FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011 Page: 5,034
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Federal Communications Commission
Washington, D.C. 20554
April 1, 2011
Richard A. Belden
Chief Operating Officer
Universal Service Administrative Company
2000 L St., N.W., Suite 200
Washington, DC 20036
Dear Mr. Belden:
This letter responds to a request by the Universal Service Administrative Company (USAC) for
written guidance regarding implementation of the interim caps on high-cost, competitive eligible
telecommunications carrier (competitive ETC) support for AT&T and ALLTEL, which were
adopted as conditions of their respective mergers in late 2007, several months before the
Commision adopted the interim cap for all competitive ETCs.' In this letter, we make clear that
USAC should implement the company-specific interim competitive ETC caps for the time period
from the consummation of each respective merger' until the industry-wide cap went into effect
on August 1, 2008.
When it approved the merger of ALLTEL Corporation and Atlantis Holdings LLC, the
Commission "impose[d] an interim cap on high-cost, competitive ETC support provided to
ALLTEL as a condition of this transaction," which, the Commission concluded, would "apply
until fundamental comprehensive reforms are adopted."' The Commission imposed a similar
interim cap on AT&T when it merged with Dobson Communications Corporation.4 Several
months later, the Commission adopted an industry-wide cap on high-cost support for all
competitive ETCs and noted in a footnote that "[t]he interim cap adopted in this Order
supersedes the interim caps on high-cost, competitive ETC support adopted in the ALLTEL-
Atlantis Order and the AT& T-Dobson Order."s
' Letter from Richard A. Belden, Chief Operating Officer. USAC, to Julie Veach, Acting Chief, Wireline
Competition Bureau, FCC, WC Docket Nos. 05-337, 06-122, at 5 (filed Aug. 24, 2009) (USAC Letter).
2 The AT&T-Dobson merger was consummated on November 15, 2007. See ULS File No 0003092368. The
ALLTEL-Atlantis Holdings merger was consummated on November 16, 2007. See ULS File No. 0003040113.
3See Applications of ALL TEL Corporation, Transferor, and Atlantis Holdings LLC, Transferee for Consent to
Transfer Control of Licenses. Leases and Authorizations, WT Docket No. 07-128, Memorandum Opinion and
Order, 22 FCC Rcd 19517, 19521, para. 9 (2007) (ALLTEL-Atlantis Order).
4 See Applications ofA T& T Inc. and Dobson Communications Corporation for Consent to Transfer Control of
Licenses andAu.thorizations, WT Docket No. 07-153, Memorandum Opinion and Order, 22 FCC Rcd 20295,
20329-30. paras. 71-72 (2007) (A T&T-Dobson Order).
5 High-Cost Universal Service Support; Federal-State Joint Board on Universal Service, WC Docket No. 05-337,
CC Docket No. 96-45, Order. 23 FCC Red 8834, 8837, para. 5 n.21 (2008) (Interim Cap Order).
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United States. Federal Communications Commission. FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011, book, April 2011; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc52169/m1/206/: accessed December 16, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.