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Tribal Telecom 2013. Federal Telecommunications Regulatory Updates. Transformation order impacts. Limitations on Capital Expenditures & Operating Expenses Regression based limitations on costs included in the calculation of High Cost Loop Support
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Tribal Telecom 2013 Federal Telecommunications Regulatory Updates
Transformation order impacts • Limitations on Capital Expenditures & Operating Expenses • Regression based limitations on costs included in the calculation of High Cost Loop Support • Approximately 160 rural rate-of-return carriers were impacted (Approximately 22%) • Only 1 of 9 Tribal carriers was impacted (11%) • Impacted carrier was not significantly over 1 of 2 limits • Remaining 8 were well below the limits • Non-impacted carriers eligible for redistributed support • Changes to limitations to be issued shortly
Transformation order impacts • Elimination of Safety Net Additive • Nominal impacts only 2 Tribal carriers • Corporate Operations Expense Limitation • No publicly available data to analyze • Appears that 1 Tribal carrier may be impacted • Elimination of Local Switching Support • Shifted to ICC CAF • 5% annual reduction for all carriers • $250 Support Cap • No impact on Tribal carriers
Transformation order impacts • Increased End User Rates • Access Recovery Charge – designed to offset a portion of switched access revenue loss • Artificially Low Local Rates – must be higher than benchmark to receive full HCLS • 7/1/12 - $10.00 • 7/1/13 - $14.00 • 7/1/14 – National Average Urban Rate
Reporting requirements • Annual Reporting Requirements – Due July 1st • 5-Year Service Quality Improvement Plan • Detailed Network Outage Report • Unfulfilled Service Requests • Complaints per 1,000 Connections • Compliance with Service Quality Standards • Compliance with Consumer Protection Rules • Ability to Function in Emergency Situations • Price Offerings
Reporting requirements • Annual Reporting Requirements – Due July 1st • Company Identification Information • Tribal Outreach and Licensing • Certification of Pricing • <= 2 standard deviations above national average • Results of Network Performance Test • Financial Reporting for Privately Held Rate of Return • Additional Voice Rate Data • Most requirements must be separately broken out for voice and broadband
Thank you Chad Duval, Principal Moss Adams LLP chad.duval@mossadams.com 209-955-6124