Part 90 of the
Commission’s rules except for holders of authorizations under Part 90 for the provision of
point-to-point fixed microwave services and authorizations in the Wireless Broadband
Services frequency band, 3650-3700 MHz;



Personal radio service authorization holders regulated under Part 95 of the Commission’s
rules; and



Amateur radio service authorization holders regulated under Part 97 of the Commission’s
rules.

These exclusions only apply to the categorically excluded entity and do not extend to other entities within
the same corporate structure or entities that are otherwise affiliated with the excluded entity. For
example, if an entity holding a television broadcast authorization is affiliated with a cable company that
provides Dedicated Service, the affiliated cable company must still respond to the data collection even
though the television broadcasting entity is not required to respond. In addition, for clarity, we point out
that these categorical exclusions do not include common carriers (wired or wireless), mobile wireless
service providers, cable system operators even if they only provide video program services, international
service providers, satellite service providers, or entities that hold FCC authorizations for the provision of
fixed point-to-point microwave services.
Note that even if you fall within one of these specific exclusion categories but were required to report
broadband connections to end users on the Form 477 for 2012, you are still required to respond to this
data collection only to indicate that you are not a Provider, Purchaser, or entity that provides Best Efforts
Business Broadband Internet Access Services in a price cap area.
D.

Responding to the Data Collection

The Commission will create a secure Special Access Web Portal for the electronic submission of
responses.9 Filers will login using an FCC Registration Number (FRN) and password and download a
data container that will include record specifications for compiling data responses and software tools to
verify that data is submitted in the appropriate format.10 Filers will subsequently login using its FRN and
password and electronically submit responses to the data collection. The Wireline Competition Bureau
9

Alternatively, for submissions containing too much data to reliably upload, respondents can make arrangements
with the Bureau for the manual submission of hard drives or other data storage devices containing their responses.
10

Responses must conform to the specifications provided in the data container. We intend to submit the instructions
and record format specifications to OMB as part of the application package seeking approval for the information
collection.

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(Bureau) will provide additional details on the electronic filing process in advance of the submission
deadline.
E.

Geographic Scope of Submitted Data and Information

With limited exceptions, we are requesting data on a nationwide basis for those geographic areas where
the ILEC is subject to price cap regulation. However, for administrative ease, respondents can submit
data that includes both price cap and non-price cap areas.
F.

When to File

Once the collection is approved by the Office of Management and Budget (OMB) in accordance with the
Paperwork Reduction Act of 1995, the Bureau will issue a public notice announcing when responses are
due.
G.

Certification of Filing Accuracy

Each submission must include a completed certification of filing accuracy. The certification must include
the name and signature of a company official (e.g., corporate officer, managing partner, or sole
proprietor) who certifies that he or she has examined the information contained in the data request
submission and that, to the best of his/her knowledge, information, and belief, all statements of fact, data,
and information contained in the submission are true and correct. Persons making false statements or
misrepresentations to the Commission can be punished by fine or imprisonment under Title 18 of the U.S.
Code. A sample certification is contained in the Mandatory Data Collection.11 Filers will electronically
submit the certification when submitting the Filer Identification Information electronically filed
with each submission, see “Section III: Additional Instructions and Data Table Specifications.”
H.

Confidentiality

Respondents are required to submit data and information on revenues, prices, expenditures, subscribers,
and facilities for the collection that is highly sensitive and not routinely made available to the public. In
advance of the filing deadline, the Bureau will issue a Protective Order detailing the procedures for
requesting confidentiality and accessing confidential and highly confidential data and information.12
I.

Retention of Records

Respondents are required to retain, for a period of three years or until the Commission issues a notice
relieving respondents of this requirement, any records, data, documents, documentation, or other
information prepared, used, or relied upon by the respondents for their responses to this data collection.13

11

See Data Collection Implementation Order, App. B.

12

See Wireline Competition Bureau Seeks Comment on Protective Order for Special Access Data Collection, WC
Docket No. 05-25, RM-10593, Public Notice, DA 13-1470 (WCB rel. June 28, 2013).
13

See Special Access Data Collection Order, 27 FCC Rcd at 16340, para. 54.

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J.

Paperwork Reduction Act Notices

This document contains information collection and recordkeeping requirements and will not become
effective until approval has been given by the OMB. Covered parties are not required to respond to the
information collection and recordkeeping requirements contained herein until a notice of approval has
been published in the Federal Register.
The time needed to complete and file responses to the data collection will vary depending on individual
circumstances. There is significant variation among Providers and Purchasers in the number of questions
to be answered and the amount of responsive data and information they are required to furnish. We have
estimated that each response to this collection of information will take an average of XX hours. This
estimate is a national average and does not necessarily represent a “typical” case. Our estimate includes
the time to read the instructions, look through existing records, gather and maintain required data, enter
the data in the online interface, and submit it electronically. If you have any comments on this estimate,
or on how we can improve the collection and reduce the burden it causes you, please write the Federal
Communications Commission, Office of Managing Director, AMD-PERM, Washington, DC 20554,
Paperwork Reduction Act Project (3060-XXXX). We will also accept your PRA comments via the
Internet if you send an email to [email protected].
Please DO NOT SEND COMPLETED DATA COLLECTION RESPONSES TO THIS ADDRESS. You
are not required to respond to a collection of information sponsored by the Federal government, and the
government may not sponsor this collection, unless it displays a currently valid OMB control number
and/or we fail to provide you with this notice. This collection has been assigned an OMB control number
of 3060-XXXX.
THIS NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW
104-13, OCTOBER 1, 1995, 44 U.S.C. SECTION 3507.
III.

ADDITIONAL INSTRUCTIONS AND DATA TABLE SPECIFICATIONS

To access the FCC website interface to submit responses to this data collection, each filer is required to
provide an FRN that is unique to the filer and password, i.e., no two filers can submit responses using the
same FRN.14 No filer can submit more than one response to the data collection questions; subsequent
corrective filings are permitted however. When submitting a response, each filer must provide the
information identified below and the requisite certification.15

14

For instructions on how to obtain an FRN, see https://fjallfoss.fcc.gov/coresWeb/publicHome.do.

15

Contact [FCC Contact] to discuss the manual submission of your database container file on hard drive(s) if it is
excessively large and cannot reasonably be submitted electronically to the FCC using the SSH File Transfer
Protocol, i.e., if the file is more than 11 gigabytes in size. The Filer Identification Information and Certification is
required even for manual submissions.

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Filer Identification Information
Name of Filer

[Text populated from CORES database]

Filer’s FCC Registration Number (FRN)

[Integer populated from CORES database]

Name of Contact for Filer

[Text]

Contact Phone Number

[Text]

Contact Address

[Text]

Contact Email Address

[Text]

Counsel of Record Name

[Text]

Counsel of Record Phone Number

[Text]

Counsel of Record Address

[Text]

Counsel of Record Email Address

[Text]

Holding Company FRN

[Integer]

Holding Company Name

[Text populated from CORES database]

Filer Identification Information cont.
□ Competitive Provider
Type of Competitive Provider (select all that apply):

□ Cable system operator
□ CLEC

Type of Filer (select all that apply)

□ IXC
□ Wireless provider
□ Other
□ ILEC
□ Entity that provides Best Efforts Business Broadband Internet Access Service to
Type of Filer cont. (select all that apply)

15,000 or more customers or 1,500 or more business broadband customers in price cap
areas

□ Purchaser
Type of Purchaser (select all that apply):

□ Mobile wireless service provider
□ Other
□ None of the above
(i.e., you are not a Provider, Purchaser, or an entity that provides Best Efforts Business
Broadband Internet Access Service to 15,000 or more customers or 1,500 or more
business broadband customers in price cap areas

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Counsel of Record. If you are represented by counsel and want to designate such counsel for the service
of notices and other documents, then complete the “Counsel of Record” fields in the Filer Identification
Information.
Holding Company. 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.
In addition, list the name and FRN for all companies covered by the submission in the “Explanatory
Attachment” and identify the companies whose information is being reported in response to a particular
section of the data collection.16 For example, the responses to Section II.A include information from
ABC CLEC Co. and DEF CLEC Co. and the responses to Section II.E include information from ABC
Wireless Co.
If filing separate responses, identify the name and FRN of the filer’s ultimate parent/holding company or
controlling entity. All reporting affiliates or commonly controlled entities must list the identical ultimate
parent/holding company name or controlling entity and FRN so the FCC can internally link the responses
to a single ultimate parent/holding company or controlling entity. In addition, 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 [FCC contact].
Corrective Resubmissions. If you need to make a corrective resubmission, contact [FCC contact name] to
make arrangements. Include with your corrective resubmission an explanation of the nature of the
correction, i.e., explaining what information you are correcting and why.

Certification
I have examined the response and certify that, to the best of my knowledge, all statements of fact, data, and information contained
therein are true and correct.
Signature
Name
Title
Date
Respondents are reminded that failure to comply with these data reporting requirements may subject them to monetary forfeitures of
up to $150,000 for each violation or each day of a continuing violation, up to a maximum of $1,500,000 for any single act or failure
to act that is a continuing violation. 47 U.S.C. § 503(b)(2); 47 C.F.R. § 1.80(b); Amendment of Section 1.80(b) of the Commission’s
Rules, Adjustment of Forfeiture Maxima to Reflect Inflation, Order, 23 FCC Rcd 9845 (2008). False statements or
misrepresentations to the Commission may be punishable by fine or imprisonment under Title 18 of the U.S. Code.

16

See Instructions at 9.

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The following is a chart showing the types of filers and the corresponding sections of data collection
questions that must be completed by each filer type. Filers falling within multiple categories must
respond to all applicable sections. For example, a Competitive Provider that purchases Dedicated
Services must respond to the data collection questions directed at Competitive Providers and Purchasers.
Type of Filer

Sections of the Data Collection that Must be Completed

Competitive Provider
ILEC
Entity that provides Best Efforts Business
Broadband Internet Access Service to
15,000 or more customers or 1,500 or
more business broadband customers in
price cap areas
Purchaser that is a mobile wireless
service provider
Purchaser that is not a mobile wireless
service provider
None of the above

Sections II.A and II.D if answer to Questions II.A.2 or II.A.2.a is “yes”
Sections II.B and II.D
Section II.C

Section II.E
Section II.F
Section II.G

EXPLANATORY ATTACHMENT
To the extent you need to explain certain assumptions or procedures taken in collecting and reporting the
information requested in this data collection, especially for the responses to the facilities and billing
information questions, include a separate document with your submission, in Word or .pdf format,
containing all of your explanations.17 You must separately upload the Explanatory Attachment as a Word
or .pdf document through the Special Access Web Portal; you will not include this document in the data
container.
QUESTIONS DIRECTED AT COMPETITIVE PROVIDERS
Question II.A.1: Affiliated Company
If you are an Affiliated Company, then you must identify each entity you are affiliated with that provides
and/or purchases Dedicated Service in Table II.A.1 within the data container. If you are not an Affiliated
Company, then you must still type “Not Applicable” in the Affiliate_Name field and “0000000000” in the
Name_FRN field. You will receive an error message upon validation of the data container if you do not
put any information into Table II.A.1.
Table II.A.1
Record Format for Affiliated Company
Field Name

Description

Type

Example

Affiliate_ID

Sequential number

Integer

1

Affiliate_Name

Name of entity with which you are affiliated

Text

Local Fiber
Incorporated

17

See, e.g., Data Collection Implementation Order, App. B, Questions II.A.4 (asking for information on Locations)
and II.A.12 (asking for billing information).

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Entity’s FCC Registration Number
(with leading zeros)

Name_FRN

Integer

0008402202

Question II.A.2: Facilities Requiring Additional Information
Table II.A.2
Record Format for Facilities Triggering Need for Additional Information
Field Name
Connection

Price_Cap?

Description
Do you own a Connection; lease a Connection under
an IRU agreement; or obtain a Connection as a UNE
to provide a Dedicated Service? (Y=Yes, N=No)
Are any of the Connections – that you own; lease as
an IRU; or obtain as a UNE to provide a Dedicated
Service – to a Location in a price cap area? (Y=Yes,
N=No, NA=Not Applicable)

Type

Example

Text

Y

Text

Y

Facilities Information
Question II.A.3: Locations Data for Competitive Providers
Competitive Providers are required to report the total number of Locations to which they had a
Connection during 2010 and during 2012 where the Competitive Provider either: (i) owned the
Connection; (ii) leased the Connection from another entity under an IRU; or (iii) obtained the Connection
as a UNE to provide a Dedicated Service. The definition of Connection is crafted to assist the
Commission with sizing the broader market for Dedicated Services by including transmission facilities
used to provide a Dedicated Service and facilities that are “capable” of providing a Dedicated Service.
To help Competitive Providers identify reportable Locations, we provide the following guidance:
 Respondents must only report Connections to non-residential Locations. A Location is where an
End User is connected, and an End User means a business, institutional, or government entity that
purchases service for its own purposes, not for resale. Accordingly, residential locations
connected by facilities are not reported.


Competitive Providers, except for cable system operators reporting Locations within their
Franchise Areas (FAs), must report all Locations with idle and in-service Connections during the
relevant reporting period regardless of the type of service provided over the Connection.



If you are a cable system operator and reporting Locations within your FA, you must report those
Locations with Connections that were connected to a Node (i.e., headend) during the relevant
reporting period that was upgraded or built to provide Metro Ethernet (or its equivalent) service
regardless of the type of service provided over the Connection or whether the Connection is idle
or in-service.18 In addition, for Locations with Connections that were not connected to a Node

18

Metro Ethernet is an Ethernet metropolitan area network service offering that involves centrally positioning one or
more gigabit Ethernet (GbE) or 10 gigabit Ethernet (10 GbE) switches in a metro area. It offers the advantage of
carrying all traffic in native Ethernet format, with no requirement for introducing SDH/SONET, frame relay, ATM
or other Physical Layer or Data Link Layer protocols that can increase both complexity and cost, while adding
overhead. See Webster’s New World Telecom Dictionary (2010); see also Ralph Santitoro, Metro Ethernet Forum
White Paper, Metro Ethernet Services – A Technical Overview (2006), available at
(continued….)

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during the relevant reporting period that is capable of providing Metro Ethernet (or its
equivalent), report only in-service Connections that were used to provide a Dedicated Service or a
service that incorporates a Dedicated Service within the offering as part of a managed solution or
bundle of services sold to the customer;19 do not report Connections that were used to provide a
service that is substantially similar to services provided to residential customers, e.g., one or two
line telephone service or best-efforts Internet access and subscription television services.20


For Locations with Connections obtained as a UNE to provide a Dedicated Service during 2010
and during 2012, all Competitive Providers must include those UNEs obtained to provide a
service that incorporated a Dedicated Service within the offering as part of a managed solution or
bundle of services sold to the customer.21
Table II.A.3
Record Format for Total Locations

Field Name

Description

Type

Example

Year

Indicator of the calendar year of the data

Integer

2010

Locations

Total Locations served during year

Integer

15

Instructions for Table II.A.3, Record Format for Total Locations (Competitive Providers):

(Continued from previous page)
http://metroethernetforum.org/White_Papers/metro-ethernet-services.pdf (providing a comprehensive technical
overview of Ethernet services) (last visited Sept. 9, 2013).
19

Examples of services incorporating a Dedicated Service could include: the Converged Business Network solution
offered by Level 3; High-Speed Dedicated Internet Access from XO or a business Ethernet solution from TW
Telecom. See Converged Business Network, Level 3 Communications Inc. (Level 3),
http://www.level3.com/en/products-and-services/data-and-internet/converged-business-network/ (discussing Level
3’s Converged Business Network offering that combines Internet, data and voice services over a single access
circuit) (last visited Sept. 9, 2013); Dedicated Internet Access, XO Communications, LLC,
http://www.xo.com/services/network/dia/Pages/overview.aspx (discussing dedicated Internet access) (last visited
Sept. 9, 2013); Business Ethernet, tw telecom, Inc., http://www.twtelecom.com/telecom-solutions/voicesolutions/business-ethernet-services/ (discussing business Ethernet services) (last visited Sept. 9, 2013).
20

See, e.g., Business Internet + Voice, Comcast Corp. (Comcast), http://business.comcast.com/smb/bundle
(discussing a Comcast Business Class bundled service offering that includes business voice, web hosting, email, and
Internet access at monthly rates) (last visited Sept. 9, 2013); Cox Business Internet, Cox Communications, Inc.,
http://ww2.cox.com/business/oklahomacity/data/business-internet.cox?campcode=gntile_b_data_internet (last
visited Sept. 9, 2013); Business Internet, Bright House Networks, http://business.brighthouse.com/products-andservices/data-and-internet/broadband-internet.html (last visited Sept. 9, 2013); Optimum: TV, Phone and Internet
Services for your Business, Cablevision Systems Corp., http://www.optimumbusiness.com/ (last visited Sept. 9,
2013).
21

See supra note 19 (providing example of services incorporating a Dedicated Service).

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

Locations: The number of Locations is the count of unique Locations to which your company
had a Connection in place during the year entered in Year. The number of Locations listed here
must equal the number of unique Locations enumerated in Question II.A.4 for each year.

Question II.A.4: Locations Data for Competitive Providers
The purpose of this question is to obtain additional information on the individual Locations with
Connections that make up the total reported in response to Question II.A.3.
Table II.A.4
Record Format for Each Location
Field Name
Location_ID
Year

Description
Sequential Location number (same Location_ID will
also be reported in the II.A.12 question related to
billing).
Indicator of the calendar year of the data

Type

Example

Integer

1

Integer

2010

Street_address

Actual situs for the Location (i.e., land were building
or cell site is located)

Text

445 Twelfth St SW

City

City of the Location

Text

Washington

State

Two-letter state postal abbreviation of the Location

Text

DC

ZIP

5-digit ZIP code (with leading zeros) of the Location

Text

20554

ZIP4

4-digit add-on code (with leading zeros) of the
Location

Text

0000

Lat

Latitude

Float

38.8835

Long

Longitude
The type of Location is a 1=building; 2=other manmade structure; 3=cell site in or on a building;
4=free-standing cell site; 5=cell site on some other
man-made structure, e.g., water tower; or
6=unknown.

Float

-77.0280

Integer

1

Loc_type

IRU_Supplier

If Connections to this Location are obtained under an
IRU, enter the name of the entity from which the
majority of capacity is obtained.

Text

DEF Co.

UNE_Supplier

If Connections to this Location are obtained as a
DS1/DS3 UNE, enter the name of the entity from
which the UNE is obtained.

Text

DEF Co.

UCL_Supplier

If Connections to this Location are obtained as an
Unbundled Copper Loop, enter the name of the
entity from which the UCL is obtained.

Text

DEF Co.

Medium

Are any of the Connections to this Location provided
over fiber? (Y/N)

Text

Y

Sold_bandwidth_total

Total bandwidth (in Mbps) of Connections provided
to the Location as sold.

Float

1.544

Sold_bandwidth_enduser

Total bandwidth (in Mbps) of Connections provided
to End Users at the Location as sold.

Float

1.544

Sold_bandwidth_tfw

Total bandwidth (in Mbps) of Connections provided
to the Location using terrestrial fixed wireless as
sold.

Float

1.544

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Table II.A.4
Record Format for Each Location
Field Name

Description

Type

Example

Sold_bandwidth_Mobile

Total bandwidth (in Mbps) of Connections to cell
sites at the Location as sold.

Float

1.544

Bandwidth_Internal

Total bandwidth used internally.

Float

1.544

Instructions for Table II.A.4, Record Format for Each Location (Competitive Providers):










Location_ID: This is a sequential integer ranging from 1 to the total number of unique Locations
to which your company had a Connection during the year reported. This field is linked to the
billing information reported in Question II.A.12 so that you must identify in Table II.A.4 every
Location ID referenced in response to the billing information question.
Year: Report the year during which your company had a Connection to the Location, i.e., 2010
or 2012.
The data fields used to identify the actual situs address must be space-delimited in standardized
Postal Service form. See http://pe.usps.gov/cpim/ftp/pubs/Pub28/pub28.pdf.
Latitude and Longitude: You can derive the coordinate fields for the location address from a
known geocoding platform like Bing maps, Google, Yahoo, batchgeo.com, Texas A&M
Geoservices or other geocoding solution. Enter values in decimal degrees to the nearest ±0.0005,
i.e., each coordinate must end in #.###0 or #.###5. Coordinates must be in the WGS84 or
NAD83 geographic coordinate system.
IRU_Supplier: Because multiple dedicated communication paths serving one or more End Users
at the same Location must be counted as a single Connection (see definition of Connection), if
you lease multiple IRUs to this Location from different Providers, identify the Provider that
supplies the majority of the capacity you lease per an IRU. If only one Provider supplies the
IRU(s), then identify that Provider as the supplier. If you do not know the name of the supplier
of your Connections via IRU agreement(s), and cannot reasonably identify the supplier for each
IRU, you can alternatively enter “unknown” in this field and indicate in the Explanatory
Attachment the total number of Connections to Locations you obtain as an IRU and the general
percentage of IRU leasing arrangements you have with particular types of suppliers, e.g., 45% of
our IRUs are with ILECs, 55% with Competitive Providers or non-ILECs.
Sold_bandwidth fields: These data fields call for the reporting of total bandwidth sold. Report
the downstream or upstream bandwidth of Dedicated Services sold across all sold Connections of
the type requested at the Location as of December 31 of the year. Report the upstream or
downstream bandwidth for symmetric services. For asymmetric services, report the average of
the upstream and downstream bandwidths. For example, for a DS1 record 1.544, for three DS1s
record 4.632, while for a 10 Gbit Ethernet service, 10,240, and for a fractional DS1 sold as a 384
Kbps service record 0.375. In the case where a Connection is in place but no bandwidth was
provided as of December 31 of the year, enter the total bandwidth sold at the last known date
during the relevant reporting period. For example, a customer or customers at the Location
purchased service through October of the year but then terminated the service so that there was no
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

service sold as of December 31; in that instance, report the total bandwidth sold in October.
Exclude services other than Dedicated Service provided to the Location from your response. In
the case where no Dedicated Service was sold to the Location, enter zero.
Bandwidth_Internal: If you are using bandwidth on this Connection to the Location for your own
internal purposes, i.e., self-provisioning service to yourself or an Affiliated Company, then report
the total bandwidth used internally as of December 31 of the year. Report the upstream or
downstream bandwidth for symmetric services. For asymmetric services, report the average of
the upstream and downstream bandwidths. For example, for a DS1 record 1.544, for three DS1s
record 4.632, while for a 10 Gbit Ethernet service, 10,240, and for a fractional DS1 sold as a 384
Kbps service record 0.375. In the case where a Connection is in place but no bandwidth was used
internally as of December 31 of the year, enter the total bandwidth used internally at the last
known date during the relevant reporting period. In the case where no bandwidth was used for
internal use, enter zero.

Question II.A.5: Fiber Network Map
Fiber Map. Competitive Providers must provide a map of the fiber routes that constitute their network.
Include those fiber “spans” (i.e., lengths of fiber with terminating equipment on both ends) within your
network that you (i) own or (ii) lease pursuant an IRU agreement. The map must show the fiber routes
that constitute your network, including the “middle-mile” transport fiber network and any fiber routes to
Locations.
You can file either a single map showing your network throughout your service territories in the United
States or file separate maps showing the network on a regional/local basis. Filers are not required to
include their long haul connections between service territories, e.g., interLATA connections between
points of presence (POP) such as the connections between a POP in Los Angeles, California and POP in
New York City.
Nodes. Identify all Nodes on your network that are points of interconnection with the networks of other
Providers and indicate the year that the Node was first used for interconnecting with another
Provider. Cable system operators must also separately indicate those Nodes that are headends that have
been upgraded to provide a Metro Ethernet (or its equivalent) service. In lieu of identifying Nodes used
for interconnection, you can submit to the Commission the interconnection data on file with the Central
Location Online Entry System (CLONES) database for your operations.22 The certification submitted in
connection with your submission will attest that the CLONES data are current and accurately depict your
network interconnection points and the “live” dates to the best of your knowledge.
Mapping information must be provided as a separate ESRI Shapefile using a line feature class containing
the data for each feature as noted below.

22

See System and Tools, Iconectiv, https://codecenter.commonlanguage.com/systems.asp?#clones (providing
information about CLONES) (last visited Sept. 9, 2013).

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Shapefile Record Format for Fiber Network
Field Name

Description

Type

Example

Provider

Provider Name

Text

ABC Co.

DBA

“Doing-business-as” name

Text

Superfone, Inc.

FRN

Provider FCC Registration Number (with leading zeros)

Text

0008402202

ID

Sequential record number

Integer

1

Instructions for Shapefile Record Format for Fiber Network Map:








The shapefile must have an assigned projection w/accompanying .prj file.
The shapefile must use an unprojected (geographic) WGS84 geographic coordinate system.
The shapefile must conform to the 1:24,000 U.S. Geological Survey National Map standard.
The ID field is a sequential integer ranging from 1 to the total number of line features.
Maps must be accompanied by metadata or a plain text “readme” file that contains a
comprehensive explanation of the methodology employed to generate the map layer including
any necessary assumptions and an assessment of the accuracy of the finished product.
The shapefile must be submitted as a WinZip archive with a name containing the company name
and FRN (e.g., CompanyName_12345678_Fiber.zip).
Cable system operators must include the FCC-assigned Physical System Identifier (PSID)
associated with each system identified.

Node information must be provided as a delimited text file, e.g., .csv, that contains the following
information.
Record Format for Nodes
Field Name

Description

Type

Example

Provider

Provider Name

Text

ABC Co.

DBA

“Doing-business-as” name

Text

Superfone, Inc.

FRN

Provider FCC Registration Number (with leading zeros)

Text

0008402202

ID

Sequential record number

Integer

1

Lat

Latitude

Float

38.8835

Long

Longitude

Float

-77.0280

Text

N

Integer

1996

Headend
NodeYear

Is this Node a headend that has been upgraded to provide a
Metro Ethernet (or its equivalent) service? (Y=Yes; N=No)
Date Node went “live” or when headend was upgraded to Metro
Ethernet (or its equivalent) service

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Instructions for Record Format for Nodes:




Latitude and Longitude: Enter values in decimal degrees to the nearest ±0.0005, i.e., each
coordinate must end in #.###0 or #.###5. Coordinates must be in the WGS84 or NAD83
geographic coordinate system.The shapefile must be submitted as a WinZip archive with a name
containing the company name and FRN (e.g., CompanyName_12345678_Fiber.zip).
NodeYear: If on or after 1995 the Node was first used for interconnecting with another Provider
or in the case of cable system operators, was upgraded to provide Metro Ethernet (or its
equivalent) service, then provide the year. If before 1995, then provide the year or enter 1000 if
unknown. We encourage respondents to provide actual dates for as far back as they are able.

Uploading Documents. All files and documents responding to this question must be submitted to the
FCC through the Special Access Web Portal (in the “Essay Questions – File Upload” section). You will
not include this information in the data container.
The web portal contains two areas for uploading documents and files. One is for uploading the
“Confidential” version of the document or file where you will indicate information deemed Confidential
and redact information that is Highly Confidential based on the Protective Order issued for the data
collection. The second area is for uploading the “Highly Confidential” version of the document or file
noting both Confidential and Highly Confidential information without any redactions. You must upload
at least one document or file in each area or you will receive an error message during the submission
process. If the document or file does not contain Confidential or Highly Confidential information, e.g.,
all information is publicly available, then upload the document or file in each area without the relevant
Confidential/Highly Confidential notations or redactions in the case of the Confidential upload area.
Question II.A.6: Sampling History of Competitive Connections by Location
Based on your response to Question II.A.4, we will provide you with a list of Locations to which your
company had a Connection in 2012. For each Location listed, provide the month and year – in the format
set forth in Table II.A.6 – that you first served the Location with a Connection that you (i) owned; (ii)
leased under an IRU; or (iii) obtained as a UNE to provide Dedicated Service.
We will derive the sample list of Locations as follows. A random sample will be drawn from the
Locations entered in Table II.A.4 equal to the maximum of: (i) p percent of the Locations to which your
company had a Connection in 2012 rounded up to the nearest integer or (ii) the number two.23
Competitive Providers with one such Location will not need to answer this question. The percentage p
will be selected to ensure that about 1,600 sampling units are drawn; based on a current estimate that
Competitive Providers serve on their own facilities 200,000 Locations, the value of p is expected to be on
the order of 0.8 percent. This sample size is expected to provide ranges for estimates of proportions of
the national population that are with 95% confidence expected to include the true value of the estimated
proportion within ±2.5% of the estimate. For example, if the sample produces an estimate of 50% of the
national population, the true value of the proportion would be in the range (47.5%, 52.5%) with 95%
confidence. The four served Locations nearest each of the sampled served Locations will be added to the
random sample of served Locations, and the resulting list, with duplicates removed, will be given to you.
23

Forcing a minimum of two sampling units per Competitive Provider allows for unambiguous estimates of the
stratified sample’s standard deviation.

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To be clear, you will not include an answer to this question within the data container or otherwise with
your initial submission to the data collection. The record format for when you do subsequently respond
to this sampling question is provided below:
Record Format for History of Competitive Connections by Location
Field Name

Description

Type

Example

…

…The carrier’s record ID for a number of locations will
be returned…

…

…

First_served

The month and year this Location was first served

Date

12/2009

Question II.A.7: Collocations by Wire Center
For each ILEC wire center where your company is collocated, provide the information listed below.
Table II.A.7
Record Format for Collocations by Wire Center
Field Name

Description

Type

Example

ID

Sequential record number

Integer

1

Street_address

Actual situs (i.e., land were building is located) address
of the collocation site

Text

1025 N Irving Street

City

City of address

Text

Arlington

State

Two-letter state postal abbreviation of address

Text

VA

ZIP

5-digit ZIP code (with leading zeros) of address

Text

22201

ZIP4

4-digit add-on code (with leading zeros) of address

Text

0005

Lat

Latitude

Float

38.8840

Long

Longitude

Float

-77.0965

CLLI

Telcordia-specified eight-character CLLI

Alphanumeric

ARTNVAAR

Instructions for Table II.A.7, Record Format for Collocations by Wire Center:





Leave cells blank in the case of data that is not applicable for that record.
The ID field is a sequential integer ranging from 1 to the total number of wire centers.
Address data fields must be space-delimited in standardized Postal Service form. See
http://pe.usps.gov/cpim/ftp/pubs/Pub28/pub28.pdf.
Latitude and Longitude: You can derive the coordinate fields for the location address from a
known geocoding platform like Bing maps, Google, Yahoo, batchgeo.com, Texas A&M
Geoservices or other geocoding solution. Enter values in decimal degrees to the nearest ±0.0005,

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i.e., each coordinate must end in #.###0 or #.###5. Coordinates must be in the WGS84 or
NAD83 geographic coordinate system.
For the CLLI code, enter the first eight digits of the CLLI code of the ILEC wire center / end
office in which your equipment is collocated.

Question II.A.8: Business Rules for Deployment
You must upload a .pdf text searchable (not a picture/image) document responding to this question
through the Special Access Web Portal in the “Essay Questions – File Upload” section; you will not
include these documents in the data container.
The web portal contains two areas for uploading documents. One is for uploading the “Confidential”
version of the document where you will indicate information deemed Confidential and redact information
that is Highly Confidential based on the Protective Order issued for the data collection. The second area
is for uploading the “Highly Confidential” version of the document noting both Confidential and Highly
Confidential information without any redactions. You must upload at least one document in each area or
you will receive an error message during the submission process. If the document does not contain
Confidential or Highly Confidential information, e.g., all information is publicly available, then upload
the document in each area without the relevant Confidential/Highly Confidential notations or redactions
in the case of the Confidential upload area.
Question II.A.9: Headquarters
Competitive Providers, except for cable system operators, must answer this question. Cable operators
must still report “Not Applicable” as instructed below to avoid receiving an error message when
validating the data container.
This question asks for the location of a Competitive Provider’s current and prior U.S. headquarters, going
as far back as 1995. In addition, Competitive Providers must identify the headquarters of Affiliated
Companies and entities acquired through merger that no longer exist if the affiliated or acquired entity
owned (or leased under an IRU agreement) Connections to five or more Locations in a given MSA at the
time of affiliation/acquisition, going as far back as 1995.
By “U.S. headquarters,” we mean the principal place where the company’s high level officers direct,
control and coordinate the company’s activities.24 For purposes of this question, we do not consider
regional field offices to be the U.S. headquarters for a company.
Table II.A.9.a-c
Record Format for U.S. Headquarters
Field Name

Description

Type

Example

Street_address

Situs address of the U.S. headquarters (i.e., land were building is
located)

Text

1025 N Irving
Street

24

High level officers could include the president, chief executive officer, chief financial officer, vice president,
general counsel, etc.

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Table II.A.9.a-c
Record Format for U.S. Headquarters
Field Name

Description

Type

Example

City

City name for U.S. headquarters

Text

Springfield

State

State name for U.S. headquarters

Text

Texas

ZIP

5 digit ZIP code for U.S. headquarters

Text

22201

ZIP4

4-digit add-on code (with leading zeros) of address

Text

0005

Year_Head

Year when U.S. headquarters established

Year

2000

Instructions for Table II.A.9.a-c, Record Format for U.S. Headquarters:
 In the initial row of the table, you will identify your current U.S. headquarters and the year
established in the Year_Head field. Cable system operators must type “Not Applicable” in the
Street_Address field and complete the remaining fields with zeros. You will receive an error
message upon validation of the data container if you do not put any information into these data
fields.
 In subsequent rows of the table, you will identify your prior U.S. headquarters going as far back
as 1995 if different from the location of your current headquarters.
Table II.A.9.d
Record Format for Headquarters of Acquired Entities
Field Name

Description

Type

Example

AcqEntity_Name

Name of acquired entity

Text

Street_address

Text

City

Situs address for the U.S. headquarters of acquired entity at time
of merger
City name for U.S. headquarters

Text

Local Fiber
Incorporated
1025 N Irving
Street
Springfield

State

State name for U.S. headquarters

Text

Texas

ZIP

5 digit ZIP code for U.S. headquarters

Text

22201

ZIP4

4-digit add-on code (with leading zeros) of address

Text

0005

Year_Head

Year when entity merged, i.e., when transaction closed

Year

2000

Instructions for Table II.A.9.d, Record Format for Headquarters of Acquired Entities:


If you did not acquire an entity during the relevant reporting period or are a cable system
operator, then you must still type “Not Applicable” in the AcqEntity_Name field and complete
the remaining fields with zeros. You will receive an error message upon validation of the data
container if you do not put any information into these data fields.

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Table II.A.9.e-f
Record Format for Headquarters for Affiliated Companies
Field Name

Description

Type

Example

AffCompany_Name

Name of Affiliated Company

Text

Year of Affiliation

Year you became affiliated with the Affiliated Company

Year

Local Fiber
Incorporated
2007

Street_address

Situs address of the U.S. headquarters for Affiliated Company

Text

City

City name for U.S. headquarters

Text

1025 N Irving
Street
Springfield

State

State name for U.S. headquarters

Text

Texas

ZIP

5 digit ZIP code for current U.S. headquarters

Text

22201

ZIP4

4-digit add-on code (with leading zeros) of address

Text

0005

Year_Head

Year when U.S. headquarters of Affiliated Company was
established

Year

2000

Instructions for Table II.A.9.e-f, Record Format for Headquarters for Affiliated Companies:






In the initial row of the table, you will identify an Affiliated Company and the current U.S.
headquarters of the Affiliated Company.
If the Affiliated Company had a prior U.S. headquarters – going back to 1995 or the year of
affiliation, whichever is earlier, then on the next row identify the same company name in the
AffCompany_Name field and provide information on the prior headquarters. If there is more
than one prior headquarters for the Affiliated Company, going back to 1995 or the year of
affiliation, whichever is earlier, then identify the prior headquarters in the subsequent rows.
Follow same reporting process for other Affiliated Companies in the subsequent rows of the table.
If you did not become affiliated with an Affiliated Company during the relevant reporting period,
then you must still type “Not Applicable” in the AffCompany_Name field and complete the
remaining fields with zeros. You will receive an error message upon validation of the data
container if you do not put any information into these data fields.

Question II.A.10: Marketing Plans
You must upload all Word, Excel, and .pdf documents responding to this question through the Special
Access Web Portal in the “Essay Questions – File Upload” section; you will not include these documents
in the data container.
The web portal contains two areas for uploading documents. One is for uploading the “Confidential”
version of the document where you will indicate information deemed Confidential and redact information
that is Highly Confidential based on the Protective Order issued for the data collection. The second area
is for uploading the “Highly Confidential” version of the document noting both Confidential and Highly
Confidential information without any redactions. You must upload at least one document in each area or
you will receive an error message during the submission process. If the document does not contain
Confidential or Highly Confidential information, e.g., all information is publicly available, then upload

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the document in each area without the relevant Confidential/Highly Confidential notations or redactions
in the case of the Confidential upload area.
Question II.A.11: Information on Requests for Proposals (RFPs)
Table II.A.11 Part 1
Record Format for RFPs
Field Name

Description

Type

Example

RFP_Type

Number 1-6 as follows:
1= Most recent RFP
won for the provision of Dedicated Services
2= Most recent RFP
won for the provision of Best Efforts Business
Broadband Internet Access Services
3= Most recent RFP won for the provision of other
high-capacity data services to business customers
4= Largest RFPs where you unsuccessfully submitted
bids in the 2010-2012 timeframe for the provision of
Dedicated Services
5= Largest RFPs where you unsuccessfully submitted
bids in the 2010-2012 timeframe for the provision of
Best Efforts Business Broadband Internet Access
Services
6= Largest RFPs where you unsuccessfully submitted
bids in the 2010-2012 timeframe for the provision of
other high-capacity data services to business customers

Integer

1

RFP_Number

Sequential number 1-5

Integer

1

RFP_Name

Name of RFP

Text

ADA Greenfield

RFP_Description

Describe the RFP, including the date that the RFP was
issued

Text

RFP_Area_Covered

Identify the geographic areas covered by the RFP

Text

RFP_Bid_Details

Details on your bid, including price offered

Text

Other_RFP_Details

Detail other competitively relevant information on RFP
and/or bid

Text

RFP
requirements
included . . .
Network
required to
cover 26 counties
in Michigan
Offered
dedicated service
for X amount.
Our bid offer
included cost of
leasing facilities
in X areas from
X where we did
not own
facilities.

Question II.A.11 Part 2. Question II.A.11 also asks Competitive Providers to identify the business rules
relied upon to determine whether to submit a bid in response to an RFP. You must upload a .pdf text
searchable (not a picture/image) document responding to this part of the question through the Special
Access Web Portal in the “Essay Questions – File Upload” section; you will not include this document in
the data container.

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The web portal contains two areas for uploading documents. One is for uploading the “Confidential”
version of the document where you will indicate information deemed Confidential and redact information
that is Highly Confidential based on the Protective Order issued for the data collection. The second area
is for uploading the “Highly Confidential” version of the document noting both Confidential and Highly
Confidential information without any redactions. You must upload at least one document in each area or
you will receive an error message during the submission process. If the document does not contain
Confidential or Highly Confidential information, e.g., all information is publicly available, then upload
the document in each area without the relevant Confidential/Highly Confidential notations or redactions
in the case of the Confidential upload area.
Billing Information
Question II.A.12-14: Billing Information Overview
These questions are interrelated. Question II.A.12 requires the filer to provide billing information for
each circuit element billed to its customers. To answer this question, you must reference adjustment and
billing codes that are defined by responses to Questions II.A.13 and II.A.14, respectively.
Question II.A.12: Prices by Circuit Element from Competitive Provider
This question requests billing information for transmission paths that are sold for the provision of a standalone Dedicated Service. By using the term “transmission paths,” this question 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. Do not provide billing information for bundled services where
the Dedicated Service component is not separately priced. Do include sales to Affiliated Companies.
Submit information for each circuit element of each circuit for each month from January 1, 2010 through
December 31, 2010 and from January 1, 2012 through December 31, 2012. Include a separate entry for
each separately-billed element on the circuit. In the case where circuits are billed as a single unit, the data
set will contain only one entry per circuit.
Table II.A.12 Part 1
Record Format for Monthly Billing Data for Circuits by Circuit Element
Field Name

Description

Type

Example

Closing_Date

Closing date of the monthly billing cycle in mm/dd/yyyy
format
Unique customer identifier used to link all circuits purchased
by a customer over all geographies and time periods. To be
linked with customer names and identification numbers in
Table II.A.12 Part 2.
Sequential location number from Question II.A.4.a where
applicable; required for circuit elements such as channel
terminations that can be associated with a particular Location

Date

06/30/2012

Integer

1274

Integer

1

Circuit_ID

Circuit identifier common to all circuit elements purchased in
common for a particular circuit

Text

HHH555XYZ

Circuit_Type

Type of circuit (DS1, DS3, DS1-UNE, DS3-UNE, other CBDS
(i.e., non-DSn), or PBDS.

Text

DS1

DSn_Bandwidth

If a DS1, DS3, DS1-UNE, or DS3-UNE, indicate the onedirection bandwidth of the circuit in Mbps.

Float

1.544

Customer_ID

Location_ID

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Table II.A.12 Part 1
Record Format for Monthly Billing Data for Circuits by Circuit Element
Field Name

Description

Type

Example

OtherCBDS_Bandwidth

If a CBDS circuit other than a DSn circuit, indicate the onedirection bandwidth of a symmetric circuit or the average onedirection bandwidth for non-symmetric circuits in Mbps.
If a PBDS circuit, indicate the one-direction bandwidth of a
symmetric circuit or the average one-direction bandwidth of
non-symmetric circuits in Mbps.
Billing code (e.g., USOC) used to identify the billed circuit
element. (This variable will also appear in Question II.A.14
and is used to link the billed circuit elements with their
descriptions.)
Number of billed units for this circuit element. Do not enter the
bandwidth of the circuit in this field.

Float

4.5

Float

100

Text

1YZXD

Float

34

Initial_NRC

Non-recurring charge (in dollars) billed for the first unit of this
circuit element

Float

0

Unit_NRC

Non-recurring charge (in dollars) billed for additional units of
this circuit element

Float

0

Initial_MRC

Monthly recurring charge (in dollars) for the first unit billed

Float

17.7

Unit_MRC

Monthly recurring charge (in dollars) for additional units billed
(if different from the amount billed for the initial unit)

Float

0

Billed

Per unit amount (in dollars) billed for the circuit element
including all “in-cycle” discounts and penalties. For circuit
elements with multiple billed units (i.e., quantity greater than
one in II.A.12.g), enter the amount billed for a single unit

Float

507.3

Total_Billed

Total monthly amount (in dollars) billed for all units of the
circuit element, including all “in-cycle” discounts and penalties

Float

12453.50

Term

Length of total time of the Term Commitment associated with
this circuit (in months). List the total length of the current
Term Commitment, not the remaining length of the Term
Commitment. A circuit purchased on a month-to-month basis
must be coded as 1.

Integer

36

End_Date

If this circuit has an associated Term Commitment, enter the
month and year the term expires.

Date

03/2014

Term_Discount_IC

Indicator variable for whether any in-cycle term discounts have
been rolled into the amount billed to the customer reported in
the Billed field (0 = No in-cycle term discounts included in
Billed amount; 1 = In-cycle term discounts included in Billed
amount)
Indicator variable showing whether this circuit contributes to a
Volume Commitment (Y=Yes, N=No)

Integer

0

Text

N

Indicator variable for whether any in-cycle volume discounts
have been rolled into the amount billed to the customer
reported in the Billed field (0 = No in-cycle volume discounts
included in Billed amount; 1 = In-cycle volume discounts
included in Billed amount)
Unique ID number (from II.A.13) for the first billing
adjustment / true-up affecting this circuit element. Leave the
field blank if there are no discounts or penalties that occur
during the monthly billing cycle affecting this circuit element.

Integer

0

Integer

1

PBDS_Bandwidth
Billing_Code

Quantity

Volume_Commitment
Vol_Discount_IC

Adjustment_ID_1

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Table II.A.12 Part 1
Record Format for Monthly Billing Data for Circuits by Circuit Element
Field Name

Description

Type

Example

Adjustment_ID_2

Unique ID number (from II.A.13) for the second billing
adjustment / true-up affecting this circuit element, if more than
one adjustment was applied to this circuit element. Leave the
field blank if there are fewer than two discounts applied to this
circuit element in the given billing cycle

Integer

26

…

[Continue to add columns for a total of ten (10) Adjusment_ID
columns.]

…

…

Adjustment_ID_10

Unique ID number (from II.A.13) for the tenth billing
adjustment/ true-up affecting this circuit element, if more than
one adjustment was applied to this circuit element. Leave the
field blank if there are fewer than ten discounts applied to this
circuit element in the given billing cycle

Integer

15

Table II.A.12 Part 2
Record Format for Identifying Customers
Field Name

Description

Type

Example

Customer_ID

Unique customer identifier used to link all circuits purchased by a
customer over all geographies and time periods. This field will
be used to link the billing information in Table II.A.12 Part 1
with the customer names and identification numbers
Where applicable, include the six-digit 499A Filer ID of the
customer
Where applicable, include the Access Customer Name
Abbreviation (ACNA) of the customer
Where applicable, include the Operating Company Number
(OCN) of the customer
Enter the name of the customer

Integer

1274

Integer

822116

String

ABC

Integer

1234

Text

Verizon Wireless

Indicator variable denoting whether the circuit is purchased by a
Provider (0 = non-Provider; 1 = Provider)

Integer

1

Customer_ID_499
Customer_ID_ACNA
Customer_ID_OCN
Customer_Name
Provider

Instructions for Table II.A.12, Parts 1 and 2:25
a. Closing_Date: Enter the date on which the customer was billed. The date must appear in
mm/dd/yyyy format. All dates must be in the ranges 01/01/2010 – 12/31/2010 or 01/01/2012 –
12/31/2012. Do not include data on circuits billed outside the appropriate date ranges, even if
services were provided within the appropriate date ranges (e.g., service that was provided in
December 2010 that was billed in January 2011). Likewise, include data on circuits billed in the
appropriate date ranges, even if the service was provided outside of those ranges (e.g., service
provided in December 2011 that was billed in January 2012).

25

Subparts listed herein refer to supbarts in Question II.A.12.

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b. The following fields in Parts 1 and 2 of Table II.A.12 are used to identify the customer of the
Dedicated Service.26
 Customer_ID: Assign a unique identifier to each customer so that all circuits purchased by the
customer can be tracked over time and across locations. The identifiers must be entered in
integer format. This Customer_ID will be used to link the circuit billing information (Table
II.A.12, Part 1) to the customer names and identification numbers (Table II.A.12, Part 2). In Part
2, provide the customer name, an indicator for whether the customer is a Provider, and, where
applicable, one of the following identification numbers: 499A filer ID, Access Customer Name
Abbreviation (ACNA), or Operating Company Number (OCN). Note, the Customer_ID variable
is required for all observations in both Part1 and Part 2. However, only one of the three
additional identification numbers (499, ACNA, OCN) need be provided, even if multiple
identification numbers are available. Each Customer_ID must appear only once in Part 2, but
will likely appear multiple times in Part 1.
 Customer_ID_499: Where applicable, include the 499A Filer ID of the customer in Part 2. The
499A Filer ID does not replace the Customer_ID variable. Both the Customer_ID and
Customer_ID_499 fields are populated for any customer with a 499A Filer ID. If the customer
does not have a 499A Filer ID, leave the field blank.
 Customer_ID_ACNA: Where applicable, include the ACNA of the customer in Part 2. The
ACNA does not replace the Customer_ID variable. Both the Customer_ID and
Customer_ID_ACNA fields are populated for any customer with an ACNA. If the customer does
not have an ACNA, leave the field blank.
 Customer_ID_OCN: Where applicable, include the Operating Company Number (OCN) of the
customer in Part 2. The OCN does not replace the Customer_ID variable. Both the Customer_ID
and Customer_ID_OCN fields are populated for any customer with an OCN. If the customer
does not have an OCN, leave the field blank.
 Customer_Name: Enter the name of the customer in Part 2. The variable must be entered as a
string and be no longer than 30 characters in length.
 Provider: Indicate whether the customer is a Provider in Part 2, i.e., a customer that pays a pass
through universal service contribution charge. Enter a 1 if the customer is a Provider and a 0
otherwise. In some instances, it may be difficult to identify if the customer is a Provider using
billing information, but can often be inferred by the existence of a 499A Filer ID or by whether
USF charges are passed on to the customer in their bill.
c. Location_ID: Include the Location ID reported in response to question II.A.4 for each circuit element
on the circuit. The Location ID is used to link the billed circuit with the facilities information
provided in Question II.A.4. That is, every Location ID referenced in response to Question II.A.12

26

See Data Collection Implementation Order § III.C (discussing changes to Questions II.A.12-14).

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must correspond to a Location ID reported in response to Question II.A.4.27 Also, for circuits that
connect two Locations, the Location ID may not be constant within the Circuit ID. For example, the
individual circuit elements for a given Circuit ID may include two channel terminations, each
terminating at a different Location. The Location ID must be populated for every circuit element in
the data set that can be tied to a Location. Specifically, any termination charge must be linked to a
Location. If the sold Dedicated Service is not to a Location, e.g., the sale of dedicated interoffice
transport, leave this field blank.
d. Circuit_ID: Assign a unique circuit identifier (Circuit ID) to all circuit elements purchased in
common for a particular circuit. If the circuit is sold over multiple time periods, the circuit identifier
must track the circuit across the multiple months and/or years it appears in the sample. We prefer that
you code the Circuit IDs as sequential integers, beginning with the number “1” (similar to the
Location ID). However, to the extent you have an established naming convention for your circuits,
that convention may be substituted in place of sequential numbering. Code the Circuit ID as a string
with a maximum of 15 characters. (Note: Because some filers may choose to use non-numeric
characters in their coding, Circuit IDs must be coded as string variables, even if they have been
renumbered as sequential integers.)
e. The following fields identify the type of circuit sold (Circuit Type), and the bandwidth of the circuit.
The Circuit Type must be populated for every circuit element in the data set. Only one of the three
bandwidth variables needs to be populated for each circuit element, depending on the type of circuit
provided.
 Circuit_Type: Indicate the type of circuit sold from the following categories: DS1, DS3, DS1UNE, DS3-UNE, other CBDS circuit (i.e., non-DSn), or PBDS. For packages of DS1s and DS3s
sold to a location, enter DS1 or DS3, respectively. Do not enter circuit types other than those
listed above.
 DSn_Bandwidth: If the circuit is a DS1, DS3, DS1-UNE, or DS3-UNE, enter the bandwidth of
the circuit in Mbps, i.e., enter 1.544 for a DS1 and enter 44.736 for a DS3. In the case where
multiple DSns are provisioned over a single circuit, enter the total bandwidth. For example, the
bandwidth for a circuit with three DS1s must be entered as 4.632 (= 3 × 1.544). For non-DSn
circuits, leave the field blank.
 OtherCBDS_Bandwidth: If the circuit is a non-DSn CBDS circuit, enter the bandwidth of the
circuit in Mbps. For symmetric services, the reported bandwidth is the one-way bandwidth of the
circuit (i.e., upstream or downstream). For asymmetric services, report the average of the
upstream and downstream bandwidths. Round the bandwidth of the circuit to three decimal
27

We note that Competitive Providers may report more unique Location IDs in response to Question II.A.4 than are
referenced in response to Question II.A.12 because Competitive Providers report Locations with Connections that
are both idle and in-service. Competitive Providers will only report billing information for those Locations with inservice Connections.

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

f.

places. For example, if the service guarantees 10 Mbps transmission speeds in one direction and
5 Mbps transmission speeds in the other direction, enter 7.500 in this field. If the circuit is a DSn
or PBDS circuit, leave this field blank.
PBDS_Bandwidth: If the circuit is a PBDS circuit, enter the bandwidth of the circuit in Mbps.
For symmetric services, the reported bandwidth is the one-way bandwidth of the circuit (i.e.,
upstream or downstream). For asymmetric services, report the average of the upstream and
downstream bandwidths. For example, if the service guarantees 150 Mbps transmission speeds in
one direction and 50 Mbps transmission speeds in the other direction, enter 100 in this field.
Round the bandwidth of the circuit to three decimal places. For non-PBDS circuits, leave this
field blank.

Billing_Code: The billing code variable (Billing Code) is used to identify the individual components
of billed circuits. The Billing Code is used to link the billed circuit elements with the description of
those elements in Question II.A.14. Examples of Billing Codes are Uniform Service Order Codes
(USOCs). However, you are not required to use USOCs to identify the circuit elements; you can
create your own Billing Codes. Similar circuit elements need to have the same Billing Code in order
to track similar charges across circuits. To the extent that circuits are billed by individual circuit
elements, the elements and billed amounts of the elements must be disaggregated into separate lineitems in the table. If circuits are billed at the overall circuit level, only one line per circuit need be
populated, and all like circuits may have the same Billing_Code and Billing Code description.

g. Quantity: Enter the number of billed units for this circuit element. Do not enter the bandwidth of the
circuit in this field. For item codes that describe per-mile charges, the Quantity is the number of
miles in the circuit that apply for that item code.
h. Initial_NRC: Insofar as the per unit monthly billed amount (Question II.A.12.l) can be broken into
recurring and non-recurring charges, enter the non-recurring charge (in dollars) billed for the first unit
of this circuit element on this circuit. Enter the charge to two decimal places and do not include other
string characters (e.g., “$”).
i.

Unit_NRC: Insofar as the per unit monthly billed amount (Question II.A.12.l) can be broken into
recurring and non-recurring charges, enter the non-recurring charge (in dollars) billed for each
additional unit of this circuit element on this circuit. Enter the charge to two decimal places and do
not include other string characters (e.g., “$”).

j.

Initial_MRC: Insofar as the per unit monthly billed amount (Question II.A.12.l) can be broken into
recurring and non-recurring charges, enter the monthly recurring charge (in dollars) billed for the first
unit of this circuit element on this circuit. Enter the charge to two decimal places and do not include
other string characters (e.g., “$”).

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k. Unit_MRC: Insofar as the per unit monthly billed amount (Question II.A.12.l) can be broken into
recurring and non-recurring charges, enter the monthly recurring charge (in dollars) billed for each
additional unit of this circuit element on this circuit. Enter the charge to two decimal places and do
not include other string characters (e.g., “$”).
l.

Billed: Per unit amount (in dollars) billed for the circuit element including all “in-cycle” discounts
and penalties. “In-cycle” discounts and penalties are those adjustments that are rolled into the actual
amount paid by the customer each month (see the instructions to Question II.A.13 for more
information on “in-cycle” vs. “out-of-cycle” billing adjustments). If in-cycle adjustments show up as
a separate line-item on the customer’s bill, they must be reported as separate line-items in Table
II.A.12. Do not include any “out-of-cycle” adjustments as otherwise reported in response to Question
II.A.12.p. For circuit elements with multiple billed units (i.e., quantity greater than one in Question
II.A.12.g), enter the amount billed for a single unit, such that the product of Quantity and Billed is the
total charge on the bill. For example, if the circuit includes two “channel termination” charges that
are both billed at the same rate (and have the same Billing_Code (Question II.A.12.f), Location_ID,
bandwidth, etc.), the quantity (Question II.A.12.g) is equal to 2, and the per unit monthly billed
amount (Question II.A.12.l) is equal to the charge for a single channel termination. Alternatively,
each channel termination may be recorded separately (i.e., on two separate lines with quantity equal
to 1 for each line). The multiplicative product requirement also applies to charges for mileage of the
circuit, if the circuit has such a charge. For example, if the circuit is 4 miles in length, the amount
entered in Quantity is 4 and the amount entered in the Billed field is the charge per 1 mile. Enter the
billed amount to two decimal places, and do not include other string characters (e.g., “$”). Fractional
miles are permitted if the customer was billed for fractional mileage for any given circuit element.
However, the amount entered in Billed must be converted to a whole-mile charge. For example, for a
half mile circuit, the Quantity is reported as 0.5 on any per-mile circuit element, but the amount in
Billed is the 1-mile charge such that the product of Quantity and Billed is equal to the total charge to
the customer.

m. Total_Billed: Total monthly amount (in dollars) billed for all units of the circuit element including all
“in-cycle” discounts and penalties. “In-cycle” discounts and penalties are those adjustments that are
rolled into the actual amount paid by the customer each month (see the instructions to Question
II.A.13 for more information on “in-cycle” vs. “out-of-cycle” billing adjustments). If in-cycle
adjustments show up as a separate line-item on the customer’s bill, they must be reported as separate
line-items in this table. Do not include any “out-of-cycle” adjustments as otherwise reported in
Question II.A.12.p.
n. The following questions seek to understand the Term Commitments under which circuits are
purchased.
 Term: Length of total time of the Term Commitment associated with this circuit (in months). List
the total length of the current Term Commitment, not the remaining length of the Term
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



Commitment. For example, in reporting circuits for calendar month January 2010, enter 60 for a
circuit that was sold in January 2007 under a 5 year commitment, even though only 24 months
remain on the current term. For circuits sold on a month-to-month basis, enter 1. We anticipate
that this value is identical for all circuit elements sold in common on the circuit. To the extent
that the term length varies across different circuit elements, enter the appropriate Term
Commitment for each individual circuit element.
End_Date: If the circuit has an associated total term longer than one month, enter the month and
year the term expires. In the preceding example, the End_Date would be coded as 12/2012, sixty
months after the five-year term was agreed to in January 2007. Leave the End_Date field blank
for those circuits purchased on a month-to-month basis.
Term_Discount_IC: Indicate whether the per unit monthly billed amount in Question II.A.12.l
includes any in-cycle discounts that have been applied due to a Term Commitment. Enter a 1 if
the per unit monthly billed amount includes in-cycle term discounts; enter 0 if the per unit
monthly billed amount does not include in-cycle term discounts. If the term discounts for this
circuit are only given through out-of-cycle adjustments as reported in Question II.A.13, enter 0.
If the circuit is not sold under a Term Commitment, leave this field blank.

o. Volume_Commitment: Indicate whether this circuit was sold under a Volume Commitment. Enter 0
if the circuit was not sold under a Volume Commitment, and enter 1 if the circuit was sold under a
commitment by the Purchaser to purchase either a specified number of circuits or to spend a
specified Revenue amount.
 Vol_Discount_IC: Indicate whether the per unit monthly billed amount in Question II.A.12.l
includes any in-cycle discounts that have been applied due to a Volume Commitment, either in
total number of circuits or total amount of expenditures (“spend”). Enter a 1 if the per unit
monthly billed amount includes in-cycle volume discounts; enter 0 if the per unit monthly billed
amount does not include in-cycle volume discounts. If the volume discounts for this circuit are
only given through out-of-cycle adjustments as reported in Question II.A.13, enter 0. If the
circuit is not sold under a Volume Commitment, leave this field blank.
p. Adjustment_ID_1; Adjustment_ID_2; …Adjustment_ID_10: For each out-of-cycle billing
adjustment applied to the circuit element, provide a unique adjustment ID that is used to link the
circuit elements with the dollar value and descriptions of the appropriate adjustments. The table must
include 10 columns for each of the ten potential Adjustment_IDs, regardless of whether all columns
are used. For rate elements with fewer than ten out-of-cycle adjustments, leave the excess
Adjustment_ID fields blank. If a circuit element had more than ten out-of-cycle adjustments applied
to it, list the Adjustment_IDs of the ten largest adjustments. For example, if a circuit element
receives five distinct adjustments, there must be five Adjustment_IDs in the first five columns. The
remaining Adjustment_ID columns (i.e., columns 6 through 10) would be left blank. In addition, all
adjustments must link back to the adjustment amounts and descriptions provided in response to
Question II.A.13. See the instructions for Question II.A.13 for further instructions on adjustments.

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Question II.A.13: Billing Adjustments
For each adjustment or true-up (including credits for meeting or penalties for not meeting contractual
obligations) to billed circuit elements, provide the following information below. Provide the adjustment
at the lowest level of aggregation available, and if possible, at the level of the individual circuit element.
If the adjustment applies to multiple circuit elements and/or circuits, provide the total dollar amount of the
billing adjustment, and include an Adjustment_ID for each circuit element reported in Question II.A.12
that can be used to link the billing adjustment (or true-up) with the appropriate circuit elements.
Note on “in-cycle” vs. “out-of-cycle” billing adjustments: Question II.A.13 is meant to capture all
adjustments, penalties, and true-ups that are settled outside of the monthly billing cycle (as opposed to
adjustments that are rolled into the price billed to the customer each month). Examples include lump-sum
discounts for Term and Volume Commitments, early termination penalties, rebates for network outages or
degraded service quality, waivers of non-recurring charges such as installation fees, etc.
For example, suppose a customer buys a single circuit with a One Month Term Only Rate of $300 per
month, but receives a $100 discount on the One Month Term Only Rate each month for committing to a
5-year Term Commitment. If the Provider of the circuit rolls the discounted amount into the monthly bill,
i.e., the customer is billed $200 every month, then the discount is considered an “in-cycle” adjustment,
and the Provider need not report it as a separate “out-of-cycle” adjustment in Table II.A.13. The seller
would only need to report the $200 charge in Question II.A.12, along with an indicator showing a Term
Commitment in Question II.A.12.m. (Alternatively, depending on the billing system, the discount may
show up as a separate -$100 line item in Question II.A.12 along with the $300 One Month Term Only
Rate.)
However, if the Provider charges the customer the full $300 for the circuit every month, then returns a
$600 payment to the purchaser every 6 months, the $600 payment must be recorded in Table II.A.13 as an
out-of-cycle adjustment, and the appropriate Adjustment_ID must appear next to the affected circuit
elements in Question II.A.12. Likewise, if the customer is billed at the $200 discounted rate each month
but then decides to terminate the contract early and pay an early termination fee of $1000, the $1000
charge is recorded as an out-of-cycle adjustment in Question II.A.13.
Table II.A.13
Record Format for Billing Adjustment Data Circuits by Circuit
Field Name

Description

Type

Example

Adjustment_ID

Unique ID number for the billing adjustment or true-up

Integer

1

Contract_ID

Unique ID number for the Tariff or other agreement from which
the adjustment originates. Leave the field blank if the adjustment
cannot be linked back to a single contract
Beginning date of adjustment period (or true-up) in mm/dd/yyyy
format

Integer

33

Date

01/01/2012

Date_to

Ending date of adjustment period (or true-up) in mm/dd/yyyy
format

Date

06/30/2012

Adjustment_Scope

Code indicating scope of adjustment. Enter 1 if adjustment
applies to single circuit element for single circuit, enter 2 if
adjustment applies to more than one circuit element on a single
circuit, enter 3 if adjustment applies to more than one circuit

Integer

2

Date_from

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Table II.A.13
Record Format for Billing Adjustment Data Circuits by Circuit
Field Name

Description

Type

Example

element across multiple circuits, enter 4 if the adjustment is an
overall adjustment that applies to every circuit purchased.
Adjustment

Total dollar amount of billing adjustment (or true-up) for all
circuit elements across all circuits covered by the adjustment.
Any increase in the amount owed to the vendor (e.g., penalty) is a
positive number while any decrease in the amount owed to the
vendor (e.g., discount or rebate) is a negative number.

Float

-100

Adj_Term

Indicator variable denoting whether the adjustment/true-up was
due to a Term Commitment (Y=Yes, N=No)

Text

N

Adj_Term_Length

If Adj_Term=1, enter the term length in months. If Adj_Term=0,
leave blank

Integer

60

Adj_Vol

Indicator variable denoting whether the adjustment/true-up was
due to a Volume Commitment (Y=Yes, N=No)

Text

N

Adj_Vol_Circ

If Adj_Vol=1, and the Tariff or other agreement required the
purchase of a certain number of circuits, enter the number of
circuits specified in the Tariff or other agreement which are
necessary to qualify for the adjustment. If Adj_Vol=0, or the
adjustment corresponds to a commitment to a given level of
expenditures/spend, leave the field blank

Integer

500

Adj_Vol_Rev

If Adj_Vol=1, and the Tariff or other agreement required the
purchase of a certain dollar amount of expenditures/spend, enter
the dollar value of the expenditure requirement. If Adj_Vol=0 or
the adjustment corresponds to a commitment to purchase a certain
number of circuits, leave the field blank
If the adjustment/true-up is for some other reason, give a brief
description of the reason for the adjustment

Float

20,000

Text

Network Outage

Adjustment_Other

Instructions for Table II.A.13, Record Format for Billing Adjustment Data Circuits by Circuit:
a. The following questions identify each out-of-cycle billing adjustment with an adjustment ID and the
Tariff or other agreement from which they originate.
 Adjustment_ID: Create a unique adjustment ID for each out-of-cycle billing adjustment applied
to customer purchases during the relevant timeframe. Although each Adjustment_ID may
correspond to multiple circuit elements in Table II.A.12, each must appear only once in Table
II.A.13. Only include adjustments which were charged/remitted to the customer during the 2010
and 2012 reporting periods. For example, do not include adjustments that were charged/remitted
in January 2011, even if the adjustment applied to service provided in December 2010. Likewise,
report any adjustments charged/remitted in January 2012, even if those adjustments applied to
service provided in December 2011.
 Contract_ID: Assign a unique ID number for the Tariff or other agreement from which the
adjustment originates. This field is used to group adjustments together by Tariff or other
agreement. Leave the field blank if the adjustment cannot be linked back to a single contract.

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b. Date_From: Enter the beginning date of the adjustment period in mm/dd/yyyy format. For example,
if the Tariff or other agreement specifies a rebate to the customer every three months, enter the
beginning date of the three-month period for which the rebate applies, and not the beginning date of
the Tariff or other agreement from which the adjustment originated. Likewise, do not enter the date
on which the adjustment was charged/remitted.
c. Date_To: Enter the ending date of the adjustment period in mm/dd/yyyy format. For example, if a
Tariff or other agreement specifies a rebate be returned to the customer every three months, enter the
ending date of the 3-month period for which the rebate applies, and not the ending date of the Tariff
or other agreement from which the adjustment originated. Likewise, do not enter the date on which
the adjustment was charged/remitted.
d. Adjustment_Scope: Enter the scope of the adjustment according to the following codes: Enter 1 if
the adjustment applies to a single circuit element on a single circuit. Enter 2 if the adjustment applies
to more than one element on a single circuit. Enter 3 if the adjustment applies to more than one
circuit elements across multiple circuits. Enter 4 if the adjustment is an overall adjustment that
applies to every circuit purchased by the customer (as indicated by the Customer_ID in Question
II.A.12). Apply the codes as described above, even if the adjustment applies to multiple time periods.
For example, if a rebate is given for a single circuit element on a single circuit (as determined by the
Circuit_ID in Question II.A.12), assign an Adjustment_Scope of 1, even if the adjustment period (as
determined by Date_From and Date_To) extends over multiple months.
e. Adjustment: Enter the total dollar amount of the billing adjustment for all circuit elements across all
circuits and across the entire adjustment period. Any increase in the amount owed to the vendor (e.g.,
penalty) must be a positive number, while any decrease in the amount owed to the vendor (e.g.,
discount or rebate) must be a negative number. For example, suppose the Provider gave the customer
a $2000 rebate on 10/31/2010, and that this rebate covered 100 circuits purchased during the sixmonth period from 04/01/2010 to 10/01/2010. In this case, the filer must enter “-2000” in the
Adjustment field with the appropriate Date_From and Date_To values. In addition, the
Adjustment_Scope (see above) must be recorded as 3, and the Adjustment_ID for this specific rebate
must be included next to the 100 circuits in the Adjustment_ID_# fields in Table II.A.12.
f.

These fields describe the type of adjustment applied to the circuit elements.
 Adj_Term: If the adjustment/true-up can be linked to a rebate given (or penalty charged) on a
Term Commitment, enter 1. Enter 0 if the adjustment was not due to a Term Commitment.
 Adj_Term_Length: If Adj_Term is equal to 1, enter the total term length (not the remaining term
length) in months. If Adj_Term is equal to 0, leave the Adj_Term_Length variable blank.
 Adj_Vol: Enter 1 if the adjustment/true-up can be linked to a rebate (or penalty) on a Volume
Commitment. Enter 0 if the adjustment was not due to a Volume Commitment. If the Volume
Commitment corresponds to a certain number of circuits, enter the number of circuits necessary to
qualify for the discount in the Adj_Vol_Circ field. If the Volume Commitment corresponds to a
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





certain level of “spend” or dollar value of services, enter the dollar amount necessary to qualify
for the discount in the Adj_Vol_Rev field.
Adj_Vol_Circ: If Adj_Vol is equal to 1, and the Tariff or other agreement required the purchase
of a certain number of circuits to qualify for a discount, enter the number of circuits. If Adj_Vol
is equal to 0 or the Volume Commitment was a commitment to a given level of expenditures or
“spend,” leave this field blank.
Adj_Vol_Rev: If Adj_Vol is equal to 1 and the Tariff or other agreement required the purchase
of a certain dollar amount of expenditures (or “spend”) to qualify for a discount, enter the dollar
value of the expenditure requirement. If Adj_Vol is equal to 0 or the Volume Commitment was a
commitment to purchase a certain number of circuits, leave this field blank.
Adjustment_Other: If the adjustment/true-up was for some reason other than a Term or Volume
Commitment, give a brief description of the reason in this field. Do not exceed 120 characters in
your response. Leave blank if either Adj_Term or Adj_Vol is equal to 1. An example of such an
adjustment may be a rebate remitted to the purchaser in compensation for an unanticipated
network outage or degraded quality of service.

Question II.A.14: Billing Code Descriptions
Provide descriptions for each unique billing code referenced in Table II.A.12 Part 1. Enter one record for
each unique billing code. Examples of common circuit elements are given in the diagram in Question
II.A.14.b. If the billed element cannot be described by the elements listed in the diagram, provide a
description of the billed element as indicated in Question II.A.14.c. For example, to the extent you bill
circuits as a whole, rather than on an element-by-element basis, provide a description that describes the
billed unit, see Question II.A.14.c, and assign a single unique billing code.
Table II.A.14 is used to link the descriptions of billing codes with the billed circuit elements reported in
Table II.A.12 Part 1 using the Billing_Code variable in each table. Although each Billing_Code may
appear multiple times in Table II.A.12 Part 1, you can only have one entry for each unique Billing_Code
reported in Table II.A.14. Additionally, every Billing_Code that appears in Table II.A.12 Part 1 must be
identified in Table II.A.14.
Table II.A.14
Record Format for Descriptions for Circuits by Circuit
Field Name

Description

Type

Example

Billing_Code

Billing code (e.g., USOC) used to identify the billed circuit
element. (This variable will aslo appear in Question II.A.12
and is used to link the billed circuit elements with their
descriptions)
Brief description of circuit element

Text

1YZXD

Text

Channel Mileage

The description of the circuit element as it appears on the
customer’s bill.

Text

Billing_Code_Description
Billing_Code_Desc_Other

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Instructions for Table II.A.14, Record Format for Descriptions for Circuits by Circuit:
a. Billing_Code: The billing code variable is used to identify the individual components of billed
circuits. The billing code is used to link the billed circuit elements in Question II.A.12 with the
description of those elements in Question II.A.14. A USOC is an example of billing code. However,
USOC codes are not required to identify the circuit elements; you can create your own billing code.
Enter the billing code as a string variable not to exceed 15 characters in length.
b. Billing_Code_Description: Choose the description from the list/diagram in Question II.A.14 that best
describes the circuit element. See list of circuit elements in Question II.A.14.b. Make every effort to
assign the billed element to one of the categories listed here. If the item billed to the customer does
not fit any of these categories, this field may be left blank and the billed element can be described in
the field Billing_Code_Desc_Other. This may occur, for example, if circuits are billed as a complete
package instead of on an element-by-element basis (i.e., all the elements in the circuit are billed
together under a single price). In such a case, a single billing code for the circuit elements listed in
Question II.A.14.b may not apply; this field may be left blank and the appropriate description of the
billed item may be filled out in Billing_Code_Desc_Other.
c. Billing_Code_Desc_Other: Enter a longer description of the circuit element. For circuit elements
categorized under one of the descriptions in Billing_Code_Description, this field is optional. If
Billing_Code_Description is left blank, this field is required. Keep descriptions under 150 characters.
Revenues, Terms and Conditions Information
Question II.A.15: Sales Revenues for CBDS
Table II.A.15
Record Format for CBDS Revenues
Field Name

Description

Type

Example

Revenue

Enter the total dollar amount of your Revenues from
the sale of CBDS for the reported Year
Indicate the service type category for which the
Revenues are reported. Enter “DS1” for DS1
Revenues, enter “DS3” for DS3 Revenues, and enter
“Other” for other CBDS Revenues.
Enter 0 if the reported Revenues are for End Users, and
enter 1 if the reported Revenues are for Providers
Enter “2010” if the reported Revenues are for the year
2010, and enter “2012” if the reported Revenues are for
the year 2012

Float

123,456

Text

DS3

Binary

1

Integer

2012

Service_Type

Customer_Type
Year

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Question II.A.16: Sales Revenues for PBDS
Table II.A.16
Record Format for PBDS Revenues
Field Name

Description

Type

Example

Revenue

Enter the total dollar amount of your Revenues from
the sale of PBDS for the reported Year
Indicate the bandwidth category for which the
Revenues are reported. Enter “A” for bandwidth less
than or equal to 1.5 Mbps, enter “B” for bandwidth
greater than 1.5 Mbps but less than or equal to 50
Mbps, enter “C” for bandwidth greater than 50 Mbps
but less than or equal to 100 Mbps, enter “D” for
bandwidth greater than 100 Mbps but less than or equal
to 1 Gbps, and enter “E” for bandwidth greater than 1
Gbps
Enter 0 if the reported Revenues are for End Users, and
enter 1 if the reported Revenues are for Providers
Enter “2010” if the reported Revenues are for the year
2010, and enter “2012” if the reported Revenues are for
the year 2012

Float

123,456

Text

D

Binary

1

Integer

2012

Bandwidth

Customer_Type
Year

Question II.A.17: Percentage of Revenues Generated from Agreement or Tariff Containing a Prior
Purchase-Based Commitment
Table II.A.17
Record Format for Revenues
Generated by Prior Purchase-Based Commitments
Field Name
Percent_Rev_2012_DS1_PPC
Percent_Rev_2012_DS3_PPC
Percent_Rev_2012_PBDS_PPC

Description

Type

Example

Percentage of Revenue from sales of DS1s in 2012 from
agreements or tariffs which contain Prior Purchase-Based
Commitments
Percentage of Revenue from sales of DS3s in 2012 from
agreements or tariffs which contain Prior Purchase-Based
Commitments
Percentage of Revenue from sales of PBDS in 2012 from
agreements or tariffs which contain Prior Purchase-Based
Commitments

Percentage

5.0

Percentage

5.0

Percentage

5.0

Question II.A.18: How do your terms and conditions compare with ILEC offerings?
Question II.A.19: Business Justification for Term and Volume Commitments
You must upload a .pdf text searchable (not a picture/image) document responding to Questions II.A.18
and II.A.19 through the Special Access Web Portal in the “Essay Questions – File Upload” section; you
will not include these documents in the data container.
The web portal contains two areas for uploading documents for each question. One is for uploading the
“Confidential” version of the document where you will indicate information deemed Confidential and
redact information that is Highly Confidential based on the Protective Order issued for the data collection.
The second area is for uploading the “Highly Confidential” version of the document noting both
Confidential and Highly Confidential information without any redactions. You must upload at least one
document in each area or you will receive an error message during the submission process. If the
document does not contain Confidential or Highly Confidential information, e.g., all information is
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publicly available, then upload the document in each area without the relevant Confidential/Highly
Confidential notations or redactions in the case of the Confidential upload area.
QUESTIONS DIRECTED AT ILECS
Question II.B.1: Affiliated Company
If you are an Affiliated Company, then you must identify each entity you are affiliated with that provides
and/or purchases Dedicated Service in Table II.B.1 within the data container. If you are not an Affiliated
Company, then you must still type “Not Applicable” in the Affiliate_Name field and “0000000000” in the
Name_FRN field. You will receive an error message upon validation of the data container if you do not
put any information into Table II.B.1.
Table II.B.1
Record Format for Affiliated Company
Field Name

Description

Type

Example

Affiliate_ID

Sequential number

Integer

1

Affiliate_Name

Name of entity with which you are affiliated

Text

Local Fiber
Incorporated

Name_FRN

Entity’s FCC Registration Number
(with leading zeros)

Integer

0008402202

Facilities Information
Question II.B.2: ILEC Locations Data for ILECs
ILECs are required to report the total number of Locations to which they provided a Connection during
2010 and during 2012 where the ILEC either: (i) owned the Connection; or (ii) leased the Connection
from another entity under an IRU.28 The definition of Connection is crafted to assist the Commission
with sizing the broader market for Dedicated Services by including transmission facilities used to provide
a Dedicated Service and facilities that are “capable” of providing a Dedicated Service.
To help ILECs identify reportable Locations, we provide the following guidance:


Respondents must only report Connections to non-residential Locations. A Location is where an
End User is connected, and an End User means a business, institutional, or government entity that
purchases service for its own purposes, not for resell. Accordingly, residential locations
connected by facilities are not reported.



Copper loops that were unable to provide a bandwidth connection of at least 1.5 Mbps in both
directions (upstream/downstream) during the relevant reporting periods “as provisioned” are not

28

ILECs are not required to separately report Locations with Connections sold as UNEs; these Connections are
instead included in the Locations reported with owned Connections. See Data Collection Implementation Order §
III.C.

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considered Connections capable of providing a Dedicated Service for the purposes of this data
collection and are not reported.


In addition to reporting Connections used to provide a Dedicated Service, report Connections
used to provide a service that incorporates a Dedicated Service within the offering as part of a
managed solution or bundle of services sold to the customer.29



Do not report Connections to Locations that were used to provide services during the relevant
reporting period that were substantially similar to the services provided to residential customers,
e.g., one or two line telephone service or best-efforts Internet access and subscription television
services like AT&T’s U-verse or Verizon’s FiOS service.30
Table II.B.2
Record Format for Total Locations

Field Name

Description

Type

Example

Year

Indicator of the calendar year of the data

Integer

2010

Locations

Total Locations served during year

Integer

15

Instructions for Table II.B.2, Record Format for Total Locations (ILECs):


Locations: The number of Locations is the count of unique Locations to which your company
provided a Connection during the year entered in Year. The number of Locations listed here
must equal the number of unique Locations enumerated in Question II.B.3 for each year.

29

Examples of services incorporating a Dedicated Service could include: AT&T’s Managed Internet Access
service, Verizon’s Private IP service, and Frontier’s Ethernet Internet Access service. See
http://www.business.att.com/enterprise/Service/network-services/internet-connectivity/managed-internet-service/
(discussing AT&T’s Managed Internet Access service that provides dedicated access to the Internet or a VPN) (last
visited June 24, 2013); http://www.verizonenterprise.com/us/products/networking/private-ip/ (discussing Verizon’s
Private IP service which provides a managed VPN / intranet) (last visited June 24, 2013);
http://www.frontier.com/enterprise/internet/internet-services/ethernet (discussing Frontier’s Ethernet Internet Access
service which provides dedicated access to the Internet) (last visited June 24, 2013).
30

See AT&T, http://www.att.com/u-verse/shop/index.jsp#fbid=axqyY_KT2cT (last visited Mar. 20, 2013); Verizon,
http://www.verizonfios.com/ (last visited Mar. 20, 2013).

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Question II.B.3: Locations Data for ILECs
The purpose of this question is to obtain additional information on the individual Locations with
Connections that make up the total reported in response to Question II.B.2.
Table II.B.3
Record Format for Each Location
Field Name

Description

Type

Example

Location_ID

Sequential Location number

Integer

1

Year

Indicator of the calendar year of the data

Integer

2010

Street_address

Actual situs for the Location (i.e., land were
building or cell site is located)

Text

445 Twelfth St SW

City of the Location
Two-letter state postal abbreviation of the
Location
5-digit ZIP code (with leading zeros) of the
Location
4-digit add-on code (with leading zeros) of the
Location
Latitude

Text

Washington

Text

DC

Text

20554

Text

0000

Float

38.8835

Longitude
The type of Location served is a 1=building;
2=other man-made structure; 3=cell site in or on a
building; 4=free-standing cell site; 5=cell site on
some other man-made structure, e.g., water tower;
or 6=unknown.
Are any of the Connections to this Location
provided over fiber? (Y/N)

Float

-77.0280

Integer

1

Text

N

City
State
ZIP
ZIP4
Lat
Long

Loc_type

Medium
Sold_bandwidth_total

Total bandwidth (in Mbps) of Connections
provided to the Location as sold.

Float

1.544

Sold_bandwidth_UNE

For those Connections sold as UNE-DS1s or UNEDS3s, total bandwidth (in Mbps) of the
Connections provided to the Location as sold.

Float

1.544

Sold_bandwidth_enduser

Total bandwidth (in Mbps) of Connections
provided to End Users at the Location as sold.

Float

1.544

Sold_bandwidth_tfw

Total bandwidth (in Mbps) of Connections
provided to the Location using terrestrial fixed
wireless as sold.

Float

1.544

Sold_bandwidth_Mobile

Total bandwidth (in Mbps) of Connections to cell
sites at the Location as sold.

Float

1.544

Instructions for Table II.B.3, Record Format for Each Location (ILECs):


Location_ID: This is a sequential integer ranging from 1 to the total number of unique Locations
to which your company provided a Connection during the year reported. This field is linked to
the billing information reported in Question II.B.4 so that you must identify in Table II.B.3 every
Location ID referenced in response to the billing information question.
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





Year: Report the year during which your company provided a Connection to the Location, i.e.,
2010 or 2012.
The data fields used to identify the actual situs address must be space-delimited in standardized
Postal Service form. See http://pe.usps.gov/cpim/ftp/pubs/Pub28/pub28.pdf.
Latitude and Longitude: You can derive the coordinate fields for the location address from a
known geocoding platform like Bing maps, Google, Yahoo, batchgeo.com, Texas A&M
Geoservices, or other geocoding solution. Enter values in decimal degrees to the nearest ±0.0005,
i.e., each coordinate must end in #.###0 or #.###5. Coordinates must be in the WGS84 or
NAD83 geographic coordinate system.
Sold_bandwidth fields: These data fields call for the reporting of total bandwidth sold. Report
the downstream or upstream bandwidth of Dedicated Services sold across all sold Connections of
the type requested at the Location as of December 31 of the year. Report the upstream or
downstream bandwidth for symmetric services. For asymmetric services, report the average of
the upstream and downstream bandwidths. For example, for a DS1 record 1.544, for three DS1s
record 4.632, while for a 10 Gbit Ethernet service, 10,240, and for a fractional DS1 sold as a 384
Kbps service record 0.375. In the case where a Connection is in place but no bandwidth was
provided as of December 31 of the year, enter the total bandwidth sold at the last known date
during the relevant reporting period. For example, a customer or customers at the Location
purchased service through October of the year but then terminated the service so that there was no
service sold as of December 31; in that instance, report the total bandwidth sold in October.
Exclude services other than Dedicated Service provided to the Location from your response. In
the case where no Dedicated Service was sold to the Location, enter zero.

Billing Information
Question II.B.4-6: Billing Information Overview
These questions are interrelated. Question II.B.4 requires the filer to provide billing information for each
circuit element billed to its customers. To answer this question, you must reference adjustment and
billing codes that are defined by responses to Questions II.B.5 and II.B.6, respectively.
Question II.B.4: Prices by Circuit Element from ILECs
This question requests billing information for transmission paths that are sold for the provision of a standalone Dedicated Service. By using the term “transmission paths,” this question is not limited to Locations
with Connections, i.e., “last-mile” facilities, reported in response to Question II.B.3 but also includes
dedicated interoffice transport facilities. Do not, however, include the sale of interLATA POP-to-POP
services or billing information for bundled services where the Dedicated Service component is not
separately priced. Do include sales to Affiliated Companies.
Submit information for each circuit element of each circuit for each month from January 1, 2010 through
December 31, 2010 and from January 1, 2012 through December 31, 2012. Include a separate entry for
each separately-billed element on the circuit. In the case where the circuits are billed as a single unit, the
data set will contain only one entry per circuit.

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Table II.B.4 Part 1
Record Format for Monthly Billing Data for Circuits by Circuit and Rate Element
Field Name

Description

Type

Example

Closing_Date

Closing date of the monthly billing cycle in mm/dd/yyyy format

Date

06/30/2012

Customer_ID

Unique customer identifier used to link all circuits purchased by a
customer over all geographies and time periods. To be linked
with customer names and identification numbers in Table II.B.4
Part 2.

Integer

1274

Location_ID

Sequential location number from Question II.B.3.a. where
applicable. Required for circuit elements such as channel
terminations that can be associated with a particular Location.

Integer

1

Circuit_ID

Circuit identifier common to all circuit elements purchased in
common for a particular circuit.

Text

HHH555XYZ

Circuit_Type

Type of circuit (DS1, DS3, DS1-UNE, DS3-UNE, other CBDS
(i.e., non-DSn), or PBDS.

Text

DS1

DSn_Bandwidth

If a DS1, DS3, DS1-UNE, or DS3-UNE, indicate the onedirection bandwidth of the circuit in Mbps.

Float

1.544

OtherCBDS_Bandwidth

If a CBDS circuit other than a DSn circuit, indicate the onedirection bandwidth of a symmetric circuit or the average onedirection bandwidth of a non-symmetric circuit in Mbps
If a PBDS circuit, indicate the one-direction bandwidth of a nonsymmetric circuit or the average one-direction bandwidth of a
non-symmetric circuit in Mbps.
Serving wire center / mileage rating point CLLI for one end of
the circuit

Float

7.5

Float

75

Text

CHCGILCL

MRP2

Serving wire center / mileage rating point CLLI for the other end
of the circuit

Text

JOLTILJO

MRP1_Lat

Latitude of MRP1

Float

38.8835

MRP1_Long

Longitude of MRP1

Float

-77.0280

MRP2_Lat

Latitude of MRP2

Float

38.8835

MRP2_Long

Longitude of MRP2

Float

-77.0280

MRP_Type

End of the circuit (1=MRP1 or 2=MRP2) associated with this
circuit element. Enter 0 if the circuit element cannot be attributed
to either MRP or the circuit element can be attributed to both
ends of the MRP. All channel terminations must be attributed to
one of the two MRPs
Billing code (e.g., USOC) used to identify the billed circuit
element. (This variable will also appear in Question II.B.6 and is
used to link the billed circuit elements with their descriptions)
Density pricing zone for the circuit element. See 47 C.F.R. §
69.123 (If not applicable, leave field blank)

Integer

0

Text

1YZXD

Integer

4

Quantity

Number of billed units for this circuit element. Do not enter the
bandwidth of the circuit in this field.

Float

34

Initial_NRC

Non-recurring charge (in dollars) billed for the first unit of this
circuit element

Float

0

Unit_NRC

Non-recurring charge (in dollars) billed for additional units of
this circuit element

Float

0

Initial_MRC

Monthly recurring charge (in dollars) for the first unit billed

Float

17.7

PBDS_Bandwidth
MRP1

Billing_Code
Zone

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Table II.B.4 Part 1
Record Format for Monthly Billing Data for Circuits by Circuit and Rate Element
Field Name

Description

Type

Example

Unit_MRC

Monthly recurring charge (in dollars) for additional units billed
(if different from the amount billed for the initial unit)

Float

0

Billed

Per unit monthly amount (in dollars) billed for the circuit element
including all “in-cycle” discounts and penalties. For circuit
elements with multiple billed units (i.e., quantity greater than one
in II.B.4.o), enter the amount billed for a single unit

Float

507.3

Total_Billed

Total monthly amount (in dollars) billed for all units of the circuit
element, including all “in-cycle” discounts and penalties

Float

12453.50

Term

Length of total time of the Term Commitment associated with this
circuit (in months). List the total length of the current Term
Commitment, not the remaining length of the Term Commitment.
A circuit purchased on a month-to-month basis is coded as 1.

Integer

36

End_Date

If this circuit has an associated Term Commitment, enter the
month and year the term expires

Date

03/2014

Term_Discount_IC

Indicator variable for whether any in-cycle term discounts have
been rolled into the amount billed to the customer reported in the
Billed field (0 = No in-cycle term discounts included in Billed
amount; 1 = In-cycle term discounts included in Billed amount)
Indicator variable showing whether this circuit contributes to a
Volume Commitment (Y=Yes, N=No)

Integer

0

Text

N

Indicator variable for whether any in-cycle volume discounts
have been rolled into the amount billed to the customer reported
in the Billed field (0 = No in-cycle volume discounts included in
Billed amount; 1 = In-cycle volume discounts included in Billed
amount)
Indicator variable showing whether this circuit was purchased out
of a Contract-Based Tariff (Y=Yes, N=No)

Integer

0

Text

N

Adjustment_ID_1

Unique ID number (from II.B.5.a) of the first billing
adjustment/true-up affecting this circuit element. Leave field
blank if there are no discounts or penalties that occur during the
monthly billing cycle affecting this circuit element

Integer

6

Adjustment_ID_2

Unique ID number (from II.B.5.a) of the second billing
adjustment/true-up affecting this circuit element, if multiple
adjustments were applied to this rate element. Leave the field
blank if there are fewer than two discounts applied to this circuit
element in the given billing cycle

Integer

14

…

[Continue to add columns for a total of ten (10) Adjustment_ID
columns.]

…

…

Adjustment_ID_10

Unique ID number (from II.B.5.a) of the tenth billing
adjustment/true-up affecting this circuit element, if multiple
adjustments were applied to this rate element. Leave the field
blank if there are fewer than ten discounts applied to this circuit
element in the given billing cycle

Integer

63

Volume_Commitment
Vol_Discount_IC

Offer

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Table II.B.4 Part 2
Record Format for Identifying Customers
Field Name

Description

Type

Example

Customer_ID

Unique customer identifier used to link all circuits purchased by a
customer over all geographies and time periods. This field will
be used to link the billing information in Table II.B.4 Part 1 with
the customer names and identification numbers
Where applicable, include the six-digit 499A Filer ID of the
customer
Where applicable, include the Access Customer Name
Abbreviation (ACNA) of the customer
Where applicable, include the Operating Company Number
(OCN) of the customer
Enter the name of the customer

Integer

1274

Integer

822116

Text

ABC

Integer

1234

Text

Verizon Wireless

Indicator variable denoting whether the circuit is purchased by a
Provider (0 = non-Provider; 1 = Provider)

Integer

1

Customer_ID_499
Customer_ID_ACNA
Customer_ID_OCN
Customer_Name
Provider

Instructions for Table II.B.4, Parts 1 and 2: 31
a. Closing_Date: Enter the date on which the customer was billed. The date must appear in
mm/dd/yyyy format. All dates must be in the ranges 01/01/2010 – 12/31/2010 or 01/01/2012 –
12/31/2012. Do not include data on circuits billed outside the appropriate date ranges, even if
services were provided within the appropriate date ranges (e.g., service that was provided in
December 2010 that was billed in January 2011). Likewise, include data on circuits billed in the
appropriate date ranges, even if the service was provided outside of those ranges (e.g., service
provided in December 2011 that was billed in January 2012).
b. The following fields in Parts 1 and 2 of Table II.B.4 are used to identify the customer of the
Dedicated Service.32
 Customer_ID: Assign a unique identifier to each customer so that all circuits purchased by the
customer can be tracked over time and across locations. The identifiers must be entered in
integer format. This Customer_ID will be used to link the circuit billing information (Table
II.B.4 Part 1) to the customer names and identification numbers (Table II.B.4 Part 2). In Part 2,
provide the customer name, an indicator for whether the customer is a Provider, and, where
applicable, one of the following identification numbers: 499A filer ID, Access Customer Name
Abbreviation (ACNA), or Operating Company Number (OCN). Note, the Customer_ID variable
is required for all observations in both Part1 and Part 2. However, only one of the three
additional identification numbers (499, ACNA, OCN) need be provided, even if multiple
31

Subparts listed herein refer to supbarts in Question II.B.4.

32

See Data Collection Implementation Order § III.C (discussing changes to Questions II.B.4-6).

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








identification numbers are available. Each Customer_ID must appear only once in Part 2, but
will likely appear multiple times in Part 1.
Customer_ID_499: Where applicable, include the 499A Filer ID of the customer. The 499A
Filer ID does not replace the Customer_ID variable. Both the Customer_ID and
Customer_ID_499 fields are populated for any customer with a 499A Filer ID. If the customer
does not have a 499A Filer ID, leave the field blank.
Customer_ID_ACNA: Where applicable, include the Access Company Name Abbreviation
(ACNA) of the customer in Part 2. The ACNA does not replace the Customer_ID variable. Both
the Customer_ID and Customer_ID_ACNA fields are populated for any customer with an
ACNA. If the customer does not have an ACNA, leave the field blank.
Customer_ID_OCN: Where applicable, include the Operating Company Number (OCN) of the
customer in Part 2. The OCN does not replace the Customer_ID variable. Both the Customer_ID
and Customer_ID_OCN fields are populated for any customer with an OCN. If the customer
does not have an OCN, leave the field blank.
Customer_Name: Enter the name of the customer in Part 2 of Question II.B.4. The variable must
be entered as a string and be no longer than 30 characters in length.
Provider: Indicate whether the customer is a Provider in Part 2. Enter a 1 if the customer is a
Provider and a 0 otherwise. In some instances, it may be difficult to identify if the customer is a
Provider using billing information, but can often be inferred by the existence of a 499A Filer ID
or by whether USF charges are passed on to the customer in their bill.

c. Location_ID: Include the Location ID for each circuit element on the circuit. The Location ID is
used to link the billed circuit with the facilities information reported in Question II.B.3. That is, every
unique Location ID referenced in Question II.B.4 must match to a Location ID reported in II.B.3.
Also, for circuits that connect two Locations, the Location ID may not be constant within the Circuit
ID. For example, the individual circuit elements for a given Circuit ID may include two channel
terminations, each terminating at a different Location. The Location ID must be populated for every
circuit element in the data set. Specifically, any termination charge must be linked to a Location. If
the sold Dedicated Service is not to a Location, e.g., the sale of dedicated interoffice transport, leave
this field blank.
d. Circuit_ID: Assign a unique circuit identifier (Circuit ID) to all circuit elements purchased in
common for a particular circuit. If the circuit is sold over multiple time periods, the circuit identifier
must track the circuit across the multiple months and/or years it appears in the sample. We prefer that
you code the Circuit IDs as sequential integers, beginning with the number “1” (similar to the
Location ID). However, to the extent you have an established naming convention for your circuits,
that convention may be substituted in place of sequential numbering. Code the Circuit ID as a string
with a maximum of 15 characters. (Note: Because some filers may choose to use non-numeric
characters in their coding, Circuit IDs must be coded as string variables, even if they have been
renumbered as sequential integers.)
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e. The following fields identify the type of circuit sold (Circuit Type), and the bandwidth of the circuit.
The Circuit Type must be populated for every circuit element in the data set. Only one of the three
bandwidth variables needs to be populated for each circuit element, depending on the type of circuit
provided.
 Circuit_Type: Indicate the type of circuit sold from the following categories: DS1, DS3, DS1UNE, DS3-UNE, other CBDS circuit (i.e., non-DSn), or PBDS. For packages of DS1s and DS3s
sold to a Location, enter DS1 or DS3, respectively. Do not enter circuit types other than those
listed above.
 DSn_Bandwidth: If the circuit is a DS1, DS3, DS1-UNE, or DS3-UNE, enter the bandwidth of
the circuit in Mbps, i.e., enter 1.544 for a DS1 and enter 44.736 for a DS3. In the case where
multiple DSns are provisioned over a single circuit, enter the total bandwidth. For example, the
bandwidth for a circuit with three DS1s must be entered as 4.632 (= 3 × 1.544). For non-DSn
circuits, leave the field blank.
 OtherCBDS_Bandwidth: If the circuit is a non-DSn CBDS circuit, enter the bandwidth of the
circuit in Mbps. For symmetric services, the reported bandwidth is the one-way bandwidth of the
circuit (i.e., upstream or downstream). For asymmetric services, report the average of the
upstream and downstream bandwidths. Round the bandwidth of the circuit to three decimal
places. For example, if the service guarantees 10 Mbps transmission speeds in one direction and
5 Mbps transmission speeds in the other direction, enter 7.500 in this field. If the circuit is a DSn
or PBDS circuit, leave this field blank.
 PBDS_Bandwidth: If the circuit is a PBDS circuit, enter the bandwidth of the circuit in Mbps.
For symmetric services, the reported bandwidth is the one-way bandwidth of the circuit (i.e.,
upstream or downstream). For asymmetric services, report the average of the upstream and
downstream bandwidths. For example, if the service guarantees 150 Mbps transmission speeds in
one direction and 50 Mbps transmission speeds in the other direction, enter 100 in this field.
Round the bandwidth of the circuit to three decimal places. For non-PBDS circuits, leave this
field blank.
f.

MRP1: Enter the 8-character CLLI for the serving wire center or mileage rating point (MRP) on one
end of the circuit.

g. MRP2: Enter the 8-character CLLI for the serving wire center or MRP on the other end of the circuit.
h. MRP1_Lat: Enter the latitude coordinate of MRP1 to the nearest ±0.0005, i.e., each coordinate must
end in #.###0 or #.###5. Coordinates must be in the WGS84 or NAD83 geographic coordinate
system.
i.

MRP1_Long: Enter the longitude coordinate of MRP1 to the nearest ±0.0005, i.e., each coordinate
must end in #.###0 or #.###5. Coordinates must be in the WGS84 or NAD83 geographic coordinate
system.
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j.

MRP2_Lat: Enter the latitude coordinate of MRP2 to the nearest ±0.0005, i.e., each coordinate must
end in #.###0 or #.###5. Coordinates must be in the WGS84 or NAD83 geographic coordinate
system.

k. MRP2_Long: Enter the longitude coordinate of MRP2 to the nearest ±0.0005, i.e., each coordinate
must end in #.###0 or #.###5. Coordinates must be in the WGS84 or NAD83 geographic coordinate
system.
l.

MRP_Type: If the billed circuit element can be associated with a specific wire center/mileage rating
point, indicate whether the wire center/mileage rating point is MRP1 or MRP2 above. Enter a 1 if the
circuit element is associated with MRP1 and enter 2 if the circuit element is associated with MRP2.
If the circuit element cannot be attributed to a single wire center, or if the circuit element can be
associated with both wire centers, enter 0 in the MRP_Type field. For example, a channel
termination from a customer location to MRP1 is coded as 1 in this field. An interconnection charge
between your network and the network of another carrier at MRP2 is coded as 2. A transport mileage
charge between MRP1 and MRP2 must be coded as a zero (unless that mileage is able to be attributed
to either MRP1 or MRP2). All charges for channel terminations need to be attributed to one of the
MRPs.

m. Billing_Code: The billing code variable (Billing Code) is used to identify the individual components
of billed circuits. The Billing Code is used to link the billed circuit elements with the description of
those elements in Question II.B.6. An example of a Billing Code is a USOC. However, you are not
required to use a USOC to identify the circuit elements; you can create your own Billing Codes.
Similar circuit elements need to have the same Billing Code in order to track similar charges across
circuits. To the extent that circuits are billed to customers by individual circuit elements, the
elements (along with the billed amounts for those elements) must be disaggregated into separate lineitems in Table II.B.4. If circuits are billed at the overall circuit level, only one line per circuit need be
populated, and all like circuits may have the same Billing_Code and Billing Code description.
n. Zone: Enter the density pricing zone for this circuit element. See 47 C.F.R. § 69.123 (density pricing
zones for special access and switched transport). If you enter a density pricing zone, then explain the
density breakpoints between each zone for your applicable study area(s) in your Explanatory
Attachment,33 e.g., pricing zone one contains offices having at least 500 equivalent DS1 channels,
pricing zone two contains offices having at least 100, but no more than 499, equivalent DS1 channels,
etc. If the density pricing zone is not applicable for a particular circuit element or group of circuit
elements, leave the field blank.

33

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o. Quantity: Enter the number of billed units for this circuit element. Do not enter the bandwidth of the
circuit in this field. For item codes that describe per-mile charges, the Quantity is the number of
miles in the circuit that apply for that item code.
p. Initial_NRC: Insofar as the per unit monthly billed amount (Question II.B.4.t) can be broken into
recurring and non-recurring charges, enter the non-recurring charge (in dollars) billed for the first unit
of this circuit element on this circuit. Enter the charge to two decimal places and do not include other
string characters (e.g., “$”).
q. Unit_NRC: Insofar as the per unit monthly billed amount (Question II.B.4.t) can be broken into
recurring and non-recurring charges, enter the non-recurring charge (in dollars) billed for each
additional unit of this circuit element on this circuit. Enter the charge to two decimal places and do
not include other string characters (e.g., “$”).
r.

Initial_MRC: Insofar as the per unit monthly billed amount (Question II.B.4.t) can be broken into
recurring and non-recurring charges, enter the monthly recurring charge (in dollars) billed for the first
unit of this circuit element on this circuit. Enter the charge to two decimal places and do not include
other string characters (e.g., “$”).

s. Unit_MRC: Insofar as the per unit monthly billed amount (Question II.B.4.t) can be broken into
recurring and non-recurring charges, enter the monthly recurring charge (in dollars) billed for each
additional unit of this circuit element on this circuit. Enter the charge to two decimal places and do
not include other string characters (e.g., “$”).
t.

Billed: Per unit monthly amount (in dollars) billed for the circuit element including all “in-cycle”
discounts and penalties. “In-cycle” discounts and penalties are those adjustments that are rolled into
the actual amount paid by the customer each month (see the instructions to Question II.B.5 for more
information on “in-cycle” vs. “out-of-cycle” billing adjustments). If in-cycle adjustments show up as
a separate line-item on the customer’s bill, they must be reported as separate line-items in Table
II.B.4. Do not include any “out-of-cycle” adjustments as otherwise reported in response to Question
II.B.4.y. For circuit elements with multiple billed units (i.e., quantity greater than one in Question
II.B.4.o), enter the amount billed for a single unit, such that the product of Quantity and Billed is the
total charge on the bill. For example, if the circuit includes two “channel termination” charges that
are both billed at the same rate (and have the same Billing_Code (Question II.B.4.m), Location_ID,
bandwidth, etc.), the quantity (Question II.B.4.o) is equal to 2, and the per unit monthly billed amount
(Question II.B.4.t) must equal the charge for a single channel termination. Alternatively, each
channel termination may be recorded separately (i.e., on two separate lines with quantity equal to 1
for each line). The multiplicative product requirement also applies to charges for mileage of the
circuit, if the circuit has such a charge. For example, if the circuit is 4 miles in length, the amount
entered in Quantity is 4 and the amount entered in the Billed field is the charge per 1 mile. Enter the
billed amount to two decimal places, and do not include other string characters (e.g., “$”). Fractional
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miles are permitted if the customer was billed for fractional mileage for any given circuit element.
However, the amount entered in the Billed field must be converted to a whole-mile charge. For
example, for a half mile circuit, the Quantity is reported as 0.5 on any per-mile circuit element, but
the amount in Billed is the 1-mile charge such that the product of Quantity and Billed is equal to the
total charge to the customer.
u. Total_Billed: Total monthly amount (in dollars) billed for all units of the circuit element including all
“in-cycle” discounts and penalties. “In-cycle” discounts and penalties are those adjustments that are
rolled into the actual amount paid by the customer each month (see the instructions to Question II.B.5
for more information on “in-cycle” vs. “out-of-cycle” billing adjustments). If in-cycle adjustments
show up as a separate line-item on the customer’s bill, they must be reported as separate line-items in
this table. Do not include any “out-of-cycle” adjustments as otherwise reported in Question II.B.4.y.
v. The following questions seek to understand the Term Commitments under which circuits are
purchased.
 Term: Length of total time of the Term Commitment associated with this circuit (in months). List
the total length of the current Term Commitment, not the remaining length of the Term
Commitment. For example, in reporting circuits for calendar month January 2010, enter 60 for a
circuit that was sold in January 2007 under a 5 year commitment, even though only 24 months
remain on the current term. For circuits sold on a month-to-month basis, enter 1. We anticipate
that this value is identical for all circuit elements sold in common on the circuit. To the extent
that the term length varies across different circuit elements, enter the appropriate term
commitment for each individual circuit element.
 End_Date: If the circuit has an associated total term longer than one month, enter the month and
year the term expires. In the preceding example, the End_Date would be coded as 12/2012, sixty
months after the five-year term was agreed to in January 2007. Leave the End_Date field blank
for those circuits purchased on a month-to-month basis.
 Term_Discount_IC: Indicate whether the per unit monthly billed amount in Question II.B.4.t
includes any in-cycle discounts that have been applied due to a Term Commitment. Enter a 1 if
the per unit monthly billed amount includes in-cycle term discounts; enter 0 if the per unit
monthly billed amount does not include in-cycle term discounts. If the term discounts for this
circuit are only given through out-of-cycle adjustments as reported in Question II.B.5, enter 0. If
the circuit is not sold under a Term Commitment, leave this field blank.
w. Volume_Commitment: Indicate whether this circuit was sold under a Volume Commitment. Enter 0
if the circuit was not sold under a Volume Commitment, and enter 1 if the circuit was sold under a
commitment by the customer to purchase either a specified number of circuits or to spend a specified
Revenue amount.
 Vol_Discount_IC: Indicate whether the per unit monthly billed amount in Question II.B.4.t
includes any in-cycle discounts that have been applied due to a Volume Commitment, either in
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total number of circuits or total amount of expenditures (“spend”). Enter a 1 if the per unit
monthly billed amount includes in-cycle volume discounts; enter 0 if the per unit monthly billed
amount does not include in-cycle volume discounts. If the volume discounts for this circuit are
only given through out-of-cycle adjustments as reported in Question II.B.5, enter 0. If the circuit
is not sold under a Volume Commitment, leave this field blank.
x. Offer: Indicate whether the circuit was purchased under a Contract-Based Tariff. Enter 1 if the
circuit was purchased under a Contract-Based Tariff and enter 0 if it was not.
y. Adjustment_ID_1; Adjustment_ID_2; …Adjustment_ID_10: For each out-of-cycle billing
adjustment applied to the circuit element, provide a unique adjustment ID that is used to link the
circuit elements with the dollar value and descriptions of the appropriate adjustments. The table must
include 10 columns for each of the ten potential Adjustment_IDs, regardless of whether all columns
are used. For rate elements with fewer than ten out-of-cycle adjustments, leave the excess
Adjustment_ID fields blank. If a circuit element had more than ten out-of-cycle adjustments applied
to it, list the Adjustment_IDs of the ten largest adjustments. For example, if a circuit element
receives five distinct adjustments, there must be five Adjustment_IDs in the first five columns. The
remaining Adjustment_ID columns (i.e., columns 6 through 10) would be left blank. In addition, all
adjustments must link back to the adjustment amounts and descriptions provided in response to
Question II.B.5. See the instructions for Question II.B.5 for further instructions on adjustments.
Question II.B.5: Billing Adjustments
For each adjustment or true-up (including credits for meeting or penalties for not meeting contractual
obligations) to billed circuit elements, provide the following information below. Provide the adjustment
at the lowest level of aggregation available, and if possible, at the level of the individual circuit element.
If the adjustment applies to multiple circuit elements and/or circuits, provide the total dollar amount of the
billing adjustment, and include an Adjustment_ID for each circuit element reported in Question II.B.4
that can be used to link the billing adjustment (or true-up) with the appropriate circuit elements.
Note on “in-cycle” vs. “out-of-cycle” billing adjustments: Question II.B.5 is meant to capture all
adjustments, penalties, and true-ups that are settled outside of the monthly billing cycle (as opposed to
adjustments that are rolled into the price billed to the customer each month). Examples include lump-sum
discounts for Term and Volume Commitments, early termination penalties, rebates for network outages or
degraded service quality, waivers of non-recurring charges such as installation fees, etc.
For example, suppose a customer buys a single circuit with a One Month Term Only Rate of $300 per
month, but receives a $100 discount on the One Month Term Only Rate each month for committing to a
5-year Term Commitment. If the Provider of the circuit rolls the discounted amount into the monthly bill,
i.e., the customer is billed $200 every month, then the discount is considered an “in-cycle” adjustment,
and the Provider need not report it as a separate “out-of-cycle” adjustment in Table II.B.5. The seller
would only need to report the $200 charge in Question II.B.4, along with an indicator showing a Term
Commitment in Question II.B.4.u. (Alternatively, depending on the billing system, the discount may

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show up as a separate -$100 line item in Question II.B.4 along with the $300 One Month Term Only
Rate.)
However, if the Provider charges the customer the full $300 for the circuit every month, then returns a
$600 payment to the purchaser every 6 months, the $600 payment must be recorded in Table II.B.5 as an
out-of-cycle adjustment, and the appropriate Adjustment_ID must appear next to the affected circuit
elements in Question II.B.4. Likewise, if the customer is billed at the $200 discounted rate each month
but then decides to terminate the contract early and pay an early termination fee of $1000, the $1000
charge must be recorded as an out-of-cycle adjustment in Question II.B.5.
Table II.B.5
Record Format for Billing Adjustment Data Circuits by Circuit
Field Name

Description

Type

Example

Adjustment_ID

Unique ID number for the billing adjustment or true-up

Integer

1

Contract_ID

Unique ID number for the Tariff or other agreement from which
the adjustment originates. Leave the field blank if the adjustment
cannot be linked back to a single contract
Beginning date of adjustment period (or true-up) in mm/dd/yyyy
format

Integer

33

Date

01/01/2012

Date_to

Ending date of adjustment period (or true-up) in mm/dd/yyyy
format

Date

06/30/2012

Adjustment_Scope

Code indicating scope of adjustment. Enter 1 if adjustment
applies to single circuit element for single circuit, enter 2 if
adjustment applies to more than one circuit element on a single
circuit, enter 3 if adjustment applies to more than one circuit
element across multiple circuits, enter 4 if the adjustment is an
overall adjustment that applies to every circuit purchased.

Integer

2

Adjustment

Total dollar amount of billing adjustment (or true-up) for all
circuit elements across all circuits covered by the adjustment.
Any increase in the amount owed to the vendor (e.g., penalty) is a
positive number while any decrease in the amount owed to the
vendor (e.g., discount or rebate) is a negative number.

Float

-100

Adj_Term

Indicator variable denoting whether the adjustment/true-up was
due to a Term Commitment (Y=Yes, N=No)

Text

Y

Adj_Term_Length

If Adj_Term=1, enter the term length in months. If Adj_Term=0,
leave blank

Integer

60

Adj_Vol

Indicator variable denoting whether the adjustment/true-up was
due to a Volume Commitment (Y=Yes, N=No)

Text

Y

Adj_Vol_Circ

If Adj_Vol=1, and the Tariff or other agreement required the
purchase of a certain number of circuits, enter the number of
circuits specified in the Tariff or other agreement which are
necessary to qualify for the adjustment. If Adj_Vol=0, or the
adjustment corresponds to a commitment to a given level of
expenditures/spend, leave blank

Integer

500

Adj_Vol_Rev

If Adj_Vol=1, and the Tariff or other agreement required the
purchase of a certain dollar amount of expenditures/spend, enter
the dollar value of the expenditure requirement. If Adj_Vol=0 or

Float

20,000

Date_from

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Table II.B.5
Record Format for Billing Adjustment Data Circuits by Circuit
Field Name

Adjustment_Other

Description
the adjustment corresponds to a commitment to purchase a certain
number of circuits, leave the field blank
If the adjustment/true-up is for some other reason, give a brief
description of the reason for the adjustment

Type

Example

Text

Network Outage

Instructions for Table II.B.5, Record Format for Billing Adjustment Data Circuits by Circuit:
a. The following questions identify each out-of-cycle billing adjustment with an adjustment ID and the
Tariff or other agreement from which they originate.
 Adjustment_ID: Create a unique adjustment ID for each out-of-cycle billing adjustment applied
to customer purchases during the relevant timeframe. Although each Adjustment_ID may
correspond to multiple circuit elements in Table II.B.4, each must appear only once in Table
II.B.5. Only include adjustments which were charged/remitted to the customer during the 2010
and 2012 reporting periods. For example, do not include adjustments that were charged/remitted
in January 2011, even if the adjustment applied to service provided in December 2010. Likewise,
report any adjustments charged/remitted in January 2012, even if those adjustments applied to
service provided in December 2011.
 Contract_ID: Assign a unique ID number for the Tariff or other agreement from which the
adjustment originates. This field is used to group adjustments together by the Tariff or other
agreement. Leave the field blank if the adjustment cannot be linked back to a single Tariff or
other agreement.
b. Date_From: Enter the beginning date of the adjustment period in mm/dd/yyyy format. For example,
if a Tariff or other agreement specifies a rebate be returned to the customer every three months, enter
the beginning date of the three-month period for which the rebate applies, and not the beginning date
of the Tariff or other agreement from which the adjustment originated. Likewise, do not enter the
date on which the adjustment was charged/remitted.
c. Date_To: Enter the ending date of the adjustment period in mm/dd/yyyy format. For example, if a
Tariff or other agreement specifies a rebate to the customer every three months, enter the ending date
of the 3-month period for which the rebate applies, and not the ending date of the Tariff or other
agreement from which the adjustment originated. Likewise, do not enter the date on which the
adjustment was charged/remitted.
d. Adjustment_Scope: Enter the scope of the adjustment according to the following codes: Enter 1 if
the adjustment applies to a single circuit element on a single circuit. Enter 2 if the adjustment applies
to more than one element on a single circuit. Enter 3 if the adjustment applies to one or more circuit
elements across multiple circuits. Enter 4 if the adjustment is an overall adjustment that applies to
every circuit purchased by the customer (as indicated by the Customer_ID in Question II.B.3). Apply
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the codes as described above, even if the adjustment applies to multiple time periods. For example, if
a rebate is given for a single circuit element on a single circuit (as determined by the Circuit_ID in
Question II.B.3), assign an Adjustment_Scope of 1, even if the adjustment period (as determined by
Date_From and Date_To) extends over multiple months.
e. Adjustment: Enter the total dollar amount of the billing adjustment for all circuit elements across all
circuits and across the entire adjustment period. Any increase in the amount owed to the vendor (e.g.,
penalty) is a positive number, while any decrease in the amount owed to the vendor (e.g., discount or
rebate) is a negative number. For example, suppose the Provider gave a customer a $2000 rebate on
10/31/2010, and that this rebate covered 100 circuits purchased during the six-month period from
04/01/2010 to 10/01/2010. In this case, the filer must enter “-2000” in the Adjustment field with the
appropriate Date_From and Date_To values. In addition, the Adjustment_Scope (see above) is
recorded as 3, and the Adjustment_ID for this specific rebate is included next to the 100 circuits in the
Adjustment_ID_# fields in Table II.B.4.
f.

These fields describe the type of adjustment applied to the circuit elements.
 Adj_Term: If the adjustment/true-up can be linked to a rebate given (or penalty charged) on a
Term Commitment, enter 1. Enter 0 if the adjustment was not due to a Term Commitment.
 Adj_Term_Length: If Adj_Term is equal to 1, enter the total term length (not the remaining term
length) in months. If Adj_Term is equal to 0, leave the Adj_Term_Length variable blank.
 Adj_Vol: Enter 1 if the adjustment/true-up can be linked to a rebate (or penalty) on a Volume
Commitment. Enter 0 if the adjustment was not due to a Volume Commitment. If the Volume
Commitment corresponds to a certain number of circuits, enter the number of circuits necessary to
qualify for the discount in the Adj_Vol_Circ field. If the Volume Commitment corresponds to a
certain level of “spend” or dollar value of services, enter the dollar amount necessary to qualify
for the discount in the Adj_Vol_Rev field.
 Adj_Vol_Circ: If Adj_Vol is equal to 1, and the Tariff or other agreement required the purchase
of a certain number of circuits to qualify for a discount, enter the number of circuits. If Adj_Vol
is equal to 0 or the Volume Commitment was a commitment to a given level of expenditures or
“spend”, leave this field blank.
 Adj_Vol_Rev: If Adj_Vol is equal to 1 and the Tariff or other agreement required the purchase
of a certain dollar amount of expenditures (or “spend”) to qualify for a discount, enter the dollar
value of the expenditure requirement. If Adj_Vol is equal to 0 or the Volume Commitment was a
commitment to purchase a certain number of circuits, leave this field blank.
 Adjustment_Other: If the adjustment/true-up was for some reason other than a Term or Volume
Commitment, give a brief description of the reason in this field. Do not exceed 120 characters in
your response. Leave blank if either Adj_Term or Adj_Vol is equal to 1. An example of such an
adjustment may be a rebate remitted to the customer in compensation for an unanticipated
network outage or degraded quality of service.

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Question II.B.6: Billing Code Descriptions
Provide descriptions for each unique billing code referenced in Table II.B.4 Part 1. Enter one record for
each unique billing code. Examples of common circuit elements are given in the diagram in Question
II.B.6.b. If the billed element cannot be described by the elements listed in the diagram, provide a
description of the billed element. To the extent you bill circuits as a whole, rather than on an element-byelement basis, describe the billed unit, see Question II.B.6.c, and assign a single unique ID.
Table II.B.6 is used to link the descriptions of billing codes with the billed circuit elements reported in
Table II.B.4 Part 1 using the Billing_Code variable in each table. Although each Billing_Code may
appear multiple times in Table II.B.4 Part 1, you can only have one entry for each unique Billing_Code
reported in Table II.B.6. Additionally, every Billing_Code that appears in Table II.B.4 Part 1 must be
identified in Table II.B.6.
Table II.B.6
Record Format for Descriptions for Circuits by Circuit
Field Name

Description

Type

Example

Billing_Code

Billing code (e.g., USOC) used to identify the billed circuit
element. (This variable will aslo appear in Question II.B.4 and
is used to link the billed circuit elements with their
descriptions)
Brief description of circuit element

Text

1YZXD

Text

Channel Mileage

The description of the circuit element as it appears on the
customer’s bill.

Text

Billing_Code_Description
Billing_Code_Desc_Other

Instructions for Table II.B.6, Record Format for Descriptions for Circuits by Circuit:
a. Billing_Code: The billing code variable is used to identify the individual components of billed
circuits. The billing code is used to link the billed circuit elements in question II.B.4 with the
description of those elements in Question II.B.6. A USOC is an example of billing code. However,
USOC codes are not required to identify the circuit elements; you can create your own billing code.
Enter the billing code as a string variable not to exceed 15 characters in length.
b. Billing_Code_Description: Choose the description from the list/diagram in Question II.B.6 that best
describes the circuit element. See list of circuit elements in Question II.B.6.b. Make every effort to
assign the billed element to one of the categories listed here. If the item billed to the customer does
not fit any of these categories, this field may be left blank and the billed element can be described in
the field Billing_Code_Desc_Other. This may occur, for example, if circuits are billed as a complete
package instead of on an element-by-element basis (i.e., all the elements in the circuit are billed
together under a single price). In such a case, a single billing code for the circuit elements listed in
Question II.B.6.b may not apply; this field may be left blank and the appropriate description of the
billed item may be filled out in Billing_Code_Desc_Other.

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Billing_Code_Desc_Other: Enter a longer description of the circuit element. For circuit elements
categorized under one of the descriptions in Billing_Code_Description, this field is optional. If
Billing_Code_Description is left blank, this field is required. Keep descriptions under 150 characters.
Question II.B.7: Wire Centers - CLLI Codes - Regulatory Treatment
Table II.B.7
Record Format for Wire Centers
Field Name

Description

Type

Example

CLLI

Telcordia-specified eight-character CLLI of the ILEC
wire center / exchange area with collocation(s)
Actual situs for the wire center (i.e., land were wire
center is located)

Text

WASHDCSW

Text

445 Twelfth St
SW

City

City of the wire center

Text

Washington

State

Two-letter state postal abbreviation of the wire center

Text

DC

ZIP

5-digit ZIP code (with leading zeros) of the wire center

Text

20554

ZIP4

4-digit add-on code (with leading zeros) of the wire
center

Text

0000

Lat

Latitude

Float

38.8835

Long

Longitude

Float

-77.0280

Street_address



Latitude and Longitude: You can derive the coordinate fields for the location address from a
known geocoding platform like Bing maps, Google, Yahoo, batchgeo.com, Texas A&M
Geoservices, or other geocoding solution. Enter values in decimal degrees to the nearest ±0.0005,
i.e., each coordinate must end in #.###0 or #.###5. Coordinates must be in the WGS84 or
NAD83 geographic coordinate system.

Revenues, Terms and Conditions Information
Question II.B.8: Sales Revenues for CBDS
Table II.B.8
Record Format for CBDS Revenues
Field Name

Description

Type

Example

Revenue

Enter the total dollar amount of your Revenues from the
sale of CBDS for the reported Year
Indicate the service type category for which the Revenues
are reported. Enter “DS1” for DS1 Revenues, enter “DS3”
for DS3 Revenues, and enter “Other” for other CBDS
Revenues
Enter 0 if the reported Revenues are for End Users, and
enter 1 if the reported Revenues are for Competitive
Providers
Enter “2010” if the reported Revenues are for the year
2010, and enter “2012” if the reported Revenues are for the

Float

123,456

Text

DS3

Binary

1

Integer

2012

Service_Type

Customer_Type
Year

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Table II.B.8
Record Format for CBDS Revenues
Field Name

Description

Type

Example

year 2012

Question II.B.9: Sales Revenues for PBDS
Table II.B.9
Record Format for PBDS Revenues
Field Name

Description

Type

Example

Revenue

Enter the total dollar amount of your Revenues from the sale
of PBDS for the reported Year
Indicate the bandwidth category for which the Revenues are
reported. Enter “A” for bandwidth less than or equal to 1.5
Mbps, enter “B” for bandwidth greater than 1.5 Mbps but
less than or equal to 50 Mbps, enter “C” for bandwidth
greater than 50 Mbps but less than or equal to 100 Mbps,
enter “D” for bandwidth greater than 100 Mbps but less than
or equal to 1 Gbps, and enter “E” for bandwidth greater than
1 Gbps
Enter 0 if the reported Revenues are for End Users, and enter
1 if the reported Revenues are for Competitive Providers
Enter “2010” if the reported Revenues are for the year 2010,
and enter “2012” if the reported Revenues are for the year
2012

Float

123,456

Text

D

Binary

1

Integer

2012

Bandwidth

Customer_Type
Year

Question II.B.10: Revenues from One Month Term Only Rates
Table II.B.10
Record Format Revenues from One Month Term Only Rates
Field Name
Revenues
Service_Type
Customer_Type
Year

Description
Enter the total dollar amount of your Revenues from One
Month Term Only Rates charged for the reported Year
Indicate the service type category for which the Revenues are
reported. Enter “DS1” for DS1 Revenues, enter “DS3” for
DS3 Revenues, and enter “PBDS” for PBDS Revenues
Enter 0 if the reported Revenues are for End Users, and enter
1 if the reported Revenues are for Competitive Providers
Enter “2010” if the reported Revenues are for the year 2010
and enter “2012” if the reported Revenues are for the year
2012

Type

Example

Float

123,456

Text

PBDS

Binary

1

Integer

2012

Question II.B.11: Number of Customers with One Month Term Only Rates
Table II.B.11
Record Format for Customers with One Month Term Only Rates
Field Name
OMT_CustCount
Service_Type

Description
Number of One Month Term Only Rate customers for DS1s,
DS3s, and PBDS as of Dec. 31, 2012
Indicate the service type category for which the Revenues are
reported. Enter “DS1” for DS1 Revenues, enter “DS3” for
DS3 Revenues, and enter “PBDS” for PBDS Revenues

Instructions – Page 54

Type

Example

Integer

54,321

Text

DS1

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Table II.B.11
Record Format for Customers with One Month Term Only Rates
Field Name

Description

Type

Example

Customer_Type

Enter 0 if the reported Revenues are for End Users, and enter
1 if the reported Revenues are for Competitive Providers

Binary

1

Question II.B.12: All Applicable Tariff Plans and Contract-Based Tariffs
Table II.B.12
Record Format for Applicable Tariff Plans and Contract-Based Tariffs
Field Name

Description

Type

Example

Tar_Plan

Plan is a Tariff Plan (Y=Yes, N=No)

Text

Y

CBT_Plan

Plan is a Contract-Based Tariff (Y=Yes, N=No)

Text

N

Plan_Name

Name of plan

Text

Green Tariff

Tar_Sec

Tariff Section and Number

Text

ABC Co.
FCC No. 2 §
7.90

Term_Com

Does plan contain a Term Commitment?
(Y=Yes, N=No)

Text

Y

Vol_Com

Does plan contain a Volume Commitment?
(Y=Yes, N=No)

Text

Y

Non_Rate_Benefit

Does plan contain a Non-Rate Benefit option?
(Y=Yes, N=No)

Text

Y

Non_Rate_Benefit_Exp

If plan contains a Non-Rate Benefit option, explain the NonRate Benefits.

Text

Plan allows
for circuit
portability . .
.

Text

Y

Text

Y

Text

Y

Text

Y

Text

N

Text

Y

Text

N

Text

N

Plan_DS1
Plan_DS3
Plan_PBDS
Plan_Other

Plan_Geo_Nat

Plan_Geo_MSA

Plan_Geo_nonMSA

PPB_Com

Does plan apply to purchase of DS1s?
(Y=Yes, N=No)
Does plan apply to purchase of DS3s?
(Y=Yes, N=No)
Does plan apply to purchase of PBDS?
(Y=Yes, N=No)
Does plan apply to purchase of other services? (Y=Yes,
N=No)
Is the plan available across your entire nationwide service
area? Enter “Y” if the plan is available across your entire
service area, including both within and outside of MSAs, and
enter “N” if it is only available in a subset of your service
area.
If the plan is not available across your entire nationwide
service area (i.e., Plan_Geo_Nat = “N”), indicate whether the
plan is available in at least one MSA. Enter “Y” if the plan is
available in at least one MSA, and enter “N” if it is only
available in non-MSA areas. If Plan_Geo_Nat = “Y”, the
value for Plan_Geo_MSA must be “Y”
If the plan is not available across your entire nationwide
service area (i.e., Plan_Geo_Nat = “N”), indicate whether the
plan is available in at least one non-MSA area. Enter “Y” if
the plan is available in at least one non-MSA, and enter “N” if
it is only available in MSAs. If Plan_Geo_Nat = “Y”, the
value for Plan_Geo_nonMSA must be “Y”
To receive a discount or Non-Rate Benefit under this plan,
must the customer make a Prior Purchase-Based
Commitment?

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Table II.B.12
Record Format for Applicable Tariff Plans and Contract-Based Tariffs
Field Name

Description

Type

Example

Text

N

Text

N

Text

N

Text

N

Text

N

Text

N

Text

N

Text

N

Float

123,456

Float

123,456

Text

We have . . .

Integer

434

Integer

434

Integer

434

Integer

434

Integer

434

(Y=Yes, N=No)

OOR_Apply

OOR_PC_Apply

PH1_Apply

PH2_Apply

PBDS1_Apply

PBDS2_Apply

Other_Apply

UNE_Cond
Rev_Tot_2010
Rev_Tot_2012
Biz_Rational
Tot_CustCount_2012
DS1_CustCount_2012
DS3_CustCount_2012
PBDS_CustCount2012
DS1_CustCount_2012_CP
DS3_CustCount_2012_CP

Do purchases of DS1 or DS3 services in areas outside of your
price cap study area(s) count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit under
this plan?
(Y=Yes, N=No, NA=Not Applicable)
Do DS1 or DS3 purchases in areas where you are subject to
price cap regulation and where pricing flexibility has not been
granted count towards meeting any Volume Commitment to
receive a discount or Non-Rate Benefit under this plan?
(Y=Yes, N=No, NA=Not Applicable)
Do DS1 or DS3 purchases in areas where you have been
granted Phase I Pricing Flexibility count towards meeting any
Volume Commitment to receive a discount or Non-Rate
Benefit under this plan?
(Y=Yes, N=No, NA=Not Applicable)
Do DS1 or DS3 purchases in areas where you have been
granted Phase II Pricing Flexibility count towards meeting
any Volume Commitment to receive a discount or Non-Rate
Benefit under this plan?
(Y=Yes, N=No, NA=Not Applicable)
Do non-tariffed PBDS purchases by the customer count
towards meeting any Volume Commitment to receive a
discount or Non-Rate Benefit under this plan?
(Y=Yes, N=No, NA=Not Applicable)
Do tariffed PBDS purchases by the customer count towards
meeting any Volume Commitment to receive a discount or
Non-Rate Benefit under this plan?
(Y=Yes, N=No, NA=Not Applicable)
Do purchases by the customer for services other than DS1s,
DS3s, and PBDS count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit under
this plan?
(Y=Yes, N=No, NA=Not Applicable)
Is the discount or Non-Rate Benefit available under this plan
conditioned on the customer limiting its purchase of UNEs,
e.g., customer must keep its purchase of UNEs below a certain
percentage of the customer’s total spend?
(Y=Yes, N=No)
Total Revenue from the provision of Dedicated Services under
this plan for 2010
Total Revenue from the provision of Dedicated Services under
this plan for 2012
What is the business justification for any Term or Volume
Commitments associated with this plan?
Total number of customers subscribed to this plan as of Dec.
31, 2012
Number of customers purchasing DS1s under this plan as of
Dec. 31, 2012
Number of customers purchasing DS3s under this plan as of
Dec. 31, 2012
Number of customers purchasing PBDS under this plan as of
Dec. 31, 2012
Number of customers that were Competitive Providers
purchasing DS1s under this plan as of Dec. 31, 2012
Number of customers that were Competitive Providers
purchasing DS3s under this plan as of Dec. 31, 2012

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Table II.B.12
Record Format for Applicable Tariff Plans and Contract-Based Tariffs
Field Name
PBDS_CustCount_2012_CP
DS1_CustCount_2012_EUsers
DS3_CustCount_2012_EUsers
PBDS_CustCount_2012_EUsers
CustCount_5orfewer
CustCount_New

CustCount_Exist

Customer_Fail

Description
Number of customers that were Competitive Providers
purchasing PBDS under this plan as of Dec. 31, 2012
Number of customers that were End Users purchasing DS1s
under this plan as of Dec. 31, 2012
Number of customers that were End Users purchasing DS3s
under this plan as of Dec. 31, 2012
Number of customers that were End Users purchasing PBDS
under this plan as of Dec. 31, 2012
Were five or fewer customers, in total, subscribed to this plan
as of Dec. 31, 2012? (Y=Yes, N=No)
If Yes, indicate the number of subscribers to this plan that
were new customers (as opposed to an existing or prior
customer) at the time they to subscribed this plan.
For those subscribers to this plan that were existing or prior
customers at the time they committed to purchasing services
under this plan, explain how the purchase commitment made
under this plan compares to the customer’s previous purchase
commitment. For example, indicate what percentage of the
previous purchase commitment, the new purchase
commitment equals.
Of those customers subscribed as of December 31, 2012, how
many in 2012 failed to meet any Volume Commitment or Term
Commitment required to retain a discount or Non-Rate Benefit
they originally agreed to when entering into this plan?

Type

Example

Integer

434

Integer

434

Integer

434

Integer

434

Text

Y

Integer

3

Text

The new
commitment
amounts to
50% of what
the customer
committed to
previously.

Integer

30

Question II.B.13: Non-Tariffed Agreements
If you have a non-tariffed agreement covered by Question II.B.13, then you must identify each agreement
in Table II.B.13 within the data container. If you do not have an agreement covered by Question II.B.13,
then type “Not Applicable” in the Agreement field. You will receive an error message upon validation of
the data container if you do not put any information into Table II.B.13.
Table II.B.13
Record Format for Non-Tariffed Agreements
Field Name

Description

Type

Example

Unique_ID

Sequential number

Integer

1

Agreement

Name of non-tariffed agreement

Text

Parties

Parties to the agreement

Text

Effective_Date

The beginning date of the time period covered by the
agreement
The ending date of the time period covered by the
agreement
Summary of relevant provisions

Date

PBDS
Agreement with
Local Fiber
Incorporated
ILEC Company
and Local Fiber
Inc.
1/15/10

Date

12/31/12

Text

Requires the
purchase of . . .

End_Date
Summary

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QUESTIONS DIRECTED AT ENTITIES PROVIDING BEST EFFORTS
Question II.C.1: Census Blocks and Price Lists for 2010 and 2012
You must separately upload all documents (e.g., Word, Excel, .pdf) responding to this question through
the Special Access Web Portal; do not include these documents in the data container.
If the State Broadband Initiative (SBI) data previously submitted accurately and completely identifies the
areas in which you offered Best Efforts Business Broadband Internet Access Services as of December 31,
2010 and as of December 31, 2012, then provide the requisite certification and identify the FRN(s) for the
entities that reported the information as part of the SBI program.
If not, then identify, on a granular level (ideally, at the census block level), the geographic areas in which
Best Efforts Business Broadband Internet Access Service was offered as of December 31, 2010 and as of
December 31, 2012. If the data are not submitted at the census block level, identify the geography at
which they are submitted, e.g., ZIP code, MSA, county, etc.
Separate from the SBI data, you must submit a price list for the Best Efforts Business Broadband Internet
Access Services that you offer within your footprint as of December 31, 2010 and as of December 31,
2012. To the extent that prices vary across your service area, identify the nature of such variation, e.g.,
variations by region or speed tier.
The Special Access Web Portal contains two areas for uploading documents for this question. One is for
uploading the “Confidential” versions of the documents where you will indicate information deemed
Confidential and redact information that is Highly Confidential based on the Protective Order issued for
the data collection. The second area is for uploading the “Highly Confidential” versions of the documents
noting both Confidential and Highly Confidential information without any redactions. You must upload
at least one document in each area or you will receive an error message during the submission process. If
the document does not contain Confidential or Highly Confidential information, e.g., all information is
publicly available, then upload the document in each area without the relevant Confidential/Highly
Confidential notations or redactions in the case of the Confidential upload area.
Below is a suggested template for formatting records in response to this question. You are not required to
format your information in this manner.
Suggested Record Format Template for Responding to Question II.C.1.c-d Part 1
Best Efforts Business Broadband Internet Access Services
Field Name

Description

Type

Example

DBA Name

Name of the entity customers could contact to
purchase service in this block with the characteristics
below.

Text

Cable Town

Census_Block

As defined by US Census Bureau; 15 digit FIPS code

Text

060290057001136

Transtech

Category of technology for the provision of Internet
access service (see Codes below)

Integer

41

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Suggested Record Format Template for Responding to Question II.C.1.c-d Part 1
Best Efforts Business Broadband Internet Access Services
Field Name

Description

Type

Example

Maxaddown

Maximum advertised download speed in Mbps
available in the census block

Float

9

Maxaddup

Maximum advertised upload speed in Mbps offered
with the above maximum advertised downstream
speed

Float

0.768

Year

Year: 2010 or 2012

Date

2010



Census_Block – Each census block must be identified using the 2010 block identifier from the
2010 TIGER/Line Block State-based Shapefile or Block County-based Shapefile. The block
identifier is a concatenation of Census 2010 state FIPS code, Census 2010 county FIPS code,
Census 2010 census tract code and Census 2010 tabulation block number. Please see the 2010
TIGER/Line Shapefiles Technical Documentation, Chapter 5, Part 5.2 at
http://www.census.gov/geo/maps-data/data/pdfs/tiger/tgrshp2010/TGRSHP10SF1CH5.pdf for
more information.



Any variation in Census_Block, DBA Name, or technology of transmission (Transtech)
necessitates the creation of a new record. For example, if a respondent indicates that broadband
service is available in a particular census block via two technologies, then the data must contain
two records for that census block. Records must be unique by Block, DBA Name, and Transtech.



Transtech – For reporting in the Transtech data field, report the technology used by the portion of
the connection that would terminate at the end-user location. If different technologies could be
used in the two directions of information transfer (“downstream” and “upstream”), report the
connection in the technology category for the downstream direction. The Transtech field must be
entered as an integer based on the following reference.
Technology of Transmission Codes
Code
10
20
30
40
41
50
60
70
71
80
90
0

Description
Asymmetric xDSL
Symmetric xDSL
Other Copper Wire
Cable Modem - DOCSIS 3.0
Cable Modem - Other
Optical Carrier/Fiber to the End User
Satellite
Terrestrial Fixed - Unlicensed
Terrestrial Fixed - Licensed
Terrestrial Mobile Wireless
Electric Power Line
Other

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Suggested Record Format Template for Responding to Question II.C.1.c-d Part 2
Best Efforts Business Broadband Internet Access Services
Field Name

Description

Type

Example

County_ID

5-digit FIPS code for the state and county or equivalent
entity.
Indicate the sum bandwidth category for which you are
reporting prices offered in this range. Enter “A” for
sum bandwidth equal to or greater than 3 Mbps but less
than or equal to 6 Mbps, enter “B” for bandwidth
greater than 6 Mbps but less than or equal to 20 Mbps,
enter “C” for bandwidth greater than 20 Mbps but less
than or equal to 50 Mbps, enter “D” for bandwidth
greater than 50 Mbps but less than or equal to 200
Mbps, and enter “E” for bandwidth greater than 200
Mbps
Enter the minimum price offered for the available Best
Efforts Business Broadband Internet Access Services in
the reported bandwidth tier
Enter the maximum price offered for the available Best
Efforts Business Broadband Internet Access Services in
the reported bandwidth tier
Indicate geographic territory where you offered the
reported price range, e.g., nationwide, certain regions,
certain states, etc.
Enter “2010” if the reported price range is for the year
2010 and enter “2012” if the reported price range is for
the year 2012

Text

01121

Text

A

Float

9.99

Float

29.99

Text

Nationwide

Integer

2012

Sum_Bandwidth

Min_Price_Range
Max_Price_Range
Price_Territory
Year








County_ID – Each county or equivalent entity must be identified using the 2010 county identifier
from the 2010 TIGER/Line County and Equivalent Entity Shapefile. The county identifier is a
concatenation of Census 2010 state FIPS code and the Census 2010 county FIPS code. See 2010
TIGER/Line Shapefiles Technical Documentation, Chapter 5, Part 5.7 at
http://www.census.gov/geo/maps-data/data/pdfs/tiger/tgrshp2010/TGRSHP10SF1CH5.pdf for
more information.
Sum_Bandwidth – To calculate the Sum_Bandwidth, add the advertised downstream and
upstream bandwidth for the Best Efforts Business Broadband Internet Access Service offered. At
a minimum, the Best Efforts Business Broadband Internet Access Service offered and reported
must have a bandwidth connection of at least 1.5 Mbps in both directions
(upstream/downstream).
Min_Price_Range – Determine the minimum price offered by looking at the prices for all
available Best Efforts Business Broadband Internet Access Services you offer within the reported
Sum_Bandwidth range and selecting the lowest price offered across those services.
Max_Price_Range – Determine the maximum price offered by looking at the prices for all
available Best Efforts Business Broadband Internet Access Services you offer within the reported
Sum_Bandwidth range and selecting the highest price offered across those services.

QUESTIONS DIRECTED AT ALL PROVIDERS
If the filer has both ILEC and Competitive Provider operations, identify the applicable operating unit
when responding to these questions. For example, if discussing promotional and advertising strategies,
indicate whether the strategies pertain to your ILEC or Competitive Provider operations or both.
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Question II.D.1: Short Term and Long-Range Strategies
Question II.D.2: Location of Recorded Policies
You must upload a .pdf text searchable (not a picture/image) document responding to these questions
through the Special Access Web Portal in the “Essay Questions – File Upload” section; you will not
include these documents in the data container.
The web portal contains two areas for uploading documents for each question. One is for uploading the
“Confidential” version of the document where you will indicate information deemed Confidential and
redact information that is Highly Confidential based on the Protective Order issued for the data collection.
The second area is for uploading the “Highly Confidential” version of the document noting both
Confidential and Highly Confidential information without any redactions. You must upload at least one
document in each area or you will receive an error message during the submission process. If the
document does not contain Confidential or Highly Confidential information, e.g., all information is
publicly available, then upload the document in each area without the relevant Confidential/Highly
Confidential notations or redactions in the case of the Confidential upload area.
QUESTIONS DIRECTED AT PURCHASERS THAT ARE MOBILE WIRELESS SERVICE
PROVIDERS
Facilities-based mobile wireless service providers purchasing Dedicated Service in price cap areas are
required to answer these questions.
Question II.E.1: Total Number of Cell Sites
Table II.E.1
Record Format for Total Cell Sites
Field Name

Description

Type

Example

Provider_Name

Name of mobile wireless service provider

Text

Local Fiber
Incorporated

Total_Number

Total number of cell sites on network

Float

100

Question II.E.2: Cell Site Locations
Provide, for each cell site on your network, the following information:
Table II.E.2
Record Format for Cell Sites by Location
Field Name

Description

Type

Example

Location_ID

Sequential location number

Integer

1

Year

Indicator of the calendar year of the data
Actual situs for the cell site (i.e., land where cell site is
located) if the cell site is located in or on a building

Integer

2010

Text

445 Twelfth St SW

Street_address

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Table II.E.2
Record Format for Cell Sites by Location
Field Name

Description

Type

City

If cell site does not have a street address, provide
description of location
City of the cell site

State
ZIP

Example

Text

500 yards N of I35 and
SR270 intersection
Washington

Two-letter state postal abbreviation of the cell site

Text

DC

5-digit ZIP code (with leading zeros) of the cell site

Text

20554

ZIP4

4-digit add-on code (with leading zeros) of the cell site

Text

0000

Lat

Latitude

Float

38.8835

Long

Longitude

Float

-77.0280

CLLI

Telcordia-specified eight-character CLLI of the ILEC
wire center that serves the cell site

Alphanumeric

WASHDCSW

Loc_type

Indicate whether cell site is 1=in or on a building;
2=on other man-made structure, e.g., water tower; 3=a
free-standing cell site

Integer

1

CBDS_Bandwidth

If a DS1, DS3, DS1-UNE, or DS3-UNE, indicate the
one-direction bandwidth of the circuit in Mbps.

Float

1.544

PBDS_Bandwidth

If the cell site is served by a PBDS, indicate the
bandwidth of the circuit(s) in Mbps.

Float

10.000

FW_Bandwidth

If the cell site is served by a wireless Connection,
indicate the bandwidth of the circuit(s) in Mbps.

Float

0

Text

Verizon, XO

Float

0

Other_address

Provider
Self_prov_bw

The name of the Provider(s) that supplies your
Connection to the cell site.
If you self-provide a Connection to the cell site,
indicate the provisioned bandwidth of the circuit in
Mbps.

Text

Instructions for Cell Sites Record Format:
1. Leave cells blank in the case of data that is not applicable for that record.
2. The Location_ID field is a sequential integer ranging from 1 to the total number of locations.
Records containing information about Connections to the same Location must be assigned the
same Location_ID.
3. Address data fields must be space-delimited in standardized Postal Service form. See
http://pe.usps.gov/cpim/ftp/pubs/Pub28/pub28.pdf.
4. Latitude and Longitude: You can derive the coordinate fields for the location address from a
known geocoding platform like Bing maps, Google, Yahoo, batchgeo.com, Texas A&M
Geoservices or other geocoding solution. Enter values in decimal degrees to the nearest ±0.0005,
i.e., each coordinate must end in #.###0 or #.###5. Coordinates must be in the WGS84 or
NAD83 geographic coordinate system.
5. For the CLLI code, enter the first eight digits of the CLLI code of the ILEC wire center serving
the location.

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Expenditures Information
Question II.E.3: Total Expenditures on Dedicated Services
Table II.E.3
Record Format for Expenditures on Dedicated Service
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on Dedicated Service

Float

4321.00

Service_Type

Indicate the service type category for which the expenditures are
reported. Enter “CBDS” for CBDS expenditures and enter “PBDS”
for PBDS expenditures
Enter 0 if the reported expenditures are for purchases from ILECs
and enter 1 if the reported expenditures are for purchases from
Competitive Providers
Enter “2010” if the reported expenditures are for the year 2010 and
enter “2012” if the reported expenditures are for the year 2012

Text

CBDS

Binary

0

Integer

2012

Provider_Type
Year

Note: If there were no expenditures for a particular category or year, then report 0.
Question II.E.4: Expenditures with ILECs under Tariffs
Table II.E.4
Record Format for Expenditures with ILECs Pursuant to a Tariff
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on Dedicated
Service for the corresponding categorical breakdown
Enter “2010” if the reported expenditures are for the
year 2010 and enter “2012” if the reported expenditures
are for the year 2012
Indicate the service type category for which the
expenditures are reported. Enter “DS1” for DS1
expenditures, enter “DS3” for DS3 expenditures, and
enter “PBDS” for PBDS expenditures
Enter the code for the appropriate contract type indicated
in the question. The codes must be a letter from “a” to
“h”. See instructions below the table for more
information on the codes for Agreement_Type
If the Agreement_Type is coded as “f” or “h”, enter the
average discount (in percentage terms) off the One
Month Term Only Rate incorporated in the expenditures
purchased under Tariff Plans (for code “f”) or ContractBased Tariffs (for code “h”) that contained a Prior
Purchase-Based Commitment. See the example in the
question on how to calculate the average discount. If
Agreement_Type is not coded as “f” or “h”, leave the
field blank
If the Year field is 2012, what percentage of your
expenditures was subject to a Term Commitment of five
or more years?

Float

5364821

Integer

2012

Text

DS3

Text

c

Float

25

Integer

45

Year
Service_Type

Agreement_Type

Avg_Discount_PPBC

5orMore

Note: If there were no expenditures for a particular category or year, then report 0.
Use the following codes for the Agreement_Type variable. Enter “a” for expenditures on ALL purchases;
enter “b” for expenditures on purchases at One Month Term Only Rates; enter “c” for expenditures
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purchased under Tariff Plans; enter “d” for expenditures purchased under Contract-Based Tariffs; enter
“e” for expenditures purchased under Tariff Plans that contained a Term Commitment but not a Volume
Commitment; enter “f” for expenditures purchased under Tariff Plans that contained a Prior PurchaseBased Commitment; enter “g” for expenditures purchased under Contract-Based Tariffs that contained a
Term Commitment but not a Volume Commitment; and enter “h” for expenditures purchased under
Contract-Based Tariffs that contained a Prior Purchase-Based Commitment.
5orMore: Provide the percentage of your expenditures in 2012 that were subject to a Term Commitment
of five or more years. If the Year field reported is 2010, then leave this field blank.
Question II.E.5: Expenditures with Competitive Providers under Tariffs
Table II.E.5
Record Format for Expenditures with Competitive Providers Pursuant to a Tariff
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on Dedicated
Service for the corresponding categorical breakdown
Enter “2010” if the reported expenditures are for the
year 2010 and enter “2012” if the reported expenditures
are for the year 2012
Indicate the service type category for which the
expenditures are reported. Enter “DS1” for DS1
expenditures, enter “DS3” for DS3 expenditures, and
enter “PBDS” for PBDS expenditures
Enter the code for the appropriate contract type
indicated in the question. The codes must be a letter
from “a” to “d”. See instructions below the table for
more information on the codes for Agreement_Type
If the Agreement_Type is coded as “d”, enter the
average discount (in percentage terms) off the One
Month Term Only Rate incorporated in the expenditures
purchased under Tariffs that contained a Prior
Purchase-Based Commitment. See the example in the
question on how to calculate the average discount. If
Agreement_Type is not coded as “d”, leave the field
blank
If the Year field is 2012, what percentage of your
expenditures was subject to a Term Commitment of five
or more years?

Float

5364821

Integer

2012

Text

DS3

Text

c

Float

25

Integer

45

Year
Service_Type

Agreement_Type

Avg_Discount_PPBC

5orMore

Note: If there were no expenditures for a particular category or year, then report 0.
Use the following codes for the Agreement_Type variable. Enter “a” for expenditures on ALL purchases;
enter “b” for expenditures on purchases at One Month Term Only Rates; enter “c” for expenditures
purchased under Tariffs that contained a Term Commitment but not a Volume Commitment; enter “d” for
expenditures purchased under Tariffs that contained a Prior Purchase-Based Commitment.
5orMore: Provide the percentage of your expenditures in 2012 that were subject to a Term Commitment
of five or more years. If the Year field reported is 2010, then leave this field blank.

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Question II.E.6: Expenditures with ILECs and Competitive Providers Pursuant to Non-Tariffs
Table II.E.6
Record Format for Expenditures with ILECs and Competitive Providers
Pursuant to Non-Tariffed Agreement
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on Dedicated
Service for the corresponding categorical breakdown
Enter “2010” if the reported expenditures are for the
year 2010 and enter “2012” if the reported
expenditures are for the year 2012
Enter 0 if the reported expenditures are for purchases
from ILECs and enter 1 if the reported expenditures
are for purchases from Competitive Providers
Indicate the service type category for which the
expenditures are reported. Enter “DS1” for DS1
expenditures, enter “DS3” for DS3 expenditures, and
enter “PBDS” for PBDS expenditures
Enter the code for the appropriate contract type
indicated in the question. The codes must be a letter
from “a” to “d”. See instructions below the table for
more information on the codes for Agreement_Type
If the Agreement_Type is coded as “d”, enter the
average discount (in percentage terms) off the nondiscounted rate incorporated in the expenditures
purchased under non-tariffed agreements that
contained a Prior Purchase-Based Commitment. See
the example in the question on how to calculate the
average discount. If Agreement_Type is not coded as
“d”, leave the field blank

Float

5364821

Integer

2012

Binary

0

Text

DS3

Text

c

Float

25

Year
Provider_Type
Service_Type

Agreement_Type

Avg_Discount_PPBC

Note: If there were no expenditures for a particular category or year, then report 0.
Use the following codes for the Agreement_Type variable. Enter “a” for expenditures on ALL purchases;
enter “b” for expenditures purchased at non-discounted rates; enter “c” for expenditures purchased under
a non-tariffed agreement that contained a Term Commitment but not a Volume Commitment; enter “d” for
expenditures purchased under a non-tariffed agreement that contained a Prior Purchase-Based
Commitment.
Question II.E.7: Expenditures under Tariffs for PBDS
Table II.E.7
Record Format for Expenditures on PBDS Purchased
Pursuant to a Tariff by Bandwidth Category
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on Tariffed PBDS
service
Enter 0 if the reported expenditures are for purchases
from ILECs and enter 1 if the reported expenditures are
for purchases from Competitive Providers
Indicate the bandwidth category for which the
expenditures are reported. Enter “A” for bandwidth
less than or equal to 1.5 Mbps, enter “B” for bandwidth
greater than 1.5 Mbps but less than or equal to 50
Mbps, enter “C” for bandwidth greater than 50 Mbps

Float

4,321.00

Binary

0

Text

B

Provider_Type
Bandwidth

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Table II.E.7
Record Format for Expenditures on PBDS Purchased
Pursuant to a Tariff by Bandwidth Category
Field Name

Description
but less than or equal to 100 Mbps, enter “D” for
bandwidth greater than 100 Mbps but less than or equal
to 1 Gbps, and enter “E” for bandwidth greater than 1
Gbps
Enter “2010” if the reported expenditures are for the
year 2010 and enter “2012” if the reported expenditures
are for the year 2012

Year

Type

Example

Integer

2012

Question II.E.8: Expenditures under Non-Tariffs for PBDS
Table II.E.8
Record Format for Expenditures on PBDS Pursuant to Non-Tariff Agreement
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on non-Tariffed
PBDS service
Enter 0 if the reported expenditures are for purchases
from ILECs and enter 1 if the reported expenditures are
for purchases from Competitive Providers
Indicate the bandwidth category for which the
expenditures are reported. Enter “A” for bandwidth
less than or equal to 1.5 Mbps, enter “B” for bandwidth
greater than 1.5 Mbps but less than or equal to 50
Mbps, enter “C” for bandwidth greater than 50 Mbps
but less than or equal to 100 Mbps, enter “D” for
bandwidth greater than 100 Mbps but less than or equal
to 1 Gbps, and enter “E” for bandwidth greater than 1
Gbps
Enter “2010” if the reported expenditures are for the
year 2010 and enter “2012” if the reported expenditures
are for the year 2012

Float

4,321.00

Binary

0

Text

B

Integer

2012

Provider_Type
Bandwidth

Year

Terms and Conditions Information
Question II.E.9: Terms and Conditions Constraints
Question II.E.10: Changing Transport Providers
Question II.E.11: Purchases Solely for the Purpose of Meeting a Prior Purchase-Based Commitment
Question II.E.12: Switching Providers
Question II.E.13: Paying One Month Term Only Rates
You must upload a .pdf text searchable (not a picture/image) document responding to these questions
through the Special Access Web Portal in the “Essay Questions – File Upload” section; you will not
include these documents in the data container.
The web portal contains two areas for uploading documents for each question. One is for uploading the
“Confidential” version of the document where you will indicate information deemed Confidential and
redact information that is Highly Confidential based on the Protective Order issued for the data collection.
The second area is for uploading the “Highly Confidential” version of the document noting both
Confidential and Highly Confidential information without any redactions. You must upload at least one
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document in each area or you will receive an error message during the submission process. If the
document does not contain Confidential or Highly Confidential information, e.g., all information is
publicly available, then upload the document in each area without the relevant Confidential/Highly
Confidential notations or redactions in the case of the Confidential upload area.
Additional Note for Questions II.E.9-11. These questions are intended to give you an opportunity to
discuss any alleged concerns that you are having with terms and conditions associated with the purchase
of Dedicated Services or with changing Providers. If you do not need, or want, to provide a response,
e.g., you do not have any alleged concerns with terms and conditions, then you can simply respond stating
as such.
Additional Note for Question II.E.12. The purpose of this question is to assess the frequency of switching
Providers for End-User Channel Terminations at as granular a geographic level as possible. Respondents
may define their own geographic areas. Given the level of detail required in other parts of the data
collection, respondents need only provide switching history in five geographic areas of their choice or
more. Respondents may provide switching history for less than five years if they do not keep such
information in the regular course of business.
Additional Note for Question II.E.13. The purpose of this question is to understand the economic impact
of paying One Month Term Only Rates on your business and consumers. Given the level of detail
required in other parts of the data collection, respondents may provide information over a shorter
timeframe. Alternatively, respondents who do not need or want to provide a response, e.g., you do not
have any alleged concerns with paying One Month Term Only Rates, then you can simply respond stating
as such.
Question II.E.14: Tariffs under which you Purchase Service
Table II.E.14
Record Format for Tariffs under which you Purchase Service
Field Name

Description

Type

Example

Tar_Plan

Plan is a Tariff Plan (Y=Yes, N=No)

Text

Y

Tariff_Name

Name of Tariff Plan

Text

TP_Provider

The Tariff Plan Provider name

Text

Regional
Volume
Discount Plan
ABC Company

TP_Tariff_Number

The Tariff Plan Name and Section Number

Text

CBT_Plan

Plan is a Contract-Based Tariff (Y=Yes, N=No)

Text

CBT_Name

Name of Contract-Based Tariff plan

Text

CBT_Provider

The Contract-Based Tariff Provider name

Text

CBT_Tariff_Number

The Contract-Based Tariff Name and Section Number

Text

Tariff_Type

Interstate (Inter) or Intrastate (Intra)

Text

ABC Tariff FCC
No. 2 § 7.4.15
Inter

Contains_Term

Contains Term Commitments (Y=Yes, N=No)

Text

Y

Instructions – Page 67

ABC Tariff FCC
No. 2 § 7.4.15
N
Regional
Volume
Discount Plan
ABC Company

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Table II.E.14
Record Format for Tariffs under which you Purchase Service
Field Name

Description

Type

Example

Contains_Vol

Contains Volume Commitments (Y=Yes, N=No)

Text

Y

Contains_NonR

Contains Non-Rate Benefits (Y=Yes, N=No)

Text

N

NonRate

If the plan contains Non-Rate Benefits, identify the
Non-Rate Benefits that were relevant to your decision to
purchase services under this plan.
Does this plan apply to the purchase of DS1s?
(Y=Yes, N=No)
Does this plan apply to the purchase of DS3s?
(Y=Yes, N=No)
Does this plan apply to the purchase of PBDS?
(Y=Yes, N=No)
Does this plan apply to the purchase of other services?
(Y=Yes, N=No)
In what geographic areas do you purchase DS1s under
this plan?
In what geographic areas do you purchase DS3s under
this plan?
In what geographic areas do you purchase PBDS under
this plan?
In what geographic areas do you purchase other
services under this plan?
To receive a discount or Non-Rate Benefit under this
plan, does your company make a Prior Purchase-Based
Commitment? (Y=Yes, N=No)
If this is an ILEC plan, do DS1, DS3, or tariffed PBDS
purchases your company makes outside the study
area(s) of the ILEC count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit
under this plan? (Y=Yes, N=No, NA=Not Applicable)
If yes, in what geographic areas outside the study
area(s) of the ILEC, do you purchase these DS1s, DS3s,
and/or tariffed PBDS?
Of the geographic areas identified, in which of those
areas would your company have purchased from a
different Provider, if at all, had it not been for the
discounts or Non-Rate Benefits received under this
plan?
Name of Provider(s) in the geographic area identified
above you would have purchased from had it not been
for the discounts or Non-Rate Benefits received under
this plan.
If this is an ILEC plan, do DS1s, DS3s, and/or tariffed
PBDS purchases your company makes from the ILEC
in price cap areas where the Commission has not
granted the ILEC pricing flexibility count towards
meeting any Volume Commitment to receive a discount
or Non-Rate Benefit under this plan? (Y=Yes, N=No,
NA=Not Applicable)
If Yes, then identify the price cap areas where you
purchase DS1s, DS3s, and/or tariffed PBDS that count
towards meeting any Volume Commitment to receive a
discount or Non-Rate Benefit under this plan.
If this is an ILEC plan, do DS1s, DS3s, and/or tariffed
PBDS purchases your company makes from the ILEC
in areas where the Commission has granted the ILEC
Phase I Pricing Flexibility count towards meeting any
Volume Commitment to receive a discount or Non-Rate

Text
Text

Plan allows for
circuit portability
...
Y

Text

Y

Text

N

Text

N

Text

California

Text

Texas

Text

Oklahoma

Text

Kansas

Text

Y

Text

Y

Text

Southern
California

Text

Southern
California

Text

ABC Co.

Text

Y

Text

Texas

Text

Y

Tariff_DS1
Tariff_DS3
Tariff_PBDS
Tariff_Other
Geo_DS1
Geo_DS3
Geo_PBDS
Geo_Other
Prior_P
Outside_Area

Outside_Area_Yes
Outside_Area_Yes_Diff

Outside_Area_Yes_Provider

ILEC_Price_Cap

ILEC_Price_Cap_Vol

ILEC_Price_Flex1

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Table II.E.14
Record Format for Tariffs under which you Purchase Service
Field Name

ILEC_Price_Flex1_Vol

ILEC_Price_Flex1_Diff

ILEC_Price_Flex1_Provider

ILEC_Price_Flex2

ILEC_Price_Flex2_Vol

ILEC_Price_Flex2_Diff

ILEC_Price_Flex2_Provider

ILEC_PBDS

ILEC_PBDS_Vol

ILEC_PBDS_Diff

ILEC_PBDS_Provider

ILEC_Other

Description
Benefit under this plan? (Y=Yes, N=No, NA=Not
Applicable)
If Yes, in what geographic areas subject to pricing
flexibility do you purchase DS1s, DS3s, and/or tariffed
PBDS that count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit
under this plan?
Of the geographic areas identified, in which of those
areas would your company have purchased from a
different Provider, if at all, had it not been for the
discounts or Non-Rate Benefits received under this
plan?
Name of Provider(s) in the geographic areas identified
above you would have purchased from had it not been
for the discounts or Non-Rate Benefits received under
this plan.
If this is an ILEC plan, do DS1s, DS3s, and/or tariffed
PBDS purchases your company makes from the ILEC
in areas where the Commission has granted the ILEC
Phase II Pricing Flexibility count towards meeting any
Volume Commitment to receive a discount or Non-Rate
Benefit under this plan? (Y=Yes, N=No, NA=Not
Applicable)
If Yes, in what geographic areas subject to pricing
flexibility do you purchase DS1s, DS3s, and/or tariffed
PBDS that count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit
under this plan?
Of the geographic areas identified, in which of those
areas would your company have purchased from a
different Provider, if at all, had it not been for the
discounts or Non-Rate Benefits received under this
plan?
Name of Provider(s) in the geographic areas identified
above you would have purchased from had it not been
for the discounts or Non-Rate Benefits received under
this plan.
If an ILEC plan, do non-tariffed PBDS purchases you
make from this ILEC count towards meeting any
Volume Commitment to receive a discount or Non-Rate
Benefit under this plan? (Y=Yes, N=No, NA=Not
Applicable)
If Yes, in what geographic areas do you purchase nontariffed PBDS that counts towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit
under this plan.
Of the geographic areas identified, in which of those
areas would your company have purchased non-tariffed
PBDS from a different Provider, if at all, had it not
been for the requirements of the plan?
Name of Provider(s) in the geographic areas identified
above you would have purchased from had it not been
for the discounts or Non-Rate Benefits received under
this plan.
If this is an ILEC plan, do purchases you make for
services other than DS1s, DS3s, and PBDS from this
ILEC count towards meeting any Volume Commitment
to receive a discount or Non-Rate Benefit under this

Instructions – Page 69

Type

Example

Text

Dallas MSA

Text

Southern
California

Text

ABC Co.

Text

Y

Text

Dallas MSA

Text

Southern
California

Text

ABC Co.

Text

Y

Text

Oklahoma City,
OK

Text

Oklahoma City,
OK

Text

ABC Co.

Text

Y

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Table II.E.14
Record Format for Tariffs under which you Purchase Service
Field Name

Description

Type

Example

Text

Cloud computing

Text

Little Rock, AR

Text

Little Rock, AR

Text

ABC Co.

Text

Yes, to obtain the
discount our
company must . .
.

plan? ((Y=Yes, N=No, NA=Not Applicable)
ILEC_Other_Service
ILEC_Other_Geo

ILEC_Other_Diff

ILEC_Other_Provider

Limiting_Purchase

If Yes, identify the other services purchased that count
towards meeting any Volume Commitment to receive a
discount or Non-Rate Benefit under this plan.
If Yes, identify the geographic areas where you
purchase these other services that count towards
meeting any Volume Commitment to receive a discount
or Non-Rate Benefit under this plan.
Of the geographic areas identified, in which of those
areas would your company have purchased those other
services from a different Provider, had it not been for
the requirements of the plan? In your response, indicate
whether the Provider that you would have purchased
from has Connections serving that geographic area.
Name of Provider(s) in the geographic areas identified
above you would have purchased from had it not been
for the discounts or Non-Rate Benefits received under
this plan.
Is the discount or Non-Rate Benefit available under this
plan conditioned on the customer limiting its purchase
of UNEs, e.g., the customer must keep its purchase of
UNEs below a certain percentage of the customer’s
total spend? If yes, then provide additional details
about the condition.

Question II.E.15: Non-Tariffed Agreements
If you have a non-tariffed agreement covered by Question II.E.15, then you must identify each agreement
in Table II.E.15 within the data container. If you do not have an agreement covered by Question II.E.15,
then type “Not Applicable” in the Agreement field. You will receive an error message upon validation of
the data container if you do not put any information into Table II.E.15.
Table II.E.15
Record Format for Non-Tariffed Agreements
Field Name

Description

Type

Example

Unique_ID

Sequential number

Integer

1

Agreement

Name of non-tariffed agreement

Text

Parties

Parties to the agreement

Text

Effective_Date

The beginning date of the time period covered by the
agreement
The ending date of the time period covered by the
agreement
Summary of relevant provisions

Date

PBDS
Agreement with
Local Fiber
Incorporated
ILEC Company
and Local Fiber
Inc.
1/15/10

Date

12/31/12

Text

Requires the
purchase of . . .

End_Date
Summary

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QUESTIONS DIRECTED AT OTHER PURCHASERS
Question II.F.1: Principal Nature of Business
Table II.F.1
Record Format for Purchaser’s Business
Field Name

Description

Type

Example

Purchaser_Name

Name of Purchaser

Text

Local Fiber
Inc.

Biz_Nature

Principal nature of Purchaser’s business

Text

CLEC

Expenditures Information
Question II.F.2: Total Expenditures on Dedicated Services
Table II.F.2
Record Format for Expenditures on Dedicated Service
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on Dedicated Service

Float

4321.00

Service_Type

Indicate the service type category for which the expenditures are
reported. Enter “CBDS” for CBDS expenditures and enter “PBDS”
for PBDS expenditures
Enter 0 if the reported expenditures are for purchases from ILECs
and enter 1 if the reported expenditures are for purchases from
Competitive Providers
Enter “2010” if the reported expenditures are for the year 2010 and
enter “2012” if the reported expenditures are for the year 2012

Text

CBDS

Binary

0

Integer

2012

Provider_Type
Year

Note: If there were no expenditures for a particular category or year, then report 0.
Question II.F.3: Expenditures with ILECs under Tariffs
Table II.F.3
Record Format for Expenditures with ILECs Pursuant to a Tariff
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on Dedicated Service for the
corresponding categorical breakdown
Enter “2010” if the reported expenditures are for the year 2010 and
enter “2012” if the reported expenditures are for the year 2012
Indicate the service type category for which the expenditures are
reported. Enter “DS1” for DS1 expenditures, enter “DS3” for DS3
expenditures, and enter “PBDS” for PBDS expenditures
Enter the code for the appropriate contract type indicated in the
question. The codes must be a letter from “a” to “h”. See
instructions below the table for more information on the codes for
Agreement_Type
If the Agreement_Type is coded as “f” or “h”, enter the average
discount (in percentage terms) off the One Month Term Only Rate
incorporated in the expenditures purchased under Tariff Plans (for
code “f”) or Contract-Based Tariffs (for code “h”) that contained a

Float

5364821

Integer

2012

Text

DS3

Text

c

Float

25

Year
Service_Type
Agreement_Type

Avg_Discount_PPBC

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Table II.F.3
Record Format for Expenditures with ILECs Pursuant to a Tariff
Field Name

5orMore

Description
Prior Purchase-Based Commitment. See the example in the
question on how to calculate the average discount. If
Agreement_Type is not coded as “f” or “h”, leave the field blank
If the Year field is 2012, what percentage of your expenditures was
subject to a Term Commitment of five or more years?

Type

Example

Integer

45

Note: If there were no expenditures for a particular category or year, then report 0.
Use the following codes for the Agreement_Type variable. Enter “a” for expenditures on ALL purchases;
enter “b” for expenditures on purchases at One Month Term Only Rates; enter “c” for expenditures
purchased under Tariff Plans; enter “d” for expenditures purchased under Contract-Based Tariffs; enter
“e” for expenditures purchased under Tariff Plans that contained a Term Commitment but not a Volume
Commitment; enter “f” for expenditures purchased under Tariff Plans that contained a Prior PurchaseBased Commitment; enter “g” for expenditures purchased under Contract-Based Tariffs that contained a
Term Commitment but not a Volume Commitment; and enter “h” for expenditures purchased under
Contract-Based Tariffs that contained a Prior Purchase-Based Commitment.
5orMore: Provide the percentage of your expenditures in 2012 that were subject to a Term Commitment
of five or more years. If the Year field reported is 2010, then leave this field blank.
Question II.F.4: Expenditures with Competitive Providers under Tariffs
Table II.F.4
Record Format for Expenditures with Competitive Providers Pursuant to a Tariff
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on Dedicated Service for the
corresponding categorical breakdown
Enter “2010” if the reported expenditures are for the year 2010 and
enter “2012” if the reported expenditures are for the year 2012
Indicate the service type category for which the expenditures are
reported. Enter “DS1” for DS1 expenditures, enter “DS3” for DS3
expenditures, and enter “PBDS” for PBDS expenditures
Enter the code for the appropriate contract type indicated in the
question. The codes must be a letter from “a” to “d”. See
instructions below the table for more information on the codes for
Agreement_Type
If the Agreement_Type is coded as “d”, enter the average discount
(in percentage terms) off the One Month Term Only Rate
incorporated in the expenditures purchased under Tariffs that
contained a Prior Purchase-Based Commitment. See the example
in the question on how to calculate the average discount. If
Agreement_Type is not coded as “d”, leave the field blank
If the Year field is 2012, what percentage of your expenditures was
subject to a Term Commitment of five or more years?

Float

5364821

Integer

2012

Text

DS3

Text

c

Float

25

Integer

45

Year
Service_Type
Agreement_Type

Avg_Discount_PPBC

5orMore

Note: If there were no expenditures for a particular category or year, then report 0.
Use the following codes for the Agreement_Type variable. Enter “a” for expenditures on ALL purchases;
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enter “b” for expenditures on purchases at One Month Term Only Rates; enter “c” for expenditures
purchased under Tariffs that contained a Term Commitment but not a Volume Commitment; enter “d” for
expenditures purchased under Tariffs that contained a Prior Purchase-Based Commitment.
5orMore: Provide the percentage of your expenditures in 2012 that were subject to a Term Commitment
of five or more years. If the Year field reported is 2010, then leave this field blank.
Question II.F.5: Expenditures with ILECs and Competitive Providers Pursuant to Non-Tariffs
Table II.F.5
Record Format for Expenditures with ILECs and Competitive Providers
Pursuant to Non-Tariffed Agreement
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on Dedicated Service for the
corresponding categorical breakdown
Enter “2010” if the reported expenditures are for the year 2010 and
enter “2012” if the reported expenditures are for the year 2012
Enter 0 if the reported expenditures are for purchases from ILECs
and enter 1 if the reported expenditures are for purchases from
Competitive Providers
Indicate the service type category for which the expenditures are
reported. Enter “DS1” for DS1 expenditures, enter “DS3” for DS3
expenditures, and enter “PBDS” for PBDS expenditures
Enter the code for the appropriate contract type indicated in the
question. The codes must be a letter from “a” to “d”. See
instructions below the table for more information on the codes for
Agreement_Type
If the Agreement_Type is coded as “d”, enter the average discount
(in percentage terms) off the non-discounted rate incorporated in
the expenditures purchased under non-tariffed agreements that
contained a Prior Purchase-Based Commitment. See the example
in the question on how to calculate the average discount. If
Agreement_Type is not coded as “d”, leave the field blank

Float

5364821

Integer

2012

Binary

0

Text

DS3

Text

c

Float

25

Year
Provider_Type
Service_Type
Agreement_Type

Avg_Discount_PPBC

Note: If there were no expenditures for a particular category or year, then report 0.
Use the following codes for the Agreement_Type variable. Enter “a” for expenditures on ALL purchases;
enter “b” for expenditures purchased at non-discounted rates; enter “c” for expenditures purchased under
a non-tariffed agreement that contained a Term Commitment but not a Volume Commitment; enter “d” for
expenditures purchased under a non-tariffed agreement that contained a Prior Purchase-Based
Commitment.
Question II.F.6: Expenditures under Tariffs for PBDS
Table II.F.6
Record Format for Expenditures on PBDS Purchased
Pursuant to a Tariff by Bandwidth Category
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on Tariffed PBDS service

Float

4,321.00

Provider_Type

Enter 0 if the reported expenditures are for purchases from ILECs
and enter 1 if the reported expenditures are for purchases from

Binary

0

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Table II.F.6
Record Format for Expenditures on PBDS Purchased
Pursuant to a Tariff by Bandwidth Category
Field Name

Description

Type

Example

Text

B

Integer

2012

Competitive Providers
Bandwidth

Indicate the bandwidth category for which the expenditures are
reported. Enter “A” for bandwidth less than or equal to 1.5 Mbps,
enter “B” for bandwidth greater than 1.5 Mbps but less than or
equal to 50 Mbps, enter “C” for bandwidth greater than 50 Mbps
but less than or equal to 100 Mbps, enter “D” for bandwidth greater
than 100 Mbps but less than or equal to 1 Gbps, and enter “E” for
bandwidth greater than 1 Gbps
Enter “2010” if the reported expenditures are for the year 2010 and
enter “2012” if the reported expenditures are for the year 2012

Year

Question II.F.7: Expenditures under Non-Tariffs for PBDS
Table II.F.7
Record Format for Expenditures on PBDS Pursuant to Non-Tariff Agreement
Field Name

Description

Type

Example

Expenditures

Enter the dollar value of expenditures on non-Tariffed PBDS
service
Enter 0 if the reported expenditures are for purchases from ILECs
and enter 1 if the reported expenditures are for purchases from
Competitive Providers
Indicate the bandwidth category for which the expenditures are
reported. Enter “A” for bandwidth less than or equal to 1.5 Mbps,
enter “B” for bandwidth greater than 1.5 Mbps but less than or
equal to 50 Mbps, enter “C” for bandwidth greater than 50 Mbps
but less than or equal to 100 Mbps, enter “D” for bandwidth greater
than 100 Mbps but less than or equal to 1 Gbps, and enter “E” for
bandwidth greater than 1 Gbps
Enter “2010” if the reported expenditures are for the year 2010 and
enter “2012” if the reported expenditures are for the year 2012

Float

4,321.00

Binary

0

Text

B

Integer

2012

Provider_Type
Bandwidth

Year

Terms and Conditions Information
Question II.F.8: Terms and Conditions Constraints
Question II.F.9: Changing Transport Providers
Question II.F.10: Purchases Solely for the Purpose of Meeting a Prior Purchase-Based Commitment
Question II.F.11: Switching Providers
Question II.F.12: Paying One Month Term Only Rates
You must upload a .pdf text searchable (not a picture/image) document responding to these questions
through the Special Access Web Portal in the “Essay Questions – File Upload” section; you will not
include these documents in the data container.
The web portal contains two areas for uploading documents for each question. One is for uploading the
“Confidential” version of the document where you will indicate information deemed Confidential and
redact information that is Highly Confidential based on the Protective Order issued for the data collection.
The second area is for uploading the “Highly Confidential” version of the document noting both
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Confidential and Highly Confidential information without any redactions. You must upload at least one
document in each area or you will receive an error message during the submission process. If the
document does not contain Confidential or Highly Confidential information, e.g., all information is
publicly available, then upload the document in each area without the relevant Confidential/Highly
Confidential notations or redactions in the case of the Confidential upload area.
Additional Note for Questions II.F.8-10. These questions are intended to give you an opportunity to
discuss any alleged concerns that you are having with terms and conditions associated with the purchase
of Dedicated Services or with changing Providers. If you do not need, or want, to provide a response,
e.g., you do not have any alleged concerns with terms and conditions, then you can simply respond stating
as such.
Additional Note for Question II.F.11. The purpose of this question is to assess the frequency of switching
Providers for End-User Channel Terminations at as granular a geographic level as possible. Respondents
may define their own geographic areas. Given the level of detail required in other parts of the data
collection, respondents need only provide switching history in five geographic areas of their choice or
more. Respondents may provide switching history for less than five years if they do not keep such
information in the regular course of business.
Additional Note for Question II.F.12. The purpose of this question is to understand the economic impact
of paying One Month Term Only Rates on your business and consumers. Given the level of detail
required in other parts of the data collection, respondents may provide information over a shorter
timeframe. Alternatively, respondents who do not need or want to provide a response, e.g., you do not
have any alleged concerns with the terms and conditions, then you can simply respond stating as such.
Question II.F.13: Tariffs under which you Purchase Service
Table II.F.13
Record Format for Tariffs under which you Purchase Service
Field Name

Description

Type

Example

Tar_Plan

Plan is a Tariff Plan (Y=Yes, N=No)

Text

Y

Tariff_Name

Name of Tariff Plan

Text

TP_Provider

The Tariff Plan Provider name

Text

Regional
Volume
Discount Plan
ABC Company

TP_Tariff_Number

The Tariff Plan Name and Section Number

Text

CBT_Plan

Plan is a Contract-Based Tariff (Y=Yes, N=No)

Text

CBT_Name

Name of Contract-Based Tariff plan

Text

CBT_Provider

The Contract-Based Tariff Provider name

Text

CBT_Tariff_Number

The Contract-Based Tariff Name and Section Number

Text

Tariff_Type

Interstate (Inter) or Intrastate (Intra)

Text

ABC Tariff FCC
No. 2 § 7.4.15
Inter

Contains_Term

Contains Term Commitments (Y=Yes, N=No)

Text

Y

Instructions – Page 75

ABC Tariff FCC
No. 2 § 7.4.15
N
Regional
Volume
Discount Plan
ABC Company

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Table II.F.13
Record Format for Tariffs under which you Purchase Service
Field Name

Description

Type

Example

Contains_Vol

Contains Volume Commitments (Y=Yes, N=No)

Text

Y

Contains_NonR

Contains Non-Rate Benefits (Y=Yes, N=No)

Text

N

NonRate

If the plan contains Non-Rate Benefits, identify the
Non-Rate Benefits that were relevant to your decision to
purchase services under this plan.
Does this plan apply to the purchase of DS1s?
(Y=Yes, N=No)
Does this plan apply to the purchase of DS3s?
(Y=Yes, N=No)
Does this plan apply to the purchase of PBDS?
(Y=Yes, N=No)
Does this plan apply to the purchase of other services?
(Y=Yes, N=No)
In what geographic areas do you purchase DS1s under
this plan?
In what geographic areas do you purchase DS3s under
this plan?
In what geographic areas do you purchase PBDS under
this plan?
In what geographic areas do you purchase other
services under this plan?
To receive a discount or Non-Rate Benefit under this
plan, does your company make a Prior Purchase-Based
Commitment? (Y=Yes, N=No)
If this is an ILEC plan, do DS1, DS3, or tariffed PBDS
purchases your company makes outside the study
area(s) of the ILEC count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit
under this plan? (Y=Yes, N=No, NA=Not Applicable)
If yes, in what geographic areas outside the study
area(s) of the ILEC, do you purchase these DS1s, DS3s,
and/or tariffed PBDS?
Of the geographic areas identified, in which of those
areas would your company have purchased from a
different Provider, if at all, had it not been for the
discounts or Non-Rate Benefits received under this
plan?
Name of Provider(s) in the geographic area identified
above you would have purchased from had it not been
for the discounts or Non-Rate Benefits received under
this plan.
If this is an ILEC plan, do DS1s, DS3s, and/or tariffed
PBDS purchases your company makes from the ILEC
in price cap areas where the Commission has not
granted the ILEC pricing flexibility count towards
meeting any Volume Commitment to receive a discount
or Non-Rate Benefit under this plan? (Y=Yes, N=No,
NA=Not Applicable)
If Yes, then identify the price cap areas where you
purchase DS1s, DS3s, and/or tariffed PBDS that count
towards meeting any Volume Commitment to receive a
discount or Non-Rate Benefit under this plan.
If this is an ILEC plan, do DS1s, DS3s, and/or tariffed
PBDS purchases your company makes from the ILEC
in areas where the Commission has granted the ILEC
Phase I Pricing Flexibility count towards meeting any
Volume Commitment to receive a discount or Non-Rate

Text
Text

Plan allows for
circuit portability
...
Y

Text

Y

Text

N

Text

N

Text

California

Text

Texas

Text

Oklahoma

Text

Kansas

Text

Y

Text

Y

Text

Southern
California

Text

Southern
California

Text

ABC Co.

Text

Y

Text

Texas

Text

Y

Tariff_DS1
Tariff_DS3
Tariff_PBDS
Tariff_Other
Geo_DS1
Geo_DS3
Geo_PBDS
Geo_Other
Prior_P
Outside_Area

Outside_Area_Yes
Outside_Area_Yes_Diff

Outside_Area_Yes_Provider

ILEC_Price_Cap

ILEC_Price_Cap_Vol

ILEC_Price_Flex1

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Table II.F.13
Record Format for Tariffs under which you Purchase Service
Field Name

ILEC_Price_Flex1_Vol

ILEC_Price_Flex1_Diff

ILEC_Price_Flex1_Provider

ILEC_Price_Flex2

ILEC_Price_Flex2_Vol

ILEC_Price_Flex2_Diff

ILEC_Price_Flex2_Provider

ILEC_PBDS

ILEC_PBDS_Vol

ILEC_PBDS_Diff

ILEC_PBDS_Provider

ILEC_Other

Description
Benefit under this plan? (Y=Yes, N=No, NA=Not
Applicable)
If Yes, in what geographic areas subject to pricing
flexibility do you purchase DS1s, DS3s, and/or tariffed
PBDS that count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit
under this plan?
Of the geographic areas identified, in which of those
areas would your company have purchased from a
different Provider, if at all, had it not been for the
discounts or Non-Rate Benefits received under this
plan?
Name of Provider(s) in the geographic areas identified
above you would have purchased from had it not been
for the discounts or Non-Rate Benefits received under
this plan.
If this is an ILEC plan, do DS1s, DS3s, and/or tariffed
PBDS purchases your company makes from the ILEC
in areas where the Commission has granted the ILEC
Phase II Pricing Flexibility count towards meeting any
Volume Commitment to receive a discount or Non-Rate
Benefit under this plan? (Y=Yes, N=No, NA=Not
Applicable)
If Yes, in what geographic areas subject to pricing
flexibility do you purchase DS1s, DS3s, and/or tariffed
PBDS that count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit
under this plan?
Of the geographic areas identified, in which of those
areas would your company have purchased from a
different Provider, if at all, had it not been for the
discounts or Non-Rate Benefits received under this
plan?
Name of Provider(s) in the geographic areas identified
above you would have purchased from had it not been
for the discounts or Non-Rate Benefits received under
this plan.
If an ILEC plan, do non-tariffed PBDS purchases you
make from this ILEC count towards meeting any
Volume Commitment to receive a discount or Non-Rate
Benefit under this plan? (Y=Yes, N=No, NA=Not
Applicable)
If Yes, in what geographic areas do you purchase nontariffed PBDS that counts towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit
under this plan.
Of the geographic areas identified, in which of those
areas would your company have purchased non-tariffed
PBDS from a different Provider, if at all, had it not
been for the requirements of the plan?
Name of Provider(s) in the geographic areas identified
above you would have purchased from had it not been
for the discounts or Non-Rate Benefits received under
this plan.
If this is an ILEC plan, do purchases you make for
services other than DS1s, DS3s, and PBDS from this
ILEC count towards meeting any Volume Commitment
to receive a discount or Non-Rate Benefit under this

Instructions – Page 77

Type

Example

Text

Dallas MSA

Text

Southern
California

Text

ABC Co.

Text

Y

Text

Dallas MSA

Text

Southern
California

Text

ABC Co.

Text

Y

Text

Oklahoma City,
OK

Text

Oklahoma City,
OK

Text

ABC Co.

Text

Y

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Table II.F.13
Record Format for Tariffs under which you Purchase Service
Field Name

Description

Type

Example

Text

Cloud computing

Text

Little Rock, AR

Text

Little Rock, AR

Text

ABC Co.

Text

Yes, to obtain the
discount our
company must . .
.

plan? ((Y=Yes, N=No, NA=Not Applicable)
ILEC_Other_Service
ILEC_Other_Geo

ILEC_Other_Diff

ILEC_Other_Provider

Limiting_Purchase

If Yes, identify the other services purchased that count
towards meeting any Volume Commitment to receive a
discount or Non-Rate Benefit under this plan.
If Yes, identify the geographic areas where you
purchase these other services that count towards
meeting any Volume Commitment to receive a discount
or Non-Rate Benefit under this plan.
Of the geographic areas identified, in which of those
areas would your company have purchased those other
services from a different Provider, had it not been for
the requirements of the plan? In your response, indicate
whether the Provider that you would have purchased
from has Connections serving that geographic area.
Name of Provider(s) in the geographic areas identified
above you would have purchased from had it not been
for the discounts or Non-Rate Benefits received under
this plan.
Is the discount or Non-Rate Benefit available under this
plan conditioned on the customer limiting its purchase
of UNEs, e.g., the customer must keep its purchase of
UNEs below a certain percentage of the customer’s
total spend? If yes, then provide additional details
about the condition.

Question II.F.14: Non-Tariffed Agreements
If you have a non-tariffed agreement covered by Question II.F.14, then you must identify each agreement
in Table II.F.14 within the data container. If you do not have an agreement covered by Question II.F.14,
then type “Not Applicable” in the Agreement field. You will receive an error message upon validation of
the data container if you do not put any information into Table II.F.14.
Table II.F.14
Record Format for Non-Tariffed Agreements
Field Name

Description

Type

Example

Unique_ID

Sequential number

Integer

1

Agreement

Name of non-tariffed agreement

Text

Parties

Parties to the agreement

Text

Begin_Date

The beginning date of the time period covered by the
agreement
The ending date of the time period covered by the
agreement
Summary of relevant provisions

Date

PBDS
Agreement with
Local Fiber
Incorporated
ILEC Company
and Local Fiber
Inc.
1/15/10

Date

12/31/12

Text

Requires the
purchase of . . .

End_Date
Summary

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QUESTION DIRECTED AT NON-PROVIDERS, NON-PURCHASERS, AND OTHER ENTITIES
NOT COVERED BY THE DATA COLLECTION
Question II.G.1: Not Required to Submit Data
Entities that reported broadband connections to end users for 2012 in the FCC Form 477 are required to
affirmatively indicate whether or not they are a Provider, a Purchaser, or an entity providing Best Efforts
Business Broadband Internet Access Services to 15,000 or more customers or 1,500 or more business
broadband customers in price cap areas. If you are “none of the above,” then you must electronically
submit a certification, stating as such, where indicated in the Special Access Web Portal.

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APPENDIX B
Mandatory Data Collection1
I. DEFINITIONS
The following definitions apply for purposes of this collection only. They are not intended to set or
modify precedent outside the context of this collection.
Affiliated Company means a company, partnership, corporation, limited liability company, or other
business entity that is affiliated with an entity that provides and/or purchases Dedicated Service. Two
entities are affiliated if one of them, or an entity that controls one of them, directly or indirectly holds a
greater than 10 percent ownership interest in, or controls, the other one.
Best Efforts Business Broadband Internet Access Service means a best efforts Internet access data service
with a minimum advertised bandwidth connection of at least 1.5 megabits per second (Mbps) in both
directions (upstream/downstream) that is marketed to enterprise customers (including small, medium, and
large businesses). For purposes of this data collection, Best Efforts Business Broadband Internet Access
Services do not include mobile wireless services, as that term is used in the 16th Annual Mobile Wireless
Competition Report.2
Circuit-Based Dedicated Service (CBDS) means a Dedicated Service that is circuit-based. Examples of
CBDS include time-division multiplexing-based, DS1 and DS3 services.
Competitive Provider means a competitive local exchange carrier (CLEC), interexchange carrier, cable
operator, wireless provider or any other entity that is subject to the Commission’s jurisdiction under the
Communications Act of 1934, as amended, and either provides a Dedicated Service or provides a
Connection over which a Dedicated Service could be provided. A Competitive Provider does not include
an ILEC operating within its incumbent service territory.
Connection means a wired “line” or wireless “channel” that provides a dedicated communication path
between a Location and the first Node on a Provider’s network. Multiple dedicated communication paths
serving one or more End Users at the same Location should be counted as a single Connection. A
Connection may be a UNE, including an Unbundled Copper Loop if modified to provide a Dedicated
Service. A Connection must have the capability of being used to provide one or more Dedicated Services;
however, a Connection can be used to provide other services as well. For example, a dedicated
communication path that is currently being used to provide a mass market broadband service but has the
capability to provide a Dedicated Service is considered a Connection for the purpose of this data
collection.
Contract-Based Tariff means a Tariff, other than a Tariff Plan, that is based on a service contract entered
into between a customer and an ILEC which has obtained permission to offer contract-based tariff
services pursuant to 47 C.F.R. § 69.701 et seq. of the Commission’s pricing flexibility rules or a
comparable tariffed intrastate service contract between a customer and an ILEC.
1

The instructions included in Appendix A and the accompanying Report and Order (DA 13-1909) provide
additional information on how to respond to these questions.
2

See Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, Annual Report and
Analysis of Competitive Market Conditions with Respect to Mobile Wireless, Including Commercial Mobile
Services, WT Docket No. 11-186, Sixteenth Report, 28 FCC Rcd 3700, 3729-30, paras. 3-5 (2013).

Federal Communications Commission

DA 13-1909

Dedicated Service transports data between two or more designated points, e.g., between an End User’s
premises and a point-of-presence, between the central office of a local exchange carrier (LEC) and a
point-of-presence, or between two End User premises, at a rate of at least 1.5 Mbps in both directions
(upstream/downstream) with prescribed performance requirements that include bandwidth-, latency-, or
error-rate guarantees or other parameters that define delivery under a Tariff or in a service-level
agreement. Dedicated Service includes, but is not limited to, CBDS and PBDS. For the purpose of this
data collection, Dedicated Service does not include “best effort” services, e.g., mass market broadband
services such as DSL and cable modem broadband access.
Disconnection means the process by which a Provider, per a customer request, terminates billing on one
or more of a customer’s Dedicated Service circuits.
DS1 and DS3, except where specified, refer to DS1s and DS3s that are not UNEs.3 DS1s and DS3s are
Dedicated Services.
End User means a business, institutional, or government entity that purchases a communications service
for its own purposes and does not resell such service. A mobile wireless service provider is considered an
End User when it purchases communications services to make connections within its own network, e.g.,
backhaul to a cell site.
End User Channel Termination means, as defined in 47 C.F.R. § 69.703(a)(2), a dedicated channel
connecting a LEC end office and a customer premises, offered for purposes of carrying special access
traffic.
Incumbent Local Exchange Carrier (ILEC) means, for the purpose of this data collection, a LEC that
provides a Dedicated Service in study areas where it is subject to price cap regulation under sections
61.41-61.49 of the Commission’s rules, 47 C.F.R. §§ 64.41-61.49.
Indefeasible Right of Use (IRU) means an indefeasible long-term leasehold interest for a minimum total
duration of ten years that gives the grantee the right to access and exclusively use specified strands of
fiber or allocated bandwidth to provide a service as determined by the grantee.4 An IRU confers on the
grantee substantially all of the risks and rewards of ownership. IRUs typically include the following
elements: (i) payment of a substantial fee up front to enter into the IRU contract;5 (ii) conveyance of tax
obligations commensurate with the risks and rewards of ownership to the grantee (e.g. as opposed to the
lesser tax burdens associated with other forms of leases); (iii) terms for payment to the grantor for
ancillary services, such as maintenance fees; (iv) all additional rights and interests necessary to enable the
IRU to be used by the grantee in the manner agreed to; and (v) no unreasonable limit on the right of the

3

See 47 U.S.C. § 251; see also 47 C.F.R. §§ 51.5 (defining network element), 51.319 (outlining specific unbundling
requirements).
4

The ten year duration is measured at the time a grantee entered into the IRU agreement.

5

To enter into an IRU contract, grantees are usually required to pay the total amount due under the terms of that
contract. However, some IRU contracts require a smaller initial payment, with installment payments throughout the
duration of the contract. At a minimum, a grantee typically pays at least 25 percent of the total amount due under
the IRU contract upfront (excluding operations and maintenance fees), with commitments to make regularly
scheduled installment payments, to qualify as an IRU. See Michael J. Lichtenstein & Charles A. Rohe, The
Treatment of IRUs in Bankruptcy Proceedings, 11 J. Bankr. L. & Prac. 83, 86 (2001).

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DA 13-1909

grantee to use the asset as it wishes (e.g., the grantee shall be permitted to splice into the IRU fiber,
though such splice points must be mutually agreed upon by grantor and the grantee of the IRU).
Location means a building, other man-made structure, a cell site on a building, a free-standing cell site, or
a cell site on some other man-made structure where the End User is connected. A Node is not a Location.
For the purposes of this data collection, cell sites are to be treated as Locations and not as Nodes.
Metropolitan Statistical Area (MSA) is a geographic area as defined by 47 C.F.R. §§ 22.909(a),
69.703(b).
Node is an aggregation point, a branch point, or a point of interconnection on a Provider’s network,
including a point of interconnection to other Provider networks. Examples include LEC central offices,
remote terminal locations, splice points (including, for example, at manholes), controlled environmental
vaults, cable system headends, cable modem termination system (CMTS) locations, and facility hubs.
Non-MSA is the portion of an ILEC’s study area that falls outside the boundaries of an MSA.6
Non-Rate Benefit means a benefit to the customer other than a discount on the One Month Term Only
Rate, e.g., a credit towards penalties or non-recurring charges or the ability to move circuits without
incurring a penalty.
One Month Term Only Rate means, for purposes of this data collection, the non-discounted monthly
recurring tariffed rate for DS1, DS3 and/or PBDS services.
Packet-Based Dedicated Service (PBDS) means a Dedicated Service that is packet-based. Examples of
PBDS include Multi-Protocol Label Switched (MPLS) services; permanent virtual circuits, virtual private
lines and similar services; ATM and Frame Relay service; (Gigabit) Ethernet Services and Metro Ethernet
Virtual Connections; and Virtual Private Networks (VPN). PBDS includes those categories of packetbased and optical transmission services for which the Commission has granted forbearance relief from
dominant carrier regulation.7
Phase I Pricing Flexibility means regulatory relief for the pricing of End User Channel Terminations
pursuant to 47 C.F.R. §§ 69.711(b), 69.727(a) of the Commission’s rules.

6

See 47 C.F.R. § 69.707(b).

7

See Petition of the Verizon Telephone Companies for Forbearance under 47 U.S.C. § 160(c) from Title II and
Computer Inquiry Rules with Respect to Their Broadband Services, WC Docket No. 04-440 (filed Dec. 20, 2004);
Letter from Edward Shakin, Vice President and Associate General Counsel, Verizon, to Marlene H. Dortch,
Secretary, FCC, WC Docket. No. 04-440, at 2-3 (filed Feb. 7, 2006); FCC News Release, Verizon Telephone
Companies’ Petition for Forbearance from Title II and Computer Inquiry Rules with Respect to their Broadband
Services Is Granted by Operation of Law (rel. Mar. 20, 2006); Petition of AT&T Inc. for Forbearance Under 47
U.S.C. § 160(c) from Title II and Computer Inquiry Rules with Respect to Its Broadband Services, Petition of
BellSouth Corporation for Forbearance Under Section 47 U.S.C. § 160(c) from Title II and Computer Inquiry Rules
with Respect to Its Broadband Services, Memorandum Opinion and Order, 22 FCC Rcd 18705 (2007); Petition of
the Embarq Local Operating Companies for Forbearance Under 47 U.S.C. § 160(c) from Application of Computer
Inquiry and Certain Title II Common-Carriage Requirements, et al., Memorandum Opinion and Order, 22 FCC Rcd
19478 (2007); Qwest Petition for Forbearance Under 47 U.S.C. § 160(c) from Title II and Computer Inquiry Rules
with Respect to Broadband Services, Memorandum Opinion and Order, 23 FCC Rcd 12260 (2008).

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Phase II Pricing Flexibility means regulatory relief for the pricing of End User Channel Terminations
pursuant to 47 C.F.R. §§ 69.711(c), 69.727(b) of the Commission’s rules.
Prior Purchase-Based Commitment means a type of Volume Commitment where the commitment is based
on either:
(i)
a certain percentage or number of the customer’s purchased in-service circuits or lines as
measured at the time of making the Volume Commitment or measured during a period of
time prior to making the Volume Commitment, e.g., based on the customer’s billing
records for the current month or prior month(s); or
(ii)
a certain percentage or dollar amount of Revenues generated by the customer’s purchases
as measured at the time of making the Volume Commitment or during a period of time
prior to making the Volume Commitment.
Providers collectively refers to both ILECs and Competitive Providers.
Purchasers means Competitive Providers and End Users that are subject to the Commission’s jurisdiction
under the Communications Act of 1934, as amended, and purchase Dedicated Service.
Revenues means intrastate and interstate billed amounts without any allowance for uncollectibles,
commissions or settlements.
Tariff means an intrastate or interstate schedule of rates and regulations filed by common carriers. This
term includes both Tariff Plans and Contract-Based Tariffs.
Tariff Plan means a Tariff, other than a Contract-Based Tariff, that provides a customer with either a
discount from any One Month Term Only Rate for the purchase of DS1 and/or DS3 services or a Non-Rate
Benefit that could be applied to these services.
Term Commitment means a commitment to purchase a Dedicated Service for a period of time, greater
than a month, in exchange for a circuit-specific discount and/or a Non-Rate Benefit.
Transport Service means a dedicated circuit that connects a designated Competitive Provider’s premises
to the wire center that serves the Competitive Provider’s customer. Such an arrangement may or may not
include channel mileage. See 47 C.F.R. § 69.709(a).
Transport Provider means a Provider that supplies Transport Service.
Unbundled Copper Loop means a copper wire local loop provided by ILECs to requesting
telecommunications carriers on a non-discriminatory basis pursuant to 47 C.F.R. § 51.319(a)(1) that can
be used by a Competitive Provider to provide a Dedicated Service, e.g., Ethernet over Copper. An
Unbundled Copper Loop is typically a 2- or 4- wire loop that the ILEC has conditioned to remove
intervening equipment such as bridge taps, load coils, repeaters, low pass filters, range extenders, etc.
between a Location and the serving wire center to allow for the provision of advanced digital services by
a Competitive Provider. These loops are commonly referred to as dry copper, bare copper, or xDSLcompatible loops. An Unbundled Copper Loop is a type of UNE.
Unbundled Network Element (UNE) means a local loop provided by an ILEC to a requesting
telecommunications carrier on a non-discriminatory basis pursuant to 47 C.F.R. § 51.319(a).

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Upgrade means that a customer transitions one or more circuits to a higher capacity circuit.
Volume Commitment means a commitment to purchase a specified volume, e.g., a certain number of
circuits or Revenues, to receive a discount on Dedicated Services and/or a Non-Rate Benefit.

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II. MANDATORY DATA COLLECTION QUESTIONS
A. Competitive Providers must respond to the following:
II.A.1. Indicate whether you are an Affiliated Company. If you are an Affiliated Company, you must
identify the entities that provide and/or purchase Dedicated Service with which you have an affiliation
(name/FRN).
II.A.2. Do you (i) own a Connection; (ii) lease a Connection from another entity under an IRU
agreement; or (iii) obtain a Connection as a UNE from an ILEC to provide a Dedicated Service?
□ Yes □ No
a. If yes, are any of these Connections to a Location within an area where the ILEC is
subject to price cap regulation or within an area where the Commission has granted Phase I
or Phase II Pricing Flexibility?
□ Yes □ No
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.
Facilities Information
II.A.3. Provide the total number of Locations to which you had a Connection during 2010 and during
2012 where your company: (i) owned the Connection; (ii) leased the Connection from another entity
under an IRU agreement; or (iii) obtained the Connection as a UNE from an ILEC in the form of DS1s,
DS3s, or Unbundled Copper Loops to provide a Dedicated Service.
II.A.4. Provide the information requested below for each Location to which your company had a
Connection during 2010 and during 2012 that you: (i) owned; (ii) leased from another entity under an
IRU agreement; or (iii) obtained as a UNE from an ILEC to provide a Dedicated Service.
a. A unique ID for the Location;
b. The actual situs address for the Location (i.e., land where the building or cell site is
located);
c. The geocode for the Location (i.e., latitude and longitude);
d. The Location type (e.g., building, other man-made structure, cell site in or on a building,
free-standing cell site, or a cell site on some other man-made structure like a water tower,
billboard, etc.);
e. Whether the Connection provided to the location uses facilities leased from another entity
under an IRU or obtained as a DS1/DS3 UNE or Unbundled Copper Loop, and in each
case, the name of the lessor of the majority of the fiber strands and/or copper loop;
f. Whether any of the Connection to the Location was provided using fiber;
g. The total sold bandwidth of the Connection provided by you to the Location in Mbps;
h. The total bandwidth to the Location sold directly by you to an End User;
i. The total sold fixed wireless bandwidth provided by you to the Location; and
j. The total bandwidth sold by you to any cell sites at the Location.
k. The total bandwidth provided to you or an Affiliated Company for internal use.
II.A.5. Provide a map showing the fiber routes that you (a) own or (b) lease pursuant to an IRU
agreement that constitute your network, including the fiber Connections to Locations. In addition,
include the locations of all Nodes used to interconnect with third party networks, and the year that each
Node went live.
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II.A.6. We will provide you with a selected list of the Locations you reported in response to question
II.A.4. For each identified Location, state the month and year that you first provided a Connection to that
Location, whether you originally supplied the Location over a UNE, and if so, when (if at all) you
switched to using a Connection that you own or lease as an IRU. If the Location was first served by your
Connection on or before January 2008, and the date the Location was first served is unknown, then enter
00/0000.
II.A.7. For each ILEC wire center where your company is collocated, provide the actual situs address,
the geocode, and the CLLI code.
II.A.8. Explain your business rule(s) used to determine whether to build a Connection to a particular
Location. Provide underlying assumptions.
a. Describe the business rules and other factors that determine where you build your
Connections. Examples of such rules/factors are minimum Term Commitments or
minimum capacity commitments by the buyer; maximum build distances from the
building to your core network; and/or number of competitors in the area. Include, also,
any factors that would prevent you from building a Connection to an otherwise suitable
Location. These could be factors that are under your control or those that are not.
b. Explain how, if at all, business density is incorporated into your business rule, and if so,
how you measure business density.
c. In areas where your business rule has been most successful, explain why. Provide
examples of geographic regions (if any) where you generally were or are able to
successfully deploy Connections, and where you generally have experienced or currently
experience serious difficulties in deploying Connections, and, if you are able to provide
examples of both kind of regions, indicate what distinguishes these different regions.
II.A.9. Provide the following information:
a. The current situs address of your U.S. headquarters (i.e., the address of the land where the
headquarters is located);
b. The year that this site became your headquarters;
c. Year established and situs address for any prior U.S. headquarters’ location for your
company, going as far back as 1995, if different from the headquarters’ location listed in
response to question II.A.9.a;
d. Going as far back as 1995, the date of acquisition and the situs address for the U.S.
headquarters location of any entity that owned, or leased under an IRU agreement,
Connections to five or more Locations in any MSA at the time you acquired the entity in a
merger where you or your subsidiary was the surviving entity.
e. The name of any Affiliated Company that owned, or leased under an IRU agreement,
Connections to five or more Locations in any MSA at the time you became affiliated with
the Affiliated Company, going as far back as 1995.
f. For each Affiliated Company listed in response to question II.A.9.e, provide:
i. The year of affiliation;
ii. The situs address for each Affiliated Company’s U.S. headquarters at the time of
affiliation;
iii. The year that the Affiliated Company established the situs address listed in response
to question II.A.9.f.i for its U.S. headquarters; and
iv. The year established and situs address for any prior U.S. headquarters’ location
designated by the Affiliated Company, going as far back as 1995 or the year of

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affiliation, whichever is most recent, if different from the headquarters’ location
listed in response to question II.A.9.f.i.
II.A.10. Provide data, maps, information, marketing materials, and/or documents identifying those
geographic areas where you, or an Affiliated Company, advertised or marketed Dedicated Service over
existing facilities, via leased facilities, or by building out new facilities as of December 31, 2010 and as of
December 31, 2012, or planned to advertise or market such services within twenty-four months of those
dates.
II.A.11. Identify the five most recent Requests for Proposals (RFPs) for which you were selected as the
winning bidder to provide each of the following: (a) Dedicated Services; (b) Best Efforts Business
Broadband Internet Access Services; and, to the extent different from (a) or (b), (c) some other form of
high-capacity data services to business customers.8 In addition, identify the five largest RFPs (by number
of connections) for which you submitted an unsuccessful competitive bid between 2010 and 2012 for
each of (a) Dedicated Services; (b) Best Efforts Business Broadband Internet Access Services; and, to the
extent different from (a) or (b), (c) some other form of high-capacity data services to business customers.9
For each RFP identified, provide a description of the RFP, the area covered, the price offered, and other
competitively relevant information. Lastly, identify the business rules you rely upon to determine
whether to submit a bid in response to an RFP.
Billing Information
II.A.12. For all Dedicated Services provided using transmission paths that you (i) own; (ii) lease from
another entity under an IRU agreement; or (iii) obtain as a UNE from an ILEC to provide a Dedicated
Service, submit the following information by circuit element by circuit billed for each month from
January 1 to December 31 for the years 2010 and 2012.
a. The closing date of the monthly billing cycle in mm/dd/yyyy format;
b. The name and six-digit 499-A Filer ID of the customer, where applicable, or other unique
ID if customer does not have a 499-A Filer ID;
c. The Location ID from question II.A.4.a that is used to link the circuit elements to the
terminating Location of the circuit (where applicable);
d. The circuit ID common to all elements purchased in common for a particular circuit;
e. The type of circuit (PBDS, or DS1 or DS3, etc.) and its bandwidth;
f. A unique billing code for the circuit element (see question II.A.14);
g. The number of units billed for this circuit element (note that the bandwidth of the circuit
must not be entered here);
h. The dollar amount of non-recurring charges billed for the first unit of this circuit element;
i. The dollar amount of non-recurring charges billed for additional units of this circuit
element (if different from the amount billed for the initial unit);
j. The monthly recurring dollar charge for the first unit of the circuit element billed;
k. The monthly recurring dollar charge for additional units (if different from the amount
billed for the initial unit);
l. Per unit charge for the circuit element;
m. The total monthly dollar amount billed for the circuit element;
8

To be clear, we expect Competitive Providers that have won RFPs in each service category to identify up to five
RFPs in each category, not a total of five RFPs across the three categories.
9

To be clear, we expect Competitive Providers that have submitted unsuccessful competitive bids for RFPs in each
service category to identify up to five RFPs in each category, not a total of five RFPs across the three categories.

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n. The Term Commitment associated with this circuit in months;
o. Indicate whether this circuit element is associated with a circuit that contributes to a
Volume Commitment; and
p. The adjustment ID (or multiple adjustment IDs) linking this circuit element to the unique
out-of-cycle billing adjustments in question II.A.13.a (below) if applicable.
II.A.13. For each adjustment, rebate, or true-up for billed Dedicated Services, provide the information
requested below.
a. A unique ID number for the billing adjustment, rebate, or true-up (see question II.A.12.p
above) and a unique ID number for the Tariff or contract from which the adjustment
originates;
b. The beginning date of the time period covered by the adjustment or true-up;
c. The ending date of the time period covered by the adjustment or true-up;
d. The scope of the billing adjustment, i.e., whether the adjustment applies to a single circuit
element on a single circuit, more than one circuit element on a single circuit, more than
one circuit element across multiple circuits, or an overall adjustment that applies to every
circuit element on every circuit purchased by the customer;
e. The dollar amount of the adjustment or true-up; and
f. A brief description of the billing adjustment, rebate or true-up, e.g., term discount,
revenue target rebate, etc.
II.A.14. For each unique billing code, please provide the following information below.
a. The billing code for the circuit element;
b. Select the phrase that best describes the circuit element from the list. Names of some
common rate elements are shown on the generalized circuit diagram below:
Channel mileage
termination

Customer
Designated
Location
A

Local distribution channel;
Channel termination;
Special access line;
Customer port connection
(Ethernet)

i.

ii.
iii.
iv.
v.

Serving
Wire
Center

Channel mileage
termination

Customer
Designated
Location
B

Serving
Wire
Center

Channel mileage;
Channel mileage facility;
Special transport

Local distribution channel;
Channel termination;
Special access line;
Customer port connection
(Ethernet)

Channel mileage facility, channel mileage, interoffice channel mileage, special
transport (a transmission path between two serving wire centers associated with
customer designated locations; a serving wire center and an international or service
area boundary point; a serving wire center and a hub, or similar type of connection);
Channel mileage termination, special transport termination (the termination of
channel mileage facility or similar transmission path);
Channel termination, local distribution channel, special access line, customer port
connection (Ethernet) (a transmission path between a customer designated location
and the associated wire center);
Clear channel capability (not shown) (an arrangement which allows a customer to
transport, for example, 1.536 Mbps of information on a 1.544 Mbps line rate with no
constraint on the quantity or sequence of one and zero bits);
Cross-connection (not shown) (semi-permanent switching between facilities,
sometimes combined with multiplexing/demultiplexing);
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vi. Multiplexing (not shown) (channelizing a facility into individual services requiring a
lower capacity or bandwidth); and
vii. Class of service and/or committed information rate (not shown) (for Ethernet, the
performance characteristics of the network and bandwidth available for a customer
port connection).
c. If none of the possible entries describes the circuit element, enter a short description.
Revenues, Terms and Conditions Information
II.A.15. What were your Revenues from the sale of CBDS in 2010 and 2012? For each year, report
Revenues in total, separately by DS1, DS3, and other CBDS sales, and separately by customer category,
i.e., sales to Providers and End Users.
II.A.16. What were your Revenues from the sale of PBDS in 2010 and 2012? For each year, report
Revenues in total, separately by customer category, i.e., sales to Providers and End Users, and separately
by bandwidth for the following categories:
a. less than or equal to 1.5 Mbps;
b. greater than 1.5, but less than or equal to 50 Mbps;
c. greater than 50, but less than or equal to 100 Mbps;
d. greater than 100, but less than or equal to 1 Gbps; and
e. greater than 1 Gbps.
II.A.17. What percentage of your Revenues from the sale of DS1, DS3, and PBDS services in 2012 were
generated from an agreement or Tariff that contains a Prior Purchase-Based Commitment?
II.A.18. If you offer Dedicated Services pursuant to an agreement or Tariff that contains either a Prior
Purchase-Based Commitment or a Non-Rate Benefit, then explain how, if at all, those sales are
distinguishable from similarly structured ILEC sales of DS1s, DS3s, and/or PBDS.
II.A.19. Provide the business justification for the Term or Volume Commitments associated with any
Tariff or agreement you offer or have in effect with a customer for the sale of Dedicated Services.
B. ILECs must respond to the following:
II.B.1. Indicate whether you are an Affiliated Company. If you are an Affiliated Company, you must
identify the entities that provide and/or purchase Dedicated Service with which you have an affiliation
(name/FRN).
Facilities Information
II.B.2. Provide the total number of Locations to which you provided a Connection in your company’s
study areas during 2010 and during 2012 where your company: (i) owned the Connection; or (ii) leased
the Connection from another entity under an IRU agreement.
II.B.3. Provide the information requested below for each Location to which your company had a
Connection during 2010 and during 2012 that you (i) owned or (ii) leased from another entity under an
IRU agreement:
a. A unique ID for the Location;

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b. The actual situs address for the Location (i.e., land where the building or cell site is
located);
c. The geocode for the Location (i.e., latitude and longitude);
d. The Location type (e.g., building, other man-made structure, cell site in or on a building,
free-standing cell site, or a cell site on some other man-made structure like a water tower,
billboard, etc.);
e. Whether any of the Connection to the Location was provided using fiber;
f. The total sold bandwidth of the Connection provided by you to the Location in Mbps;
g. The total bandwidth to the Location sold by you as UNEs in the form of DS1s and/or
DS3s;
h. The total bandwidth to the Location sold directly by you to an End User;
i. The total sold fixed wireless bandwidth provided by you to the Location; and
j. The total bandwidth sold by you to any cell sites at the Location.
Billing Information
II.B.4. For all Dedicated Services provided using transmission paths that you (i) own or (ii) lease from
another entity under an IRU agreement, submit the following information by circuit element by circuit
billed for each month from January 1 to December 31 for the years 2010 and 2012.
a. The closing date of the monthly billing cycle in mm/dd/yyyy format;
b. The name and six-digit 499A Filer ID of the customer, where applicable, or other unique
ID if customer does not have a 499A Filer ID;
c. The Location ID from question II.B.3.a that is used to link the circuit elements to the
terminating Location of the circuit (where applicable);
d. The circuit ID common to all elements purchased in common for a particular circuit;
e. The type of circuit, (DS1 sold as a UNE, DS3 sold as a UNE, PBDS, non-UNE DS1s or
DS3s, etc.) and the bandwidth of the circuit;
f. The serving wire center / mileage rating point Common Language Location Identification
(CLLI) of one end of the circuit (MRP1);
g. The serving wire center / mileage rating point CLLI of the other end of the circuit
(MRP2);
h. The latitude of MRP1;
i. The longitude of MRP1;
j. The latitude of MRP2;
k. The longitude of MRP2;
l. End of the circuit (1=MRP1 or 2=MRP2) associated with this circuit element;
m. The billing code for the circuit element (see question II.B.6);
n. The density pricing zone for the circuit element;10
o. The number of units billed for this circuit element (note that the bandwidth of the circuit
must not be entered here);
p. The dollar amount of non-recurring charges billed for the first unit of this circuit element;
q. The dollar amount of non-recurring charges billed for additional units of this circuit
element (if different from the amount billed for the initial unit);
r. The monthly recurring dollar charge for the first unit of the circuit element billed;
s. The monthly recurring dollar charge for additional units (if different from the amount
billed for the initial unit);
t. Per unit charge for the circuit element;
10

See 47 C.F.R. § 69.123 (density pricing zones for special access and switched transport).

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u. The total monthly dollar amount billed for the circuit element;
v. The Term Commitment associated with this circuit in months;
w. Indicate whether this circuit element is associated with a circuit that contributes to a
Volume Commitment;
x. Indicate whether this circuit element was purchased pursuant to a Contract-Based Tariff;
and
y. The adjustment ID (or multiple adjustment IDs) linking this circuit element to the unique
out-of-cycle billing adjustments in question II.B.5.a (below) if applicable.
II.B.5. For each adjustment, rebate, or true-up for billed Dedicated Services, provide the information
requested below.
a. A unique ID for the billing adjustment or true-up (see question II.B.4.y above);
b. A unique ID number for the contract or Tariff from which the adjustment originates;
c. The beginning date of the time period covered by the adjustment or true-up;
d. The ending date of the time period covered by the adjustment or true-up;
e. The scope of the billing adjustment, i.e., whether the adjustment applies to a single circuit
element on a single circuit, more than one circuit element on a single circuit, more than
one circuit element across multiple circuits, or an overall adjustment that applies to every
circuit element on every circuit purchased by the customer;
f. The dollar amount of the adjustment or true-up;
g. Whether the adjustment is associated with a Term Commitment, and if so, the length of
the term specified in the contract or Tariff necessary to achieve the rebate;
h. Whether the adjustment is associated with a Volume Commitment, and if so, the number
of circuits and/or dollar amount specified in the contract or Tariff necessary to achieve
the rebate; and
i. If the adjustment is for some other reason, a brief description of the reason for the
adjustment.
II.B.6. For each unique billing code, please provide the following information below.
a. The billing code for the circuit element;
b. The phrase that best describes the circuit element from the list. Names of some common
rate elements are shown on the generalized circuit diagram below:
Channel mileage
termination

Customer
Designated
Location
A

Serving
Wire
Center

Local distribution channel;
Channel termination;
Special access line;
Customer port connection
(Ethernet)

Channel mileage
termination

Customer
Designated
Location
B

Serving
Wire
Center

Channel mileage;
Channel mileage facility;
Special transport

Local distribution channel;
Channel termination;
Special access line;
Customer port connection
(Ethernet)

i.

Channel mileage facility, channel mileage, interoffice channel mileage, special
transport (a transmission path between two serving wire centers associated with
customer designated locations; a serving wire center and an international or service
area boundary point; a serving wire center and a hub, or similar type of connection);
ii. Channel mileage termination, special transport termination (the termination of
channel mileage facility or similar transmission path);
iii. Channel termination, local distribution channel, special access line, customer port
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connection (Ethernet) (a transmission path between a customer designated location
and the associated wire center);
iv. Clear channel capability (not shown) (an arrangement which allows a customer to
transport, for example, 1.536 Mbps of information on a 1.544 Mbps line rate with no
constraint on the quantity or sequence of one and zero bits);
v. Cross-connection (not shown) (semi-permanent switching between facilities,
sometimes combined with multiplexing/demultiplexing);
vi. Multiplexing (not shown) (channelizing a facility into individual services requiring a
lower capacity or bandwidth); and
vii. Class of service and/or committed information rate (not shown) (for Ethernet, the
performance characteristics of the network and bandwidth available for a customer
port connection).
c. If none of the possible entries describes the rate element, enter a short description.
II.B.7. List the CLLI code for each one of your wire centers that was subject to price cap regulation as of
December 31, 2010 and as of December 31, 2012, i.e., those wire centers in your incumbent territory
where the Commission had not granted you pricing flexibility. For those MSAs and Non-MSAs where the
Commission granted you Phase I or Phase II Pricing Flexibility as of December 31, 2010 and as of
December 31, 2012, list the CLLI codes for the wire centers associated with each MSA and Non-MSA for
each year, the name of the relevant MSA and Non-MSA for each year, and the level of pricing flexibility
granted for the MSA and Non-MSA, i.e., Phase I and/or Phase II Pricing Flexibility.
Revenues, Terms and Conditions Information
II.B.8. What were your Revenues from the sale of CBDS services in 2010 and 2012? For each year,
report Revenues in total, separately by DS1, DS3, and other CBDS sales, and separately by customer
category, i.e., sales to Competitive Providers and End Users.
II.B.9. What were your Revenues from the sale of PBDS services in 2010 and 2012? For each year,
report Revenues in total, separately by customer category, i.e., sales to Competitive Providers and End
Users, and separately by bandwidth for the following categories:
a. less than or equal to 1.5 Mbps;
b. greater than 1.5, but less than or equal to 50 Mbps;
c. greater than 50, but less than or equal to 100 Mbps;
d. greater than 100, but less than or equal to 1 gigabyte per second (Gbps); and
e. greater than 1 Gbps.
II.B.10. What were your Revenues from the One Month Term Only Rate charged for DS1, DS3, and/or
PBDS services in 2010 and 2012? For each year, report Revenues in total, separately by DS1, DS3, and
PBDS sales as applicable, and separately by customer category, i.e., sales to Competitive Providers and
End Users.
II.B.11. How many customers were purchasing DS1, DS3, and/or PBDS services pursuant to your One
Month Term Only Rates as of December 31, 2012? Report customer numbers in total, separately for DS1,
DS3, and PBDS services as applicable, and separately by customer category, i.e., the number of DS1,
DS3, and PBDS service customers that were Competitive Providers and End Users.
II.B.12. Separately list all Tariff Plans and Contract-Based Tariffs that can be applied to the purchase of
DS1, DS3 and/or PBDS services and provide the information requested below for each plan.
a. This plan is a:
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□ Tariff Plan □ Contract-Based Tariff (select one)
b. Plan name:
c. Tariff and Section Number(s):

□

d. This plan contains:
Term Commitment(s) □ Volume Commitment(s)
□ Non-Rate Benefit option(s) (select all that apply)
e. If the plan contains options for Non-Rate Benefits, explain the available Non-Rate
Benefits.
f.

This plan can be applied to the purchase of:
□ DS1 services □ DS3 services □ PBDS

□ Other (select all that apply)

g. In what geographic areas is this plan available, e.g., nationwide or certain MSAs?
i.

Is plan available in □MSAs, □Non-MSAs, or □ both types of areas?

ii. If plan is available in Non-MSAs, indicate the states where the Non-MSA areas are
located?
h. To receive a discount or Non-Rate Benefit under this plan, must the customer make a
Prior Purchase-Based Commitment?
□ Yes □ No
i.

Do purchases of DS1 or DS3 services in areas outside of the study area(s) where you are
subject to price cap regulation (e.g., purchases from an Affiliated Company that is a
CLEC) count towards meeting any Volume Commitment to receive a discount or NonRate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment)

j.

Do DS1 or DS3 purchases in areas where you are subject to price cap regulation and
where pricing flexibility has not been granted count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment)

k. Do DS1 or DS3 purchases in areas where you have been granted Phase I Pricing
Flexibility count towards meeting any Volume Commitment to receive a discount or NonRate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment)
l. Do DS1 or DS3 purchases in areas where you have been granted Phase II Pricing
Flexibility count towards meeting any Volume Commitment to receive a discount or NonRate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment)
m. Do non-tariffed PBDS purchases by the customer count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment)
n. Do tariffed PBDS purchases by the customer count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment)
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o. Do purchases by the customer for services other than DS1s, DS3s, and PBDS count
towards meeting any Volume Commitment to receive a discount or Non-Rate Benefit
under this plan?
□ Yes □ No □ N/A (no Volume Commitment)
p. Is the discount or Non-Rate Benefit available under this plan conditioned on the customer
limiting its purchase of UNEs, e.g., customer must keep its purchase of UNEs below a
certain percentage of the customer’s total spend?
□ Yes □ No
q. What were your Revenues from the provision of Dedicated Service under this plan in
2010 and in 2012?
r.

What is the business justification for any Term or Volume Commitments associated with
this plan?

s. How many customers were subscribed to this plan as of December 31, 2012? Report
customer numbers in total, separately for DS1, DS3, and PBDS services as applicable,
and separately by customer category, i.e., the number of DS1, DS3, and/or PBDS
customers that were Competitive Providers and End Users.
i.

If there were five or fewer customers subscribed to this plan as of December 31,
2012, indicate the number of subscribers to this plan that were new customers (as
opposed to an existing or prior customer) at the time they subscribed to this plan.

ii. For those subscribers to this plan that were existing or prior customers at the time
they committed to purchasing services under this plan, explain how the purchase
commitment made under this plan compares to the customer’s previous purchase
commitment. For example, indicate what percentage of the previous purchase
commitment, the new purchase commitment equals.
t.

Of those customers subscribed as of December 31, 2012, how many in 2012 failed to
meet any Volume Commitment or Term Commitment required to retain a discount or NonRate Benefit they originally agreed to when entering into this plan?

II.B.13. Indicate whether you have any non-tariffed agreement with an End User or Competitive
Provider that, directly or indirectly, provides a discount or a Non-Rate Benefit on the purchase of tariffed
DS1s, DS3s, and/or PBDS, restricts the ability of the End User or Competitive Provider to obtain UNEs,
or negatively affects the ability of the End User or Competitive Provider to purchase Dedicated Services.
If so, identify each agreement, including the parties to the agreements, the effective date, end date, and a
summary of the relevant provisions.
C. Certain Entities that provide Best Efforts Business Broadband Internet Access Services must
respond to the following:
II.C.1. If you provide Best Efforts Business Broadband Internet Access Services to 15,000 or more
customers or 1,500 or more business broadband customers in areas where the ILEC is subject to price
cap regulation, then answer the following questions:
a. Did you submit data in connection with the State Broadband Initiative (SBI) Grant
Program for 2010?
□ Yes □ No
b. Did you submit data in connection with the SBI Grant Program for 2012?
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□

Yes

□

DA 13-1909

No

If you answered “no” to questions II.C.1.a and II.C.1.b, then you do not need to answer
any further questions in this section.
c. Did the data you submitted in connection with the SBI Grant Program in 2010
accurately and completely identify the areas in which you offered Best Efforts
Business Broadband Internet Access Services and exclude those areas where you did
not offer such services as of December 31, 2010?
□ Yes □ No
i.

If yes, then provide the list of prices for those Best Efforts Business Broadband
Internet Access Services that you were marketing in each census block submitted
in connection with the SBI Grant Program as of December 31, 2010. If there is a
price variation within your service footprint, indicate which prices are associated
with which census blocks.
ii. If no, then provide a list of all the census blocks in which you offered Best
Efforts Business Broadband Internet Access Services as of December 31, 2010,
and a list of the prices for those Best Efforts Business Broadband Internet Access
Services that you were marketing in each census block as of December 31, 2010.
If there is a price variation within your service footprint, indicate which prices
are associated with which census blocks.
d. Did the data you submitted in connection with the SBI Grant Program in 2012
accurately and completely identify the areas in which you offered Best Efforts
Business Broadband Internet Access Services and exclude those areas where you did
not offer such services as of December 31, 2012?
□ Yes □ No
i.

If yes, then provide the list of prices for those Best Efforts Business Broadband
Internet Access Services that you were marketing in each census block submitted
in connection with the SBI Grant Program as of December 31, 2012. If there is a
price variation within your service footprint, indicate which prices are associated
with which census blocks.
ii. If no, then provide a list of all the census blocks in which you offered Best
Efforts Business Broadband Internet Access Services as of December 31, 2012,
and a list of the prices for those Best Efforts Business Broadband Internet Access
Services that you were marketing in each census block as of December 31, 2012.
If there is a price variation within your service footprint, indicate which prices
are associated with which census blocks.
D. All Providers must respond to the following:
II.D.1. Describe your company’s short term and long-range promotional and advertising strategies and
objectives for winning new – or retaining current – customers for Dedicated Services. In your
description, please describe the size (e.g., companies with 500 employees or less, etc.), geographic scope
(e.g., national, southeast, Chicago, etc.), and type of customers your company targets or plans to target
through these strategies.
II.D.2. Identify where your company’s policies are recorded on the following Dedicated Service-related
processes: (a) initiation of service; (b) service Upgrades; and (c) service Disconnections. For instance,
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identify where your company records recurring and non-recurring charges associated with the processes
listed above. If recorded in a Tariff, provide the specific Tariff section(s). If these policies are recorded
in documents other than Tariffs, list those documents and state whether they are publicly available. If
they are publicly available, explain how to find them. For documents that are not publicly available, state
whether they are conveyed to customers orally or in writing.
E. Purchasers that are mobile wireless service providers must respond to the following:
II.E.1. How many cell sites do you have on your network?
II.E.2. Provide the information requested below for each cell site on your network as of December 31,
2010 and as of December 31, 2012.
a. A unique ID for the cell site;
b. The actual situs address of the cell site (i.e., land where the cell site is located) if the cell
site is located in or on a building;
c. The geocode for the cell site (i.e., latitude and longitude);
d. The CLLI code of the incumbent LEC wire center that serves the cell site, where
applicable;
e. Whether the cell site is in or on a building, is a free-standing cell site, or is on some other
type of man-made structure, e.g., a water tower, billboard, etc.;
f. If the cell site is served by a CBDS, indicate the equivalent number of DS1s used;
g. If the cell site is served by a PBDS, indicate the total bandwidth of the circuit or circuits
in Mbps;
h. If the cell site is served by a wireless Connection, indicate the total bandwidth of the
circuit or circuits in Mbps;
i. The name of the Provider(s) that supplies your Connection to the cell site; and
j. If you self-provide a Connection to the cell site, the provisioned bandwidth of that selfprovided Connection.
Expenditures Information
II.E.3. What were your expenditures, i.e., dollar volume of purchases, on Dedicated Services for 2010
and 2012? For each year, report expenditures in total, separately for CBDS and PBDS purchases, and
separately for purchases from ILECs and Competitive Providers.
II.E.4. Provide your company’s expenditures, i.e., dollar volume of purchases, for DS1s, DS3s, and/or
PBDS purchased from ILECs pursuant to a Tariff in 2010 and in 2012. For each of the following
categories, report expenditures for each year in total and separately for DS1s, DS3s and PBDS:
a. All DS1s, DS3s, and PBDS;
b. DS1s, DS3s, and PBDS purchased at One Month Term Only Rates;
c. DS1s, DS3s, and PBDS purchased under Tariff Plans;
d. DS1s, DS3s, and PBDS purchased under Contract-Based Tariffs;
e. DS1s, DS3s, and PBDS purchased under Tariff Plans that contained a Term Commitment
but not a Volume Commitment;
f. DS1s, DS3s, and PBDS purchased under Tariff Plans that contained a Prior PurchaseBased Commitment;
i. Of the total (and for the separate DS1, DS3, and PBDS totals where applicable),
indicate the average discount from the One Month Term Only Rate incorporated in
the expenditures.
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For purposes of calculating the percentages described above, an example would be a
Tariff Plan that requires a purchase of 20 DS1s and 10 DS3s and generates expenditures
of $2,000 for calendar-year 2012. If those same circuits were purchased at One Month
Term Only Rates of $100 per DS1 and $200 per DS3, then total expenditures would
instead be $4,000. Since the Tariff Plan under this scenario generated 50% of the
expenditures that would be generated from One Month Term Only Rates, the discount
would be 50%.
g. DS1s, DS3s, and PBDS purchased under Contract-Based Tariffs that contained a Term
Commitment but not a Volume Commitment; and
h. DS1s, DS3s, and PBDS purchased under Contract-Based Tariffs that contained a Prior
Purchase-Based Commitment;
i. Of the total (and for the separate DS1 and DS3 totals if available), indicate the
average discount from the One Month Term Only Rate incorporated in the
expenditures.
An example of how to calculate this percentage can be found at question II.E.4.f.i.
i.

What percentage of your expenditures in 2012 were subject to a Term Commitment of
five or more years?

II.E.5. What were your expenditures, i.e., dollar volume of purchases, on DS1s, DS3s, and/or PBDS
purchased from Competitive Providers pursuant to a Tariff in 2010 and in 2012? Report expenditures in
total and separately for DS1s, DS3s and PBDS, as applicable, for the following categories for each year:
a. All DS1s, DS3s, and PBDS;
b. DS1s, DS3s, and PBDS purchased at One Month Term Only Rates;
c. DS1s, DS3s, and PBDS purchased under Tariffs that contained a Term Commitment but
not a Volume Commitment;
d. DS1s, DS3s, and PBDS purchased under Tariffs that contained a Prior Purchase-Based
Commitment;
i. Of the total (and for the separate DS1, DS3, and PBDS totals where applicable),
indicate the average discount from the One Month Term Only Rate incorporated in
the expenditures.
An example of how to calculate this percentage can be found at question II.E.4.f.i
e. What percentage of your expenditures in 2012 were subject to a Term Commitment of
five or more years?
II.E.6. What were your expenditures, i.e., dollar volume of purchases, on DS1s, DS3s, and/or PBDS
purchased from ILECs and Competitive Providers pursuant to an agreement (not a Tariff) in 2010 and in
2012? Report expenditures in total, separately for purchases from ILECs and Competitive Providers, and
separately for DS1s, DS3s and PBDS, as applicable, for the following categories for each year:
a. All DS1s, DS3s, and PBDS;
b. DS1s, DS3s, and PBDS purchased at a non-discounted rate;
c. DS1s, DS3s, and PBDS purchased under a non-tariffed agreement that contained a Term
Commitment but not a Volume Commitment;
d. DS1s, DS3s, and PBDS purchased under a non-tariffed agreement that contained a Prior
Purchase-Based Commitment;
i. Of the total (and for the separate DS1, DS3, and PBDS totals where applicable),
indicate the average discount from the non-discounted rate incorporated in the
expenditures.
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An example of how to calculate this percentage can be found at question II.E.4.f.i
II.E.7. What were your expenditures, i.e., dollar volume of purchases, on PBDS purchased under a
Tariff in 2010 and in 2012?
a. Separately for purchases from ILECs and Competitive Providers for the following service
bandwidth categories:
i. less than or equal to 1.5 Mbps;
ii. greater than 1.5, but less than or equal to 50 Mbps;
iii. greater than 50, but less than or equal to 100 Mbps;
iv. greater than 100, but less than or equal to 1 Gbps; or
v. greater than 1 Gbps.
II.E.8. What were your expenditures, i.e., dollar volume of purchases, on non-tariffed PBDS in 2010 and
in 2012?
a. Separately for purchases from ILECs and Competitive Providers for the following service
bandwidth categories:
i. less than or equal to 1.5 Mbps;
ii. greater than 1.5, but less than or equal to 50 Mbps;
iii. greater than 50, but less than or equal to 100 Mbps;
iv. greater than 100, but less than or equal to 1 Gbps; or
v. greater than 1 Gbps.
Terms and Conditions Information
II.E.9. Explain whether the terms and conditions of any Tariff or contract to which you are a party for the
purchase of Dedicated Services or the policies of any of your Providers constrain your ability to:
a. Decrease your purchases from your current Provider(s);
b. Purchase services from another Provider currently operating in the geographic areas in
which you purchase services;
c. Purchase non-tariffed services, such as Ethernet services, from your current Provider of
tariffed DS1, DS3, and/or PBDS services or from other Providers operating in the
geographic areas in which you purchase tariffed services;
d. Contract with Providers that are considering entering the geographic areas in which you
purchase tariffed services;
e. Move circuits, for example, moving your DS1 and/or DS3 End-User Channel
Terminations to connect to another Transport Provider; or
f. Otherwise obtain Dedicated Services or change Providers.
Relevant terms and conditions, among others, may include: (a) early termination penalties; (b) shortfall
provisions; (c) overlapping/supplemental discounts plans with different termination dates; (d)
requirements to include all services, including new facilities, under a Tariff Plan or Contract-Based
Tariff; or (e) requiring purchases in multiple geographic areas to obtain maximum discounts.
In your answer, highlight contracts where you contend that a term or condition is a particularly onerous
constraint by comparison with more typical provisions in other contracts. Also, at a minimum, list: (a)
the Provider and indicate whether the Provider is an ILEC or a Competitive Provider; (b) a description of
the term or condition; (c) the geographic area in which the services are provided; (d) the name of the
vendor providing the service; and (e) where relevant, the specific Tariff number(s) and section(s), or if the

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policy at issue is recorded in documents other than Tariffs, list those documents and how you obtained
them.
If you allege that a term, condition, or Provider’s policy negatively affects your ability to obtain
Dedicated Services, state whether you have brought a complaint to the Commission, a state commission
or court about this issue and the outcome. If you have not brought a complaint, explain why not.
II.E.10. If you purchase, or purchased, Transport Service and End User Channel Terminations from the
same Provider, explain your experience with changing Transport Service from one Provider to another
between January 1, 2010 and December 31, 2012 while keeping your End User Channel Terminations
with the original Provider. Where appropriate, identify the Provider(s) in your responses below and
indicate whether they are an ILEC or a Competitive Provider.
a. How many times did you change Transport Service while keeping your End User
Channel Terminations with the original Provider? An estimate of the number of circuits
moved to a new Transport Provider, or the number of such changes requested for each
year, is sufficient.
b. What was the length of time, on average, it took for the original Provider to complete the
process of connecting your last-mile End-user Channel Terminations to another
Transport Provider? An estimate is sufficient.
c. Were you given the opportunity to negotiate the amount of time it would take to complete
the process of connecting your End User Channel Terminations to another Transport
Provider on a case-by-case basis? In answering this question, also describe and provide
citations to the ILEC’s or Competitive Provider’s policies, rules or, where relevant, Tariff
provisions, if known, explaining the transition process.
d. How did connecting to a new Transport Provider impact the rate you paid for the End
User Channel Terminations you continued to purchase from the original Provider?
e. Did connecting to a new Transport Provider typically impact the rate you continued to
pay for Transport Service from the original Provider while the change in Transport
Providers remained pending? If so, how? What was the average percentage change in
rates? For example, did you ever pay a One Month Term Only Rate during that time?
II.E.11. Describe any circumstances since January 1, 2010, in which you have purchased circuits pursuant
to a Tariff, solely for the purpose of meeting a Prior Purchase-Based Commitment required for a discount
or Non-Rate Benefit from your Provider (i.e., you would not have purchased the circuit but for the
requirement that you meet a Volume Commitment required for a discount or Non-Rate Benefit from your
Provider). In your description, provide at least one example, which at a minimum, lists:
a. The name of the Provider providing the circuits at issue;
b. A description of the Prior Purchase-Based Commitment;
c. The Tariff and section number(s) of the specific terms and conditions described;
d. The number of circuits you would not have purchased but for the Prior Purchase-Based
Commitment requirement to receive a discount or Non-Rate Benefit;
i. Of the circuits reported in II.E.11.d, how many did you not use at all?
e. A comparison of the dollar amount of the unnecessary circuit(s) purchased versus the
dollar amount of penalties your company would have had to pay under the Prior
Purchase-Based Commitment had it not purchased and/or maintained the circuit(s), and a
description of how that comparison was calculated.
f. How many circuits were activated under the identified Tariff plan and not used when you
initially entered into the plan? What were these unused circuits as a percent of the total
circuits currently purchased under this Tariff plan? Indicate the percent of the total

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circuits currently purchased under this Tariff plan that exceed your Prior Purchase-Based
Commitment.
g. For the Prior Purchase-Based Commitment, indicate whether you are able to buy any
DS1s or DS3s from the Provider outside of the identified Tariff plan, or are you required
to make all purchases from the Provider pursuant to the identified Tariff plan?
II.E.12. For each year for the past five years, state the number of times and in what geographic area(s)
you have switched from purchasing End-User Channel Terminations from one Provider of Dedicated
Services to another.
II.E.13. Explain the circumstances since January 1, 2010 under which you have paid One Month Term
Only Rates for DS1, DS3, and/or PBDS services and the impact, if any, it had on your business and your
customers. In your response, indicate any general rules you follow, if any, concerning the maximum
number of circuits and maximum amount of time you will pay One Month Term Only Rates, and your
business rationale for any such rules.
II.E.14. Separately list all Tariffs under which your company purchases DS1s, DS3s, and/or PBDS and
provide the information requested below for each plan.
a. This plan is a:
□ Tariff Plan

□

Contract-Based Tariff (select one)

b. Plan name:
c. Provider name:
d. Tariff and Section Number(s):
e. Tariff type:
□ Interstate

□

□

Intrastate

f. This plan contains:
Term Commitment(s) □ Volume Commitment(s)
□ Non-Rate Benefit option(s) (select all that apply)
g. If the plan contains Non-Rate Benefits, identify the Non-Rate Benefits that were relevant
to your decision to purchase services under this plan.
h. This plan can be applied to the purchase of:
□ DS1 services □ DS3 services □ PBDS

□ Other (select all that apply)

i.

In what geographic areas do you purchase DS1s, DS3s, and/or PBDS under this plan, e.g.,
nationwide, certain states, or certain MSAs?

j.

To receive a discount or Non-Rate Benefit under this plan, does your company make a
Prior Purchase-Based Commitment?
□ Yes □ No

k. If this is an ILEC plan, do DS1, DS3, or tariffed PBDS purchases your company makes
outside the study area(s) of the ILEC (e.g., purchases from an Affiliated Company of the
ILEC that is providing out-of-region service as a CLEC) count towards meeting any
Volume Commitment to receive a discount or Non-Rate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)

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i.

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If you answered yes, in what geographic areas outside the study area(s) of the ILEC,
do you purchase these DS1s, DS3s and/or tariffed PBDS?

ii. For each geographic area identified, state whether your company would have
purchased from a different Provider, if at all, had it not been for the discounts or
Non-Rate Benefits received under this plan? In your response, indicate whether the
Provider that you would have purchased from has Connections serving that
geographic area and the Provider’s name.
l.

If this is an ILEC plan, do DS1, DS3, and/or tariffed PBDS purchases your company
makes from the ILEC in price cap areas where the Commission has not granted the ILEC
pricing flexibility count towards meeting any Volume Commitment to receive a discount
or Non-Rate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)
i.

If you answered yes, then identify the price cap areas where you purchase DS1s,
DS3s, and/or tariffed PBDS that count towards meeting any Volume Commitment to
receive a discount or Non-Rate Benefit under this plan?

m. If this is an ILEC plan, do DS1, DS3 and/or tariffed PBDS purchases your company
makes from the ILEC in areas where the Commission has granted Phase I Pricing
Flexibility count towards meeting any Volume Commitment to receive a discount or NonRate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)
i.

If you answered yes, in what geographic areas subject to pricing flexibility do you
purchase DS1s, DS3s, and/or tariffed PBDS that count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit under this plan?

ii. For each geographic area identified, state whether your company would have
purchased from a different Provider, if at all, had it not been for the requirements of
the Tariff Plan? In your response, indicate whether the Provider that you would have
purchased from has Connections serving that geographic area and the Provider’s
name.
n. If this is an ILEC plan, do DS1, DS3 and/or tariffed PBDS purchases your company
makes from the ILEC in areas where the Commission has granted Phase II Pricing
Flexibility count towards meeting any Volume Commitment to receive a discount or NonRate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)
i.

If you answered yes, in what geographic areas subject to pricing flexibility do you
purchase DS1s, DS3s, and/or tariffed PBDS that count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit under this plan?

ii. For each geographic area identified, state whether your company would have
purchased from a different Provider, if at all, had it not been for the requirements of
the Tariff Plan? In your response, indicate whether the Provider that you would have
purchased from has Connections serving that geographic area and the Provider’s
name.
o. If this is an ILEC plan, do non-tariffed PBDS purchases your company makes from this
ILEC count towards meeting any Volume Commitment to receive a discount or Non-Rate
Benefit under this plan?

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□

Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)

i.

If you answered yes, in what geographic areas do you purchase non-tariffed PBDS
that counts towards meeting any Volume Commitment to receive a discount or NonRate Benefit under this plan.

ii. For each geographic area identified, state whether your company would have
purchased non-tariffed PBDS from a different Provider, if at all, had it not been for
the requirements of the plan? In your response, indicate whether the Provider that
you would have purchased from has Connections serving that geographic area and
the Provider’s name.
p. If this is an ILEC plan, do purchases you make for services other than DS1s, DS3s, and
PBDS from this ILEC count towards meeting any Volume Commitment to receive a
discount or Non-Rate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)
i.

If you answered yes, identify the other services purchased and the geographic areas
where you purchase these services that count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit under this plan.

ii. For each geographic area identified, state whether your company would have
purchased those other services from a different Provider, had it not been for the
requirements of the plan? In your response, indicate whether the Provider that you
would have purchased from has Connections serving that geographic area and the
Provider’s name.
q. Is the discount or Non-Rate Benefit available under this plan conditioned on the customer
limiting its purchase of UNEs, e.g., the customer must keep its purchase of UNEs below a
certain percentage of the customer’s total spend? If yes, then provide additional details
about the condition.
II.E.15. Indicate whether you have any non-tariffed agreement with an ILEC that, directly or indirectly,
provides a discount or a Non-Rate Benefit on the purchase of tariffed DS1, DS3, and/or PBDS services,
restricts your ability to obtain UNEs, or negatively affects your ability to purchase Dedicated Services. If
so, identify each agreement, including the parties to the agreement, the effective date, end date, and a
summary of the relevant provisions.
F. Purchasers that are not mobile wireless service providers must respond to the following:
II.F.1. What is the principal nature of your business, e.g., are you a CLEC, cable system operator, fixed
wireless service provider, wireless Internet service provider, interconnected VoIP service provider, etc.?
Expenditures Information
II.F.2. What were your expenditures, i.e., dollar volume of purchases, on Dedicated Services for 2010
and 2012? For each year, report expenditures in total, separately for CBDS and PBDS purchases, and
separately for purchases from ILECs and Competitive Providers.

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II.F.3. Provide your company’s expenditures, i.e., dollar volume of purchases, for DS1s, DS3s, and/or
PBDS purchased from ILECs pursuant to a Tariff in 2010 and in 2012. For each of the following
categories, report expenditures for each year in total and separately for DS1s, DS3s and PBDS:
a. All DS1s, DS3s, and PBDS;
b. DS1s, DS3s, and PBDS purchased at One Month Term Only Rates;
c. DS1s, DS3s, and PBDS purchased under Tariff Plans;
d. DS1s, DS3s, and PBDS purchased under Contract-Based Tariffs;
e. DS1s, DS3s, and PBDS purchased under Tariff Plans that contained a Term Commitment
but not a Volume Commitment;
f. DS1s, DS3s, and PBDS purchased under Tariff Plans that contained a Prior PurchaseBased Commitment;
i. Of the total (and for the separate DS1, DS3, and PBDS totals where applicable),
indicate the average discount from the One Month Term Only Rate incorporated in
the expenditures.
For purposes of calculating the percentages described above, an example would be a
Tariff Plan that requires a purchase of 20 DS1s and 10 DS3s and generates expenditures
of $2,000 for calendar-year 2012. If those same circuits were purchased at One Month
Term Only Rates of $100 per DS1 and $200 per DS3, then total expenditures would
instead be $4,000. Since the Tariff Plan under this scenario generated 50% of the
expenditures that would be generated from One Month Term Only Rates, the discount
would be 50%.
g. DS1s, DS3s, and PBDS purchased under Contract-Based Tariffs that contained a Term
Commitment but not a Volume Commitment; and
h. DS1s, DS3s, and PBDS purchased under Contract-Based Tariffs that contained a Prior
Purchase-Based Commitment;
i. Of the total (and for the separate DS1 and DS3 totals if available), indicate the
average discount from the One Month Term Only Rate incorporated in the
expenditures.
An example of how to calculate this percentage can be found at question II.F.3.f.i.
i.

What percentage of your expenditures in 2012 were subject to a Term Commitment of
five or more years?

II.F.4. What were your expenditures, i.e., dollar volume of purchases, on DS1s, DS3s, and/or PBDS
purchased from Competitive Providers pursuant to a Tariff in 2010 and in 2012? Report expenditures in
total and separately for DS1s, DS3s and PBDS, as applicable, for the following categories for each year:
a. All DS1s, DS3s, and PBDS;
b. DS1s, DS3s, and PBDS purchased at One Month Term Only Rates;
c. DS1s, DS3s, and PBDS purchased under Tariffs that contained a Term Commitment but
not a Volume Commitment;
d. DS1s, DS3s, and PBDS purchased under Tariffs that contained a Prior Purchase-Based
Commitment;
i. Of the total (and for the separate DS1, DS3, and PBDS totals where applicable),
indicate the average discount from the One Month Term Only Rate incorporated in
the expenditures.
An example of how to calculate this percentage can be found at question II.F.3.f.i
e. What percentage of your expenditures in 2012 were subject to a Term Commitment of
five or more years?
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II.F.5. What were your expenditures, i.e., dollar volume of purchases, on DS1s, DS3s, and/or PBDS
purchased from ILECs and Competitive Providers pursuant to an agreement (not a Tariff) in 2010 and in
2012? Report expenditures in total, separately for purchases from ILECs and Competitive Providers, and
separately for DS1s, DS3s and PBDS, as applicable, for the following categories for each year:
a. All DS1s, DS3s, and PBDS;
b. DS1s, DS3s, and PBDS purchased at a non-discounted rate;
c. DS1s, DS3s, and PBDS purchased under a non-tariffed agreement that contained a Term
Commitment but not a Volume Commitment;
d. DS1s, DS3s, and PBDS purchased under a non-tariffed agreement that contained a Prior
Purchase-Based Commitment;
i. Of the total (and for the separate DS1, DS3, and PBDS totals where applicable),
indicate the average discount from the non-discounted rate incorporated in the
expenditures.
An example of how to calculate this percentage can be found at question II.F.3.f.i
II.F.6. What were your expenditures, i.e., dollar volume of purchases, on PBDS purchased under a
Tariff in 2010 and in 2012?
a. Separately for purchases from ILECs and Competitive Providers for the following service
bandwidth categories:
i. less than or equal to 1.5 Mbps;
ii. greater than 1.5, but less than or equal to 50 Mbps;
iii. greater than 50, but less than or equal to 100 Mbps;
iv. greater than 100, but less than or equal to 1 Gbps; or
v. greater than 1 Gbps.
II.F.7. What were your expenditures, i.e., dollar volume of purchases, on non-tariffed PBDS in 2010 and
in 2012?
a. Separately for purchases from ILECs and Competitive Providers for the following service
bandwidth categories:
i. less than or equal to 1.5 Mbps;
ii. greater than 1.5, but less than or equal to 50 Mbps;
iii. greater than 50, but less than or equal to 100 Mbps;
iv. greater than 100, but less than or equal to 1 Gbps; or
v. greater than 1 Gbps.

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Terms and Conditions Information
II.F.8. Explain whether the terms and conditions of any Tariff or contract to which you are a party for the
purchase of Dedicated Services or the policies of any of your Providers constrain your ability to:
a. Decrease your purchases from your current Provider(s);
b. Purchase services from another Provider currently operating in the geographic areas in
which you purchase services;
c. Purchase non-tariffed services, such as Ethernet services, from your current Provider of
tariffed DS1, DS3, and/or PBDS services or from other Providers operating in the
geographic areas in which you purchase tariffed services;
d. Contract with Providers that are considering entering the geographic areas in which you
purchase tariffed services;
e. Move circuits, for example, moving your DS1 and/or DS3 End-User Channel
Terminations to connect to another Transport Provider; or
f. Otherwise obtain Dedicated Services or change Providers.
Relevant terms and conditions, among others, may include: (a) early termination penalties; (b) shortfall
provisions; (c) overlapping/supplemental discounts plans with different termination dates; (d)
requirements to include all services, including new facilities, under a Tariff Plan or Contract-Based
Tariff; or (e) requiring purchases in multiple geographic areas to obtain maximum discounts.
In your answer, highlight contracts where you contend that a term or condition is a particularly onerous
constraint by comparison with more typical provisions in other contracts. Also, at a minimum, list: (a)
the Provider and indicate whether the Provider is an ILEC or a Competitive Provider; (b) a description of
the term or condition; (c) the geographic area in which the services are provided; (d) the name of the
vendor providing the service; and (e) where relevant, the specific Tariff number(s) and section(s), or if the
policy at issue is recorded in documents other than Tariffs, list those documents and how you obtained
them.
If you allege that a term, condition, or Provider’s policy negatively affects your ability to obtain
Dedicated Services, state whether you have brought a complaint to the Commission, a state commission
or court about this issue and the outcome. If you have not brought a complaint, explain why not.
II.F.9. If you purchase, or purchased, Transport Service and End User Channel Terminations from the
same Provider, explain your experience with changing Transport Service from one Provider to another
between January 1, 2010 and December 31, 2012 while keeping your End User Channel Terminations
with the original Provider. Where appropriate, identify the Provider(s) in your responses below and
indicate whether they are an ILEC or a Competitive Provider.
a. How many times did you change Transport Service while keeping your End User
Channel Terminations with the original Provider? An estimate of the number of circuits
moved to a new Transport Provider, or the number of such changes requested for each
year, is sufficient.
b. What was the length of time, on average, it took for the original Provider to complete the
process of connecting your last-mile End-user Channel Terminations to another
Transport Provider? An estimate is sufficient.
c. Were you given the opportunity to negotiate the amount of time it would take to complete
the process of connecting your End User Channel Terminations to another Transport
Provider on a case-by-case basis? In answering this question, also describe and provide
citations to the ILEC’s or Competitive Provider’s policies, rules or, where relevant, Tariff
provisions, if known, explaining the transition process.
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d. How did connecting to a new Transport Provider impact the rate you paid for the End
User Channel Terminations you continued to purchase from the original Provider?
e. Did connecting to a new Transport Provider typically impact the rate you continued to
pay for Transport Service from the original Provider while the change in Transport
Providers remained pending? If so, how? What was the average percentage change in
rates? For example, did you ever pay a One Month Term Only Rate during that time?
II.F.10. Describe any circumstances since January 1, 2010, in which you have purchased circuits pursuant
to a Tariff, solely for the purpose of meeting a Prior Purchase-Based Commitment required for a discount
or Non-Rate Benefit from your Provider (i.e., you would not have purchased the circuit but for the
requirement that you meet a Volume Commitment required for a discount or Non-Rate Benefit from your
Provider). In your description, provide at least one example, which at a minimum, lists:
a. The name of the Provider providing the circuits at issue;
b. A description of the Prior Purchase-Based Commitment;
c. The Tariff and section number(s) of the specific terms and conditions described;
d. The number of circuits you would not have purchased but for the Prior Purchase-Based
Commitment requirement to receive a discount or Non-Rate Benefit;
i. Of the circuits reported in II.F.10.d, how many did you not use at all?
e. A comparison of the dollar amount of the unnecessary circuit(s) purchased versus the
dollar amount of penalties your company would have had to pay under the Prior
Purchase-Based Commitment had it not purchased and/or maintained the circuit(s), and a
description of how that comparison was calculated.
f. How many circuits were activated under the identified Tariff plan and not used when you
initially entered into the plan? What were these unused circuits as a percent of the total
circuits currently purchased under this Tariff plan? Indicate the percent of the total
circuits currently purchased under this Tariff plan that exceed your Prior Purchase-Based
Commitment.
g. For the Prior Purchase-Based Commitment, indicate whether you are able to buy any
DS1s or DS3s from the Provider outside of the identified Tariff plan, or are you required
to make all purchases from the Provider pursuant to the identified Tariff plan?
II.F.11. For each year for the past five years, state the number of times and in what geographic area(s)
you have switched from purchasing End-User Channel Terminations from one Provider of Dedicated
Services to another.
II.F.12. Explain the circumstances since January 1, 2010 under which you have paid One Month Term
Only Rates for DS1, DS3, and/or PBDS services and the impact, if any, it had on your business and your
customers. In your response, indicate any general rules you follow, if any, concerning the maximum
number of circuits and maximum amount of time you will pay One Month Term Only Rates, and your
business rationale for any such rules.
II.F.13. Separately list all Tariffs under which your company purchases DS1s, DS3s, and/or PBDS and
provide the information requested below for each plan.
a. This plan is a:
□ Tariff Plan

□

Contract-Based Tariff (select one)

b. Plan name:
c. Provider name:
d. Tariff and Section Number(s):
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e. Tariff type:
□ Interstate

□

□

DA 13-1909

Intrastate

f. This plan contains:
Term Commitment(s) □ Volume Commitment(s)
□ Non-Rate Benefit option(s) (select all that apply)
g. If the plan contains Non-Rate Benefits, identify the Non-Rate Benefits that were relevant
to your decision to purchase services under this plan.
h. This plan can be applied to the purchase of:
□ DS1 services □ DS3 services □ PBDS

□ Other (select all that apply)

i.

In what geographic areas do you purchase DS1s, DS3s, and/or PBDS under this plan, e.g.,
nationwide, certain states, or certain MSAs?

j.

To receive a discount or Non-Rate Benefit under this plan, does your company make a
Prior Purchase-Based Commitment?
□ Yes □ No

k. If this is an ILEC plan, do DS1, DS3 or tariffed PBDS purchases your company makes
outside the study area(s) of the ILEC (e.g., purchases from an Affiliated Company of the
ILEC that is providing out-of-region service as a CLEC) count towards meeting any
Volume Commitment to receive a discount or Non-Rate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)
i.

If you answered yes, in what geographic areas outside the study area(s) of the ILEC,
do you purchase these DS1s, DS3s, and/or tariffed PBDS?

ii. For each geographic area identified, state whether your company would have
purchased from a different Provider, if at all, had it not been for the discounts or
Non-Rate Benefits received under this plan? In your response, indicate whether the
Provider that you would have purchased from has Connections serving that
geographic area and the Provider’s name.
l.

If this is an ILEC plan, do DS1, DS3, and/or tariffed PBDS purchases your company
makes from the ILEC in price cap areas where the Commission has not granted the ILEC
pricing flexibility count towards meeting any Volume Commitment to receive a discount
or Non-Rate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)
i.

If you answered yes, then identify the price cap areas where you purchase DS1s,
DS3s, and/or tariffed PBDS that count towards meeting any Volume Commitment to
receive a discount or Non-Rate Benefit under this plan?

m. If this is an ILEC plan, do DS1, DS3, and/or tariffed PBDS purchases your company
makes from the ILEC in areas where the Commission has granted Phase I Pricing
Flexibility count towards meeting any Volume Commitment to receive a discount or NonRate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)
i.

If you answered yes, in what geographic areas subject to pricing flexibility do you
purchase DS1s, DS3s, and/or tariffed PBDS that count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit under this plan?
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ii. For each geographic area identified, state whether your company would have
purchased from a different Provider, if at all, had it not been for the requirements of
the Tariff Plan? In your response, indicate whether the Provider that you would have
purchased from has Connections serving that geographic area and the Provider’s
name.
n. If this is an ILEC plan, do DS1, DS3, and/or tariffed PBDS purchases your company
makes from the ILEC in areas where the Commission has granted Phase II Pricing
Flexibility count towards meeting any Volume Commitment to receive a discount or NonRate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)
i.

If you answered yes, in what geographic areas subject to pricing flexibility do you
purchase DS1s, DS3s, and/or tariffed PBDS that count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit under this plan?

ii. For each geographic area identified, state whether your company would have
purchased from a different Provider, if at all, had it not been for the requirements of
the Tariff Plan? In your response, indicate whether the Provider that you would have
purchased from has Connections serving that geographic area and the Provider’s
name.
o. If this is an ILEC plan, do non-tariffed PBDS purchases your company makes from this
ILEC count towards meeting any Volume Commitment to receive a discount or Non-Rate
Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)
i.

If you answered yes, in what geographic areas do you purchase non-tariffed PBDS
that counts towards meeting any Volume Commitment to receive a discount or NonRate Benefit under this plan.

ii. For each geographic area identified, state whether your company would have
purchased non-tariffed PBDS from a different Provider, if at all, had it not been for
the requirements of the plan? In your response, indicate whether the Provider that
you would have purchased from has Connections serving that geographic area and
the Provider’s name.
p. If this is an ILEC plan, do purchases you make for services other than DS1s, DS3s, and
PBDS from this ILEC count towards meeting any Volume Commitment to receive a
discount or Non-Rate Benefit under this plan?
□ Yes □ No □ N/A (no Volume Commitment, not an ILEC plan)
i.

If you answered yes, identify the other services purchased and the geographic areas
where you purchase these services that count towards meeting any Volume
Commitment to receive a discount or Non-Rate Benefit under this plan.

ii. For each geographic area identified, state whether your company would have
purchased those other services from a different Provider, had it not been for the
requirements of the plan? In your response, indicate whether the Provider that you
would have purchased from has Connections serving that geographic area and the
Provider’s name.
q. Is the discount or Non-Rate Benefit available under this plan conditioned on the customer
limiting its purchase of UNEs, e.g., the customer must keep its purchase of UNEs below a

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certain percentage of the customer’s total spend? If yes, then provide additional details
about the condition.
II.F.14. Indicate whether you have any non-tariffed agreement with an ILEC that, directly or indirectly,
provides a discount or a Non-Rate Benefit on the purchase of tariffed DS1, DS3, and/or PBDS services,
restricts your ability to obtain UNEs, or negatively affects your ability to purchase Dedicated Services. If
so, identify each agreement, including the parties to the agreement, the effective date, end date, and a
summary of the relevant provisions.
G. Non-Providers, Non-Purchasers, and other entities not covered by the scope of this inquiry but
that were instructed to respond to this data collection must respond to the following:
II.G.1. If you must respond to this data collection because you were required to file the FCC Form 477 to
report the provision of “broadband connections to end user locations” for Year 2012 but are not (a) a
Provider or a Purchaser as defined in this data collection or (b) an entity that provides Best Efforts
Business Broadband Internet Access Services to15,000 or more customers or 1,500 or more business
broadband customers in areas where the ILEC is subject to price cap regulation, then indicate as such
below and complete the certification accompanying this data collection.
□ I am not a Provider.

□

I am not a Purchaser.

□ I do not provide Best Efforts Business Broadband Internet Access Services to15,000 or
more customers or 1,500 or more business broadband customers in areas where the ILEC is subject to
price cap regulation.
(select all that apply)

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CERTIFICATION
I have examined the response and certify that, to the best of my knowledge, all statements of fact,
data, and information contained therein are true and correct.
Signature: _________________________
Printed Name: ______________________
Title: _____________________________
Date: ____________
* Respondents are reminded that failure to comply with these data reporting requirements may subject
them to monetary forfeitures of up to $150,000 for each violation or each day of a continuing violation,
up to a maximum of $1,500,000 for any single act or failure to act that is a continuing violation.11 False
statements or misrepresentations to the Commission may be punishable by fine or imprisonment under
Title 18 of the U.S. Code.

11

47 U.S.C. § 503(b)(2); 47 C.F.R. § 1.80(b); Amendment of Section 1.80(b) of the Commission’s Rules, Adjustment
of Forfeiture Maxima to Reflect Inflation, Order, 23 FCC Rcd 9845 (2008).

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