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.






The FCC released a Public Notice reminding service providers and equipment manufacturers of their obligations under the FCC’s disability accessibility rules. By April 1, 2015, covered entities must complete, submit, and maintain the following three pieces of information in the “Recordkeeping Compliance Certification and Contact Information Registry” (RCCCI Registry):

  1. annual recordkeeping compliance certifications;
  2. current contact information for consumers; and
  3. current U.S. agent for service contact information.


The RCCCI Registry, a web-based system, is the sole means for filing annual recordkeeping compliance certifications and contact information, and for updating that contact information as needed. This is the same system that has been used since 2013. Failure to file a certification and failure to keep information current is a violation of the FCC’s rules and may subject the filer to forfeiture or other penalties. In addition, if an informal complaint is not served to the correct address, it could delay or prevent that applicable manufacturer or service provider from timely responding. Failure to respond to a complaint or order of the FCC may subject a party to sanctions or other penalties.



The FCC announced the selection of the Helen Keller National Center for Deaf-Blind Youth and Adults (HKNC) for certification to participate in the National Deaf-Blind Equipment Distribution Program (NDBEDP) for the state of Hawaii, effective March 3, 2015. The new selection was made because the entity currently serving Utah informed the FCC that it would be unable to continue to participate in the NDBEDP and would be relinquishing its certifications. See the Regulatory Mix dated 2/9/15.



The California Public Utilities Commission issued a PROPOSED Decision denying Google Fiber Inc.’s, petition to provide all state-franchised video service providers (VSPs) the right to access public utility infrastructure in accordance with the rates, terms, and conditions of the right-of-way rules (ROW Rules). The PUC said it lacks explicit statutory authority to (1) grant state-franchised VSPs the right to access public utility infrastructure and (2) promulgate and enforce safety regulations with respect to VSPs.

  • However, public utilities have authority under PU Code §767.7(a)(3) to enter into voluntary contracts with state-franchised VSPs for access to utility infrastructure. Contractual access to public utility infrastructure must comply with the PUC’s safety regulations pursuant to PU Code §768.5.
  • In addition, the PUC recognizes that some state-franchised VSPs may be classified as a “cable television corporation” as defined by PU Code §216.4. A cable television corporation may access public utility infrastructure in accordance with the ROW Rules and safety regulations.


Comments on the Proposed Decision are due March 12, 2015. It is expected that this issue will be included on the PUC’s March 26, 2015, Business Meeting agenda.



The Commission- assigned ALJ in the matter of the Qwest Corporation, dba CenturyLink QC, application to consolidate Sullivan, Aurora, and Brighton Rate Centers into the Denver Rate Center adopted a procedural schedule. In April parties will file testimony/attachments and rebuttals, prehearing motions and responses, and any stipulation and any settlement reached. An evidentiary hearing will take place on May 5, 2015, at 9:00 a.m. It will be followed by a hearing to take public comment at 4:00 p.m. Not later than May 12, 2015, each party will file its post-hearing statement of position. The Commission decision on the application is expected not later than August 19, 2015.



TMI’s Spring Telecom Regulatory Seminar & Workshop is scheduled April 30 & May 1, 2015, in Maitland, FL

     Among the topics to be explored are: 

  • VoIP: What is regulated and what is not
  • Best Practices for De-tariffing 
  • Step 4 in Access Reduction
  • Distinction between end office and transport
  • Special Access – what’s next?
  • IP Transition progress
  • Open Internet/Net Neutrality and Interconnection
  • Internet under Title II
  • Review of Telecom Regulatory Reports and Obligations for CLECs, VoIPs, OSPs, IXCs, and others (format & scheduling, too)
  • Form 499 Details and Developments
  • USF Exemption Certificates
  • Telecom Audits

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