The Regulatory Mix

The Regulatory Mix, TMI’s daily blog of regulatory activities, is a snapshot of PUC, FCC, legislative, and occasionally court, issues that our regulatory monitoring team uncovers each day. Depending on their significance, some items may be the subject of a TMI Regulatory Bulletin.






Lifeline Dispute Resolutions

USAC announced it adopted a Dispute Resolution Process for ETCs to use in instances where the National Lifeline Accountability Database (NLAD) rejects subscriber information. The document includes a series of codes to use for resolving instances where a subscriber fails for certain reasons including, but not limited to, the third party identification verification (TPIV) check. Significantly, the series of codes provided for resolving TPIV failures no longer includes the use of a utility bill. Therefore, ETCs must phase out the utility bill as a source of identity verification when disputing TPIV failures for the NLAD. As a result: (1) all enrollments after May 15, 2014 that use a utility bill to confirm identity ( resolve a TPIV failure) will be rejected; and (2) all TPIV dispute resolution ticket submitted to the NLAD after Friday, June 20, 2014 will be rejected if the ETC uses a utility bill to confirm a subscriber’s identity. USAC also announced a phase-out process for instances where the ETC intended to use or did use a utility bill to confirm identity prior to the removal of the utility bill from the list of USAC codes.


911 Reliability Workshop

The FCC announced its Public Safety and Homeland Security Bureau will hold a workshop on June 2, 2014, from 1:00 to 4:00 p.m. on the process for submitting annual certifications required under the FCC’s new 911 reliability rules. Individuals interested in attending must pre-register online at or by contacting Eric Schmidt at (202) 418-1214 or by email at The deadline for pre-registration is May 27, 2014. The event will be shown live at and those watching the live video stream of the event may email event-related questions to


The workshop will include a presentation from Bureau staff on the proposed development of the certification process, followed by a question-and-answer session. Questions include how each certification should be submitted, how certifying entities will indicate and explain alternative measures or claims of non-applicability, and how the FCC can maintain confidentiality of certification information presumed confidential under the rules. Bureau staff also will discuss the role of vendors and third-party service providers where 911 service is delivered over shared or interdependent infrastructure and seek input on how covered entities could indicate such relationships as part of their certifications. The discussion will be limited to the process by which covered entities will submit information required by the FCC’s rules and will not revisit the basis or need for those rules or interpret the certification requirements as they relate to specific entities.


The FCC’s 911 reliability rules only apply to entities that: (1) provide 911, E911, or NG911 capabilities such as call routing, automatic location information (ALI), automatic number identification (ANI), or the functional equivalent of those capabilities, directly to a PSAP, statewide default answering point, or appropriate local emergency authority; and/or (2) operate one or more central offices that directly serve a PSAP. The rules do not apply to entities that merely provide the capability for customers to originate 911 calls.




A new law in Indiana will limit the Indiana Utility Regulatory Commission’s authority over interconnection to the authority delegated to it by federal law. The law also: (1) repeals the provision authorizing the Commission to establish access line rates to be charged by ILECs to payphone providers; and (2) clarifies that eligible telecommunications carriers (ETCs) must assess both the statewide and prepaid wireless 911 charges to their eligible customers. TMI Regulatory Bulletin Service subscribers see Indiana Bulletin dated 4/28/14.

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