High Cost

Requesting Confidential Information

Access to Wire Center Confidential Line Count Information

Parties wishing to obtain access to wire center line count data submitted pursuant to 47 C.F.R sections 36.611 and 36.612 and for which confidential treatment was sought must comply with the confidentiality procedures developed consistent with two orders - one adopted by the Federal Communications Commission (FCC) and one adopted by the FCC's Common Carrier Bureau.

The Line Count Confidentiality Order [M.S.Word file, 96kb], issued by the FCC April 7, 2000, denied, to a limited extent, requests by certain non-rural carriers for confidential treatment of quarterly line count data at the wire center level. The FCC reasoned that the number of lines in wire centers receiving support may be determined once the FCC releases statewide forward-looking support amounts, carrier-by-carrier hold harmless support amounts, and the per-line support amounts available in a wire center and that the public availability of per-line and total support amounts was essential to ensure that support is portable to eligible telecommunications carriers.

The Interim Protective Order [PDF file, 42kb], adopted by the Common Carrier Bureau April 7, 2000, facilitated the review of line count data at the wire center level submitted for wire centers not receiving support under the High Cost Model component. Confidential line count information defined in the Interim Protective Order is subject to the terms of that order until the FCC makes a final determination on the manner in which the information is to be treated.

Procedures for Gaining Access to Wire Center Confidential Line Count Information at USAC's Washington, D.C. Office

  1. Any Authorized Representative desiring access to Wire Center Confidential Line Count Information (WC CLCI) pursuant to the Interim Protective Order [PDF file, 42kb] of the Federal Communications Commission (CC Docket No. 96-45, April 7, 2000, DA 00-773) may do so by contacting the Universal Service Administrative Company (USAC) in writing.

  2. Written requests for access to WC CLCI must reasonably describe which set of CLCI is requested, whether inspection or copying of the CLCI is being requested, and the name of the authorized representative who is to be provided access to the CLCI. A set of WC CLCI is comprised of one (1) complete quarterly submission and can be described by referring to the due date of the filing. A separate written request is required for access to each quarterly submission. A sample declaration is attached.

  3. Each written request for access to WC CLCI shall be mailed with an appropriate certificate of service (which must include the appropriate submitting parties and the FCC) and appropriate declaration or declarations to USAC at the address below, and to each of the appropriate submitting parties:

    4. USAC
    Attn: WC CLCI Data Request
    2000 L Street, N.W.
    Suite 200
    Washington, D.C. 20036

  4. All appropriate submitting parties who furnished WC CLCI in confidence will be notified by the requesting authorized representative at the time that the request for disclosure is submitted to USAC, and will be afforded five (5) days notice of the disclosure of their CLCI. USAC staff is authorized to identify the carriers that have furnished WC CLCI in confidence. A service of process list can be obtained by calling USAC at (202-776-0200).
  5. USAC will make every effort to schedule an appointment to provide access to the requested WC CLCI within not less than six (6) days nor more than twenty (20) days of receipt of the notice at the USAC office in Washington, D.C. Authorized representatives should contact USAC at (202) 776-0200 to schedule an appointment.

    6. An "Authorized Representative" is:

    • The individual identified on the Declaration form by the reviewing party.

    • Counsel for the reviewing party, including in-house counsel and their associated attorneys, paralegals, clerical staff, and other employees, to the extent reasonably necessary to render professional services by counsel for a reviewing party.

    • Specified persons, including employees of the reviewing parties, requested by counsel to furnish technical or other expert advice or service or otherwise engaged to prepare material for the express purpose of formulating filings in this docket, except that disclosure to persons in a position to use this information for competitive commercial or business purposes shall be prohibited.

    • Any person designated by the Commission in the public interest, upon such terms as the Commission may deem proper.

    A "Reviewing Party" is a person or entity reviewing or seeking in good faith to review WC CLCI only for the purpose of reviewing the underlying information and verifying per-line interstate access universal service support amounts.

    If the required declaration and a certificate of service-that includes the date served-from an authorized representative is on file with USAC, then the staff of USAC is authorized to make the specified CLCI available to the authorized representative. Access to the CLCI may be provided at a previously scheduled appointment during normal business hours (9:00 a.m. - 6:00 p.m. ET).

  6. Access to the WC CLCI will not be provided to an authorized representative until a properly executed original declaration as specified in these procedures has been provided to USAC.

  7. USAC will maintain a log of all requests along with a copy of the properly executed declaration and certificate of service. The log will specify the date of the request and will clearly identify when the files were inspected or copied (noting whether paper or electronic copy). The ultimate disposition of the copy should be noted in the USAC log.

  8. If USAC is requested to make and furnish paper copies of WC CLCI for use by authorized representatives, the request must be in writing. The fee for this service shall be $0.15 per page, plus any applicable postage and handling charges. The charge for electronic copies will be the actual cost of the media and other operating costs of processing the request if USAC has the capability to produce the requested media format.

  9. When the WC CLCI is no longer useful for the purposes set forth in the Interim Protective Order [PDF file, 42kb], it shall be returned to USAC or destroyed by the authorized representative, and notice of the destruction shall be given to USAC.

  10. Concerns regarding USAC's procedures for handling access to WC CLCI should be addressed to the FCC.

[ Declaration M.S. Word file, 23kb]

Access to Interstate Access Confidential Line Count Information

Parties wishing to obtain access to interstate access line count data submitted pursuant to 47 C.F.R. Section 54.802 and for which confidential treatment was sought must comply with the confidentiality procedures developed consistent with two orders adopted by the FCC's Common Carrier Bureau.

The IAS Confidentiality Order [M.S. Word file], released September 20, 2000, denied, to a limited extent, requests by certain price-cap local exchange carriers (LECs) for confidential treatment of line count data submitted in accordance with the FCC's rules implementing the IAS component. The bureau denied the confidentiality requests only to the extent necessary for USAC to publish the following information: (1) total interstate access support by state and by eligible carrier within each state; and (2) per-line interstate access support available in each price-cap LEC's study area, by unbundled network element (UNE) zone and customer class.

The IAS Interim Protective Order [ M.S. Word file], also released September 20, 2000, facilitated and expedited the review of the study area or UNE zone line count data submitted pursuant to section 54.802 of the FCC's rules that cannot be determined when USAC releases the results of calculations showing per-line and statewide IAS support amounts. Confidential line count information defined in the IAS Interim Protective Order is subject to the terms of that order until the FCC makes a final determination on the manner in which the data is to be treated.

Procedure for Gaining Access to Interstate Access Confidential Line Count Information at USAC's Washington, D.C. Office

  1. Any Authorized Representative desiring access to Interstate Access Confidential Line Count Information (IAS CLCI) pursuant to the IAS Interim Protective Order of the Federal Communications Commission (CC Docket No. 96-45, September 20, 2000, DA 00-2133) may do so by contacting the Universal Service Administrative Company (USAC) in writing.

  2. Written requests for access to IAS CLCI must reasonably describe which set of CLCI is requested, whether inspection or copying of the CLCI is being requested, and the name of the authorized representative who is to be provided access to the CLCI. A set of IAS CLCI is comprised of one (1) complete quarterly submission and can be described by referring to the due date of the filing. A separate written request is required for access to each quarterly submission. A sample declaration is attached.

  3. Each written request for access to IAS CLCI shall be mailed with an appropriate certificate of service (which must include the appropriate submitting parties and the FCC) and appropriate declaration or declarations to USAC at the address below, and to each of the appropriate submitting parties:

    USAC
    Attn: IAS CLCI Data Request
    2000 L Street, N.W.
    Suite 200
    Washington, D.C. 20036

  4. All appropriate submitting parties who furnished IAS CLCI in confidence will be notified by the requesting authorized representative at the time that the request for disclosure is submitted to USAC, and will be afforded five (5) days notice of the disclosure of their CLCI. USAC staff is authorized to identify the carriers that have furnished IAS CLCI in confidence. A service of process list can be obtained by calling USAC at (202-776-0200).

  5. USAC will make every effort to schedule an appointment to provide access to the requested IAS CLCI within not less than six (6) days nor more than twenty (20) days of receipt of the notice at the USAC office in Washington, D.C. Authorized representatives should contact USAC at (202) 776-0200 to schedule an appointment.

    6. An "Authorized Representative" is:

    • The individual identified on the Declaration form by the reviewing party.
    • Counsel for the reviewing party, including in-house counsel and their associated attorneys, paralegals, clerical staff, and other employees, to the extent reasonably necessary to render professional services by counsel for a reviewing party.
    • Specified persons, including employees of the reviewing parties, requested by counsel to furnish technical or other expert advice or service or otherwise engaged to prepare material for the express purpose of formulating filings in this docket, except that disclosure to persons in a position to use this information for competitive commercial or business purposes shall be prohibited.
    • Any person designated by the Commission in the public interest, upon such terms as the Commission may deem proper.

    A "Reviewing Party" is a person or entity reviewing or seeking in good faith to review IAS CLCI only for the purpose of reviewing the underlying information and verifying per-line interstate access universal service support amounts.

    If the required declaration and a certificate of service-that includes the date served-from an authorized representative is on file with USAC, then the staff of USAC is authorized to make the specified CLCI available to the authorized representative. Access to the CLCI may be provided at a previously scheduled appointment during normal business hours (9:00 a.m. - 6:00 p.m. ET).

  6. Access to the CLCI will not be provided to an authorized representative until a properly executed original declaration as specified in these procedures has been provided to USAC.

  7. USAC will maintain a log of all requests along with a copy of the properly executed declaration and certificate of service. The log will specify the date of the request and will clearly identify when the files were inspected or copied (noting whether paper or electronic copy). The ultimate disposition of the copy should be noted in the USAC log.

  8. If USAC is requested to make and furnish paper copies of IAS CLCI for use by authorized representatives, the request must be in writing. The fee for this service shall be $0.15 per page, plus any applicable postage and handling charges. The charge for electronic copies will be the actual cost of the media and other operating cost of processing the request if USAC has the capability to produce the requested media format.

  9. When the IAS CLCI is no longer useful for the purposes set forth in the IAS Interim Protective Order, it shall be returned to USAC or destroyed by the authorized representative, and notice of the destruction shall be given to USAC.

  10. Concerns regarding USAC's procedures for handling access to IAS CLCI should be addressed to the FCC.

[ Declaration M.S. Word file, 22kb ]


Last modified on 1/11/2008