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​ IUB Issues Order on Access Tariff Filings All LECs must File by June 1st

Friday, May 5, 2017   (0 Comments)
Posted by: Christine Mounts
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Special Report

May 4, 2017

 

IUB Issues Order on Access Tariff Filings
All LECs must File by June 1st

To implement the annual reduction of intrastate access charges mandated by the FCC’s 2011 Access Reform Order, all Rate-of-Return carriers must make filings to the IUB, USAC and FCC by June 1st.

The IUB Order released an “Order Regarding Intrastate Access Tariff Filings” on May 2nd that requires all LECs to make a filing with the IUB on or before June 1st to show compliance with the FCC’s intercarrier compensation rate step downs.

Those step downs require rate of return carriers to reduce their composite terminating end office access rates by July 1, 2017 to $0.0007 per minute plus two-thirds of any difference between the carrier’s 2016 target composite terminating end office access rate and $0.0007 per minute.Assuming your 2016 rate was $0.005, the 2017 we calculate the 2017 rate to be $0.003567. We urge carriers to verify their own rate calculations.

The requirements for what a LEC must file depend on whether it concurs in the ITA Intrastate Access Tariff (yes, it is still called the “ITA Tariff”).

1. LECs who Concur in the ITA Intrastate Access Tariff.

The Alliance made a filing on Thursday, May 4, 2017 to confirm that the ITA Intrastate Access Tariff is compliant with the requirements of the Federal Communications Commission’s November 2011 order concerning universal service and intercarrier compensation reform.

The ICA Tariff Compliance filing notifies the IUB that the ITA Access Tariff will automatically reflect the required changes once NECA files its revised tariff rates in June that will be effective July 1st.Click here to read it.

Therefore, LECs who concur in the ITA Access Tariff only need to file a letter advising the IUB that their own access tariff will be compliant via the ITA access tariff compliance.Here’s how to do that:

1. Filings must be made using the IUB’s EFS System.

2. The title of the filing must be named "FCC Compliance Filing – Intrastate Access Tariff" and any documents must carry the same name. The IUB will assign a TF docket number when it receives the filing.

3. Instead of filing revised tariff sheets, the concurring LEC should file a letter that indicates the name of the LEC or association in whose intrastate access tariff the LEC concurs. We have attached a sample IUB Tariff Compliance Filing form that you may wish to use. This is a template you can use and this is similar to the one we distributed last year. We understand that some companies will choose to have their consultants file this letter, and others may choose to file the letter on their own.

4. Though the IUB Order states that all LECs must provide “sufficient documentation or work papers” Alliance staff has confirmed with IUB staff that most LECs that concur in the ITA Tariff will not have additional work papers, and that the Alliance’s Compliance Filing gives adequate verification of the required reduction.

5. In the event a carrier considers any of the supporting documentation required for the tariff filings to be confidential, the carrier shall file both a public and a confidential version of the material using the Board's EFS according to Board rule 14.12, along with a request for confidential treatment pursuant to Board rule 1.9 and Iowa Code § 22.7.

2. LECs who do not Concur in the ITA Intrastate Access Tariff must comply with the following filing instructions:

  1. Filings must be made using the IUB’s EFS System.
  2. The title of the filing must be named "FCC Compliance Filing – Intrastate Access Tariff" and any documents must carry the same name. The IUB will assign a TF docket number when it receives the filing.
  3. The access tariff revision filings must be accompanied by sufficient documentation or work papers to allow the Board, OCA, and affected IXCs to verify that the required reductions have been made.
  4. There may be some LECs with intrastate access tariffs on file that already reflect the level of access rates required to be in effect by July 1. A LEC with an already-compliant intrastate access tariff must still make a filing with the Board, but the filing need not include revised tariff sheets. Instead, any LEC in this situation should file a letter explaining why its tariff is already compliant with the intended July 1 intrastate access tariff reductions.
  5. In the event a carrier considers any of the supporting documentation required for the tariff filings to be confidential, the carrier shall file both a public and a confidential version of the material using the Board's EFS according to Board rule 14.12, along with a request for confidential treatment pursuant to Board rule 1.9 and Iowa Code § 22.7.

Other Important Notes:

  1. A CLEC that benchmarks its rates to the access rates of a competing ILEC must still make a filing with the Board, but that filing should not include any revised tariff sheets. Instead, the benchmarking LEC should file a letter indicating the name of the competing ILEC whose rates the CLEC uses as a benchmark. A rural CLEC subject to the rural exemption that uses the NECA rates should file a letter indicating it uses the NECA benchmark.
  2. Effective November 18, 2015, the Board amended its rule at 199 IAC 22.14(2)(d)(1) to eliminate the three cents per minute carrier common line charge for terminating exchange access traffic.
  3. We urge all LECs to read the entirety of the IUB’s Order -- click here to read it.
  4. Questions about this informational order and the process for filing tariff revisions may be directed to Jim Langenberg, Senior Utility Analyst, Telecommunications Section at 515-725-7327 or jim.langenberg@iub.iowa.gov

(contact Dave Duncan for more information)


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