*Pages 1--19 from Microsoft Word - 42554* Federal Communications Commission DA 04- 3046 Before the Federal Communications Commission Washington, D. C. 20554 In the Matter of Federal- State Joint Board on Universal Service ALLTEL Communications, Inc. Petition for Designation as an Eligible Telecommunications Carrier in the state of Alabama Petition for Designation as an Eligible Telecommunications Carrier in the state of Florida Petition for Designation as an Eligible Telecommunications Carrier in the state of Georgia Petition for Designation as an Eligible Telecommunications Carrier in the state of North Carolina Petition for Designation as an Eligible Telecommunications Carrier in the Commonwealth of Virginia ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC Docket No. 96- 45 ORDER Adopted: September 24, 2004 Released: September 24, 2004 By the Chief, Wireline Competition Bureau: I. INTRODUCTION 1. In this Order, we grant the petitions of ALLTEL Communications, Inc. (ALLTEL) to be designated as an eligible telecommunications carrier (ETC) for the requested service areas in Alabama, Florida, Georgia, North Carolina, and Virginia, pursuant to section 214( e)( 6) of the Communications Act of 1934, as amended (the Act). 1 In so doing, we conclude that ALLTEL, a commercial mobile radio 1 See Application of ALLTEL Communications, Inc. for Designation as an Eligible Telecommunications Carrier in the State of Alabama, filed April 14, 2003 (Alabama Petition); First Amendment to the Application of ALLTEL Communications, Inc. for Designation as an Eligible Telecommunications Carrier in the State of Alabama, filed May 21, 2003 (Alabama Amendment); Application of ALLTEL Communications, Inc. for Designation as an Eligible Telecommunications Carrier in the State of Florida, filed November 20, 2003 (Florida Petition); Application of ALLTEL Communications, Inc. for Designation as an Eligible Telecommunications Carrier in the State of Georgia, filed August 26, 2003 (Georgia Petition); Amendment to Application of ALLTEL Communications, Inc. for Designation as an Eligible Telecommunications Carrier in the State of Georgia, filed September 15, 2003 (Georgia Amendment); Application of ALLTEL Communications, Inc. for Designation as an (continued....) 1 Federal Communications Commission DA 04- 3046 2 service (CMRS) carrier, has satisfied the statutory eligibility requirements of section 214( e)( 1) to be designated as an ETC. 2 II. BACKGROUND A. The Act 2. Section 254( e) of the Act provides that “only an eligible telecommunications carrier designated under section 214( e) shall be eligible to receive specific Federal universal service support.” 3 Pursuant to section 214( e)( 1), a common carrier designated as an ETC must offer and advertise the services supported by the federal universal service mechanisms throughout the designated service area. 4 3. Section 214( e)( 2) of the Act provides state commissions with the primary responsibility for performing ETC designations. 5 Section 214( e)( 6), however, directs the Commission, upon request, to designate as an ETC “a common carrier providing telephone exchange service and exchange access that is not subject to the jurisdiction of a State commission.” 6 Under section 214( e)( 6), the Commission may, with respect to an area served by a rural telephone company, and shall, in all other cases, designate more than one common carrier as an ETC for a designated service area, consistent with the public interest, convenience, and necessity, so long as the requesting carrier meets the requirements of section 214( e)( 1). 7 Before designating an additional ETC for an area served by a rural telephone company, the Commission must determine that the designation is in the public interest. 8 The Wireline Competition Bureau (Bureau) has delegated authority to perform ETC designations. 9 (... continued from previous page) Eligible Telecommunications Carrier in the State of North Carolina, filed August 26, 2003 (North Carolina Petition); Application of ALLTEL Communications, Inc. for Designation as an Eligible Telecommunications Carrier in the State of Virginia, filed April 14, 2003 (Virginia Petition); First Amendment to the Application of ALLTEL Communications, Inc. for Designation as an Eligible Telecommunications Carrier in the State of Virginia, filed May 21, 2003 (Virginia Amendment); Letter from Glenn S. Rabin, Counsel for ALLTEL Communications, Inc. to Marlene H. Dortch, Secretary, FCC, dated March 1, 2004 (ALLTEL March 1, 2004 Supplement); Letter from Cheryl A. Tritt, Counsel for ALLTEL Communications, Inc. to Marlene H. Dortch, Secretary, FCC, dated September 20, 2004. See also 47 U. S. C. § 214( e)( 6). 2 47 U. S. C. § 214( e)( 1). 3 47 U. S. C. § 254( e). 4 47 U. S. C. § 214( e)( 1). 5 47 U. S. C. § 214( e)( 2). See also Federal- State Joint Board on Universal Service; Promoting Deployment and Subscribership in Unserved Areas, Including Tribal and Insular Areas, Twelfth Report and Order, Memorandum Opinion and Order, and Further Notice of Proposed Rulemaking, CC Docket No. 96- 45, 15 FCC Rcd 12208, 12255, para. 93 (2000) (Twelfth Report and Order). 6 47 U. S. C. § 214( e)( 6). See, e. g., Federal- State Joint Board on Universal Service, Virginia Cellular, LLC Petition for Designation as an Eligible Telecommunications Carrier for the Commonwealth of Virginia, Memorandum Opinion and Order, CC Docket No. 96- 45, 19 FCC Rcd 1563 (2004) (Virginia Cellular Order); Federal- State Joint Board on Universal Service, Highland Cellular, Inc. Petition for Designation as an Eligible Telecommunications Carrier for the Commonwealth of Virginia, Memorandum Opinion and Order, CC Docket No. 96- 45, 19 FCC Rcd 6422 (2004) (Highland Cellular Order). 7 47 U. S. C. § 214( e)( 6). 8 Id. 9 See Procedures for FCC Designation of Eligible Telecommunications Carriers Pursuant to Section 214( e)( 6) of the Communications Act, Public Notice, CC Docket No. 96- 45, 12 FCC Rcd 22947, 22948 (1997) (Section 214( e)( 6) Public Notice). The Wireline Competition Bureau was previously named the Common Carrier Bureau. 2 Federal Communications Commission DA 04- 3046 3 B. Commission Requirements for ETC Designation 4. An ETC petition must contain the following: (1) a certification and brief statement of supporting facts demonstrating that the petitioner is not subject to the jurisdiction of a state commission; (2) a certification that the petitioner offers or intends to offer all services designated for support by the Commission pursuant to section 254( c); (3) a certification that the petitioner offers or intends to offer the supported services “either using its own facilities or a combination of its own facilities and resale of another carrier’s services;” (4) a description of how the petitioner “advertise[ s] the availability of [supported] services and the charges therefor using media of general distribution;” and (5) if the petitioner meets the definition of a “rural telephone company” pursuant to section 3( 37) of the Act, the petitioner must identify its study area, or, if the petitioner is not a rural telephone company, it must include a detailed description of the geographic service area for which it requests an ETC designation from the Commission. 10 5. On June 30, 2000, the Commission released the Twelfth Report and Order which, among other things, set forth how a carrier seeking ETC designation from the Commission must demonstrate that the state commission lacks jurisdiction to perform the ETC designation. 11 Carriers seeking designation as an ETC for service provided on non- tribal lands must provide the Commission with an “affirmative statement” from the state commission or a court of competent jurisdiction that the carrier is not subject to the state commission’s jurisdiction. 12 The requirement to provide an “affirmative statement” ensures that the state commission has had “a specific opportunity to address and resolve issues involving a state commission’s authority under state law to regulate certain carriers or classes of carriers.” 13 6. On January 22, 2004, the Commission released the Virginia Cellular Order, which granted in part and denied in part the petition of Virginia Cellular, LLC (Virginia Cellular) to be designated as an ETC throughout its licensed service area in the Commonwealth of Virginia. 14 In that Order, the Commission utilized a new public interest analysis for ETC designations and imposed ongoing conditions and reporting requirements on Virginia Cellular. 15 The Commission further stated that the framework enunciated in the Virginia Cellular Order would apply to all ETC designations for rural areas pending further action by the Commission. 16 Following the framework established in the Virginia Cellular Order, on April 12, 2004, the Commission released the Highland Cellular Order, which granted in part and denied in part the petition of Highland Cellular, Inc. to be designated as an ETC in portions of its licensed service area in the Commonwealth of Virginia. 17 In the Highland Cellular Order, the Commission concluded, among other things, that a telephone company in a rural study area may not be designated as a competitive ETC below the wire center level. 18 10 See Section 214( e)( 6) Public Notice, 12 FCC Rcd at 22948- 49 (1997); 47 U. S. C. § 3( 37). See also Federal- State Joint Board on Universal Service, Western Wireless Corporation Petition for Preemption of an Order of the South Dakota Public Utilities Commission, Declaratory Ruling, CC Docket No. 96- 45, 15 FCC Rcd 15168 (2000) (Declaratory Ruling), recon. pending. 11 See Twelfth Report and Order, 15 FCC Rcd at 12255- 65, paras. 93- 114. 12 Id., 15 FCC Rcd at 12255, para. 93. 13 Id. 14 See Virginia Cellular Order, 19 FCC Rcd at 1564, para. 1. 15 See id., 19 FCC Rcd at 1565, 1575- 76, 1584- 85, paras. 4, 27, 28, 46. 16 See id., 19 FCC Rcd at 1565, para. 4. 17 See Highland Cellular Order, 19 FCC Rcd at 6422, para. 1. 18 See id., 19 FCC Rcd at 6438, para. 33. 3 Federal Communications Commission DA 04- 3046 4 C. ALLTEL Petitions 7. Pursuant to section 214( e)( 6), ALLTEL filed with this Commission five petitions and amendments thereto, seeking designation as an ETC in study areas served by both rural and non- rural incumbent local exchange carriers (LECs) in the states of Alabama, Florida, Georgia, North Carolina, and Virginia. 19 ALLTEL subsequently bifurcated its petitions into separate requests for ETC designation in non- rural and rural service areas, and later voluntarily withdrew the portions of those petitions seeking ETC designation in rural service areas, without prejudice to any subsequent refiling of those requests. 20 The Bureau released public notices seeking comment on these petitions. 21 Throughout this process, several parties filed comments and oppositions. 22 In light of the new ETC designation framework established in the Virginia Cellular Order, on March 1, 2004, ALLTEL filed a supplement to its ETC petitions. 23 On April 2, 2004, the Bureau released a public notice seeking comment concerning all supplemented ETC petitions, including the petitions filed by ALLTEL. 24 III. DISCUSSION 8. After careful review of the record before us, we find that ALLTEL has met all the requirements set forth in section 214( e)( 1) and (e)( 6) to be designated as an ETC by this Commission for its licensed service areas described herein. ALLTEL’s ETC designation for the non- rural service areas of Alabama, Florida, Georgia, North Carolina, and Virginia is effective immediately. A. Commission Authority to Perform the ETC Designation 9. We find that ALLTEL has demonstrated that the Commission has authority to consider ALLTEL’s petitions under section 214( e)( 6) of the Act. 25 ALLTEL’s petitions each include an affirmative statement from the relevant state commission stating that requests for designation as eligible 19 See supra note 1. 20 See Letter from Cheryl A. Tritt, Counsel for ALLTEL Communications, Inc. to Marlene H. Dortch, Secretary, FCC, dated November 10, 2003; Letter from Cheryl A. Tritt, Counsel for ALLTEL Communications, Inc. to Marlene H. Dortch, Secretary, FCC, dated May 21, 2004; infra para. 19. Accordingly, our analysis here is limited to the non- rural service areas in Alabama, Florida, Georgia, North Carolina, and Virginia for which ALLTEL seeks ETC designation. 21 See Wireline Competition Bureau Seeks Comment on ALLTEL Communications, Inc. Petition for Designation as an Eligible Telecommunications Carrier In the State of Alabama, Public Notice, CC Docket No. 96- 45, 18 FCC Rcd 11339 (2003); Wireline Competition Bureau Seeks Comment on ALLTEL Communications, Inc. Petition for Designation as an Eligible Telecommunications Carrier and Rural Service Area Redefinition In the State of Georgia, Public Notice, CC Docket No. 96- 45, 18 FCC Rcd 24989 (2003); Wireline Competition Bureau Seeks Comment on ALLTEL Communications, Inc. Petition for Designation as an Eligible Telecommunications Carrier and Rural Service Area Redefinition In the State of North Carolina, Public Notice, CC Docket No. 96- 45, 18 FCC Rcd 24985 (2003); Wireline Competition Bureau Seeks Comment on ALLTEL Communications, Inc. Petition for Designation as an Eligible Telecommunications Carrier In the State of Virginia, Public Notice, CC Docket No. 96- 45, 18 FCC Rcd 11336 (2003); Parties are Invited to Comment on Supplemented Petitions for Eligible Telecommunications Carrier Designations, Public Notice, CC Docket No. 96- 45, 19 FCC Rcd 6405 (2004). 22 See Appendix A for a list of entities filing comments, reply comments, and oppositions associated with the five petitions for ETC designation. 23 See ALLTEL March 1, 2004 Supplement. 24 See Parties are Invited to Comment on Supplemented Petitions for Eligible Telecommunications Carrier Designations, Public Notice, CC Docket 96- 45, 19 FCC Rcd 6405 (2004). 25 47 C. F. R. § 214( e)( 6). 4 Federal Communications Commission DA 04- 3046 5 telecommunications carriers should be sought from the Commission. 26 B. Offering and Advertising the Supported Services 10. Offering the Services Designated for Support. ALLTEL has demonstrated through the required certifications and related filings that it now offers, or will offer upon designation as an ETC, the services supported by the federal universal service mechanism. As noted in its petitions, ALLTEL is authorized to provide cellular radiotelephone service in Alabama, Florida, Georgia, North Carolina, and Virginia. 27 ALLTEL certifies that it now provides or will provide throughout its designated service area the services and functionalities enumerated in section 54.101( a) of the Commission’s rules. 28 ALLTEL has also certified that, in compliance with rule section 54.405, it will make available and advertise Lifeline service to qualifying low- income consumers. 29 Furthermore, ALLTEL made commitments that closely track those set forth in the Virginia Cellular Order and the Highland Cellular Order, including: (1) annual reporting of progress towards buildout plans, unfulfilled service requests, and complaints per 1,000 handsets; (2) specific commitments to provide service to requesting customers in the area for which it is designated, including those areas outside existing network coverage; and (3) specific commitments to construct new cell sites in areas outside its network coverage. 30 11. We reject the claims of certain commenters that ALLTEL does not provide the required services and functionalities supported by the universal service mechanism. First, commenters argue that ALLTEL should be required to offer unlimited local calling to mirror the services offered by wireline 26 Alabama Petition at 2- 3 & Exhibit A; Florida Petition at 3- 4 & Exhibit B; Georgia Petition at 2- 3 & Exhibit B; North Carolina Petition at 3- 4 & Exhibit B; Virginia Petition at 3 & Exhibit A. See also CTIA Georgia Comments at 3- 4; CTIA North Carolina Comments at 3- 4; CTIA Virginia Comments at 2- 3; 27 Alabama Petition at 1; Florida Petition at 2; Georgia Petition at 1; North Carolina Petition at 1; Virginia Petition at 1. 28 Alabama Petition at 1- 2; Florida Petition at 2; Georgia Petition at 1- 2; North Carolina Petition at 1- 2; Virginia Petition at 1. 29 Alabama Petition at 4- 6; Florida Petition at 4- 8; Georgia Petition at 4- 8; North Carolina Petition at 5- 8; Virginia Petition at 4- 7; ALLTEL March 1, 2004 Supplement at 6; ALLTEL Alabama/ Virginia Reply at 15. 47 C. F. R. § 54. 405. We note that ETCs must comply with state requirements in states that have Lifeline programs. See Lifeline and Link- Up, Report and Order and Further Notice of Proposed Rulemaking, WC Docket No. 03- 109, 19 FCC Rcd 8302, 8320 at para. 29 (2003). 30 ALLTEL March 1, 2004 Supplement at 4- 6; Letter from Cheryl A. Tritt, Counsel for ALLTEL Communications, Inc. to Marlene H. Dortch, Secretary, FCC, dated July 9, 2004 (July 9, 2004 Letter). ALLTEL has provided detailed information on how it will use universal service support to construct cell sites throughout the states in which it is designated as an ETC. ALLTEL March 1, 2004 Supplement at Exhibit B. Specifically, ALLTEL provides the location by study area of new cell sites and the cost of build- out plans, which ALLTEL projects will be carried out within one year of receiving ETC designation. See id. at 5- 6 and Exhibit B. In addition, ALLTEL has provided the figures on the populations that will be served by each new cell site that ALLTEL proposes to construct using ETC funds. July 9, 2004 Letter at Attachment A. According to these plans, within 12 months of receiving ETC designation, ALLTEL will use universal service support to begin construction of 12 cell sites in Alabama, seven cell sites in Florida, five cell sites in Georgia, 20 cell sites in North Carolina, and 19 cell sites in Virginia. ALLTEL March 1, 2004 Supplement at Exhibit B. The proposed cell sites in Alabama will serve 753,118 people; the proposed cell sites in Florida will serve 1,553, 253 people; the proposed cell sites in Georgia will serve 360,834 people; the proposed cell sites in North Carolina will serve 5,216,571 people; and the proposed cell sites in Virginia will serve 1,583, 495 people. July 9, 2004 Letter at Attachment A. We recognize that these plans may change over time depending on consumer demand, fluctuation in universal service support, and related factors. See, e. g., Virginia Cellular Order, 19 FCC Rcd at 1571, para. 16. 5 Federal Communications Commission DA 04- 3046 6 carriers. 31 No such requirement is necessary because the Commission has not established a minimum local usage requirement and ALLTEL has pledged compliance with any and all minimum local usage requirements required by applicable law. 32 In any event, we note that ALLTEL includes local usage in all of its calling plans. 33 Second, we disagree that ETC designation would be improper in this case due to the mobile nature of ALLTEL’s services. Specifically, certain commenters contend that the service area in which a customer resides may bear no relationship to the location where wireless support will be actually used by ALLTEL and therefore undermines the purpose of the universal service fund. 34 The Commission has found previously, however, that universal service offerings enable competitive wireless ETCs to provide benefits to customers that do not have access to wireline phones, such as consumers that often must drive significant distances to places of employment, stores, schools, and other critical community locations. 35 We also note that the Commission is currently seeking comment on this and related issues. 36 Third, we reject the argument that ETC designation is unwarranted because ALLTEL has failed to demonstrate that it currently offers certain supported services, such as voice grade access to the public switched network, and ALLTEL has not shown that it will effectively advertise the Lifeline and Link- Up programs. 37 We are satisfied by ALLTEL’s statements that it will provide all the services supported by the universal service program, including access to the public switched telephone network, and commits to participate in and advertise the Lifeline and Link- Up programs. 38 12. Offering the Supported Services Using a Carrier’s Own Facilities. ALLTEL has demonstrated that it satisfies the requirement of section 214( e)( 1)( A) that it offer the supported services using either its own facilities or a combination of its own facilities and resale of another carrier’s services. 39 ALLTEL states that it intends to provide the supported services using its existing network infrastructure. 40 13. Advertising Supported Services. ALLTEL has demonstrated that it satisfies the requirement of section 214( e)( 1)( B) to advertise the availability of the supported services and the charges therefor using media of general distribution. 41 In addition to its current advertising, 42 ALLTEL has 31 CenturyTel Reply at 10- 11; NASUCA Comments at 3; CenturyTel Supplemental Comments at 5- 6. See also Alabama Rural LEC Comments at 26. 32 Alabama Petition at 4- 5; Florida Petition at 5- 6; Georgia Petition at 4- 5; North Carolina Petition at 5- 6; Virginia Petition at 4- 5. 33 Alabama Petition at 4- 5; Florida Petition at 5- 6; Georgia Petition at 5; North Carolina Petition at 5- 6; Virginia Petition at 4- 5. 34 Alabama Rural LECs Comments at 15; CenturyTel Reply at 12- 13; CenturyTel Supplemental Comments at 6. 35 See Highland Cellular Order, 19 FCC Rcd at 6432- 33, para. 23. 36 Federal- State Joint Board on Universal Service, Notice of Proposed Rulemaking, CC Docket No. 96- 45, FCC 04- 127 (rel. June 8, 2004) (ETC High- Cost NPRM). 37 Alabama Rural LECs Comments at 24- 25, 27- 28. 38 Alabama Petition at 4- 6; Florida Petition at 4- 8; Georgia Petition at 4- 8; North Carolina Petition at 5- 8; Virginia Petition at 4- 7; ALLTEL March 1, 2004 Supplement at 6; ALLTEL Alabama/ Virginia Reply at 15. See also 47 C. F. R. §§ 54.101, 54.405. 39 47 C. F. R. § 214( e)( 1)( A). 40 See Alabama Petition at 7; Florida Petition at 8- 9; Georgia Petition at 8; North Carolina Petition at 8- 9; Virginia Petition at 7. 41 47 C. F. R. § 214( e)( 1)( B). 42 Alabama Petition at 7; Florida Petition at 9; Georgia Petition at 8; North Carolina Petition at 9; Virginia Petition at 7. 6 Federal Communications Commission DA 04- 3046 7 committed to specific methods to publicize the availability of Lifeline and Link- up service and improved service in unserved or underserved areas. 43 C. Public Interest Analysis 14. We conclude that it is “consistent with the public interest, convenience, and necessity” to designate ALLTEL as an ETC throughout its licensed non- rural service areas in the states of Alabama, Florida, Georgia, North Carolina, and Virginia. 44 In determining whether the public interest is served, the Commission places the burden of proof upon the ETC applicant. 45 We conclude that ALLTEL has satisfied the burden of proof in establishing that its universal service offering in these five states will provide benefits to non- rural consumers. 15. We conclude, as required by section 214( e)( 6) of the Act, that it is “consistent with the public interest, convenience, and necessity” to designate ALLTEL as an ETC for its requested service area that is served by non- rural telephone companies, as provided in Appendix B. 46 We note that the Bureau previously has found designation of additional ETCs in areas served by non- rural telephone companies to be per se in the public interest based upon a demonstration that the requesting carrier complies with the statutory eligibility obligations of section 214( e)( 1) of the Act. 47 In the Virginia Cellular Order and the Highland Cellular Order, however, the Commission determined that designation of an additional ETC in a non- rural telephone company’s study area based merely upon a showing that the requesting carrier complies with section 214( e)( 1) of the Act does not necessarily satisfy the public interest in every instance. 48 While some commenters argue that ALLTEL has failed to demonstrate that its designation as an ETC would serve the public interest, 49 nearly all these objections are to ALLTEL’s applications for ETC status in rural areas, and these applications have been withdrawn. 50 ALLTEL’s public interest showing here is sufficient based on the detailed commitments ALLTEL has made to ensure that it provides high quality service throughout the proposed non- rural service areas. Specifically, despite only seeking designation in areas served by non- rural carriers, ALLTEL has made the same or similar commitments to those made by ETCs in rural areas in the Virginia Cellular Order and the Highland Cellular Order, including setting forth a specific plan for responding to requests for service, agreeing to provide the Commission with data on how high- cost support funds were used, and committing to inform customers of its services, including Lifeline and Link- up, through a variety of media. 51 In addition, ALLTEL has also made service quality commitments comparable to those made in the Virginia Cellular Order and the Highland Cellular Order, including compliance with the Cellular Telecommunications Industry Association (CTIA) Code for Wireless Service and a commitment to provide the Commission 43 See ALLTEL March 1, 2004 Supplement at 6. 44 47 U. S. C. § 214( e)( 6). See Appendix B. 45 See Virginia Cellular Order, 19 FCC Rcd at 1574- 75, para. 26; Highland Cellular Order, 19 FCC Rcd 6431, para. 20. 46 See 47 U. S. C. § 214( e)( 6). See also Appendix B. 47 See, e. g., Cellco Partnership d/ b/ a Bell Atlantic Mobile Petition for Designation as an Eligible Telecommunications Carrier, Memorandum Opinion and Order, CC Docket No. 96- 45, 16 FCC Rcd 39 (2000). 48 See Virginia Cellular Order, 19 FCC Rcd at 1575, para. 27; Highland Cellular Order, 19 FCC Rcd at 6431- 32, para. 21. 49 Alabama Rural Local Exchange Carriers Comments at 5- 18; CenturyTel Reply at 4- 13; OPASTCO Reply at 2- 8; 50 See infra para. 19. 51 Virginia Cellular Order, 19 FCC Rcd at 1575- 1580, paras. 28- 35; Highland Cellular Order, 19 FCC Rcd at 6432-38, paras. 22- 33; ALLTEL March 1, 2004 Supplement at 4- 6. 7 Federal Communications Commission DA 04- 3046 8 with consumer complaint data. 52 Certainly, if ALLTEL is willing to meet these requirements in areas served by non- rural carriers, it would be hard to find that ALLTEL’s application in the present case fell short of meeting the public interest standard. We therefore find that ALLTEL has demonstrated that its designation as an ETC in these non- rural study areas is consistent with the public interest, as required by section 214( e)( 6). 53 16. The Commission is seeking comment on the Recommended Decision of the Federal Joint-Board on Universal Service (Joint Board) concerning the process for designation of ETCs and the Commission’s rules regarding high- cost universal service support. 54 Verizon argues that, in light of the impact that ETC designations have on the universal service fund, the Commission should not rule on any pending ETC petitions until the completion of the rulemaking proceeding. 55 Although Verizon raises important issues, we decline to delay ruling on pending ETC petitions at this time. We believe that grant of these ETC designations will not dramatically burden the universal service fund. For example, even assuming that ALLTEL captures each and every customer located in the affected study areas, the overall size of the high- cost support mechanisms would not significantly increase. 56 Nevertheless, we continue to be mindful on the impact on the universal service fund due to the rapid growth in the number of competitive ETCs. We note that the outcome of the rulemaking proceeding could potentially impact, among other things, the amount of support that ALLTEL and other competitive ETCs receive in the future. 17. We further disagree with Verizon’s argument that we should not designate any additional competitive ETCs because it could have a significant impact on the access charge plan established by the Commission’s CALLS Order. 57 In the voluntarily negotiated CALLS plan, price cap carriers, inter alia, agreed to establish a $650 million target for interstate access support. Similar to other types of universal service support, interstate access support is portable to competitive ETCs. 58 Consequently, because interstate access support is targeted to $650 million, when a competitive ETC receives interstate access support, there is a corresponding reduction in support available to incumbent carriers. As the CALLS plan was being considered, portability of support to competitive ETCs and its relation to the $650 million 52 ALLTEL March 1, 2004 Supplement at 4. Under the CTIA Consumer Code, wireless carriers agree to: (1) disclose rates and terms of service to customers; (2) make available maps showing where service is generally available; (3) provide contract terms to customers and confirm changes in service; (4) allow a trial period for new service; (5) provide specific disclosures in advertising; (6) separately identify carrier charges from taxes on billing statements; (7) provide customers the right to terminate service for changes to contract terms; (8) provide ready access to customer service; (9) promptly respond to consumer inquiries and complaints received from government agencies; and (10) abide by policies for protection of consumer privacy. 53 See 47 U. S. C. § 214( e)( 6). 54 ETC High- Cost NPRM, supra n. 36; Federal- State Joint Board on Universal Service, Recommended Decision, CC Docket No. 96- 45, 19 FCC Rcd 4257 (2004) (Joint Board Recommended Decision). Among other things, the Joint Board recommended that the Commission adopt permissive federal guidelines for states to consider when designating ETCs under section 214 of the Act. Joint Board Recommended Decision, 19 FCC Rcd at 4258, para. 2. 55 See Verizon Comments at 1- 5. 56 For example, out of the five states in which ALLTEL seeks designation, the incumbent carriers in Florida receive the most high- cost support. The total amount of high- cost support reserved by such carriers is approximately 1.52% of the total high cost support available to all ETCs. 57 See generally Verizon Opposition; CenturyTel Reply at 7- 8; CenturyTel Supplemental Comments at 4. See Access Charge Reform, Sixth Report and Order, CC Docket Nos. 96- 262 and 94- 1, Report and Order, CC Docket No. 99- 249, Eleventh Report and Order, CC Docket No 96- 45, 15 FCC Rcd 12962 (2000) (subsequent history omitted) (CALLS Order). 58 See 47 C. F. R. § 54. 307( a). 8 Federal Communications Commission DA 04- 3046 9 target was contemplated. 59 Accordingly, the CALLS plan is functioning as contemplated by the agreement. We further note that the CALLS plan was designed for a five- year period, which ends in 2005. 60 As part of its consideration of the appropriate regulatory mechanism to replace the CALLS plan, the Commission can examine whether the interstate access support mechanism remains sufficient. 61 D. Designated Service Areas 18. We designate ALLTEL as an ETC in the requested service areas in Alabama, Florida, Georgia, North Carolina, and Virginia served by non- rural telephone companies, as listed in Appendix B. 62 This designation is effective immediately. E. ALLTEL’s Request for Withdrawal 19. In its petitions, ALLTEL also sought designation as an ETC in study areas served by rural incumbent LECs in each of the five states. 63 On November 10, 2003, ALLTEL bifurcated its petitions into separate requests for ETC designation in non- rural and rural service areas, “to allow separate and expeditious consideration of . . . the non- rural [incumbent LEC] study areas covered” by these petitions. 64 On May 21, 2004, ALLTEL voluntarily withdrew the portions of those petitions seeking ETC designation in rural service areas, without prejudice to any subsequent refiling of those requests. 65 We grant ALLTEL’s request for partial withdrawal. F. Regulatory Oversight 20. ALLTEL is obligated under section 254( e) of the Act to use high- cost support “only for the provision, maintenance, and upgrading of facilities and services for which support is intended” and is required under section 54.313 of the Commission’s rules to certify annually that it is in compliance with this requirement. 66 ALLTEL has certified to the Commission that, consistent with section 54.313 of the Commission’s rules, all federal high- cost support will be “used for the provision, maintenance and upgrading of facilities and services for which the support is intended, pursuant to Section 254( e)” of the Act in the area for which ALLTEL is designated as an ETC. 67 ALLTEL has further requested that the Commission find that ALLTEL has met the appropriate certification filing deadline in order for it to begin 59 See CTIA Reply Comments at 4- 5 (quoting Comments of Coalition for Affordable Local and Long Distance Services (CALLS), CC Docket Nos. 94- 1, 96- 45, 96- 262, 99- 249, filed Nov. 12, 1999); Sprint Reply at 3 (quoting same). 60 See CALLS Order, 15 FCC Rcd at 12977, 13046, paras. 35- 36, 201. 61 See id., 15 FCC Rcd at 12977, para. 36 (“[ A] s the term of the CALLS Proposal nears its end, we envision that the Commission will conduct a proceeding to determine whether and to what degree it can deregulate price cap LECs to reflect the existence of competition. At that time, the Commission can also examine whether the interstate access universal service support mechanism remains sufficient.”). 62 See Appendix B. 63 See supra note 1. 64 See Letter from Cheryl A. Tritt, Counsel for ALLTEL Communications, Inc. to Marlene H. Dortch, Secretary, FCC, dated November 10, 2003. 65 Letter from Cheryl A. Tritt, Counsel for ALLTEL Communications, Inc. to Marlene H. Dortch, Secretary, FCC, dated May 21, 2004. 66 47 C. F. R. § 54. 313. 67 Alabama Petition at Exhibit F; Florida Petition at Exhibit F; Georgia Petition at Exhibit G; North Carolina Petition at Exhibit G; Virginia Petition at Exhibit F. 9 Federal Communications Commission DA 04- 3046 10 receiving support as of its ETC designation date. 68 Accordingly, we treat ALLTEL’s certifications as timely so that it can begin receiving universal service support as of the date of its ETC designation. 69 21. Separate and in addition to its annual certification filing under rule section 54.313, ALLTEL has committed to submit records and documentation on an annual basis detailing: (1) its progress towards meeting its build- out plans; (2) the number of complaints per 1,000 handsets; and (3) information detailing how many requests for service from potential customers were unfulfilled for the past year. 70 We require ALLTEL to submit these additional data to the Commission and USAC on October 1 of each year beginning October 1, 2005. 71 We find that reliance on ALLTEL’s commitments is reasonable and consistent with the public interest, the Act, and the Fifth Circuit decision in Texas Office of Public Utility Counsel v. FCC. 72 We conclude that fulfillment of these additional reporting requirements will further the Commission’s goal of ensuring that ALLTEL satisfies its obligation under section 214( e) of the Act to provide supported services throughout its designated service area. We note that the Commission may institute an inquiry on its own motion to examine any ETC’s records and documentation to ensure that the high- cost support it receives is being used “only for the provision, maintenance, and upgrading of facilities and services” in the areas where it is designated as an ETC. 73 ALLTEL will be required to provide such records and documentation to the Commission and USAC upon request. We further emphasize that if ALLTEL fails to fulfill the requirements of the statute, the Commission’s rules, or the terms of this Order after it begins receiving universal service support, the Commission has authority to revoke its ETC designation. 74 The Commission also may assess forfeitures for violations of Commission rules and orders. 75 IV. ANTI- DRUG ABUSE ACT CERTIFICATION 22. Pursuant to section 5301 of the Anti- Drug Abuse Act of 1988, no applicant is eligible for any new, modified, or renewed instrument of authorization from the Commission, including authorizations issued pursuant to section 214 of the Act, unless the applicant certifies that neither it, nor 68 Alabama Petition at 13; Florida Petition at 14- 15; Georgia Petition at 16; North Carolina Petition at 16; Virginia Petition at 13. 69 Section 54.313 provides that the certification must be filed by October 1 of the preceding calendar year to receive support beginning in the first quarter of a subsequent calendar year. 47 C. F. R. § 54. 313( d). If the October 1 deadline for first quarter support is missed, the certification must be filed by January 1 for support to begin in the second quarter, by April 1 for support to begin in the third quarter, and by July 1 for support to begin in the fourth quarter. See id. In instances where carriers are not subject to the jurisdiction of a state, the Commission allows an ETC to certify directly to the Commission and USAC that federal high- cost support will be used in a manner consistent with section 254( e). See 47 C. F. R. § 54.313( b). Moreover, although we accept ALLTEL’s certification as timely so that it can receive support as of its ETC designation date, consistent with the Commission’s rules, the relevant state commissions are not precluded from filing future certifications on behalf of ALLTEL stating that universal service support is being used for its intended purposes. See 47 C. F. R. § 54. 313. 70 See ALLTEL March 1, 2004 Supplement at 4- 6. 71 ALLTEL’s initial submission concerning consumer complaints per 1,000 handsets and unfulfilled service requests will include data from the date ETC designation is granted through June 30, 2005. Future submissions concerning consumer complaints and unfulfilled service requests will include data from July 1 of the previous calendar year through June 30 of the reporting calendar year. 72 Texas Office of Public Utility Counsel v. FCC, 183 F. 3d 393, 417- 18 (5 th Cir. 1999). 73 47 U. S. C. §§ 220, 403; 47 C. F. R. § 54. 313. 74 See Declaratory Ruling, 15 FCC Rcd at 15174, para. 15. See also 47 U. S. C. § 254( e). 75 See 47 U. S. C. § 503( b). 10 Federal Communications Commission DA 04- 3046 11 any party to its application, is subject to a denial of federal benefits, including Commission benefits. 76 This certification must also include the names of individuals specified by section 1.2002( b) of the Commission’s rules. 77 ALLTEL has provided a certification consistent with the requirements of the Anti-Drug Abuse Act of 1988. 78 We find that ALLTEL has satisfied the requirements of the Anti- Drug Abuse Act of 1988, as codified in sections 1.2001- 1.2003 of the Commission’s rules. 79 V. ORDERING CLAUSES 23. Accordingly, IT IS ORDERED that, pursuant to the authority contained in section 214( e)( 6) of the Communications Act, 47 U. S. C. § 214( e)( 6), and the authority delegated in sections 0.91 and 0.291 of the Commission’s rules, 47 C. F. R. §§ 0.91, 0.291, ALLTEL Communications, Inc. IS DESIGNATED AN ELIGIBLE TELECOMMUNICATIONS CARRIER throughout its licensed non-rural service area in the states of Alabama, Florida, Georgia, North Carolina, and Virginia to the extent described herein. 24. IT IS FURTHER ORDERED that a copy of this Memorandum Opinion and Order SHALL BE transmitted by the Wireline Competition Bureau to the Alabama Public Service Commission, Florida Public Service Commission, Georgia Public Service Commission, North Carolina Utilities Commission, Virginia State Corporation Commission, and the Universal Service Administrative Company. 25. IT IS FURTHER ORDERED, pursuant to the authority delegated under sections 0.91 and 0.291 of the Commission's rules, 47 C. F. R. §§ 0.91, 0.291, that the request by ALLTEL Communications, Inc. to withdraw its petitions for designation as an Eligible Telecommunications Carrier with regard to areas served by rural telephone companies in the states of Alabama, Florida, Georgia, North Carolina, and Virginia IS GRANTED, as described herein. FEDERAL COMMUNICATIONS COMMISSION Jeffrey J. Carlisle Chief Wireline Competition Bureau 76 47 U. S. C. § 1.2002( a); 21 U. S. C. § 862. 77 See ETC Procedures PN, 12 FCC Rcd at 22949. Section 1.2002( b) provides that a “party to the application” shall include: “( 1) If the applicant is an individual, that individual; (2) If the applicant is a corporation or unincorporated association, all officers, directors, or persons holding 5% or more of the outstanding stock or shares (voting/ and or non- voting) of the petitioner; and (3) If the applicant is a partnership, all non- limited partners and any limited partners holding a 5% or more interest in the partnership.” 47 C. F. R. § 1.2002( b). 78 See Alabama Petition at 13 and Exhibit G; Florida Petition at 15 and Exhibit G; Georgia Petition at 16 and Exhibit H; North Carolina Petition at 16 and Exhibit H; Virginia Petition at 13 and Exhibit G. 79 47 C. F. R. §§ 1. 2001- 2003. 11 Federal Communications Commission DA 04- 3046 12 Appendix A Parties Filing Comments, Reply Comments, Oppositions, Supplemental Comments Petition for Designation as an Eligible Telecommunications Carrier in the state of Alabama Comments Alabama Rural Local Exchange Carriers (Alabama Rural LECs) Reply Comments ALLTEL Communications, Inc. (ALLTEL) CenturyTel of Alabama, LLC (CenturyTel) Organization for the Promotion and Advancement of Small Telecommunications Companies (OPASTCO) Sprint Corporation (Sprint) Opposition Verizon Communications, Inc. (Verizon) Supplemental Comments CenturyTel Supplemental Reply Comments ALLTEL Petition for Designation as an Eligible Telecommunications Carrier in the state of Florida Reply Comments ALLTEL Petition for Designation as an Eligible Telecommunications Carrier in the state of Georgia Comments Cellular Telecommunications & Internet Association (CTIA) National Association of State Utility Consumer Advocates (NASUCA) OPASTCO Reply Comments ALLTEL Opposition Verizon 12 Federal Communications Commission DA 04- 3046 13 Petition for Designation as an Eligible Telecommunications Carrier in the Commonwealth of North Carolina Comments Cellular Telecommunications & Internet Association (CTIA) National Association of State Utility Consumer Advocates (NASUCA) OPASTCO Reply Comments ALLTEL Opposition Verizon Petition for Designation as an Eligible Telecommunications Carrier in the Commonwealth of Virginia Comments CTIA Virginia Rural Southside Telephone Companies Reply Comments ALLTEL OPASTCO Sprint Opposition Verizon Supplemental Reply Comments ALLTEL 13 Federal Communications Commission DA 04- 3046 14 Appendix B Non- Rural Wire Centers for Inclusion in ALLTEL’s ETC Service Area ALABAMA BELLSOUTH SAC 255181 PRVLALMA BYMNALMA FRHPALMA MOBLALSF CYTNALMA EUFLALMA CNVIALMA WBTNALNM CLANALMA MPVLALMA JCSNALNM THVLALMA EVRGALMA GDWRALMA SELMALMT HLVIALMA MTGMALMB WTMPALMA BRTOALMA FTDPALMA TSKGALMA CTRNALNM MOBLALSE MOBLALAZ MOBLALPR MOBLALSK MOBLALAP MOBLALSH MOBLALOS MOBLALSA MTVRALMA BLFNALMA MOBLALTH MOBLALBF MTGMALNO MTGMALMT MTGMALDA MARNALNM UNTWALNM TROYALMA ALCYALMT DDVLALMA MCINALMA ALABAMA VERIZON NORTH SAC 259789 80 JMSNALXA THRSALXA CFVLALXA RCFRALXA ORVLALXA TLLSALXA NTSLALXA BLBTALXA FWRVALXA DPISALXA GDBAALXA IRSEALXA ALBRALXA PNHLALXA ALABAMA VERIZON SOUTH SAC 259788 81 CLIOALXA LSVLALXA FRHMALXA GRGNALXA GNVLALXA MCKNALXA ELBAALXA ENTRALXA KSTNALXA NWBCALXA ANDSALXA GNTTALXA OPPALXA RDLVALXA BTLYALXA DOZRALXA LVRNALXA ARITALXA DLVLALXA MLCYALXA ECHOALXA NWTNALXA OZRKALXA GENVALXA HRFRALXA SMSNALXA SLCMALXA 80 On August 1, 2002, these wire centers were transferred to CenturyTel of Alabama. 81 On August 1, 2002, these wire centers were transferred to CenturyTel of Alabama. 14 Federal Communications Commission DA 04- 3046 15 ABVLALXA HDLDALXA NWVIALXA CLMAALXA DTHNALXA WCBGALXA BNKSALXA BRNDALXA FLORIDA VERIZON FLORIDA SAC 210328 BRBAFLXA ENWDFLXA VENCFLXS VENCFLXA NRPTFLXA OSPRFLXA SEKYFLXA SSDSFLXA SARKFLXA LGBKFLXA SRSTFLXA NRSDFLXA SPRGFLXA ANMRFLXA PLSLFLXA BRTNFLXX PLMTFLXA MYCYFLXA SGBEFLXA PRSHFLXA SPBGFLXS PSDNFLXA SKWYFLXA NGBHFLXA SPBGFLXA INRKFLXX BAYUFLXA LLMNFLXA RSKNFLXA LRGOFLXA GNDYFLXA PNLSFLXA FHSDFLXA WIMMFLXA CLWRFLXA BYSHFLXA DNDNFLXA CNSDFLXA WLCRFLXA ALFAFLXA BHPKFLXA STGRFLXA OLDSFLXA WSSDFLXA HYPKFLXA SWTHFLXA TAMPFLXX YBCTFLXA TRSPFLXA SMNLFLXA TAMPFLXE SLSPFLXA BRNDFLXA BRJTFLXA KYSTFLXA PNCRFLXA CRWDFLXA UNVRFLXA TMTRFLXA SNSPFLXA THNTFLXA NPRCFLXA MLBYFLXA LUTZFLXA PTCYFLXA BARTFLXA FRSTFLXA HDSNFLXA LNLKFLXA HGLDFLXA MNLKFLXA ALTRFLXA WLCHFLXA LKLDFLXA BBPKFLXA LKLDFLXE LKWLFLXA ZPHYFLXA LKLDFLXN WNHNFLXC CYGRFLXA INLKFLXA ABDLFLXA LKWLFLXE DUNDFLXA LKALFLXA PKCYFLXA HNCYFLXA HNCYFLXN POINFLXA FLORIDA BELLSOUTH SAC 215191 KYHGFLMA KYWSFLMA SGKYFLMA BGPIFLMA MRTHFLVE ISLMFLMA KYLRFLMA KYLRFLLS NKLRFLMA PNSCFLPB PNSCFLWA GLBRFLMC PNSCFLBL PNSCFLHC PNSCFLFP CNTMFLLE HLNVFLMA PACEFLPV 15 Federal Communications Commission DA 04- 3046 16 MLTNFLRA WWSPFLSH WWSPFLHI PCBHFLNT PNCYFLMA BKVLFLJF PNCYFLCA JAY FLMA LYHNFLOH MNSNFLMA CDKYFLMA YNTWFLMA YNFNFLMA SYHSFLCC VERNFLMA DNLNFLWM CHPLFLJA CFLDFLMA CSCYFLBA OLTWFLLN BRSNFLMA TRENFLMA GCVLFLMA ARCHFLMA NWBYFLMA MCNPFLMA HAVNFLMA GSVLFLNW GSVLFLMA HWTHFLMA WELKFLMA PMPKFLMA PLTKFLMA LKCYFLMA MDBGFLPM GCSPFLCN STAGFLSH STAGFLBS MXVLFLMA STAGFLMA ORPKFLRW BLDWFLMA MNDRFLLW ORPKFLMA MNDRFLLO JCVLFLWC JCVLFLNO MNDRFLAV JCVLFLRV JCVLFLSJ JCVLFLJT JCVLFLSM JCVLFLCL JCVLFLAR JCVLFLBW PNVDFLMA JCVLFLLF JCBHFLSP JCVLFLFC JCBHFLAB JCBHFLMA JCVLFLOW JCVLFLIA FTGRFLMA YULEFLMA FRBHFLFP FMTNALMT GEORGIA BELL SOUTH SAC 225192 BNBRGAMA CLQTGAES THVLGAMA PLHMGAMA ARTNGAES LKPKGAMA CMLLGAMA NWTNGAHD VLDSGAMA LERYGAMA BCTNGAMA SPRKGAMA ALBYGAMA SYLVGAES LSBGGAMA TFTNGAMA SMVLGAMA WYCRGAMA CORDGAMA BLCSGAES HZLHGAMA LMCYGAMA BXLYGAES ESMNGAES CCHRGAMA JHCRGAES VDALGAMA LYNSGAMA DBLNGAMA CXTNGAMA WGVLGAES SWBOGAES SVNHGAWB SVNHGASI SVNHGADE POLRGAMA SVNHGABS SVNHGAWI SVNHGAGC SNVLGAES TBISGAMA WDLYGAMA LSVLGAMA MLLNGAMA GBSNGAES WRNSGAMA WRTNGAMA WYBOGAES SRDSGAES THSNGAMA HRLMGAMA HPHZGAES APNGGAES AGSTGAFL AGSTGAAU AGSTGATH AGSTGAMT 16 Federal Communications Commission DA 04- 3046 17 NORTH CAROLINA BELLSOUTH SAC 235193 ACMENCMA ARSNNCMA APEXNCCE ATSNNCMA BLMTNCCE BSCYNCMA BRGWNCMA BURLNCDA BURLNCHA CRBHNCCE CARYNCCE CARYNCWS CSHYNCMA CPHLNCRO CHRLNCER CHRLNCCR CHRLNCRE CHRLNCLP CHRLNCBO CHRLNCOD CHRLNCSH CHRLNCTH CHRLNCCA CHRLNCCE CHRLNCMI CHRLNCDE CHRLNCUN CHVLNCCE CLMTNCMA CLEVNCMA GSTANCDA DVSNNCPO DNVRNCMA BURLNCEL FAMTNCMA RLGHNCGA GSTANCSO LWLLNCMA GTWDNCMA GBSNNCMA GLBONCMA GLBONCAD SXPHNCMA GNHMNCMA GNBONCPG GNBONCAP GNBONCAS GNBONCEU GNBONCLA GNBONCHO GNBONCMC GRVRNCMA HMLTNCMA SCHLNCHA HSVLNCCE JULNNCMA KGMTNCMA KNDLNCCE LTMRNCCE LRBGNCMA LWDLNCCE LENRNCHU LENRNCHA LNTNNCMA LCSTNCMA LNBHNCMA LMTNNCMA MADNNCCE MLTNNCMA MNTINCMA MGTNNCGL MGTNNCGR MTHLNCMA MTOLNCCE NWTNNCMA PMBRNCCE RLGHNCJO RLGHNCMO RLGHNCGL RLGHNCSB RLGHNCHO RLGHNCSI RDVLNCSI RDVLNCMA RCHMNCMA RWLDNCMA RFFNNCMA SLBRNCMA SCHLNCMA SELMNCMA SHLBNCMA SOPTNCCE STNLNCCE SSVLNCMA SSVLNCJE STPNNCMA SRFDNCCE TYVLNCMA TRMNNCMA LNTNNCVA WNDLNCPI WLMGNCLE WLMGNCFO WLMGNCWI WGVLNCMA WNSLNCCL WNSLNCAR WNSLNCVI WNSLNCWA WNSLNCLE WNSLNCFI WNSLNCWH WNSLNCGL ZBLNNCCE 17 Federal Communications Commission DA 04- 3046 18 NORTH CAROLINA VERIZON SOUTH NC SAC 234334 CRDMNCXA CRDMNCXM DRHMNCXE DRHMNCXB DRHMNCXG DRHMNCXM DRHMNCXD DRHMNCXA DRHMNCXT DRHMNCXC ALTNNCXA MONRNCXA GSCKNCXA DRHMNCXH NORTH CAROLINA VERIZON SOUTH NC (CONTEL) SAC 230509 KNISNCXA NORTH CAROLINA NORTH STATE SAC 230491 HGPNNCXE HGPNNCXB HGPNNCXA HGPNNCXD HGPNNCXF HGPNNCXC RNMNNCXA THVLNCXB THVLNCXA VIRGINIA VERIZON S VA (CONTEL) SAC 190233 ALBRVAXA AMHRVAXA APMTVAXA BMNVAXA BYKNVAXA CPRNVAXA CRTDVAXA CSCYVAXA HCKRVAXA GRBRVAXA CLVLVAXA CRLDVAXA DNDRVAXA DSPAVAXA DSWLVAXA EMPRVAXA EPFKVAXA FKLNVAXB GLDSVAXA GLCSVAXA GRBRVAXB SBWKVAXA HNVRVAXA HAYSVAXA IVORVAXA JRRNAXA LRVLVAXA OLCHVAXA ALWDVAXA SMFDVAXA CLMTVAXA STCKVAXA HLLDVAXA CHKTVAXA SRRWAXA PRANVAXB PUNGVAXA PRANVAXA WKFDVAXA WNDSVAXA 18 Federal Communications Commission DA 04- 3046 19 VIRGINIA VERIZON VA, INC. SAC 195040 APLCVAAP PNRWAPR ASLDVAAS BDFRVABD BTHIVABT BGISVABI BSGPVABG DCVLVADV CHCYVACC CHHMVACH CHSKVACD CHSKVAGU CHSKVADC CHESVACR WHOKVAWO CLWDVACW CLNCVACL CLVRVACL COBNVACB CLHGVACO CNCRVACN CGVLVACL CLPPVARV CLPPVACU CLPPVAGR DANNVADA DAVLVAFP DVPNADP DNWDVADW FIFEVAFI GCLDVAGO GNWDVAGW HMPNVAWD HMPNVAQN HMPNVADC HMPNVAAB HYSIVAHY HNKRVAHK HPWLVAHW JNVLVAJV LBNNVALB SWCKVASC CLPPVALI LVTNVALN LYBGVACV LYBGVAYB LYBGVANL LYBGVATM LYBGVAOF LYBGVACH LYBGVAMH MDSNVAMA MNKNVAMN MCKWAMK MCHWAMV MDLNAMD NLFRVANF NWNWVAJF NWNWVAHU NWNWVAYK NWNWVAHV NWNWVAND NRFLVAGS NRFLVAWC NRFLVABS NRFLVASP NRFLVABL NRFLVAOD NRFLVAOV NRTNVANO PNGPVAPG PONDVAPO PTBGVACD PTBGVAPB PTMOVAHS PTMOVAHF PWHNAPW PRFRVAPF QNTNVAQN VARNVAVR RCMDVACG RCMDVAIT RCMDVALS RCMDVAHL RCMDVAGK RCMDVAPS RCMDVASR RCMDVAGY RCMDVAGR RCMDVARA RCMDVAPE RCMDVAHS RCMDVASN RCMDVAHR RCMDVATC RNGLVARG RKVLVARK RSHLVALE LBNNVARD SNTNVASS STCHVASC STPLVASP SNMTVASM DRVRVADR SFFLVASK WHVLVAWH TOANVATO VRBHVAIR VRBHVAIL VRBHVASR VRBHVACC VRBHVAPT VRBHVARC VRBHVAVB SWVLVASV VRBHVACT VRBHVAGN WVRLVAWV WLBGVAWM WNTRVAWG WISEVAWI 19