Universal Service Contribution Methodology; High-Cost Universal Service Support; IP-Enabled Services; Lifeline and Link Up; Developing a Unified Intercarrier Compensation Regime; Numbering Resource Optimization; Intercarrier Compensation for ISP-Bound Traffic; Implementation of the Local Competition Provisions in the Telecommunications Act of 1996; Federal-State Joint Board on Universal Service, 72732-72737 [E8-28464]
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Federal Register / Vol. 73, No. 231 / Monday, December 1, 2008 / Rules and Regulations
FEDERAL COMMUNICATIONS
COMMISSION
47 CFR Parts 51, 54, 61, and 69
[WC Docket Nos. 06–122, 05–337, 04–36,
03–109; CC Docket Nos. 01–92, 99–200, 99–
68, 96–98, 96–45; FCC 08–262]
Universal Service Contribution
Methodology; High-Cost Universal
Service Support; IP-Enabled Services;
Lifeline and Link Up; Developing a
Unified Intercarrier Compensation
Regime; Numbering Resource
Optimization; Intercarrier
Compensation for ISP-Bound Traffic;
Implementation of the Local
Competition Provisions in the
Telecommunications Act of 1996;
Federal-State Joint Board on Universal
Service
Federal Communications
Commission.
ACTION: Clarification.
AGENCY:
SUMMARY: In this document, the Federal
Communications Commission
(Commission) took two actions. First,
the Commission responded to a writ of
mandamus that would have vacated the
Commission’s rules governing
compensation for ISP-bound traffic had
the Commission not acted by November
5, 2008. Specifically, the Commission
held that although ISP-bound traffic
falls within the scope of section
251(b)(5) of the Communications Act,
this interstate, interexchange traffic is to
be afforded different treatment from
other section 251(b)(5) traffic pursuant
to our authority under section 201 and
251(i) of the Act. The Commission thus
maintained the $.0007 cap and the
mirroring rule. Second, the Commission
responded to the Comprehensive
Reform Recommended Decision of the
Federal-State Joint Board on Universal
Service (Joint Board). The Commission
is statutorily obligated to complete any
proceeding regarding subsequent
recommendations from the Joint Board
within one year. The Commission
thanked the Joint Board and its staff for
their hard work in studying these
difficult issues and in developing their
recommendations, but chose not to
implement these recommendations at
this time.
DATES: Effective Date: November 5,
2008.
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FOR FURTHER INFORMATION CONTACT:
Jennifer McKee, Telecommunications
Access Policy Division, Wireline
Competition Bureau, 202–418–7400 or
TTY: 202–418–0484 (universal service),
or Victoria Goldberg, Pricing Policy
Division, Wireline Competition Bureau,
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202–418–1520 or TTY 202–418–0484
(intercarrier compensation).
SUPPLEMENTARY INFORMATION: This is the
Commission’s Order on Remand and
Report and Order in WC Docket Nos.
06–122, 05–337, 04–36, 03–109; CC
Docket Nos. 01–92, 99–200, 99–68, 96–
98, 96–45, adopted on November 5,
2008 and released on November 5, 2008.
Copies of the Order on Remand and
Report and Order and Further Notice of
Proposed Rulemaking and any
subsequently filed documents in this
matter are or will be available on the
Commission’s Internet site at https://
www.fcc.gov and for public inspection
Monday through Thursday from 8 a.m.
to 4:30 p.m. and Friday from 8 a.m. to
11:30 a.m. at the FCC Reference
Information Center, Portals II, 445 12th
St., SW., Room CY–A257, Washington,
DC 20554. Copies of any such
documents may also be purchased from
the Commission’s copy contractor, Best
Copy and Printing, Inc. (BCPI), Portals
II, 445 12th St., SW., Room CY–B402,
Washington, DC 20554, telephone (202)
488–5300, facsimile (202) 488–5563,
TTY (202) 488–5672, e-mail
fcc@bcpiweb.com. Accessible formats
(computer diskettes, large print, audio
recording and Braille) are available to
persons with disabilities by contacting
the Consumer & Governmental Affairs
Bureau, at (202) 418–0531, TTY (202)
418–7365, or at fcc504@fcc.gov.
Order on Remand and Report and
Order
1. The actions we take in this order
respond to the writ of mandamus
granted by the United States Court of
Appeals for the District of Columbia
Circuit (DC Circuit) directing the
Commission to respond to its prior
remand of the Commission’s intercarrier
compensation rules for Internet Service
Provider (ISP)-bound traffic. As
discussed below, we conclude that we
have authority to impose ISP-bound
traffic rules.
A. Background
2. On February 26, 1999, the
Commission issued a Declaratory Ruling
and Notice of Proposed Rulemaking in
which it held that ISP-bound traffic is
jurisdictionally interstate because end
users access websites across state lines.
Because the Local Competition First
Report and Order concluded that the
reciprocal compensation obligation in
section 251(b)(5) applied only to local
traffic, the Commission found in the
Declaratory Ruling that ISP-bound
traffic is not subject to section 251(b)(5).
On March 24, 2000, in the Bell Atlantic
decision, the D.C. Circuit vacated
certain provisions of the Declaratory
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Ruling. The court did not question the
Commission’s finding that ISP-bound
traffic is interstate. Rather, the court
held that the Commission had not
adequately explained how its end-toend jurisdictional analysis was relevant
to determining whether a call to an ISP
is subject to reciprocal compensation
under section 251(b)(5). In particular,
the court noted that a LEC serving an
ISP appears to perform the function of
‘‘termination’’ because the LEC delivers
traffic from the calling party through its
end office switch to the called party, the
ISP.
3. On April 27, 2001, the Commission
released the ISP Remand Order, which
concluded that section 251(g) excludes
ISP-bound traffic from the scope of
Section 251(b)(5). The Commission
explained that section 251(g) maintains
the pre-1996 Act compensation
requirements for ‘‘exchange access,
information access, and exchange
services for such access,’’ thereby
excluding such traffic from the
reciprocal compensation requirements
that the 1996 Act imposed. The
Commission concluded that ISP-bound
traffic was ‘‘information access’’ and,
therefore, was subject instead to the
Commission’s section 201 jurisdiction
over interstate communications. The
Commission also found ‘‘convincing
evidence in the record’’ that carriers had
‘‘targeted ISPs as customers merely to
take advantage of * * * intercarrier
payments’’ (including offering free
service to ISPs, paying ISPs to be their
customers, and sometimes engaging in
outright fraud). It therefore adopted an
ISP payment regime in order to ‘‘limit,
if not end, the opportunity for
regulatory arbitrage.’’ The Commission
concluded that a bill-and-keep regime
might eliminate incentives for arbitrage
and force carriers to look to their own
customers for cost recovery. To avoid a
flash cut to bill-and-keep, however, the
Commission adopted a compensation
regime pending completion of the
Intercarrier Compensation proceeding.
Specifically, the regime adopted by the
Commission consisted of: (1) A
gradually declining cap on intercarrier
compensation for ISP-bound traffic,
beginning at $.0015 per minute-of-use
and declining to $.0007 per minute-ofuse; (2) a growth cap on total ISP-bound
minutes for which a LEC may receive
this compensation; (3) a ‘‘new markets
rule’’ requiring bill-and-keep for the
exchange of this traffic if two carriers
were not exchanging traffic pursuant to
an interconnection agreement prior to
the adoption of the regime; and (4) a
‘‘mirroring rule’’ that gave incumbent
LECs the benefit of the rate cap only if
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they offered to exchange all traffic
subject to Section 251(b)(5) at the same
rates. These rate caps reflected the
downward trend in intercarrier
compensation rates contained in thenrecently negotiated interconnection
agreements.
4. On May 3, 2002, the DC Circuit
found that the Commission had not
provided an adequate legal basis for the
rules it adopted in the ISP Remand
Order. Once again, the court did not
question the Commission’s finding that
ISP-bound traffic is jurisdictionally
interstate. Rather, the court held that
section 251(g) of the Act did not provide
a basis for the Commission’s decision.
The court held that section 251(g) is
simply a transitional device that
preserved obligations that predated the
1996 Act until the Commission adopts
superseding rules, and that there was no
pre-1996 Act obligation with respect to
intercarrier compensation for ISP-bound
traffic. Although the court rejected the
legal rationale for the compensation
rules, the court remanded, but did not
vacate, the ISP Remand Order to the
Commission, and it observed that ‘‘there
is plainly a non-trivial likelihood that
the Commission has authority’’ to adopt
the rules. Accordingly, the rules
adopted in the ISP Remand Order have
remained in effect.
5. On November 5, 2007, Core filed a
petition for writ of mandamus with the
DC Circuit seeking to compel the
Commission to enter an order resolving
the court’s remand in the WorldCom
decision. On July 8, 2008, the court
granted a writ of mandamus and
directed the Commission to respond to
the WorldCom remand in the form of a
final, appealable order which explains
its legal authority to issue the pricing
rules for ISP-bound traffic adopted in
the ISP Remand Order . The court
directed the Commission to respond to
the writ of mandamus by November 5,
2008.
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B. Discussion
6. In this order, we respond to the DC
Circuit’s remand order in WorldCom v.
FCC, and the court’s writ of mandamus
in Core Communications Inc.
Specifically, we hold that although ISPbound traffic falls within the scope of
section 251(b)(5), this interstate,
interexchange traffic is to be afforded
different treatment from other section
251(b)(5) traffic pursuant to our
authority under section 201 and 251(i)
of the Act.
1. Scope of Section 251(b)(5)
7. As an initial matter, we conclude
that the scope of Section 251(b)(5) is
broad enough to encompass ISP-bound
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traffic. To be sure, we acknowledge that,
in the Local Competition First Report
and Order, the Commission found that
section 251(b)(5) applies only to local
traffic, and some commenters continue
to press for such an interpretation. As
other commenters recognize, however,
the Commission, in the ISP Remand
Order, reconsidered that judgment and
concluded that it was a mistake to read
section 251(b)(5) as limited to local
traffic, given that ‘‘local’’ is not a term
used in section 251(b)(5). We recognize,
as the Supreme Court noted in AT&T
Corp. v. Iowa Utilities Board, that ‘‘[i]t
would be a gross understatement to say
that the 1996 Act is not a model of
clarity.’’ Nevertheless, we find that the
better view is that section 251(b)(5) is
not limited to local traffic.
8. We begin by looking at the text of
the statute. Section 251(b)(5) imposes on
all LECs the ‘‘duty to establish
reciprocal compensation arrangements
for the transport and termination of
telecommunications.’’ The Act broadly
defines ‘‘telecommunications’’ as ‘‘the
transmission, between or among points
specified by the user, of information of
the user’s choosing, without change in
the form or content of the information
as sent and received.’’ Its scope is not
limited geographically (‘‘local,’’
‘‘intrastate,’’ or ‘‘interstate’’) or to
particular services (‘‘telephone
exchange service,’’ telephone toll
service,’’ or ‘‘exchange access’’). We find
that the traffic we elect to bring within
this framework fits squarely within the
meaning of ‘‘telecommunications.’’ We
also observe that had Congress intended
to preclude the Commission from
bringing certain types of
telecommunications traffic within the
section 251(b)(5) framework, it could
have easily done so by incorporating
restrictive terms in section 251(b)(5).
Because Congress used the term
‘‘telecommunications,’’ the broadest of
the statute’s defined terms, we conclude
that section 251(b)(5) is not limited only
to the transport and termination of
certain types of telecommunications
traffic, such as local traffic.
9. In the Local Competition First
Report and Order the Commission
concluded that Section 251(b)(5) applies
only to local traffic, but recognized that
‘‘[u]ltimately * * * the rates that local
carriers impose for the transport and
termination of local traffic and for the
transport and termination of long
distance traffic should converge.’’ In the
ISP Remand Order, the Commission
reversed course on the scope of section
251(b)(5), finding that ‘‘the phrase ‘local
traffic’ created unnecessary ambiguities,
and we correct that mistake here.’’ The
ISP Remand Order noted that ‘‘the term
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‘local,’ not being a statutorily defined
category, * * * is not a term used in
section 251(b)(5).’’ The Commission
found that the scope of section 251(b)(5)
is limited only by section 251(g), which
temporarily grandfathered the pre-1996
Act rules governing ‘‘exchange access,
information access, and exchange
services for such access’’ provided to
interexchange carriers and information
service providers until ‘‘explicitly
superseded by regulations prescribed by
the Commission.’’ On appeal, the DC
Circuit left intact the Commission’s
findings concerning the scope of section
251(b)(5), although it took issue with
other aspects of the ISP Remand Order.
10. We disagree with commenters
who argue that section 251(b)(5) only
can be applied to traffic exchanged
between LECs, and not traffic exchanged
between a LEC and another carrier. The
Commission rejected that argument in
the Local Competition Order, finding
that section 251(b)(5) applies to traffic
exchanged by a LEC and any other
telecommunications carrier, and
adopted rules implementing that
finding. In a specific application of that
principle, the Commission concluded
that ‘‘CMRS providers will not be
classified as LECs,’’ but nevertheless
found that ‘‘LECs are obligated,
pursuant to section 251(b)(5) (and the
corresponding pricing standards of
section 252(d)(2)), to enter into
reciprocal compensation agreements
with all CMRS providers.’’ No one
challenged that finding on appeal, and
it has been settled law for the past 12
years. We see no reason to revisit that
conclusion now. While section 251(b)(5)
indisputably imposes the duty to
establish reciprocal compensation
arrangements on LECs alone, Congress
did not limit the class of potential
beneficiaries of that obligation to LECs.
11. We also disagree with commenters
who argue that section 252(d)(2)(A)(i)
limits the scope of section 251(b)(5).
Section 252(d)(2)(A)(i) provides that a
state commission ‘‘shall not consider
the terms and conditions for reciprocal
compensation to be just and reasonable’’
unless ‘‘such terms and conditions
provide for the mutual and reciprocal
recovery by each carrier of costs
associated with the transport and
termination on each carrier’s network
facilities of calls that originate on the
network facilities of the other carrier.’’
Verizon and others argue that this
provision necessarily excludes
interexchange traffic from the scope of
section 251(b)(5), because at the time
the 1996 Act was passed calls neither
originated nor terminated on an
interexchange carrier’s network. We
reject this reasoning because it
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erroneously assumes that Congress
intended the pricing standards in
section 252(d)(2) to limit the otherwise
broad scope of section 251(b)(5). We do
not believe that Congress intended the
tail to wag the dog.
12. Section 251(b)(5) defines the
scope of traffic that is subject to
reciprocal compensation. Section
252(d)(2)(A)(i), in turn, deals with the
mechanics of who owes what to whom,
it does not define the scope of traffic to
which Section 251(b)(5) applies. Section
252(d)(2)(A)(i) provides that, at a
minimum, a reciprocal compensation
arrangement must provide for the
recovery by each carrier of costs
associated with the transport and
termination on each carrier’s network of
calls that originate on the network of the
other carrier. Section 252(d)(2)(A)(i)
does not address what happens when
carriers exchange traffic that originates
or terminates on a third carrier’s
network. This does not mean, as
Verizon suggests, that Section 251(b)(5)
must be read as limited to traffic
involving only two carriers. Rather, it
means that there is a gap in the pricing
rules in Section 252(d)(2), and the
Commission has authority under section
201(b) to adopt rules to fill that gap.
13. We also reject Verizon’s argument
that a telecommunications carrier that
delivers traffic to an ISP is not eligible
for reciprocal compensation because the
carrier does not ‘‘terminate’’
telecommunications traffic at the ISP. In
the Local Competition Order, the
Commission defined ‘‘termination’’ as
‘‘the switching of traffic that is subject
to Section 251(b)(5) at the terminating
carrier’s end office switch * * * and
delivery of that traffic to the called
party’s premises.’’ As the DC Circuit
suggested in the Bell Atlantic decision,
‘‘Calls to ISPs appear to fit this
definition: The traffic is switched by the
LEC whose customer is the ISP and then
delivered to the ISP, which is clearly the
‘called party.’ ’’ We agree.
14. Verizon also argues that the
reference to reciprocal compensation in
the competitive checklist in section 271,
which was designed to ensure that local
markets are open to competition,
somehow shows that Congress intended
to limit the scope of section 251(b)(5) to
local traffic. We do not see how this
argument sheds any light on the scope
of section 251(b)(5). Congress no doubt
included the reference to reciprocal
compensation in section 271 because
section 251(b)(5) applies to local traffic,
a point that no one disputes. That does
not suggest, however, that section
251(b)(5) applies only to local traffic.
15. We need not respond to every
other variation of the argument that the
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history and structure of the Act
somehow demonstrate that section
251(b)(5) is limited to local traffic. At
best, these arguments show that one
plausible interpretation of the statute is
that section 251(b)(5) applies only to
local traffic, a view that the Commission
embraced in the Local Competition First
Report and Order. These arguments do
not persuade us, however, that this is
the only plausible reading of the statute.
Moreover, many of the same arguments
based on the history and context of the
adoption of section 251 to limit its
scope to local traffic were rejected by
the DC Circuit in the context of section
251(c). We find that the better reading
of the Act as a whole, in particular the
broad language of section 251(b)(5) and
the grandfather clause in section 251(g),
supports our view that the transport and
termination of all telecommunications
exchanged with LECs is subject to the
reciprocal compensation regime in
sections 251(b)(5) and 252(d)(2).
16. Notwithstanding section
251(b)(5)’s broad scope, we agree with
the finding in the ISP Remand Order
that traffic encompassed by section
251(g) is excluded from Section
251(b)(5) except to the extent that the
Commission acts to bring that traffic
within its scope. Section 251(g)
preserved the pre-1996 Act regulatory
regime that applies to access traffic,
including rules governing ‘‘receipt of
compensation.’’ Here, however, the DC
Circuit has held that ISP-bound traffic
did not fall within the section 251(g)
carve out from Section 251(b)(5) as
‘‘there had been no pre-Act obligation
relating to intercarrier compensation for
ISP-bound traffic.’’ As a result, we find
that ISP-bound traffic falls within the
scope of section 251(b)(5).
2. Authority Under Section 201
17. The section 251(b)(5) finding
above, however, does not end our legal
analysis here. That is because the ISPbound traffic at issue here is clearly
interstate in nature and thus also subject
to our section 201 authority. The
Commission unquestionably has
authority to regulate intercarrier
compensation with respect to interstate
access services, rates charged by CMRS
providers, and other traffic subject to
Commission authority such as ISPbound traffic. Section 2(a) of the Act
establishes the Commission’s
jurisdiction over interstate services, for
which the Commission ensures just,
reasonable, and not unjustly and
unreasonably discriminatory rates under
section 201 and 202. Likewise, the
Commission has authority over the rates
of CMRS providers pursuant to section
332 of the Act.
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18. In sections 251 and 252 of the Act,
Congress altered the traditional
regulatory framework based on
jurisdiction by expanding the
applicability of national rules to
historically intrastate issues and state
rules to historically interstate issues. In
the Local Competition First Report and
Order, the Commission found that the
1996 Act created parallel jurisdiction for
the Commission and the states over
interstate and intrastate matters under
sections 251 and 252. The Commission
and the states ‘‘are to address the same
matters through their parallel
jurisdiction over both interstate and
intrastate matters under Sections 251
and 252.’’ Moreover, section 251(i)
provides that ‘‘[n]othing in this section
shall be construed to limit or otherwise
affect the Commission’s authority under
section 201.’’ In the Local Competition
First Report and Order, the Commission
concluded that section 251(i) ‘‘affirms
that the Commission’s preexisting
authority under section 201 continues to
apply for purely interstate activities.’’
19. In implementing sections 251 and
252 in the Local Competition First
Report and Order, the Commission’s
treatment of LEC–CMRS traffic provides
an instructive example. Prior to the
1996 Act, the Commission expressly
preempted ‘‘state and local regulations
of the kind of interconnection to which
CMRS providers are entitled’’ based on
its authority under sections 201 and 332
of the Act. Nevertheless, in the Local
Competition First Report and Order, the
Commission brought LEC–CMRS
interconnection within the section 251
framework as it relates to intraMTA
(including interstate intraMTA) traffic.
The Commission recognized, however,
that it continued to retain separate
authority over CMRS traffic.
20. Courts confirmed that, in
permitting LEC–CMRS interconnection
to be addressed through the section 251
framework, the Commission did not in
any way lose its independent
jurisdiction or authority to regulate that
traffic under other provisions of the Act.
Thus, although the Eighth Circuit
invalidated the Commission’s TELRIC
pricing rules in general, it recognized
that ‘‘because section 332(c)(1)(B) gives
the FCC the authority to order LECs to
interconnect with CMRS carriers, we
believe that the Commission has the
authority to issue the rules of special
concern to the CMRS providers,
[including the reciprocal compensation
rules] but only as these provisions apply
to CMRS providers. Thus, [the pricing]
rules * * * remain in full force and
effect with respect to the CMRS
providers, and our order of vacation
does not apply to them in the CMRS
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context.’’ Subsequently, the DC Circuit
held that CMRS providers were entitled
to pursue formal complaints under
section 208 of the Act for violations of
the Commission’s reciprocal
compensation rules.
21. We build upon our actions in the
Local Competition First Report and
Order and find here that addressing ISPbound traffic through the section 251
framework does not diminish the
Commission’s independent jurisdiction
or authority to regulate traffic under
other provisions of the Act. Specifically,
we retain our authority under section
201 to regulate ISP-bound traffic,
despite acknowledging that such traffic
is section 251(b)(5) traffic. With respect
to interstate services, the Act has long
provided us with the authority to
establish just and reasonable ‘‘charges,
practices, classifications, and
regulations.’’ The Commission thus
retains full authority to regulate charges
for traffic and services subject to federal
jurisdiction, even when it is within the
sections 251(b)(5) and 252(d)(2)
framework. Because we re-affirm our
findings concerning the interstate nature
of ISP-bound traffic, which have not
been vacated by any court, it follows
that such traffic falls under the
Commission’s section 201 authority
preserved by the Act and that we
therefore have the authority to issue
pricing rules pursuant to that section.
This conclusion is reinforced by section
251(i) of the Act. As the Commission
explained in the ISP Remand Order,
section 251(i) ‘‘expressly affirms the
Commission’s role in an evolving
telecommunications marketplace, in
which Congress anticipates that the
Commission will continue to develop
appropriate pricing and compensation
mechanisms for traffic that falls within
the purview of section 201.’’ It
concluded that section 251(i), together
with section 201, equips the
Commission with the tools necessary to
keep pace with regulatory developments
and new technologies. When read
together, these statutory sections
preserve the Commission’s authority to
address new issues that fall within its
section 201 authority over interstate
traffic, including compensation for the
exchange of ISP-bound traffic.
Consequently, in the ISP Remand Order,
the Commission properly exercised its
authority under section 201(b) to issue
pricing rules governing the payment of
compensation between carriers for ISPbound traffic.
22. Our result today is consistent with
the DC Circuit’s opinion in Bell
Atlantic, which concluded that the
jurisdictional nature of traffic is not
dispositive of whether reciprocal
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compensation is owed under section
251(b)(5). It is also consistent with the
DC Circuit’s WorldCom decision, in
which the court rejected the
Commission’s view that section 251(g)
excluded ISP-bound traffic from the
scope of section 251(b)(5), but made no
other findings. Finally, this result does
not run afoul of the Eighth Circuit’s
decision on remand from the Supreme
Court in the Iowa Utilities Board
litigation, which held that ‘‘the FCC
does not have the authority to set the
actual prices for the state commissions
to use’’ under section 251(b)(5). At the
time of that decision, under the Local
Competition First Report and Order,
section 251(b)(5) applied only to local
traffic. Thus, the Eighth Circuit merely
held that the Commission could not set
reciprocal compensation rates for local
traffic. The court did not address the
Commission’s authority to set reciprocal
compensation rates for interstate traffic.
In sum, the Commission plainly has
authority to establish pricing rules for
interstate traffic, including ISP-bound
traffic, under section 201(b), and that
authority was preserved by section
251(i).
3. Other Issues
23. Most commenters urge the
Commission to maintain the
compensation rules governing ISPbound traffic until the Commission is
able to complete comprehensive
intercarrier compensation reform. These
parties contend that a higher
compensation rate would create new
opportunities for arbitrage and impose
substantial financial burdens on
wireless companies, incumbent LECs
and state public utility commissions.
They further claim that the existing
regime has simplified interconnection
negotiations.
24. In the ISP Remand Order, the
Commission found that the one-way
nature of ISP-bound traffic creates
significant arbitrage opportunities. Due
to the unbalanced nature of ISP-bound
traffic, the Commission observed that
reciprocal compensation arrangements
created enormous incentives for
competitive LECs to sign up ISPs as
customers. The Commission cited
evidence that competitive LECs, on
average, terminated eighteen times more
traffic than they originated, resulting in
annual CLEC reciprocal compensation
billings of approximately two billion
dollars, 90 percent of which was for ISPbound traffic. The Commission
concluded that ‘‘the record strongly
suggests that CLECs target ISPs in large
part because of the availability of
reciprocal compensation payments.’’
This undermined the operation of
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72735
competitive markets because
competitive LECs were able to recover a
disproportionate share of their costs
from other carriers. To limit arbitrage
opportunities that arose from
‘‘excessively high reciprocal
compensation rates,’’ the Commission
adopted a gradually declining cap on
intercarrier compensation for ISP-bound
traffic, beginning at $.0015 per minute
of use and declining to $.0007 per
minute of use, the current cap. The
Commission derived the rate caps from
contemporaneous interconnection
agreements, in which carriers
voluntarily agreed to rates comparable
to the rate caps adopted by the
Commission. The interconnection
agreements included lower rates for
unbalanced traffic than for balanced
traffic, and the rates declined over time,
like the rate caps. Although the
Commission made no specific findings
with regard to the actual costs
associated with delivering traffic to
ISPs, it noted evidence in the record
that technological advances were
reducing the costs incurred by carriers
when handling all forms of traffic. The
Commission also noted that ‘‘negotiated
reciprocal compensation rates continue
to decline as ILECs and CLECs negotiate
new agreements.’’
25. On July 14, 2003, Core
Communications, Inc. (‘‘Core’’) filed a
petition pursuant to Section 10 of the
Communications Act requesting that the
Commission forbear from enforcing the
rate caps and certain other provisions
set forth in the ISP Remand Order with
respect to the exchange of ISP-bound
traffic between telecommunications
carriers. In 2004, the Commission
denied the petition with respect to rate
caps and the mirroring rule,
determining that Core had satisfied
none of the three prongs of the statutory
test for forbearance. First, the
Commission found that forbearance
from enforcement of the rate caps was
not consistent with the public interest.
To the contrary, the Commission
concluded that rate caps remained
necessary to prevent regulatory arbitrage
and to promote efficient investment in
telecommunications services and
facilities. Second, the Commission
found limited potential for
discrimination under the rate caps. The
caps applied to ISP-bound traffic only to
the extent that an incumbent carrier
offered to exchange all traffic at the
same rate under section 251(b)(5).
Accordingly, the Commission
concluded that Core had not proven that
the rate caps resulted in impermissible
discrimination against or between
competitive carriers or services. Finally,
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the Commission found that Core had not
demonstrated that enforcement of the
rate caps was not necessary for the
protection of consumers. Core advanced
speculative general claims that the caps
caused artificially high rates, had forced
competitive carriers from the market,
and had deterred investment in
telecommunications services, all to
consumers’ detriment. The Commission
rejected these unsupported claims,
explaining that the rate caps were
designed to prevent the subsidization of
dial-up Internet access customers at the
expense of consumers of basic
telephone service and to avoid
regulatory arbitrage and discrimination
between services. For these reasons, the
Commission denied Core’s petition for
forbearance insofar as rate caps were
concerned.
26. In 2006, the DC Circuit affirmed
our decision not to forbear from the rate
cap (and the mirroring rule). The Court
found reasonable the Commission’s
‘‘view that the rate caps are necessary to
prevent the subsidization of dial-up
Internet access consumers by consumers
of basic telephone service’’ that would
occur if reciprocal compensation rates
applied to one-way ISP-bound traffic.
The Court likewise rejected Core’s
contention that the rate cap was
‘‘unreasonably discriminatory,’’ both
because one-way ISP-bound calls were
fundamentally different from other
forms of traffic and because the
mirroring rule ensures that ‘‘‘the caps
apply to ISP-bound traffic only if an
incumbent LEC offers to exchange all
section 251(b)(5) traffic at the same
rate.’’’ Finally, the Court concluded that
the Commission’s concern that the rate
cap was necessary to prevent
‘‘‘regulatory arbitrage’ and ‘distorted
economic incentives’’’ was reasonable.
27. The policy justifications provided
by the Commission in 2001 for the rules
at issue here have not been questioned
by any court. In addition, the policy
justifications provided by the
Commission for refusing to forbear from
enforcement of these rules were upheld
by the DC Circuit in 2006. We therefore
disagree with parties who suggest that
the Commission, in responding to the
DC Circuit’s remand in WorldCom, must
offer detailed new justifications for the
ISP intercarrier payment regime; we
have already offered our justifications
for that regime. Moreover, both the
WorldCom remand and Core writ of
mandamus focused on the issue of legal
authority. We also reject arguments that
the Commission unlawfully delegated
its authority in the ISP Remand Order
and arguments that the Commission
addressed previously in the Core
Forbearance Order.
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28. The Commission long has stated
its intention to move to a more unified
intercarrier compensation regime.
Progress is difficult due to competing
priorities, such as competition,
innovation, universal service, and other
goals. The Commission recognized in
2001 that ISP-bound traffic represented
a unique arbitrage problem that required
immediate attention, based on the
policy concerns discussed above. The
Commission remains committed to
moving towards a more unified
intercarrier compensation regime, as
evidenced by the Further Notice issued
in conjunction with this order.
29. In sum, we maintain the $.0007
cap and the mirroring rule pursuant to
our Section 201 authority. These rules
shall remain in place until we adopt
more comprehensive intercarrier
compensation reform.
II. Report and Order—Reform of HighCost Universal Service Support
30. In this report and order, we
address the ‘‘Recommended Decision’’
of the Federal-State Joint Board on
Universal Service (Joint Board), which
was released on November 20, 2007. As
discussed below, we appreciate the
great efforts expended by the Joint
Board and its staff in considering how
best to reform the current high-cost
support mechanism and in developing
its recommendations. We choose not to
implement the recommendations
contained in the Comprehensive Reform
Recommended Decision at this time,
however.
A. Background
31. The 1996 Act amended the
Communications Act of 1934 with
respect to the provision of universal
service. In the 1996 Act, Congress
sought to preserve and advance
universal service, while at the same
time opening all telecommunications
markets to competition. Section 254(b)
of the Act directs the Joint Board and
the Commission to base policies for the
preservation and advancement of
universal service on several general
principles, plus other principles that the
Commission may establish. Among
other things, section 254(b) directs that
there should be specific, predictable,
and sufficient federal and state
universal service support mechanisms;
quality services should be available at
just, reasonable, and affordable rates;
and access to advanced
telecommunications and information
services should be provided in all
regions of the nation.
32. The Commission implemented the
universal service provisions of the 1996
Act in the 1997 Universal Service First
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Report and Order. Among other things,
the Commission adopted rules to create
explicit universal service support
mechanisms for customers living in
rural and high-cost areas. Pursuant to
section 254(e) of the Act, an entity must
be designated as an eligible
telecommunications carrier (ETC) to
receive high-cost universal service
support. ETCs may be incumbent LECs,
or non-incumbent LECs, which are
referred to as ‘‘competitive ETCs.’’
Under the existing high-cost support
distribution mechanism, incumbent LEC
ETCs receive high-cost support for their
intrastate services based on their costs.
Competitive ETCs receive support for
each line based on the support the
incumbent LEC would receive for that
line in the service area. This support to
competitive ETCs is known as
‘‘identical support.’’ The Commission’s
universal service high-cost support rules
do not distinguish between primary and
secondary lines; therefore, high-cost
support may go to a single end user for
multiple connections. Further, the
Commission’s rules result in subsidizing
multiple competitors in the same highcost area.
33. High-cost support for competitive
ETCs has grown rapidly over the last
several years, placing extraordinary
pressure on the federal universal service
fund. In 2001, high-cost universal
service support totaled approximately
$2.6 billion. By 2007, the amount of
high-cost support had grown to
approximately $4.3 billion per year. In
recent years, this growth has been due
mostly to increased support provided to
competitive ETCs, which receive highcost support based on the per-line
support that the incumbent LECs
receive pursuant to the identical
support rule. Competitive ETC support,
in the six years from 2001 through 2007,
has grown from under $17 million to
$1.18 billion—an annual growth rate of
over 100 percent. This ‘‘funded
competition’’ has grown significantly in
a large number of rural, insular, or highcost areas; in some study areas more
than 20 competitive ETCs currently
receive support.
34. To address the growth in
competitive ETC support, the Joint
Board recommended an interim cap on
the amount of high-cost support
available to competitive ETCs, pending
comprehensive high-cost universal
service reform. The Commission
adopted this recommendation on May 1,
2008.
35. For the past several years, the
Joint Board and the Commission have
been exploring ways to reform the
Commission’s high-cost program. In the
most recent high-cost support
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comprehensive reform efforts, the Joint
Board issued a recommended decision
on November 20, 2007. The Universal
Service Joint Board’s recommended
decision included several
recommendations to address the growth
in high-cost support and to reform the
high-cost mechanisms. Specifically, the
Universal Service Joint Board
recommended that the Commission
should: (1) Deliver high-cost support
through a provider of last resort fund, a
mobility fund, and a broadband fund;
(2) cap the high-cost fund at $4.5
billion, the approximate level of 2007
high-cost support; (3) reduce the
existing funding mechanisms during a
transition period; (4) add broadband and
mobility to the list of services eligible
for support under section 254 of the Act;
(5) eliminate the identical support rule;
and (6) ‘‘explore the most appropriate
auction mechanisms to determine highcost universal service support.’’
36. On January 29, 2008, the
Commission released the Joint Board
Comprehensive Reform NPRM, seeking
comment on the Joint Board’s
Comprehensive Reform Recommended
Decision. Pursuant to section 254(a)(2),
the Commission ‘‘shall complete any
proceeding to implement subsequent
recommendations from any Joint Board
on universal service within one year
after receiving such recommendations.’’
37. We have carefully reviewed the
Joint Board’s Comprehensive Reform
Recommended Decision and the
comments that were filed in response to
the Commission’s Joint Board
Comprehensive Reform NPRM. We
thank the Joint Board and its staff for
their hard work in studying these
difficult issues and in developing their
recommendations. We choose not to
implement these recommendations at
this time, however.
Federal Communications Commission.
Marlene H. Dortch,
Secretary.
[FR Doc. E8–28464 Filed 11–28–08; 8:45 am]
BILLING CODE 6712–01–P
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DEPARTMENT OF TRANSPORTATION
DEPARTMENT OF COMMERCE
Pipeline and Hazardous Materials
Safety Administration
National Oceanic and Atmospheric
Administration
49 CFR Part 192
50 CFR Part 300
[Docket No. PHMSA–2005–23447]
[Docket No. 071203794–81464–02]
RIN 2137–AE25
RIN 0648–AW36
Pipeline Safety: Standards for
Increasing the Maximum Allowable
Operating Pressure for Gas
Transmission Pipelines
Pacific Halibut Fisheries; Subsistence
Fishing
Pipeline and Hazardous
Materials Safety Administration
(PHMSA), Department of Transportation
(DOT)
ACTION: Stay of final rule.
AGENCY:
SUMMARY: This Notice stays the effective
date of a final rule published October
17, 2008 (73 FR 62148). In accordance
with the Congressional Review Act, the
final rule will be effective on December
22, 2008, 60 days after the final rule was
transmitted to Congress .
DATES: Effective December 1, 2008
§§ 192.112, 192.328, 192.611(a)(1);
192.611(a)(3)(i), (ii) and (iii); 192.619(a)
and (d); and 192.620 are stayed until
December 22, 2008.
FOR FURTHER INFORMATION CONTACT:
Alan Mayberry by phone at (202) 366–
5124, or by e-mail at
alan.mayberry@dot.gov.
SUPPLEMENTARY INFORMATION:
B. Discussion
I. Supplementary Background
On October 17, 2008 PHMSA issued
a final rule under Docket No. PHMSA–
2005–23447 amending the Pipeline
Safety Regulations (PSR; 49 CFR parts
190–199) to increase the regulatory
maximum allowable operating pressure
(MAOP) for certain gas transmission
pipelines. The October 17, 2008 Federal
Resister notice announced that the final
rule would be effective November 17,
2008, thirty days after its publication.
Because the final rule is a major rule
within the meaning of the Congressional
Review Act, however, its effective date
must be delayed until 60 days after
publication in the Federal Register or
transmission to Congress, whichever is
later. The final rule was transmitted to
Congress on October 22, 2008.
Accordingly, we are staying its effective
date until December 22, 2008.
Issued in Washington, DC, on November
24, 2008 under authority delegated in 49 CFR
part 1.
Carl T. Johnson,
Administrator.
[FR Doc. E8–28435 Filed 11–28–08; 8:45 am]
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National Marine Fisheries
Service (NMFS), National Oceanic and
Atmospheric Administration (NOAA),
Commerce.
ACTION: Final rule.
AGENCY:
SUMMARY: NMFS issues a final rule to
amend the subsistence fishery rules for
members of an Alaska Native tribe
eligible to harvest Pacific halibut in
waters in and off Alaska for customary
and traditional use. The action correctly
defines the location of Village of
Kanatak tribal headquarters and
International Pacific Halibut
Commission (IPHC) halibut regulatory
area (Area) in which the tribe’s members
may subsistence fish. The action would
change the tribe’s headquarters from
Egegik to Wasilla and the corresponding
Area from 4E to Area 3A. The intent of
this action is to remove restrictions on
participation of Village of Kanatak tribal
members in traditional subsistence
fisheries for Pacific halibut by correcting
the tribe’s headquarters to its actual
location in Wasilla.
DATES: Effective December 31, 2008.
ADDRESSES: Copies of the Categorical
Exclusion and Regulatory Impact
Review prepared for this action, as well
as the environmental assessment
prepared for the original subsistence
halibut action are available by mail from
NMFS, Alaska Region, P.O. Box 21668,
Juneau, AK 99802–1668, Attn: Ellen
Sebastian, Records Officer; in person at
NMFS, Alaska Region, 709 West 9th
Street, Room 420A, Juneau, Alaska; and
via the Internet at the NMFS Alaska
Region website at https://
alaskafisheries.noaa.gov.
FOR FURTHER INFORMATION CONTACT:
Peggy Murphy, 907–586–7843.
SUPPLEMENTARY INFORMATION: The
United States and Canada participate in
the International Pacific Halibut
Commission (IPHC) and promulgate
regulations governing the Pacific halibut
(Hippoglossus stenolepis) fishery under
the authority of the Northern Pacific
Halibut Act of 1982 (Halibut Act).
Regulations governing the allocation
and catch of halibut in U.S. convention
waters that are in agreement with the
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Agencies
[Federal Register Volume 73, Number 231 (Monday, December 1, 2008)]
[Rules and Regulations]
[Pages 72732-72737]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-28464]
[[Page 72732]]
=======================================================================
-----------------------------------------------------------------------
FEDERAL COMMUNICATIONS COMMISSION
47 CFR Parts 51, 54, 61, and 69
[WC Docket Nos. 06-122, 05-337, 04-36, 03-109; CC Docket Nos. 01-92,
99-200, 99-68, 96-98, 96-45; FCC 08-262]
Universal Service Contribution Methodology; High-Cost Universal
Service Support; IP-Enabled Services; Lifeline and Link Up; Developing
a Unified Intercarrier Compensation Regime; Numbering Resource
Optimization; Intercarrier Compensation for ISP-Bound Traffic;
Implementation of the Local Competition Provisions in the
Telecommunications Act of 1996; Federal-State Joint Board on Universal
Service
AGENCY: Federal Communications Commission.
ACTION: Clarification.
-----------------------------------------------------------------------
SUMMARY: In this document, the Federal Communications Commission
(Commission) took two actions. First, the Commission responded to a
writ of mandamus that would have vacated the Commission's rules
governing compensation for ISP-bound traffic had the Commission not
acted by November 5, 2008. Specifically, the Commission held that
although ISP-bound traffic falls within the scope of section 251(b)(5)
of the Communications Act, this interstate, interexchange traffic is to
be afforded different treatment from other section 251(b)(5) traffic
pursuant to our authority under section 201 and 251(i) of the Act. The
Commission thus maintained the $.0007 cap and the mirroring rule.
Second, the Commission responded to the Comprehensive Reform
Recommended Decision of the Federal-State Joint Board on Universal
Service (Joint Board). The Commission is statutorily obligated to
complete any proceeding regarding subsequent recommendations from the
Joint Board within one year. The Commission thanked the Joint Board and
its staff for their hard work in studying these difficult issues and in
developing their recommendations, but chose not to implement these
recommendations at this time.
DATES: Effective Date: November 5, 2008.
FOR FURTHER INFORMATION CONTACT: Jennifer McKee, Telecommunications
Access Policy Division, Wireline Competition Bureau, 202-418-7400 or
TTY: 202-418-0484 (universal service), or Victoria Goldberg, Pricing
Policy Division, Wireline Competition Bureau, 202-418-1520 or TTY 202-
418-0484 (intercarrier compensation).
SUPPLEMENTARY INFORMATION: This is the Commission's Order on Remand and
Report and Order in WC Docket Nos. 06-122, 05-337, 04-36, 03-109; CC
Docket Nos. 01-92, 99-200, 99-68, 96-98, 96-45, adopted on November 5,
2008 and released on November 5, 2008. Copies of the Order on Remand
and Report and Order and Further Notice of Proposed Rulemaking and any
subsequently filed documents in this matter are or will be available on
the Commission's Internet site at https://www.fcc.gov and for public
inspection Monday through Thursday from 8 a.m. to 4:30 p.m. and Friday
from 8 a.m. to 11:30 a.m. at the FCC Reference Information Center,
Portals II, 445 12th St., SW., Room CY-A257, Washington, DC 20554.
Copies of any such documents may also be purchased from the
Commission's copy contractor, Best Copy and Printing, Inc. (BCPI),
Portals II, 445 12th St., SW., Room CY-B402, Washington, DC 20554,
telephone (202) 488-5300, facsimile (202) 488-5563, TTY (202) 488-5672,
e-mail fcc@bcpiweb.com. Accessible formats (computer diskettes, large
print, audio recording and Braille) are available to persons with
disabilities by contacting the Consumer & Governmental Affairs Bureau,
at (202) 418-0531, TTY (202) 418-7365, or at fcc504@fcc.gov.
Order on Remand and Report and Order
1. The actions we take in this order respond to the writ of
mandamus granted by the United States Court of Appeals for the District
of Columbia Circuit (DC Circuit) directing the Commission to respond to
its prior remand of the Commission's intercarrier compensation rules
for Internet Service Provider (ISP)-bound traffic. As discussed below,
we conclude that we have authority to impose ISP-bound traffic rules.
A. Background
2. On February 26, 1999, the Commission issued a Declaratory Ruling
and Notice of Proposed Rulemaking in which it held that ISP-bound
traffic is jurisdictionally interstate because end users access
websites across state lines. Because the Local Competition First Report
and Order concluded that the reciprocal compensation obligation in
section 251(b)(5) applied only to local traffic, the Commission found
in the Declaratory Ruling that ISP-bound traffic is not subject to
section 251(b)(5). On March 24, 2000, in the Bell Atlantic decision,
the D.C. Circuit vacated certain provisions of the Declaratory Ruling.
The court did not question the Commission's finding that ISP-bound
traffic is interstate. Rather, the court held that the Commission had
not adequately explained how its end-to-end jurisdictional analysis was
relevant to determining whether a call to an ISP is subject to
reciprocal compensation under section 251(b)(5). In particular, the
court noted that a LEC serving an ISP appears to perform the function
of ``termination'' because the LEC delivers traffic from the calling
party through its end office switch to the called party, the ISP.
3. On April 27, 2001, the Commission released the ISP Remand Order,
which concluded that section 251(g) excludes ISP-bound traffic from the
scope of Section 251(b)(5). The Commission explained that section
251(g) maintains the pre-1996 Act compensation requirements for
``exchange access, information access, and exchange services for such
access,'' thereby excluding such traffic from the reciprocal
compensation requirements that the 1996 Act imposed. The Commission
concluded that ISP-bound traffic was ``information access'' and,
therefore, was subject instead to the Commission's section 201
jurisdiction over interstate communications. The Commission also found
``convincing evidence in the record'' that carriers had ``targeted ISPs
as customers merely to take advantage of * * * intercarrier payments''
(including offering free service to ISPs, paying ISPs to be their
customers, and sometimes engaging in outright fraud). It therefore
adopted an ISP payment regime in order to ``limit, if not end, the
opportunity for regulatory arbitrage.'' The Commission concluded that a
bill-and-keep regime might eliminate incentives for arbitrage and force
carriers to look to their own customers for cost recovery. To avoid a
flash cut to bill-and-keep, however, the Commission adopted a
compensation regime pending completion of the Intercarrier Compensation
proceeding. Specifically, the regime adopted by the Commission
consisted of: (1) A gradually declining cap on intercarrier
compensation for ISP-bound traffic, beginning at $.0015 per minute-of-
use and declining to $.0007 per minute-of-use; (2) a growth cap on
total ISP-bound minutes for which a LEC may receive this compensation;
(3) a ``new markets rule'' requiring bill-and-keep for the exchange of
this traffic if two carriers were not exchanging traffic pursuant to an
interconnection agreement prior to the adoption of the regime; and (4)
a ``mirroring rule'' that gave incumbent LECs the benefit of the rate
cap only if
[[Page 72733]]
they offered to exchange all traffic subject to Section 251(b)(5) at
the same rates. These rate caps reflected the downward trend in
intercarrier compensation rates contained in then-recently negotiated
interconnection agreements.
4. On May 3, 2002, the DC Circuit found that the Commission had not
provided an adequate legal basis for the rules it adopted in the ISP
Remand Order. Once again, the court did not question the Commission's
finding that ISP-bound traffic is jurisdictionally interstate. Rather,
the court held that section 251(g) of the Act did not provide a basis
for the Commission's decision. The court held that section 251(g) is
simply a transitional device that preserved obligations that predated
the 1996 Act until the Commission adopts superseding rules, and that
there was no pre-1996 Act obligation with respect to intercarrier
compensation for ISP-bound traffic. Although the court rejected the
legal rationale for the compensation rules, the court remanded, but did
not vacate, the ISP Remand Order to the Commission, and it observed
that ``there is plainly a non-trivial likelihood that the Commission
has authority'' to adopt the rules. Accordingly, the rules adopted in
the ISP Remand Order have remained in effect.
5. On November 5, 2007, Core filed a petition for writ of mandamus
with the DC Circuit seeking to compel the Commission to enter an order
resolving the court's remand in the WorldCom decision. On July 8, 2008,
the court granted a writ of mandamus and directed the Commission to
respond to the WorldCom remand in the form of a final, appealable order
which explains its legal authority to issue the pricing rules for ISP-
bound traffic adopted in the ISP Remand Order . The court directed the
Commission to respond to the writ of mandamus by November 5, 2008.
B. Discussion
6. In this order, we respond to the DC Circuit's remand order in
WorldCom v. FCC, and the court's writ of mandamus in Core
Communications Inc. Specifically, we hold that although ISP-bound
traffic falls within the scope of section 251(b)(5), this interstate,
interexchange traffic is to be afforded different treatment from other
section 251(b)(5) traffic pursuant to our authority under section 201
and 251(i) of the Act.
1. Scope of Section 251(b)(5)
7. As an initial matter, we conclude that the scope of Section
251(b)(5) is broad enough to encompass ISP-bound traffic. To be sure,
we acknowledge that, in the Local Competition First Report and Order,
the Commission found that section 251(b)(5) applies only to local
traffic, and some commenters continue to press for such an
interpretation. As other commenters recognize, however, the Commission,
in the ISP Remand Order, reconsidered that judgment and concluded that
it was a mistake to read section 251(b)(5) as limited to local traffic,
given that ``local'' is not a term used in section 251(b)(5). We
recognize, as the Supreme Court noted in AT&T Corp. v. Iowa Utilities
Board, that ``[i]t would be a gross understatement to say that the 1996
Act is not a model of clarity.'' Nevertheless, we find that the better
view is that section 251(b)(5) is not limited to local traffic.
8. We begin by looking at the text of the statute. Section
251(b)(5) imposes on all LECs the ``duty to establish reciprocal
compensation arrangements for the transport and termination of
telecommunications.'' The Act broadly defines ``telecommunications'' as
``the transmission, between or among points specified by the user, of
information of the user's choosing, without change in the form or
content of the information as sent and received.'' Its scope is not
limited geographically (``local,'' ``intrastate,'' or ``interstate'')
or to particular services (``telephone exchange service,'' telephone
toll service,'' or ``exchange access''). We find that the traffic we
elect to bring within this framework fits squarely within the meaning
of ``telecommunications.'' We also observe that had Congress intended
to preclude the Commission from bringing certain types of
telecommunications traffic within the section 251(b)(5) framework, it
could have easily done so by incorporating restrictive terms in section
251(b)(5). Because Congress used the term ``telecommunications,'' the
broadest of the statute's defined terms, we conclude that section
251(b)(5) is not limited only to the transport and termination of
certain types of telecommunications traffic, such as local traffic.
9. In the Local Competition First Report and Order the Commission
concluded that Section 251(b)(5) applies only to local traffic, but
recognized that ``[u]ltimately * * * the rates that local carriers
impose for the transport and termination of local traffic and for the
transport and termination of long distance traffic should converge.''
In the ISP Remand Order, the Commission reversed course on the scope of
section 251(b)(5), finding that ``the phrase `local traffic' created
unnecessary ambiguities, and we correct that mistake here.'' The ISP
Remand Order noted that ``the term `local,' not being a statutorily
defined category, * * * is not a term used in section 251(b)(5).'' The
Commission found that the scope of section 251(b)(5) is limited only by
section 251(g), which temporarily grandfathered the pre-1996 Act rules
governing ``exchange access, information access, and exchange services
for such access'' provided to interexchange carriers and information
service providers until ``explicitly superseded by regulations
prescribed by the Commission.'' On appeal, the DC Circuit left intact
the Commission's findings concerning the scope of section 251(b)(5),
although it took issue with other aspects of the ISP Remand Order.
10. We disagree with commenters who argue that section 251(b)(5)
only can be applied to traffic exchanged between LECs, and not traffic
exchanged between a LEC and another carrier. The Commission rejected
that argument in the Local Competition Order, finding that section
251(b)(5) applies to traffic exchanged by a LEC and any other
telecommunications carrier, and adopted rules implementing that
finding. In a specific application of that principle, the Commission
concluded that ``CMRS providers will not be classified as LECs,'' but
nevertheless found that ``LECs are obligated, pursuant to section
251(b)(5) (and the corresponding pricing standards of section
252(d)(2)), to enter into reciprocal compensation agreements with all
CMRS providers.'' No one challenged that finding on appeal, and it has
been settled law for the past 12 years. We see no reason to revisit
that conclusion now. While section 251(b)(5) indisputably imposes the
duty to establish reciprocal compensation arrangements on LECs alone,
Congress did not limit the class of potential beneficiaries of that
obligation to LECs.
11. We also disagree with commenters who argue that section
252(d)(2)(A)(i) limits the scope of section 251(b)(5). Section
252(d)(2)(A)(i) provides that a state commission ``shall not consider
the terms and conditions for reciprocal compensation to be just and
reasonable'' unless ``such terms and conditions provide for the mutual
and reciprocal recovery by each carrier of costs associated with the
transport and termination on each carrier's network facilities of calls
that originate on the network facilities of the other carrier.''
Verizon and others argue that this provision necessarily excludes
interexchange traffic from the scope of section 251(b)(5), because at
the time the 1996 Act was passed calls neither originated nor
terminated on an interexchange carrier's network. We reject this
reasoning because it
[[Page 72734]]
erroneously assumes that Congress intended the pricing standards in
section 252(d)(2) to limit the otherwise broad scope of section
251(b)(5). We do not believe that Congress intended the tail to wag the
dog.
12. Section 251(b)(5) defines the scope of traffic that is subject
to reciprocal compensation. Section 252(d)(2)(A)(i), in turn, deals
with the mechanics of who owes what to whom, it does not define the
scope of traffic to which Section 251(b)(5) applies. Section
252(d)(2)(A)(i) provides that, at a minimum, a reciprocal compensation
arrangement must provide for the recovery by each carrier of costs
associated with the transport and termination on each carrier's network
of calls that originate on the network of the other carrier. Section
252(d)(2)(A)(i) does not address what happens when carriers exchange
traffic that originates or terminates on a third carrier's network.
This does not mean, as Verizon suggests, that Section 251(b)(5) must be
read as limited to traffic involving only two carriers. Rather, it
means that there is a gap in the pricing rules in Section 252(d)(2),
and the Commission has authority under section 201(b) to adopt rules to
fill that gap.
13. We also reject Verizon's argument that a telecommunications
carrier that delivers traffic to an ISP is not eligible for reciprocal
compensation because the carrier does not ``terminate''
telecommunications traffic at the ISP. In the Local Competition Order,
the Commission defined ``termination'' as ``the switching of traffic
that is subject to Section 251(b)(5) at the terminating carrier's end
office switch * * * and delivery of that traffic to the called party's
premises.'' As the DC Circuit suggested in the Bell Atlantic decision,
``Calls to ISPs appear to fit this definition: The traffic is switched
by the LEC whose customer is the ISP and then delivered to the ISP,
which is clearly the `called party.' '' We agree.
14. Verizon also argues that the reference to reciprocal
compensation in the competitive checklist in section 271, which was
designed to ensure that local markets are open to competition, somehow
shows that Congress intended to limit the scope of section 251(b)(5) to
local traffic. We do not see how this argument sheds any light on the
scope of section 251(b)(5). Congress no doubt included the reference to
reciprocal compensation in section 271 because section 251(b)(5)
applies to local traffic, a point that no one disputes. That does not
suggest, however, that section 251(b)(5) applies only to local traffic.
15. We need not respond to every other variation of the argument
that the history and structure of the Act somehow demonstrate that
section 251(b)(5) is limited to local traffic. At best, these arguments
show that one plausible interpretation of the statute is that section
251(b)(5) applies only to local traffic, a view that the Commission
embraced in the Local Competition First Report and Order. These
arguments do not persuade us, however, that this is the only plausible
reading of the statute. Moreover, many of the same arguments based on
the history and context of the adoption of section 251 to limit its
scope to local traffic were rejected by the DC Circuit in the context
of section 251(c). We find that the better reading of the Act as a
whole, in particular the broad language of section 251(b)(5) and the
grandfather clause in section 251(g), supports our view that the
transport and termination of all telecommunications exchanged with LECs
is subject to the reciprocal compensation regime in sections 251(b)(5)
and 252(d)(2).
16. Notwithstanding section 251(b)(5)'s broad scope, we agree with
the finding in the ISP Remand Order that traffic encompassed by section
251(g) is excluded from Section 251(b)(5) except to the extent that the
Commission acts to bring that traffic within its scope. Section 251(g)
preserved the pre-1996 Act regulatory regime that applies to access
traffic, including rules governing ``receipt of compensation.'' Here,
however, the DC Circuit has held that ISP-bound traffic did not fall
within the section 251(g) carve out from Section 251(b)(5) as ``there
had been no pre-Act obligation relating to intercarrier compensation
for ISP-bound traffic.'' As a result, we find that ISP-bound traffic
falls within the scope of section 251(b)(5).
2. Authority Under Section 201
17. The section 251(b)(5) finding above, however, does not end our
legal analysis here. That is because the ISP-bound traffic at issue
here is clearly interstate in nature and thus also subject to our
section 201 authority. The Commission unquestionably has authority to
regulate intercarrier compensation with respect to interstate access
services, rates charged by CMRS providers, and other traffic subject to
Commission authority such as ISP-bound traffic. Section 2(a) of the Act
establishes the Commission's jurisdiction over interstate services, for
which the Commission ensures just, reasonable, and not unjustly and
unreasonably discriminatory rates under section 201 and 202. Likewise,
the Commission has authority over the rates of CMRS providers pursuant
to section 332 of the Act.
18. In sections 251 and 252 of the Act, Congress altered the
traditional regulatory framework based on jurisdiction by expanding the
applicability of national rules to historically intrastate issues and
state rules to historically interstate issues. In the Local Competition
First Report and Order, the Commission found that the 1996 Act created
parallel jurisdiction for the Commission and the states over interstate
and intrastate matters under sections 251 and 252. The Commission and
the states ``are to address the same matters through their parallel
jurisdiction over both interstate and intrastate matters under Sections
251 and 252.'' Moreover, section 251(i) provides that ``[n]othing in
this section shall be construed to limit or otherwise affect the
Commission's authority under section 201.'' In the Local Competition
First Report and Order, the Commission concluded that section 251(i)
``affirms that the Commission's preexisting authority under section 201
continues to apply for purely interstate activities.''
19. In implementing sections 251 and 252 in the Local Competition
First Report and Order, the Commission's treatment of LEC-CMRS traffic
provides an instructive example. Prior to the 1996 Act, the Commission
expressly preempted ``state and local regulations of the kind of
interconnection to which CMRS providers are entitled'' based on its
authority under sections 201 and 332 of the Act. Nevertheless, in the
Local Competition First Report and Order, the Commission brought LEC-
CMRS interconnection within the section 251 framework as it relates to
intraMTA (including interstate intraMTA) traffic. The Commission
recognized, however, that it continued to retain separate authority
over CMRS traffic.
20. Courts confirmed that, in permitting LEC-CMRS interconnection
to be addressed through the section 251 framework, the Commission did
not in any way lose its independent jurisdiction or authority to
regulate that traffic under other provisions of the Act. Thus, although
the Eighth Circuit invalidated the Commission's TELRIC pricing rules in
general, it recognized that ``because section 332(c)(1)(B) gives the
FCC the authority to order LECs to interconnect with CMRS carriers, we
believe that the Commission has the authority to issue the rules of
special concern to the CMRS providers, [including the reciprocal
compensation rules] but only as these provisions apply to CMRS
providers. Thus, [the pricing] rules * * * remain in full force and
effect with respect to the CMRS providers, and our order of vacation
does not apply to them in the CMRS
[[Page 72735]]
context.'' Subsequently, the DC Circuit held that CMRS providers were
entitled to pursue formal complaints under section 208 of the Act for
violations of the Commission's reciprocal compensation rules.
21. We build upon our actions in the Local Competition First Report
and Order and find here that addressing ISP-bound traffic through the
section 251 framework does not diminish the Commission's independent
jurisdiction or authority to regulate traffic under other provisions of
the Act. Specifically, we retain our authority under section 201 to
regulate ISP-bound traffic, despite acknowledging that such traffic is
section 251(b)(5) traffic. With respect to interstate services, the Act
has long provided us with the authority to establish just and
reasonable ``charges, practices, classifications, and regulations.''
The Commission thus retains full authority to regulate charges for
traffic and services subject to federal jurisdiction, even when it is
within the sections 251(b)(5) and 252(d)(2) framework. Because we re-
affirm our findings concerning the interstate nature of ISP-bound
traffic, which have not been vacated by any court, it follows that such
traffic falls under the Commission's section 201 authority preserved by
the Act and that we therefore have the authority to issue pricing rules
pursuant to that section. This conclusion is reinforced by section
251(i) of the Act. As the Commission explained in the ISP Remand Order,
section 251(i) ``expressly affirms the Commission's role in an evolving
telecommunications marketplace, in which Congress anticipates that the
Commission will continue to develop appropriate pricing and
compensation mechanisms for traffic that falls within the purview of
section 201.'' It concluded that section 251(i), together with section
201, equips the Commission with the tools necessary to keep pace with
regulatory developments and new technologies. When read together, these
statutory sections preserve the Commission's authority to address new
issues that fall within its section 201 authority over interstate
traffic, including compensation for the exchange of ISP-bound traffic.
Consequently, in the ISP Remand Order, the Commission properly
exercised its authority under section 201(b) to issue pricing rules
governing the payment of compensation between carriers for ISP-bound
traffic.
22. Our result today is consistent with the DC Circuit's opinion in
Bell Atlantic, which concluded that the jurisdictional nature of
traffic is not dispositive of whether reciprocal compensation is owed
under section 251(b)(5). It is also consistent with the DC Circuit's
WorldCom decision, in which the court rejected the Commission's view
that section 251(g) excluded ISP-bound traffic from the scope of
section 251(b)(5), but made no other findings. Finally, this result
does not run afoul of the Eighth Circuit's decision on remand from the
Supreme Court in the Iowa Utilities Board litigation, which held that
``the FCC does not have the authority to set the actual prices for the
state commissions to use'' under section 251(b)(5). At the time of that
decision, under the Local Competition First Report and Order, section
251(b)(5) applied only to local traffic. Thus, the Eighth Circuit
merely held that the Commission could not set reciprocal compensation
rates for local traffic. The court did not address the Commission's
authority to set reciprocal compensation rates for interstate traffic.
In sum, the Commission plainly has authority to establish pricing rules
for interstate traffic, including ISP-bound traffic, under section
201(b), and that authority was preserved by section 251(i).
3. Other Issues
23. Most commenters urge the Commission to maintain the
compensation rules governing ISP-bound traffic until the Commission is
able to complete comprehensive intercarrier compensation reform. These
parties contend that a higher compensation rate would create new
opportunities for arbitrage and impose substantial financial burdens on
wireless companies, incumbent LECs and state public utility
commissions. They further claim that the existing regime has simplified
interconnection negotiations.
24. In the ISP Remand Order, the Commission found that the one-way
nature of ISP-bound traffic creates significant arbitrage
opportunities. Due to the unbalanced nature of ISP-bound traffic, the
Commission observed that reciprocal compensation arrangements created
enormous incentives for competitive LECs to sign up ISPs as customers.
The Commission cited evidence that competitive LECs, on average,
terminated eighteen times more traffic than they originated, resulting
in annual CLEC reciprocal compensation billings of approximately two
billion dollars, 90 percent of which was for ISP-bound traffic. The
Commission concluded that ``the record strongly suggests that CLECs
target ISPs in large part because of the availability of reciprocal
compensation payments.'' This undermined the operation of competitive
markets because competitive LECs were able to recover a
disproportionate share of their costs from other carriers. To limit
arbitrage opportunities that arose from ``excessively high reciprocal
compensation rates,'' the Commission adopted a gradually declining cap
on intercarrier compensation for ISP-bound traffic, beginning at $.0015
per minute of use and declining to $.0007 per minute of use, the
current cap. The Commission derived the rate caps from contemporaneous
interconnection agreements, in which carriers voluntarily agreed to
rates comparable to the rate caps adopted by the Commission. The
interconnection agreements included lower rates for unbalanced traffic
than for balanced traffic, and the rates declined over time, like the
rate caps. Although the Commission made no specific findings with
regard to the actual costs associated with delivering traffic to ISPs,
it noted evidence in the record that technological advances were
reducing the costs incurred by carriers when handling all forms of
traffic. The Commission also noted that ``negotiated reciprocal
compensation rates continue to decline as ILECs and CLECs negotiate new
agreements.''
25. On July 14, 2003, Core Communications, Inc. (``Core'') filed a
petition pursuant to Section 10 of the Communications Act requesting
that the Commission forbear from enforcing the rate caps and certain
other provisions set forth in the ISP Remand Order with respect to the
exchange of ISP-bound traffic between telecommunications carriers. In
2004, the Commission denied the petition with respect to rate caps and
the mirroring rule, determining that Core had satisfied none of the
three prongs of the statutory test for forbearance. First, the
Commission found that forbearance from enforcement of the rate caps was
not consistent with the public interest. To the contrary, the
Commission concluded that rate caps remained necessary to prevent
regulatory arbitrage and to promote efficient investment in
telecommunications services and facilities. Second, the Commission
found limited potential for discrimination under the rate caps. The
caps applied to ISP-bound traffic only to the extent that an incumbent
carrier offered to exchange all traffic at the same rate under section
251(b)(5). Accordingly, the Commission concluded that Core had not
proven that the rate caps resulted in impermissible discrimination
against or between competitive carriers or services. Finally,
[[Page 72736]]
the Commission found that Core had not demonstrated that enforcement of
the rate caps was not necessary for the protection of consumers. Core
advanced speculative general claims that the caps caused artificially
high rates, had forced competitive carriers from the market, and had
deterred investment in telecommunications services, all to consumers'
detriment. The Commission rejected these unsupported claims, explaining
that the rate caps were designed to prevent the subsidization of dial-
up Internet access customers at the expense of consumers of basic
telephone service and to avoid regulatory arbitrage and discrimination
between services. For these reasons, the Commission denied Core's
petition for forbearance insofar as rate caps were concerned.
26. In 2006, the DC Circuit affirmed our decision not to forbear
from the rate cap (and the mirroring rule). The Court found reasonable
the Commission's ``view that the rate caps are necessary to prevent the
subsidization of dial-up Internet access consumers by consumers of
basic telephone service'' that would occur if reciprocal compensation
rates applied to one-way ISP-bound traffic. The Court likewise rejected
Core's contention that the rate cap was ``unreasonably
discriminatory,'' both because one-way ISP-bound calls were
fundamentally different from other forms of traffic and because the
mirroring rule ensures that ```the caps apply to ISP-bound traffic only
if an incumbent LEC offers to exchange all section 251(b)(5) traffic at
the same rate.''' Finally, the Court concluded that the Commission's
concern that the rate cap was necessary to prevent ```regulatory
arbitrage' and `distorted economic incentives''' was reasonable.
27. The policy justifications provided by the Commission in 2001
for the rules at issue here have not been questioned by any court. In
addition, the policy justifications provided by the Commission for
refusing to forbear from enforcement of these rules were upheld by the
DC Circuit in 2006. We therefore disagree with parties who suggest that
the Commission, in responding to the DC Circuit's remand in WorldCom,
must offer detailed new justifications for the ISP intercarrier payment
regime; we have already offered our justifications for that regime.
Moreover, both the WorldCom remand and Core writ of mandamus focused on
the issue of legal authority. We also reject arguments that the
Commission unlawfully delegated its authority in the ISP Remand Order
and arguments that the Commission addressed previously in the Core
Forbearance Order.
28. The Commission long has stated its intention to move to a more
unified intercarrier compensation regime. Progress is difficult due to
competing priorities, such as competition, innovation, universal
service, and other goals. The Commission recognized in 2001 that ISP-
bound traffic represented a unique arbitrage problem that required
immediate attention, based on the policy concerns discussed above. The
Commission remains committed to moving towards a more unified
intercarrier compensation regime, as evidenced by the Further Notice
issued in conjunction with this order.
29. In sum, we maintain the $.0007 cap and the mirroring rule
pursuant to our Section 201 authority. These rules shall remain in
place until we adopt more comprehensive intercarrier compensation
reform.
II. Report and Order--Reform of High-Cost Universal Service Support
30. In this report and order, we address the ``Recommended
Decision'' of the Federal-State Joint Board on Universal Service (Joint
Board), which was released on November 20, 2007. As discussed below, we
appreciate the great efforts expended by the Joint Board and its staff
in considering how best to reform the current high-cost support
mechanism and in developing its recommendations. We choose not to
implement the recommendations contained in the Comprehensive Reform
Recommended Decision at this time, however.
A. Background
31. The 1996 Act amended the Communications Act of 1934 with
respect to the provision of universal service. In the 1996 Act,
Congress sought to preserve and advance universal service, while at the
same time opening all telecommunications markets to competition.
Section 254(b) of the Act directs the Joint Board and the Commission to
base policies for the preservation and advancement of universal service
on several general principles, plus other principles that the
Commission may establish. Among other things, section 254(b) directs
that there should be specific, predictable, and sufficient federal and
state universal service support mechanisms; quality services should be
available at just, reasonable, and affordable rates; and access to
advanced telecommunications and information services should be provided
in all regions of the nation.
32. The Commission implemented the universal service provisions of
the 1996 Act in the 1997 Universal Service First Report and Order.
Among other things, the Commission adopted rules to create explicit
universal service support mechanisms for customers living in rural and
high-cost areas. Pursuant to section 254(e) of the Act, an entity must
be designated as an eligible telecommunications carrier (ETC) to
receive high-cost universal service support. ETCs may be incumbent
LECs, or non-incumbent LECs, which are referred to as ``competitive
ETCs.'' Under the existing high-cost support distribution mechanism,
incumbent LEC ETCs receive high-cost support for their intrastate
services based on their costs. Competitive ETCs receive support for
each line based on the support the incumbent LEC would receive for that
line in the service area. This support to competitive ETCs is known as
``identical support.'' The Commission's universal service high-cost
support rules do not distinguish between primary and secondary lines;
therefore, high-cost support may go to a single end user for multiple
connections. Further, the Commission's rules result in subsidizing
multiple competitors in the same high-cost area.
33. High-cost support for competitive ETCs has grown rapidly over
the last several years, placing extraordinary pressure on the federal
universal service fund. In 2001, high-cost universal service support
totaled approximately $2.6 billion. By 2007, the amount of high-cost
support had grown to approximately $4.3 billion per year. In recent
years, this growth has been due mostly to increased support provided to
competitive ETCs, which receive high-cost support based on the per-line
support that the incumbent LECs receive pursuant to the identical
support rule. Competitive ETC support, in the six years from 2001
through 2007, has grown from under $17 million to $1.18 billion--an
annual growth rate of over 100 percent. This ``funded competition'' has
grown significantly in a large number of rural, insular, or high-cost
areas; in some study areas more than 20 competitive ETCs currently
receive support.
34. To address the growth in competitive ETC support, the Joint
Board recommended an interim cap on the amount of high-cost support
available to competitive ETCs, pending comprehensive high-cost
universal service reform. The Commission adopted this recommendation on
May 1, 2008.
35. For the past several years, the Joint Board and the Commission
have been exploring ways to reform the Commission's high-cost program.
In the most recent high-cost support
[[Page 72737]]
comprehensive reform efforts, the Joint Board issued a recommended
decision on November 20, 2007. The Universal Service Joint Board's
recommended decision included several recommendations to address the
growth in high-cost support and to reform the high-cost mechanisms.
Specifically, the Universal Service Joint Board recommended that the
Commission should: (1) Deliver high-cost support through a provider of
last resort fund, a mobility fund, and a broadband fund; (2) cap the
high-cost fund at $4.5 billion, the approximate level of 2007 high-cost
support; (3) reduce the existing funding mechanisms during a transition
period; (4) add broadband and mobility to the list of services eligible
for support under section 254 of the Act; (5) eliminate the identical
support rule; and (6) ``explore the most appropriate auction mechanisms
to determine high-cost universal service support.''
36. On January 29, 2008, the Commission released the Joint Board
Comprehensive Reform NPRM, seeking comment on the Joint Board's
Comprehensive Reform Recommended Decision. Pursuant to section
254(a)(2), the Commission ``shall complete any proceeding to implement
subsequent recommendations from any Joint Board on universal service
within one year after receiving such recommendations.''
B. Discussion
37. We have carefully reviewed the Joint Board's Comprehensive
Reform Recommended Decision and the comments that were filed in
response to the Commission's Joint Board Comprehensive Reform NPRM. We
thank the Joint Board and its staff for their hard work in studying
these difficult issues and in developing their recommendations. We
choose not to implement these recommendations at this time, however.
Federal Communications Commission.
Marlene H. Dortch,
Secretary.
[FR Doc. E8-28464 Filed 11-28-08; 8:45 am]
BILLING CODE 6712-01-P