The_Mix_logo3.pngThe 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 Briefing.




The FCC issued a Public Notice concerning the public disclosure of analyses of the confidential and highly confidential data filed in response to its special access data collection (SADC- nka the business data services data collection). In response to recent public statements and various inquiries, the FCC is reminding parties that the results of any analyses (including statistical descriptions) performed on the confidential and highly confidential data submitted in response to the SADC are themselves confidential or highly confidential, as the case may be. Watch for our upcoming blog on this topic.

          IP Transition

The FCC has moved on to the next phase of the information collection review associated with the customer disclosure requirements of its new back up power rules. See our 8/6/15 Blog “FCC Adopts Rules for the IP Transition. TMI Briefing Service subscribers see Briefings dated 8/12/15 and 10/16/15. Comments on this phase are due February 24, 2016. The FCC received only one set of comments in response to its initial information collection notice. See the Regulatory Mix dated 11/9/15. The FCC has not changed its burden estimates, but has included, with its final PRA Supplemental Statement, an appendix containing a template that providers may use to disclose the required information to consumers. Interested parties may comment on this appendix. The FCC said that, once approved by OMB, the template can be used as a guideline for respondents to follow in complying with the new third party disclosure requirement of Section 12.5.


Several parties have filed comments in response to the Commission’s comments on a proposed revision of General Order 133, Section 4 which addresses Major Service Interruption Reporting obligations, including the FCC’s Network Outage Reporting System (NORS) reporting requirements. TMI Briefing Service subscribers see Briefing dated 1/6/16. As proposed, the revision would expand the applicability of the existing GO 133-C, Section 4 to cover (a) wireline and wireless resellers; and (b) VoIP Providers. Among other things, the parties argue that Public Utilities Code §§ 285 and 710 do not support imposing the major service interruption reporting requirement to VoIP Providers. Section 285 authorizes the PUC to impose the public purpose program surcharges to customers of VoIP Provides. Section 710 prohibits PUC regulation of VoIP or Internet Protocol-enabled services. Reply comments on the proposed changes to General Order 133-D are due February 12, 2016.


VoIP (Digital Phone) Requirements


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