Federal Communications Commission DA 14-1387
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Revision of ARMIS Annual Summary Report
(FCC Report 43-01), ARMIS USOA Report
(FCC Report 43-02), ARMIS Joint Cost Report
(FCC Report 43-03), ARMIS Access Report
(FCC Report 43-04), ARMIS Service Quality
Report (FCC Report 43-05), ARMIS Customer
Satisfaction Report (FCC Report 43-06), ARMIS 
Infrastructure Report (FCC Report 43-07), 
ARMIS Operating Data Report (FCC Report 43-
08), ARMIS Forecast of Investment Usage Report
(FCC Report 495A), and ARMIS Actual Usage of
Investment Report (FCC Report 495B) for Certain
Class A and Tier 1 Telephone Companies
Petition of Qwest Corporation for
Forbearance from Enforcement of the
Commission’s ARMIS and 492A
Reporting Requirements Pursuant to 47
U.S.C. § 160
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CC Docket No. 86-182
WC Docket No. 07-204
ORDER
Adopted:  September 24, 2014 Released:  September 24, 2014
By the Chief, Industry Analysis and Technology Division, Wireline Competition Bureau: 
 
1. In this Order, we revise certain aspects of the electronic filing procedures for Automated 
Reporting Management Information System (ARMIS) reports pursuant to the authority delegated to the 
Wireline Competition Bureau (Bureau) in the ARMIS Review Order1 to comply with the Commission’s 
cyber security policies.  These changes should neither increase the burden on those filing these reports nor
affect interested parties that view these reports, but are essential to maintaining the integrity and security 
of the Commission’s information systems and data network. 
  
1 1998 Biennial Regulatory Review -- Review of ARMIS Reporting Requirements, Petition for Forbearance of the 
Independent Telephone and Telecommunications Alliance, CC Docket No. 98-117, AAD File No. 98-43, 
Report and Order and Fifth Memorandum Opinion and Order, 14 FCC Rcd 11443, 11453-54, paras. 18-20 (1999) 
(ARMIS Review Order).
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2. Background.   In 1999, the Commission delegated to the Bureau “the authority to take the 
necessary steps to implement electronic filing of ARMIS data.”2 In response, the Bureau has released 
numerous orders and revised instructions to improve the reports and facilitate the filing process, including 
establishing the Electronic ARMIS Filing System (EAFS).3 For electronic filing, the Bureau adopted four 
basic requirements:  (1) beginning with reporting year 1990, all ARMIS reports must be filed 
electronically; (2) all files must be coded in ASCII; (3) a separate ASCII file must be prepared for each 
report; and (4) the electronic submission will serve as the carrier’s official filing.4
3. Since electronic filing was adopted, the number and volume of ARMIS reports has decreased 
considerably.  Carriers formerly filed as many as ten ARMIS reports annually, with each report 
containing one or more data tables.5 The largest carriers were granted conditional forbearance from filing 
the vast majority of these reports in 2008, and, by 2013, the remaining carriers subject to these reports 
were granted similar conditional forbearance.6 By the time of the annual filing in 2013, carriers filed at 
most only the ARMIS 43-01 report and certain fields of the ARMIS 43-08 report using EAFS. Assuming 
all eligible carriers take advantage of the Commission’s most recent grant of conditional forbearance,7
those carriers subject to these reports (large and mid-size carriers) will each have to file only the pole 
attachment data included in ARMIS Report 43-01, Table III, and ARMIS Report 43-08, Table III, 
Columns FC, FD, and FE (line count information) and Column FI (growth in access line information). 
Also since electronic filing was adopted, increases in unauthorized computer access have led the federal 
government to adopt stringent cyber security requirements.  The EAFS predates recent security upgrades 
and its information submission capabilities are not compatible with required security regulations, 
mandates and directives.  
4. Discussion.  To ensure the security of the Commission’s electronic filing systems and data 
network, we are disabling the EAFS submission capabilities, and modifying ARMIS electronic filing 
procedures to require electronic submission using the Commission’s Electronic Comment Filing System 
(ECFS) rather than EAFS.  ECFS is used routinely by carriers for the filing of comments, petitions, 
waivers and other information, as well as by the public to access the full records of proceedings.  Thus, 
we believe that both those filing ARMIS reports and those wishing to access these reports will have no 
difficulty using ECFS.
  
2 ARMIS Review Order, 14 FCC Rcd at 11466, para. 45.  Only price cap carriers and carriers with annual revenues 
above a certain threshold were ever required to file ARMIS reports.  See Federal Communications Commission, 
ARMIS Filing Requirements for Carriers (Mar. 14, 2014), http://transition.fcc.gov/wcb/armis/filereqt.html.  
3 See, e.g., Revision of ARMIS Annual Summary Report et al., AAD File No. 95-91 et al., Order, 17 FCC Rcd 25421 
(Industry Analysis & Tech. Div. 2002) (ARMIS Revision Order).
4 ARMIS Revision Order, 17 FCC Rcd at 25453, Part VIII.
5 Federal Communications Commission, ARMIS Data Descriptions (Mar. 14, 2014), 
http://transition.fcc.gov/wcb/armis/descriptions.html.
6 See Service Quality Customer Satisfaction, Infrastructure and Operating Data Gathering, Petition of AT&T Inc. 
for Forbearance Under 47 U.S.C. § 160(c) from Enforcement of Certain of the Commission’s ARMIS Reporting  
Requirements et. al., WC Docket No. 08-190 et al., Memorandum Opinion and Order and  Notice of Proposed 
Rulemaking, 23 FCC Rcd 13647 (2008); Petition of Qwest Corporation for Forbearance from Enforcement of the 
Commission’s ARMIS and 492A Reporting  Requirements Pursuant to 47 U.S.C. § 160(c) et al., WC Docket Nos. 
07-204, 07- 273, Memorandum Opinion and Order, 23 FCC Rcd 18483, 18484, para 1, 18487, para. 8 (2008) 
(ARMIS Forbearance Order); Petition of USTelecom for Forbearance Under 47 U.S.C. § 160(c) from Enforcement 
of Certain Legacy Telecommunications Regulations, WC Docket No. 12-61, Memorandum Opinion and Order, 28 
FCC Rcd 7627, 7676, para. 108 (2013) (USTelecom Forbearance Long Order), pet. for rev. pending sub nom. 
Verizon v. FCC, No. 13-1220 (D.C. Cir. filed July 15, 2013).
7 USTelecom Forbearance Long Order, 28 FCC Rcd at 7676, para. 108.
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5. The Bureau will release a public notice announcing the transition date to ECFS, which will be 
prior to the next annual filing on April 1, 2015.  As of this transition date, all ARMIS filings, including 
resubmissions, are to be made in CC Docket No. 86-182, which ensures that reports are located in the same 
docket and will be easy to find.8  Although no further submissions will be accepted via EAFS, we 
anticipate that website links to EAFS will remain active on the Commission’s website ARMIS pages so 
that data from earlier ARMIS filings can be accessed in the same manner as in the past.  However, filings 
after the transition date can neither be submitted nor viewed in EAFS.  
6. To facilitate viewing ARMIS reports in ECFS, we are also modifying the requirements that 
all files must be coded in ASCII and that a separate ASCII file be submitted for each report.9 Instead, 
carriers must submit all ARMIS reports in a machine-searchable, reader-friendly file format10 and include 
all reports that are required for the carrier’s annual filing together in a single ECFS filing. Thus, for 
example, after the transition date, carriers required to file pole attachment data formerly contained in 
ARMIS Report 43-01, Table III in WC Docket No. 07-204 as a condition of forbearance should include 
their pole attachment data in this single ECFS filing, along with Table III of ARMIS Report 43-08.   
ARMIS filing requirements regarding table format, including row and column definitions, will remain the 
same although adjustments to the ARMIS filing instructions will be made to allow the change from the 
use of ASCII text to any reader-friendly format.11 The Bureau will announce the availability of revised 
ARMIS filing instructions in the public notice providing the transition date from EAFS to ECFS.
7. A transmittal letter and a certification signed by a corporate officer must still accompany each 
report, including filings of pole attachment data, and mid-size carriers must continue to submit the 
certification required by section 64.905 of the Commission’s rules.12 These must also be submitted as 
part of the carrier’s ARMIS filing in ECFS.13
8. We urge those carriers that are eligible for conditional forbearance from the ARMIS 43-01 
filing requirement under the Commission’s recent order and are interested in obtaining forbearance to file 
their compliance plans well in advance of the April 1, 2015 deadline so that the Commission has 
sufficient opportunity to review the plans.  Carriers subject to ARMIS requirements who have not met the 
conditions for forbearance will be expected to file the full ARMIS Report 43-01, Tables I, II, and III. 
  
8 Although carriers were previously required to file the pole attachment data in WC Docket No. 07-204, ARMIS 
Forbearance Order, 27 FCC Rcd at 18491, we believe that requiring that all ARMIS data be filed in a single docket 
will facilitate public access to the data.
9 ARMIS Revision Order, 17 FCC Rcd at 25453, Part VIII. 
10 For the purposes of filing ARMIS reports, we define machine searchable to mean a format which is searchable by 
computer. For example, tables filed in Microsoft Excel or Microsoft Word format, though they will be converted to 
Adobe Acrobat by ECFS, will still be searchable when converted.  Filers should avoid submitting ARMIS report 
files that have been scanned, or generated from any file that has been scanned, because this can compromise the 
readability of and ability to search the table contents. (This restriction does not apply to transmittal letters and 
certifications.)  We define reader friendly to mean any format that can be read without computer conversion. For 
example, in ARMIS reports, we expect that table headers and other identifying information will be readable by the 
public when the file is accessed via ECFS.  
11 The revised ARMIS instructions will be posted on the Commission’s website at 
http://transition.fcc.gov/wcb/armis/descriptions.html.
12 FCC ARMIS Report – Instructions at 8 (Dec. 2013), 
ftp://ftp.fcc.gov/pub/Daily_Releases/Daily_Business/2014/db0313/DOC-326044A8.pdf.
13 Carriers will continue to be obligated to correct any erroneous data in their submissions.  See id. at 7.   
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9. Paperwork Reduction Act (PRA).  The Commission has PRA authority to collect the 
information contained in the ARMIS Reports.14 The Commission will report the changes adopted in this 
Order to the Office of Management and Budget.  
10. Accordingly, IT IS ORDERED, pursuant to the authority contained in sections 1, 4(i), 4(j), 
201-205, 215, 218, 219, and 220 of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 
154(i), 154(j), 201-205, 215, 218, 219, and 220, and sections 0.91 and 0.291 of the Commission’s rules, 
47 C.F.R. §§ 0.91 and 0.291, that FCC Report 43-01, the Annual Summary Report, FCC Report 43-02, 
the USOA Report, FCC Report 43-03, the Joint Cost Report, FCC Report 43-04, the Access Report, FCC 
Report 43-05, the Service Quality Report, FCC Report 43-07, the Infrastructure Report, FCC Report 43-
08, the Operating Data Report, ARMIS Forecast of Investment Usage Report (FCC Report 495A), and 
ARMIS Actual Usage of Investment Report (FCC Report 495B) for Certain Class A and Tier 1 
Telephone Companies ARE REVISED, as set forth above.
FEDERAL COMMUNICATIONS COMMISSION
Rodger A. Woock 
Chief 
Industry Analysis and Technology Division
Wireline Competition Bureau
  
14 OMB Control Numbers 3060-0512, 3060-0496.