FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011 Page: 5,150
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Federal Communications Commission
Washington, D.C. 20554
April 7, 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 from the Universal Service Administrative Company (USAC)
for written guidance regarding the requirement, set forth in section 54.20 l(dX2) of the
Commission's rules,' regarding the scope of eligible telecommunications carriers (ETCs)
obligation to advertise services supported by federal universal service support mechanisms.
Specifically, USAC requested guidance regarding whether ETCs "are required to separately list
each [of the nine] supported service(s) enumerated in 47 C.F.R. 54.101,"3 when advertising the
availability of such services. The Wireline Competition Bureau sought comment on the question
posed in the USAC Letter.4 After consideration of the filed comments in this proceeding5 and
Commission precedent, this letter confirms that ETCs are not required to separately list each of
the enumerated supported services in their advertisements.6
47 C.F.R. 54.201(d)(2).
2 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 (filed Aug. 21, 2009) (USAC Letter).
I Id. There are currently nine such supported services enumerated in section 54.101: (1) voice grade access to the
public switched network: (2) local usage; (3) dual-tone multi-frequency signaling or its fictional equivalent; (4)
single-party service or its functional equivalent; (5) access to emergency services; (6) access to operator services;
(7) access to interexchange service; (8) access to directory assistance; and (9) toll limitation for qualifying low-
income consumers. See 47 C.F.R. 54.101(a).
4 See Comment Sought on Request for Universal Service Fund Policy Guidance Requested by the Universal
Service Administrative Company,; WC Docket Nos. 05-337. 06-122. CC Docket No. 96-45, Public Notice, 24 FCC
Recd 12093 (Wireline Comp. Bur. 2009).
5 No commenter suggested that the Commission's rules require ETCs to list separately each of the supported
services in their advertisements.
6 The Commission recently sought comment on modifying section 54.201(d)(2) in the context of comprehensive
universal service reform. See Connect America Fund, WC Docket No. 10-90, A National Broadband Plan for Our
Future, GN Docket No. 09-5 I, Establishing Just and Reasonable Rates for Local Exchange Carriers, WC Docket
No. 07-135, High-Cost Universal Service Support, WC Docket No. 05-337, Developing a Unified Intercarrier
Compensation Regime. CC Docket No. 01-92, Federal-State Joint Board on Universal Service, CC Docket No.
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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/m1/322/: accessed September 25, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.