FCC Special Access

On December 19, 2014, the Federal Communications Commission once again updated its Frequently Asked Questions (FAQs) about its Special Access Data Collection. See our blogs dated 10/21/14, 11/5/14, 11/17/14, 11/25/14, 12/9/14, and 12/15/14 . As before, the document does not indicate what changed. To assist our clients, we again compared the documents and identified the items below as “new.” We’ve included the name of the FAQ section that changed as well as the number of the specific new question(s).


As a reminder, the due dates are as follows:

  • January 29, 2015, for large businesses with more than 1,500 employees as measured at the parent company level; and
  • February 27, 2015, for other entities required to provide data and information in response to the data collection (i.e., entities with 1,500 or fewer employees).


The following are the new questions added December 19, 2014.


Who must respond to the collection?

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

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


10. A price cap conversion occurred in 2013. Am I required to file?

Most of the questions in the data collection ask for data, e.g., Locations with Connections and billing information, for calendar 2013, giving the FCC a snapshot in time. Since 2013, the FCC has granted one petition to convert three ILECs to price cap regulation. See 2014 CenturyLink Price Cap Conversion Order. The three ILECs are affiliates of CenturyLink – i.e., CenturyTel of Chester, Inc., CenturyTel of Potsville, Inc., and CenturyTel of the Midwest- Wisconsin (Wayside), and collectively have less than 6,000 access lines. With respect to these converted price cap areas, Providers and Purchasers are not required to respond to the collection.


Exemptions from Responding

5. Are resellers required to respond to the collection?

Resellers are not necessarily exempted from the collection. Pure resellers may have reporting obligations to respond to the Purchaser questions in section II.E and Competitive Provider Questions II.A.1-2. However, pure resellers that answer “no” to Questions II.A.2 and II.A.2a are not required to respond to the remaining section II.A questions or the section II.D questions.


Competitive Provider Questions (Section II.A)

11. Where do I upload information on interconnecting Nodes in the Special Access Web

Portal? (Question II.A.5)

You will provide locations of all Nodes used to interconnect with third party networks and the year each Node went live in the “Essay Upload” portion of the Special Access Web Portal, not in the Database Container.


13. Are monthly term discounts for a circuit separate line items in the tables for monthly

billing data for circuits by circuit element? (Question II.A.12)

If you have a separate line item for the monthly discount, you should report it as a separate line item. In that case, the Term_Discount_IC field would be “0” because you explicitly included a separate line for the discount. For example, assume the circuit base charge is $1000 and customer received a 40% term discount: Case 1: The provider could bill as two line items, with line 1 being the $1000, and line 2 being the -$400 (for a total of $600). In this case, the Provider should report both line items and leave the “Term_Discount_IC” variable as a “0”, because the discount was explicitly reported (rather than “rolled in” to the reported amount); Case 2: The Provider could simply bill the circuit as a single line item, with that line being $600 for the circuit. However, implicit in this charge is a term discount. In this case, the provider should report the $600 charge, but also report the “Term Discount_IC” variable as a “1”, since the discount has been applied to the circuit. See Instructions – Page 21-27.


Regulatory Briefing


Inteserra Local Filing Tracker


Switched Access Study