Federal Communications Commission DA 16-117
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Lifeline and Link Up Reform and 
Modernization
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WC Docket No. 11-42
ORDER
Adopted:  February 2, 2016 Released: February 2, 2016
By the Chief, Wireline Competition Bureau:
1. In this Order, in response to various requests the Wireline Competition Bureau (Bureau) 
extends the transition period before the effective date of the Commission’s interpretation of the term 
“former reservations in Oklahoma,” as used within section 54.400(e) of the Commission’s rules,
1
for 120 
days, until June 8, 2016.  In addition, in order to provide impacted parties additional certainty regarding 
the boundaries of the “former reservations in Oklahoma,” we release a digital shapefile in conjunction 
with this Order.
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2. Background. On June 18, 2015, the Commission adopted the 2015 Lifeline Reform 
Order to further modernize the Lifeline program.
3
  As part of its reform, the Commission for the first time 
formally interpreted “the former reservations in Oklahoma” within section 54.400(e) of the Commission’s 
rules – defining it by the geographic boundaries reflected in the Historical Map of Oklahoma 1870-1890 
(Oklahoma Historical Map or Map),
4
which the Commission found would “improv[e] administration of 
the Lifeline program and distribution of enhanced Tribal support.”
5
  In order to ensure an effective 
transition to the new map for all affected parties, and to ensure that the new map accurately embodied the 
“former reservations in Oklahoma,” the Commission provided a 180-day transition period from the 
effective date of the 2015 Lifeline Reform Order to implement the Commission’s interpretation of section 
54.400(e).
6
  Based on the 180-day transition period, the Commission’s interpretation of “former 
reservations of Oklahoma” utilizing the Oklahoma Historical Map is scheduled to become effective on 
February 9, 2016.
3. The Order also required the Commission to “actively seek government-to-government 
consultation with Tribal Nations in Oklahoma on the efficacy and appropriateness of other maps and 
                                                     
1
See Letter from Bob Anthony, Chairman, Oklahoma Corporation Commission, to Marlene H. Dortch, Secretary, 
FCC, WC Docket No. 11-42, at 2 (filed Nov. 18, 2015) (OCC Ex Parte).
2
Federal Communications Commission, Enhanced Lifeline Support Maps, https://www.fcc.gov/general/oklahoma-
enhanced-lifeline-support-maps (last visited Feb. 2, 2016).
3
Lifeline & Link Up Reform & Modernization, Second Further Notice of Proposed Rulemaking, Order on 
Reconsideration, Second Report and Order, and Memorandum Opinion and Order, 30 FCC Rcd 7818 (2015) (2015
Lifeline Reform Order or Order).
4
Id. at 7903, para. 257.
5
Id. at 7904, para. 260.
6
Id. at 7907, para. 265.
Federal Communications Commission DA 16-117
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geospatial information assets.”
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  The Commission directed the Office of Native Affairs and Policy 
(ONAP) to coordinate the consultation “for the specific purposes of ensuring the accuracy and operational 
effectiveness of the boundaries as presented in the Oklahoma Historical Map.”
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  If the Bureau determines 
that “the Oklahoma Historical Map should be departed from in any way,” the Bureau is instructed to 
provide “a further revised interpretation of the appropriate boundaries of the former reservations in 
Oklahoma” to the Commission and “provide impacted parties an appropriate additional transition 
period.”
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4. Government-to-government consultation began soon after the adoption of the 2015 
Lifeline Reform Order.  In-person consultations between ONAP, other Commission staff, and Oklahoma 
Tribal Nations occurred in Norman, Oklahoma and Tulsa, Oklahoma on August 5 and 7, 2015, 
respectively.  At those consultations, Commission staff met with representatives from 10 Tribal nations 
and 2 Native organizations to discuss the impact of the proposed changes in the 2015 Lifeline Reform 
Order and the implementation of the Oklahoma Historical Map.  At the same time as the August 
consultations, and also as part of the consultation process, the Commission developed a digital version of 
the adopted Oklahoma Historical Map for Tribal representatives to review.  Once the digital version of 
the Map was available, the Commission sent a letter to Oklahoma Tribal leaders explaining how to access 
the digital version and soliciting comments regarding the Map’s accuracy.
10
  Soon thereafter, the Bureau 
and ONAP consulted with Tribal leaders, via teleconference, to further discuss the Map and the best ways 
for interested parties to participate in the consultation process.  Finally, Commission staff most recently 
engaged in several in-person consultations with Tribal leaders on January 12 and 13, 2016 in Norman, 
Oklahoma and Catoosa, Oklahoma to discuss the use of the Oklahoma Historical Map as well as other 
issues impacting Lifeline and Link Up on Tribal lands. 
5. While some Oklahoma Tribal leaders believe that the Oklahoma Historical Map 
accurately represents the “former reservations in Oklahoma”,
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the Cherokee Nation has concerns 
regarding the accuracy of the Map’s boundaries.  Specifically, the Cherokee Nation argues that the 
Cherokee Outlet
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should remain as a “former reservation in Oklahoma.”
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  The Cherokee Nation states 
that the Cherokee Outlet was given to the Cherokee Nation in the 1835 Treaty of New Echota,
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and that 
the Cherokee Nation retained possession of the Cherokee Outlet until a forced sale in 1889.
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6. On November 18, 2015, the OCC requested a 90-day extension of the effective date of 
the Commission’s interpretation of the “former reservations in Oklahoma” using the Oklahoma Historical 
                                                     
7
Id. at 7907, para. 265.
8
Id.
9
Id. at 7907, para. 266.
10
Letter from Irene M. Flannery, Acting Chief, Office of Native Affairs and Policy, FCC Consumer and 
Governmental Affairs Bureau, and Ryan B. Palmer, Division Chief, Telecommunications Access Policy Division, 
FCC Wireline Competition Bureau, to Tribal Nations Leaders (Nov. 2, 2015) (WC Docket No. 11-42, filed Dec. 31, 
2015) (Tribal Leader Letter).
11
Letter from Kay Rhoads, Senior Chief, Sac and Fox Nation, to Irene Flannery, Acting Chief, Office of Native 
Affairs and Policy, FCC, WC Docket No. 11-42 (filed Dec. 31, 2015).
12
2015 Lifeline Reform Order at 7906, para. 264 & n.531 (describing the Cherokee Outlet as “a 60 mile strip of land 
approximately 225 miles long on the northern edge of Oklahoma between the 96
th
and 100
th
meridians, into which, 
over time, certain Tribal Nations obtained their Tribal lands in Oklahoma.”).    
13
Cherokee Nation Comments, WC Docket No. 11-42, at 3-4 (filed Dec. 4, 2015).
14
Id.
15
Id.
Federal Communications Commission DA 16-117
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Map.
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  On December 21, 2015, Cox Communications, Inc. (Cox) filed comments supporting the OCC’s 
request and stating that it would need to begin work by December 31, 2015, in order to comply with the 
February 9, 2016 deadline.
17
  On January 15, 2016, Assist Wireless filed comments supporting the OCC’s 
request for an extension, but separately requested an additional extension of the implementation deadline, 
for a period of either 120 or 180 days.
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  Each party expressed a desire for additional electronic mapping 
resources from the Commission in order to ensure proper implementation of the newly adopted 
interpretation of “former reservations in Oklahoma.”
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7. Discussion.  We find persuasive the concern that “the current effective date of February 
9, 2016, will preclude ETCs from being able to provide consumers with adequate advance notice” of the 
change in areas eligible for enhanced Tribal support.
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  While the extensions requested ranged from 90 to 
180 days, we conclude that a 120-day extension will give affected parties sufficient notice without 
causing undue delay.  We therefore grant the request for an extension of the effective date of the 
Commission’s interpretation of “former reservations in Oklahoma” within section 54.400(e) and extend 
the implementation date of the Map by 120 days, until June 8, 2016.  Moreover, while the Bureau has 
already shared a digital file with Tribal Nations during the consultation process concerning the Map 
adopted by the 2015 Lifeline Reform Order, we recognize that additional electronic mapping resources 
would be helpful to parties in their implementation in efforts.  Accordingly, in conjunction with today’s 
Order, the Bureau will release a shapefile showing the boundaries of the Oklahoma Historical Map as 
adopted in the 2015 Lifeline Reform Order.  Providing this map in advance of implementation will help to 
ensure an orderly and efficient transition process by allowing providers and consumers to determine 
geocoded locations within the “former reservations in Oklahoma” map adopted by the Commission.
8. We also believe that this brief extension of time is warranted in light of the results of the 
Tribal consultation that occurred pursuant to the 2015 Lifeline Reform Order.  The Commission, in 
adopting its interpretation of “former reservations in Oklahoma” emphasized the importance of consulting 
with the Tribal Nations to ensure the accuracy of the Oklahoma Historical Map.  During the consultation 
process, Bureau and ONAP staff had the opportunity to learn more about the Cherokee Nation’s concerns 
regarding the Cherokee Outlet’s status as a “former reservation in Oklahoma.”  Extending the Map’s 
implementation date gives the Commission an opportunity to appropriately evaluate and respond to the 
concerns that were raised during the consultation process.
9. With that consideration in mind, the Bureau will also release, at the same time as the 
shapefile described above, a second map that highlights the boundaries of the Cherokee Outlet that the 
Cherokee Nation contends should remain as Tribal lands for the Lifeline and Link Up programs.
10. ACCORDINGLY, IT IS ORDERED, pursuant to the authority contained in sections 1-4 
and 254 of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151-154 and 254, and sections 
0.91, 0.291, and 1.3 of the Commission’s rules, 47 C.F.R. §§ 0.91, 0.291, and 1., that the OCC’s request 
for extension of time to implement section 54.400(e) is granted.
                                                     
16
OCC Ex Parte.
17
Letter from Jenny Prime, Director, Regulatory Affairs, Cox Communications, to Marlene H. Dortch, Secretary, 
FCC, WC Docket No. 11-42, at 1-2 (filed Dec. 21, 2015) (Cox Letter).
18
Letter from John Heitmann, Counsel, Assist Wireless, LLC and Easy Telephone Services Company dba Easy 
Wireless, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 11-42 et al., at 1 (filed Jan. 15, 2016) (Assist 
Wireless Ex Parte).  
19
Id. 
20
OCC Ex Parte at 2.
Federal Communications Commission DA 16-117
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FEDERAL COMMUNICATIONS COMMISSION
Matthew S. DelNero
Chief
Wireline Competition Bureau