Federal Communications Commission DA 16-260
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Special Access for Price Cap Local Exchange 
Carriers
AT&T Corporation Petition for Rulemaking to 
Reform Regulation of Incumbent Local Exchange 
Carrier Rates for Interstate Special Access Services
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WC Docket No. 05-25
RM-10593
ORDER
Adopted:  March 9, 2016 Released:  March 9, 2016
By the Associate Chief, Wireline Competition Bureau:
1. In this Order, the Wireline Competition Bureau (Bureau) grants the objections filed by 
AT&T and Verizon to a request filed by Bruce A. Kushnick, and the objections of CenturyLink and 
Verizon to a request from Neil Stevens, seeking access to Confidential and Highly Confidential data and 
information submitted in response to the data collection in the business data services (special access) 
rulemaking proceeding.
2. On December 11, 2012, the Federal Communications Commission (Commission or FCC) 
adopted the Data Collection Order, initiating a data collection for a comprehensive analysis of the market 
for business data services (Collection).1 Those required to respond to the collection included “providers 
and purchasers of special access services as well as some entities that provide best efforts business 
broadband Internet access services” (the Submitting Parties).2 The Collection and analysis are part of a 
rulemaking proceeding to reform the Commission’s rules for the regulation of business data services.3  
3. The Bureau issued a Data Collection Protective Order on October 14, 2014, pursuant to 
delegated authority, establishing the process for designating, submitting and accessing the data and 
information submitted.4 The Data Collection Protective Order is a supplement to protective orders 
  
1 Special Access for Price Cap Local Exchange Carriers; AT&T Corp. Petition for Rulemaking to Reform 
Regulation of Incumbent Local Exchange Carrier Rates for Interstate Special Access Services, Order and Further 
Notice of Proposed Rulemaking, 27 FCC Rcd 16318 (2012) (Data Collection Order); Report and Order, 28 FCC 
Rcd 13189 (WCB 2013); Order on Reconsideration, 29 FCC Rcd 10899 (WCB 2014); Order, 29 FCC Rcd 14346 
(WCB 2014).  The last group of data submissions was due February 27, 2015.  See Special Access for Price Cap 
Local Exchange Carriers; AT&T Corp. Petition for Rulemaking to Reform Regulation of Incumbent Local Exchange 
Carrier Rates for Interstate Special Access Services, Order and Further Notice of Proposed Rulemaking, 29 FCC 
Rcd 14346, 14346, para. 1 (2014).
2 See Data Collection Order, 27 FCC Rcd at 16327, para. 20.
3 See id. at 16319, para. 1.
4 Special Access for Price Cap Local Exchange Carriers, AT&T Corp. Petition for Rulemaking to Reform 
Regulation of Incumbent Local Exchange Carrier Rates for Interstate Special Access Services, Order and Data 
Collection Protective Order, 29 FCC Rcd 11657 (WCB 2014) (Data Collection Protective Order); Order and 
Modified Data Collection Protective Order, 30 FCC Rcd 10027 (WCB 2015).
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previously issued in the proceeding.5 Parties seeking access to Confidential and Highly Confidential data 
and information are required to file executed Acknowledgements of Confidentiality (Acknowledgements) 
agreeing to be bound by the terms of the applicable protective order, and Submitting Parties are given an 
opportunity to object to the potential Reviewing Parties’ access.  Under the terms of the Data Collection 
Protective Order, the objection period is within five business days from when the Bureau announces the 
filing of Acknowledgements by public notice.6
4. On October 7, 2015, the Bureau released a public notice announcing that Mr. Kushnick 
on behalf of the New Networks Institute (NNI) had filed an Acknowledgement seeking access to the 
collected data pursuant to the Data Collection Protective Order.7 Mr. Kushnick also filed signed 
Acknowledgements seeking access to information submitted in the proceeding pursuant to the Modified 
First Protective Order and the Second Protective Order.8 Objections were filed by two Submitting 
Parties, AT&T and Verizon, which questioned Mr. Kushnick’s qualifications to access the information 
protected under all three of these protective orders.9  
5. AT&T, a Submitting Party, filed an objection on October 13, 2015, stating that Mr. 
Kushnick does not qualify to obtain access to the Confidential or Highly Confidential submissions under 
the protective orders adopted in this rulemaking because neither he nor the entity he filed on behalf of, 
NNI, is a Participant in the proceeding as defined in the protective orders.10 A “Participant,” as defined 
by the Data Collection Protective Order, is “a person or entity that has filed, or has a good faith intention 
to file, material comments in this proceeding.”11 Verizon, also a Submitting Party, raised the same 
objection on October 15, 2015.12 Mr. Kushnick replied on October 22, 2015, arguing that NNI is 
qualified under the protective orders as a Participant because “it does intend to participate in this 
proceeding and will do so in a meaningful way.” 13 In response, AT&T stated that Mr. Kushnick’s “bare, 
self-serving assertion” of intent to participate in the proceeding “cannot satisfy the protective order’s 
  
5 See Data Collection Protective Order, 29 FCC Rcd at 11665-66, paras. 23-24.  The earlier protective orders are the 
Modified First Protective Order and the Second Protective Order.  Special Access for Price Cap Local Exchange 
Carriers; AT&T Corporation Petition for Rulemaking to Reform Regulation of Incumbent Local Exchange Carrier 
Rates for Interstate Special Access Services, Modified Protective Order, 25 FCC Rcd 15168 (WCB 2010) (Modified 
First Protective Order); Second Protective Order, 25 FCC Rcd 17725 (WCB 2010) (Second Protective Order).
6 Data Collection Protective Order, 29 FCC Rcd at 11665, para. 23, 11673, Appx. A at para. 5.
7 Additional Parties Seeking Access to Data and Information Filed in Response to the Special Access Data 
Collection, Public Notice, 30 FCC Rcd 10889 (WCB 2015).  
8 Letter from Bruce A. Kushnick, Telecom Analyst, NNI, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 
05-25 (filed Sept. 30, 2015).
9 Letter from Rishi P. Chhatwal, Counsel to AT&T, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-25 
(filed Oct. 13, 2015) (AT&T Objection); Letter from Curtis L. Groves, Assistant General Counsel, Federal 
Regulatory and Legal Affairs, Verizon, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-25 (Oct. 15, 
2015) (Verizon Kushnick Objection); Letter from Curtis L. Groves, Assistant General Counsel, Federal Regulatory 
and Legal Affairs, Verizon, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-25 (filed Nov. 16, 2015) 
(Verizon Stevens Objection); Letter from Christopher T. Shenk, Counsel to AT&T, to Marlene H. Dortch, Secretary, 
FCC, WC Docket No. 05-25 (filed Dec. 18, 2015) (AT&T Reply).
10 AT&T Objection at 2; AT&T Reply at 1.
11 Data Collection Protective Order, 29 FCC Rcd at 11671, Attach. A at para. 1.  
12 Verizon Kushnick Objection at 1.
13 Letter from Bruce A. Kushnick, Executive Director, NNI, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 
05-25, at 1, 2 (citation omitted) (Oct. 22, 2015) (NNI Reply).
Federal Communications Commission DA 16-260
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standard” of a Participant.14 On December 24 and 31, 2015, and February 17, 2016, Mr. Kushnick filed 
further responses taking issue with the attempts of AT&T and Verizon to block his access to the data.15  
6. On November 6, 2015, the Bureau released a public notice announcing that Mr. Stevens, 
a “tech policy writer at Red State,” had filed an Acknowledgement seeking access to Confidential and 
Highly Confidential data and information pursuant to the Data Collection Protective Order.16 Mr. 
Stevens also filed signed Acknowledgements seeking access to the submissions pursuant to the Modified 
First Protective Order and Second Protective Order.17 Submitting Parties, CenturyLink and Verizon, 
filed objections to the access sought by Mr. Stevens.18 CenturyLink states that “[a]llowing access to [the 
submitted] data to RedState.com would be inconsistent with both the terms and intent of the Protective 
Orders to protect this critically sensitive business information.”19 Verizon similarly contends that Mr. 
Stevens is not qualified to receive access to the submitted data and information under the protective 
orders, and that “[n]either Mr. Kushnick nor Mr. Stevens has a legitimate reason to access the highly 
sensitive business materials Verizon has submitted to the Commission under Protective Orders.”20 On 
November 16, 2015, CenturyLink filed again objecting to Mr. Stevens’s access to the Confidential and 
Highly Confidential data and information, stating that “Mr. Stevens (as well as RedState.com) is not a 
‘Participant’ in the Special Access proceeding” and, therefore, not qualified to receive access under the 
protective orders of this proceeding.21 Mr. Stevens has not replied to the objections raised.
7. Submissions made pursuant to the Data Collection Protective Order,  include data and 
information submitted on locations with facilities, prices charged, revenues, expenditures, and business 
strategies.22 This information is commercially sensitive and is not routinely made available to the public 
by the Submitting Parties.23 Only eligible persons may receive access to the submission, pursuant to the 
protective orders in this proceeding.  The Bureau adopted the procedures set forth in the Data Collection 
Protective Order after having sought comment “on ‘various methods of allowing restricted access to 
highly confidential data in a secure data environment.’”24  
  
14 AT&T Reply at 4-5 (“Mr. Kushnick has offered no evidence of New Networks’ good faith or ability to file 
material comments.”).
15 Letter from Bruce A. Kushnick, Executive Director, NNI, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 
05-25 (filed Dec. 24, 2015); Letter from Bruce A. Kushnick, Executive Director, NNI, to Marlene H. Dortch, 
Secretary, FCC, WC Docket No. 05-25 (filed Dec. 31, 2015); Letter from Bruce A. Kushnick, Executive Director, 
NNI, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-25 (filed Feb. 17, 2015).
16 Additional Parties Seeking Access to Data and Information Filed in Response to the Special Access Data 
Collection, WC Docket No. 05-25; Public Notice, 30 FCC Rcd 12363 (WCB 2015).
17 Letter from Neil Stevens, Contributing Editor, Red State, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 
05-25 (Oct. 22, 2015) (Stevens Signed Acknowledgements).
18 Letter from Craig J. Brown, Senior Associate General Counsel, CenturyLink, to Marlene H. Dortch, Secretary, 
FCC, WC Docket No. 05-25 (filed Oct. 13, 2015) (CenturyLink Objection); Letter from Craig J. Brown, Senior 
Associate General Counsel, CenturyLink, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-25 (filed Nov. 
16, 2015) (CenturyLink Reply); Verizon Stevens Objection. 
19 CenturyLink Objection at 3; CenturyLink Objection at 2.
20 Verizon Stevens Objection at 2.
21 CenturyLink Reply at 2.
22 Data Collection Protective Order, 29 FCC Rcd at 11658, para. 3.
23 Id.
24 Modified Data Collection Protective Order, 30 FCC Rcd at 10028, para. 3 (quoting Wireline Competition Bureau 
Seeks Comment on Protective Order for Special Access Data Collection, Public Notice, 28 FCC Rcd 9170, 9171 
(WCB 2013)).
Federal Communications Commission DA 16-260
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8. The Data Collection Protective Order is designed to protect this “competitively sensitive 
information from unauthorized disclosure to competitors and the general public at large while still giving 
interested parties the opportunity, through their appropriate representatives, to participate in the 
rulemaking proceeding as required by the Administrative Procedure Act (APA).”25 The Data Collection 
Protective Order limits access to Highly Confidential data and information “to Outside Counsel and 
Outside Consultants and their employees who are not involved in the Competitive Decision-Making 
activities of a competitor of a Submitting Party or a person with whom the Submitting Party does 
business.”26 The terms, “Outside Counsel of Record” and “Outside Consultant,” each refer to the 
“Participant,” on whose behalf either the Outside Counsel of Record or Outside Consultant would 
potentially gain access to Confidential and Highly Confidential data and information.27 Parties granted 
access to the collected data and information are allowed to use it only for participating in the underlying 
rulemaking proceeding and are prohibited from using it for any purpose other than such participation.28
9. The Second Protective Order limits access to highly confidential and competitively 
sensitive documents, similar to the Data Collection Protective Order, “to Outside Counsel of Record, 
their employees, and Outside Consultants whom they retain to assist them in this proceeding.”29 The 
Second Protective Order took “steps above and beyond the restrictions contained in prior protective 
orders,” in response to “commenters who raised security concerns” and “object[ions] to the very fact that 
the [Modified First Protective Order] allows review of their confidential information” under any 
circumstances, and further limited access to Submitting Parties’ data and information.30 The Second 
Protective Order also further limits access to outside consultant or experts only if either was “retained for 
the purpose of assisting Counsel.”31 Additional steps were also taken to mitigate “the potential risks of 
the collected data on critical communications infrastructure” as part of the Modified Data Collection 
Protective Order.32
10. Discussion.  As the Commission has explained, the protection “of commercially sensitive 
materials submitted by parties pursuant to protective orders and confidentiality agreements is a very 
serious matter requiring vigilance by Commission staff as well as all parties gaining access to such 
information.”33 The Commission “recognize[s] that parties have a legitimate concern that their 
competitively sensitive and other confidential information not be made available to their competitors, 
those with whom they do business, or the general public.”34 Any unauthorized disclosure “‘could lead to 
substantial competitive and financial harm to the party submitting that information[,] . . . undermine 
  
25 Modified Data Collection Protective Order, 30 FCC Rcd at 10031, para. 8.
26 Data Collection Protective Order, 29 FCC Rcd at 11665, 11673, para. 23 & Attach. A at para. 5.
27 Id. at 11670-71, Attach. A, para. 1.  
28 Modified Data Collection Protective Order, 30 FCC Rcd at 10036, para. 20.
29 Second Protective Order, 25 FCC Rcd at 17726, para. 3.
30 Modified Data Collection Protective Order, 30 FCC Rcd at 10033, para. 13-14.
31 Second Protective Order, 25 FCC Rcd at 17727, para. 5.
32 Modified Data Collection Protective Order, 30 FCC Rcd at 10037, para. 24.
33 Applications of America Online, Inc. and Time Warner Inc. for Transfers of Control, CS Docket No. 00-30, 
Memorandum Opinion and Order, 16 FCC Rcd 2400, 2406, para. 27 (Cable Services Bur. 2001) (AOL/Time Warner 
Order) (quoting Applications of Craig O. McCaw and AT&T Co. for Consent to Transfer of Control of McCaw 
Cellular Commc’ns Inc. and its Subsidiaries, File No. ENF-93-44 et al., Memorandum Opinion and Order, 9 FCC 
Rcd 5836, 5924, para. 163 (1994) (McCaw/AT&T Order)).
34 See Applications of Charter Communications, Inc., Time Warner Cable Inc., and Advance/Newhouse Partnership 
for Consent to Assign or Transfer Control of Licenses and Authorizations, MB Docket No. 15-149, Order, 30 FCC 
Rcd 10360, 10367, para. 16 (2015) (Charter Order).
Federal Communications Commission DA 16-260
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public confidence in the effectiveness and integrity of the Commission’s processes, and have a chilling 
effect on the willingness of parties to provide us with information needed to fulfill our regulatory 
duties.’”35 As AT&T notes, “if the industry were to lose confidence in the robustness of the 
Commission’s procedures for protecting competitively sensitive confidential information, the existing 
protective order system (which has worked well) could easily devolve into routine and costly 
interlocutory litigation.”36 In light of the potential harms that can be caused by the unauthorized 
disclosure of confidential information, we examine the requests and objections to Mr. Stevens and Mr. 
Kushnick being permitted to review the confidential competitively sensitive information submitted in this 
docket, and grant the objections.  
11. Mr. Stevens is a tech policy writer and contributing editor for RedState.com, a website 
focusing on reporting politically-oriented news.37 In filing his Acknowledgments, he does not claim to 
represent or be employed by any other entity or party to these proceedings.  We find that Mr. Stevens is 
not an Outside Consultant, Outside Counsel of Record or Outside Counsel employed by a Participant in 
this proceeding, as those terms are used in the protective orders.  Mr. Stevens is therefore not eligible to 
review confidential information pursuant to the protective orders.38  
12. Mr. Kushnick has sought access to the confidential data submitted in this proceeding in 
his capacity as Executive Director of NNI.  According to its Reply, NNI is “a market research firm” that 
“focus[es] on the public interest” and whose members purchase communications services.39 On its 
website, NNI appears to distinguish between NNI, which is described as a market research firm, and a 
sister organization, Teletruth, of which Mr. Kushnick is Chairman and which NNI describes as an 
independent customer advocacy group.40 According to NNI, Teletruth also provides phone bill auditing 
services,41 and through those services, NNI has “helped to initiate and successfully complete numerous 
Class Action suits [regarding telecommunications services] in specific states.”42 NNI does not state 
whether it provides purchasing or other commercial advice for its members, and while its Reply and 
website imply that it does not, Mr. Kushnick’s biography on the Huffington Post website describes NNI 
as a “market research and consulting firm.”43 If NNI is engaged in commercial activity advising 
customers of the Submitting Parties, its employees who engage in those activities would not be eligible to 
review confidential material.44
  
35 AOL/Time Warner Order, 16 FCC Rcd at 19669, para. 4 (quoting McCaw/AT&T Order, 9 FCC Rcd at 5923-24, 
para. 163).
36 AT&T Reply at 3 (citing CBS Corp. v. FCC, 785 F.3d 699 (D.C. Cir. 2015)).
37 See Stevens Signed Acknowledgements at 1 (filing “on behalf of Neil Stevens, tech policy writer at Red State”); 
id.  Attach. (executing Acknowledgements as “Contributing Editor, RedState.com”); see also Red State.com, 
http://www.redstate.com/about/ (last visited Feb. 19, 2016).  According to the website, “RedState is the most widely 
read right of center site on Capitol Hill, is highly respected and cited in the media, and has rapidly become one of 
the most influential voices of the grassroots on the right.”  Id.
38 See Data Collection Protective Order, 29 FCC Rcd at 11673, Appx. A at para. 5.
39 See NNI Reply at 1, 2.
40 See, e.g., New Networks, New Networks Advisors, http://newnetworks.com/new-networks-advisors/ (last visited 
Feb. 19, 2016).
41 Id.
42 Id.; New Networks, History & Mission, http://newnetworks.com/mission-statement/ (last visited Feb. 19, 2016).
43 The Huffington Post, Bruce Kushnick, http://www.huffingtonpost.com/bruce-kushnick/ (last visited Feb. 19, 
2016).
44 See, e.g., Letter to Joseph I. Marchese, Esq., Burson & Fisher, P.A., from Rick Kaplan, Chief, Wireless 
Telecommunications Bureau, FCC, 26 FCC Rcd 11235 (2011) (upholding objection to attorneys who were involved 
in class action law suits against the submitting parties).
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13. NNI states that Mr. Kushnick is a telecommunications expert with 34 years’ experience.45  
AT&T argues, however, that “Mr. Kushnick’s main occupation appears to be authoring blog posts that 
appear on websites including websites for the NNI, Tele-Truth, and the Huffington Post . . . and authoring 
books.”46 Mr. Kushnick has also described himself as a journalist in court filings.47 AT&T asserts it is 
concerned that Mr. Kushnick will improperly use any confidential information he reviews, even if 
inadvertently.  It argues that Mr. Kushnick “believes special access information should be public, another 
obvious basis for concern.”48 AT&T further argues “At the very least, once Mr. Kushnick were permitted 
to see the data, it would be difficult to ‘un-ring the bell,’ and to prevent his knowledge of those data from 
affecting his publically written blog posts and books, potentially resulting in inadvertent but nonetheless 
harmful disclosure of highly confidential data.”49 We note that Mr. Kushnick has written publicly in a 
blog post that “In order to see this FCC data we had to sign a confidentiality agreement that restricts the 
use of the information in anything except what is filed in this original FCC proceeding, Docket Number 
05-25.  However, it will give us insight into a marketplace that is now totally obscured, hidden from 
view.”50  
14. AT&T states that NNI has never filed comments in these proceedings.  While NNI has 
submitted various general reports about telecommunications issues, they do not address the specific issues 
in this docket and have been simultaneously filed in multiple wireline proceedings.  For example, on 
December 16, 2016, NNI filed two reports regarding Verizon’s financial accounting practices.  Those 
reports were filed in a total of 29 Commission dockets.51 Finally, AT&T argues that “When a person who 
has previously shown no interest in a decade-old proceeding suddenly seeks access to a newly collected 
mass of highly competitively sensitive information, that person should bear the burden of demonstrating 
whether such disclosure is appropriate - especially in the context of the more stringent protections here 
and the lack of transparency in who is behind Mr. Kushnick’s organizations.”52  
15. After carefully reviewing all of the parties’ submissions, we grant the objections filed 
against Mr. Kushnick.  First, there is some doubt as to whether or not NNI provides commercial services 
or, in conjunction with affiliated organizations, engages in other activities (such as bill auditing).  If so, 
Mr. Kushnick would not qualify as an Outside Consultant within the meaning of the protective orders.  
Further complicating matters is that on February 3, 2016, NNI submitted a filing in this docket in which it 
described itself as “now a consortium of independent telecom analysts, forensic auditors, and lawyers.”53  
Thus, the exact nature of NNI’s activities and Mr. Kushnick’s role (whether Mr. Kushnick is acting as a 
representative of NNI or is he now acting in his own capacity) is unclear.  Second, there is a question as 
to Mr. Kushnick’s purpose for reviewing the confidential materials.  Providing a person with background 
knowledge of an industry or “insight into a marketplace” is not a proper reason under the protective 
orders to be allowed to review companies’ most highly competitively sensitive information.  
  
45 NNI Reply at 2.
46 AT&T Reply at 6.
47 Complaint, Bruce A. Kushnick v. FCC, Case No. 1:15-cv-02229 (D.D.C. Dec. 22, 2015); AT&T Reply at 6-7.
48 AT&T Reply at 6-7.
49 Id.
50 Huffington Post, The Blog, http://www.huffingtonpost.com/bruce-kushnick/att-to-fcc-stop-kushnick_b_ 8308888 
.html (last visited Feb. 19, 2016).
51 Letter from Bruce Kushnick, NNI, to Marlene Dortch, Secretary, FCC, WC Docket No. 05-25 (filed Dec. 16, 
2015).  Similarly, Mr. Kushnick filed a letter in multiple proceedings stating that he needs access to the data because 
it will corroborate his claims about the telephone companies accounting practices.  Letter from Bruce A. Kushnick, 
Executive Director, NNI, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 05-25 (filed Feb. 17, 2015).
52 AT&T Reply at 7.
53 Letter from Bruce Kushnick, NNI to Marlene Dortch, Secretary, FCC, WC Docket No. 05-25 (filed Feb. 3, 2016).
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16. Moreover, Mr. Kushnick’s lack of previous involvement in this proceeding along with 
the very general nature of his filings in this docket and other dockets raise doubt as to whether he would 
use his review of the confidential information to provide comments specifically on the questions at issue 
in this proceeding – which is the only proper use of the materials allowed under the terms of the 
protective orders.  An additional factor in our consideration is Mr. Kushnick’s work as a journalist and 
author.  Many experts write books and articles, and most public interest groups maintain websites, and 
engaging in these activities will not by itself disqualify a person as an Outside Consultant under the 
Commission’s protective orders.  On the other hand, a person is not entitled to access confidential 
material under a protective order in his capacity as a journalist or author.  The Commission has stated 
“We will not permit access to confidential materials by anyone who is not participating in the proceeding 
in good faith or by someone who we have good reason to believe will not be using the information for 
proper purposes.”54 Based on all of these factors and the evidence in the record, we conclude that Mr. 
Kushnick has not shown that he is qualified under the protective orders to review the confidential 
information submitted in this docket.
17. Accordingly, IT IS ORDERED, pursuant to sections 1, 4(i), and 5(c) of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 154(i), 155(c), sections 0.91, and 0.291 of 
the Commission’s rules, 47 C.F.R. §§ 0.91, and 0.291, and the authority delegated to the Bureau in the 
Data Collection Order, 27 FCC Rcd at 16340, para. 52, that the objections filed by AT&T on October 13, 
2015, Verizon on October 15, 2015 and November 16, 2015, and CenturyLink on October 13, 2015 ARE 
GRANTED.  
18. IT IS FURTHER ORDERED that, pursuant to section 1.102(b)(1) of the Commission’s 
rules, 47 C.F.R. § 1.102(b)(1), this Order SHALL BE EFFECTIVE upon release. 
FEDERAL COMMUNICATIONS COMMISSION
Deena M. Shetler
Associate Chief
Wireline Competition Bureau
  
54 Charter Order, 30 FCC Rcd at 10368, para. 16.