text:
You Don't Always Know What You Think You Know
By Alan Scherstuhl
Daniel Radcliffe'll Never do a Rom-Com With Emma Watson
By Amy Nicholson
Film Critics Need to Learn to Look and Enjoy
By Charles Taylor
Robin Williams Could Always Find the Raw Seriousness in...
By Stephanie Zacharek
By Brian Feinzimer
The Purge: Anarchy Sets Up Frank Grillo to Finally Be...
By CAROLINA DEL BUSTO
Anna Kendrick Had Her Heart Broken by a Hot Dog
By AMY NICHOLSON
Richard Linklater Explains His Secret Movie Boyhood
By Amy Nicholson
Of course, there's no reason to sentimentalize the Colombian civil war, none of whose factions can be described as good liberals. Still, Collateral Damage is far more telling in what it suggests—unwittingly for the most part—about us, about the rabid mixture of hubris, paranoia, xenophobia and downright muddleheadedness with which we define our own place on the stage of world terrorism, not to mention the bizarre uses to which American individualism can be put under pressure. That the movie offers a ringing endorsement of vigilante justice is par for the course: it's an Arnold Schwarzenegger thriller. Yet in the process of tracking down the man who not only killed his family, but—in a plot twist whose eerie prescience must have the distributors reaching for their Maalox—also plans to blow up some crucial government buildings in Washington, D.C., Gordy finds himself a target not only of El Lobo, but of a ruthless CIA loose cannon, represented in a weaselly turn by the Canadian actor Elias Koteas. Meanwhile, scenes of U.S.-sponsored planes zooming in to flatten the drug baron's hideaway evoke shades of Apocalypse Now and fears of the Vietnamization of American involvement in Colombia. Collateral Damage may be pressing its Hollywood-liberal credentials here, but it wouldn't surprise me if the vast majority of American moviegoers see in Gordy a reflection of their own mistrust of institutions, be they "theirs" or ours. It may, after all, be easier for Americans to love a firefighter than it is for them to love their government.
Collateral Damage was directed by Andrew Davis; written by David and Peter Griffiths; produced by Steven Reuther and David Foster; and stars Arnold Schwarzenegger and Cliff Curtis. Now playing countywide.
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text: You are looking at zazzle.co.uk's Colours Of The Desert art page, where you can find a fantastic range of Colours Of The Desert prints and posters in all sizes, ready for customisation or to buy just as they are. Print on one of seven different types of media, from basic paper to canvas. Custom-fitted frames and matting are also available. Become an artist yourself by uploading your own designs or by adding personalised text at no extra cost! To see some of the other products available on zazzle.co.uk, check out our main colours of the desert page.

subset: commoncrawl


text:
December 1, 2015
PANAMA CITY, Fla. (AP) -- A Florida Panhandle man faces 20 years
in prison for fatally stabbing another man during a party.
As part of a deal with Bay County prosecutors, 25-year-old Chesley Williams agreed to plead no contest Wednesday to second-degree murder. His trial had been scheduled for next week.
He had been claiming self-defense.
Authorities say Williams stabbed 23-year-old Paul Anthony Brown at the Bluewater Inn in January. Both men had been outside smoking cigarettes when they got into a fight. There were no witnesses to the stabbing, and it's not clear how they began to argue.
Prosecutors say Williams stabbed Brown six to nine times.
A judge is scheduled to approve the plea deal and sentence Williams on Monday.
Information from: The News Herald, http://www.newsherald.com
(Copyright 2011 by The Associated Press. All Rights Reserved.)
Click Here to access the online Public Inspection File
Viewers with disabilities can get assistance accessing this station's FCC Public Inspection File by contacting the station with the information listed below. Questions or concerns relating to the accessibility of the FCC's online public file system should be directed to the FCC at 888-225-5322, 888-835-5322 (TTY), or firstname.lastname@example.com.


text:
For her students who haven't yet experienced world travel first-hand, Melody Bigham is using her curriculum to bring the world to them.
The Ripley High School Family and Consumer Science teacher uses her nutrition and wellness class to introduce the students to other countries and peoples.
"Our school believes in global education and exposing our students to different cultures," she said.
In the years since Toyota has become a part of Northeast Mississippi the company has sought to introduce Mississippians to Japanese business culture, social culture and food culture.
Many local residents work at the Toyota manufacturing plant, and also at other companies that are part of the company's manufacturing stream.
Since those companies not only employ local people but also bring managers and their families from Japan to Mississippi, it is important that everyone gain more understanding of each other as the two cultures interact.
"Our curriculum was revised in 2007, and this semester we had a Japanese culture class to demonstrate proper social etiquette with table settings, table service and table manners," Bigham said.
The students in grades 9-12 enjoyed green tea and sweets with presenter Naomi Yamakawa, the coordinator of Japanese Outreach Programs and Continuing Education at the University of Mississippi.
"The students really liked it and want her to come back," Bigham said. "They were asking a lot of questions and she had a lot of visuals."
For the rest of the story, see the Jan. 30 edition of the Southern Sentinel.


text:
i read around saying someone who pulls sumo and squats wide can use one suit. i pull sumo and squat medium/shoulder stance, would i get any carryover toward my sumo pull if i wore a squat suit made for close stance?
what are some recommendations for a squat suit that fits my approach?


text:
Jestico + Whiles reveals Greenwich housing
Jestico + Whiles has unveiled these designs for a substantial housing project on the Greenwich Peninsula, south London.
The London-based practice will design 207 new houses on the peninsula that will form part of the wider regeneration of the area set out in Terry Farrell's masterplan.
Backed by developer Mode Homes, Jestico + Whiles will provide a variety of housing types from apartment blocks to three-storey terraced housing.
The scheme will also deliver a 'coherent' network of streets, as well as a 'grand staircase' that will connect a podium courtyard to the parkside promenade.
According to the practice, the scheme – one of the first to be developed on the peninsula – has to both respond to its current context and 'anticipate the eventual context' as the peninsula is developed.
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text:
FCC Seeks Targeted Information in USF/ICC Transformation Proceeding
Download OptionsReleased: August 3, 2011
Federal Communications CommissionNews Media Information 202 / 418-0500
445 12th St., S.W.
Fax-On-Demand 202 / 418-2830
Washington, D.C. 20554Internet: https://www.fcc.gov
Release Date: August 3, 2011
WC Docket Nos. 10-90, 07-135, 05-337, 03-109;
CC Docket No. 01-92, 96-45
GN Docket No. 09-51
Comment Date: August 24, 2011
Reply Comment Date: August 31, 2011
intercarrier compensation (ICC) system in light of recent technological, market, and regulatory changes,
on February 9, 2011, the Commission released the Universal Service and Intercarrier Compensation
Transformation Notice of Proposed Rulemaking (USF-ICC Transformation NPRM).1 The NPRM sought
public comment on reforms to modernize USF and ICC for broadband, control the size of the USF as it
transitions to support broadband, require accountability from companies receiving support, and use
market-driven and incentive-based policies that maximize the value of scarce program resources for the
benefit of consumers. Previously, on October 14, 2010, the Commission released the Universal Service
Reform Mobility Fund Notice of Proposed Rulemaking (Mobility Fund NPRM), which proposed to
expand mobile voice and data service availability by using a market-based mechanism to award one-time
support from accumulated USF reserves.2 In response to the USF-ICC Transformation NPRM, a number
of parties have offered specific proposals for reform, including a proposal by the State Members of the
Federal-State Universal Service Joint Board (State Members), the "RLEC Plan" put forward by the Joint
Rural Associations, and the "America's Broadband Connectivity Plan" filed by six Price Cap Companies
("ABC Plan").3 We seek comment on how these proposals comport with the Commission's articulated
1 Connect America Fund; A National Broadband Plan for Our Future; Establishing Just and reasonable Rates for
Local Exchange Carriers; High-Cost Universal Service Support; Developing a Unified Intercarrier Compensation
Regime; Federal-State Joint Board on Universal Service; Lifeline and Link-Up; WC Docket Nos. 10-90, 07-135,
05-337, 03-109, CC Docket Nos. 01-92, 96-45, GN Docket No. 09-51, Notice of Proposed Rulemaking and Further
Notice of Proposed Rulemaking, 26 FCC Rcd 4554 (2011).
2 Universal Service Reform Mobility Fund, Notice of Proposed Rulemaking, 25 FCC Rcd 14,716 (2010).
3 Comments by the State Members of the Federal-State Joint Board on Universal Service, WC Docket No. 10-90 et
al. (filed May 2, 2011) (State Member Comments); Comments of NECA, NTCA, OPASTCO, and WTA, WC
Docket No. 10-90 et al. (filed May 2, 2011) (RLEC Plan); Letter from Robert W. Quinn, Jr., AT&T, Steve Davis,
CenturyLink, Michael T. Skrivan, FairPoint, Kathleen Q. Abernathy, Frontier, Kathleen Grillo, Verizon, and
Michael D. Rhoda, Windstream, to Marlene H. Dortch, FCC, WC Docket No. 10-90 et al. (filed July 29, 2011)
(ABC Plan). See also Letter from Walter B. McCormick, Jr., United States Telecom Association, Robert W. Quinn,
objectives and statutory requirements. We invite comment on specific aspects of the proposals and on
additional issues that are not fully developed in the record.
Universal Service
A. Separate Support for Mobile Broadband.
Several parties propose that the Commission create two separate components of the
Connect America Fund, one focused on ensuring that consumers receive fixed voice and
broadband service (which could be wired or wireless) from a single provider of last resort
in areas that are uneconomic to serve with fixed service, and one focused on providing
ongoing support for mobile voice and broadband service in areas that are uneconomic to
serve with mobile service (i.e., a Mobile Connect America Fund), with the two
components together providing annual support under a defined budget.4 We seek
comment on providing separate funding for fixed broadband (wired or wireless) and
mobility. How should the Commission set the relative budgets of two separate
components?5 How should the budgets be revised over time?
In the USF/ICC Transformation NPRM, the Commission sought comment on phasing
down high-cost support for competitive eligible telecommunications carriers (competitive
ETCs) over 5 years and transitioning such support to the CAF.6 To what extent would
projected savings associated with intercarrier compensation reform for wireless carriers
as proposed in the ABC Plan help offset reductions in high-cost support for competitive
ETCs? We ask parties to substantiate their comments with data and remind parties that
they may file data under the protective order issued in this proceeding.7
B. Elimination of Rural and Non-Rural Carrier Distinctions.
Jr., AT&T, Melissa Newman, CenturyLink, Michael T. Skrivan, FairPoint, Kathleen Q. Abernathy, Frontier,
Kathleen Grillo, Verizon, Michael D. Rhoda, Windstream, Shirley Bloomfield, NTCA, John Rose, OPASTCO, and
Kelly Worthington, WTA, to Chairman Julius Genachowski, Commissioner Michael J. Copps, Commissioner
Robert M. McDowell, Commissioner Mignon Clyburn, FCC, WC Docket No. 10-90 et al. (filed July 29, 2011)
(Joint Letter).
4 See, e.g., State Member Comments at 2, 68-73; ABC Plan, Attachment 1 at 8; RLEC Plan at 83; United States
Cellular Corp. April 18 Comments at 20; American Cable Association April 18 Comments at 5-6; AT&T April 18
Comments at 86-87, 108-09; Nebraska Pub. Serv. Comm. April 18 Comments at 17.
5 We note the wide range of proposed budgets for a mobility fund. Compare ABC Plan, Attachment 1 at 9 (at most
$300 million) with US Cellular, Letter from David A. LaFuria, Counsel to United States Cellular Corporation, to
Marlene H. Dortch, FCC, WC Docket No. 05-337 et al., at 5 (filed July 29, 2011) (US Cellular July 29, 2011 Ex
Parte)(at least $1.3 billion). US Cellular has proposed that we determine appropriate support levels for mobile
carriers in targeted high cost rural areas using a model of an efficient level of costs. See Letter from David A.
LaFuria, Counsel to United States Cellular Corporation, to Marlene H. Dortch, FCC, WC Docket No. 05-337et al.
(filed June 16, 2011) (US Cellular June 16 Ex Parte); U.S. Cellular July 29 Ex Parte.
6 USF/ICC Transformation NPRM, 26 FCC Rcd at 4641, para. 248.
7 Developing a Unified Intercarrier Compensation Regime, CC Docket No. 01-92; WC Docket Nos. 07-135, 10-90,
05-337; GN Docket No. 09-51, Protective Order, 25 FCC Rcd 13160 (WCB 2010) (Protective Order).
In the USF/ICC Transformation NPRM, the Commission sought comment on two
potential paths for the long term CAF: (1) use a competitive, technology-neutral bidding
process to determine CAF recipients; or (2) offer the current voice carrier of last resort a
right of first refusal to serve the area for an amount of ongoing support determined by a
cost model, with a competitive process if the incumbent refuses the offer.8 Several
parties that jointly filed a letter proposing a path for reform propose a hybrid system in
which support would be determined under a combination of a forward-looking cost
model and competitive bidding in areas served by price cap companies, while companies
that today are regulated under a rate of return methodology would continue to receive
support based on embedded costs, albeit with greater accountability and cost controls.9
Similarly, the State Members suggest that a forward-looking model be used for price cap
companies, while rate of return companies would have the option of receiving support
under a model or based on embedded costs.10 We seek comment on the policy
implications of eliminating the current references to rural and non-rural carriers in our
rules and of adopting two separate approaches to determining support for carriers that
operate in rural areas that are uneconomic to serve, based on whether a company is
regulated under rate of return or price caps in the interstate jurisdiction.
C. CAF Support for Price Cap Areas.
1. Use of a Model.
o Both the State Members and the ABC Plan would use a forward-looking model
to determine support amounts for areas where there is no private sector business
case to offer broadband.11 We seek comment on what information would need to
be filed in the record regarding the CostQuest Broadband Analysis Tool
(CQBAT model) for the Commission to consider adopting it, as proposed in the
ABC Plan.
o The ABC Plan proposes using one technology to determine the modeled costs of
4 Mbps download/768 kbps upload service, while permitting support recipients
to use any technology capable of meeting those requirements.12 Should the
amounts determined by a model be adjusted to reflect the technology actually
deployed? Is ten years an appropriate time frame for determining support levels,
given statutory requirements for an evolving definition of universal service?
Should the model reflect the costs of building a network capable of meeting
future consumer demand for higher bandwidth that reasonably can be anticipated
five years from now?
2. Right of First Refusal (ROFR)
8 USF-ICC Transformation NPRM, 26 FCC Rcd at 4681-90, paras. 417-447.
9 See Joint Letter at 2.
10 State Member Comments at 38-39.
11 See ABC Plan, Attach. 1 (Framework of the Proposal) at 3-6, Attach. 3 (Model Description); State Member
Comments at 37-38.
12 ABC Plan, Attach. 1 at 2, 7.
o The ABC Plan would give an incumbent local exchange carrier (LEC) the
opportunity to accept or decline a model-determined support amount in a wire
center if the incumbent LEC has already made high-speed Internet service
available to more than 35 percent of the service locations in the wire center.13
We seek comment on this proposal. Would aggregating census blocks to
something other than a wire center be an improvement to the proposal? Is 35
percent a reasonable threshold? Should areas that are overlapped by an
unsubsidized facilities-based provider be excluded when calculating the
percentage? Is the opportunity to exercise a ROFR reasonable consideration for
an incumbent LEC's ongoing responsibility to serve as a voice carrier of last
resort throughout its study areas, even as legacy support flows are being phased
down? Should any ROFR go to the provider with the most broadband
deployment in the relevant area rather than automatically to the incumbent
LEC?14 Alternatively, if there are at least two providers in the relevant area that
exceed the threshold, should the Commission use competitive bidding to select
the support recipient?
3. Public Interest Obligations
o Last year, the Federal-State Joint Board on Universal Service recommended that
the Commission adopt a principle "that universal service support should be
directed where possible to networks that provide advanced services, as well as
voice services."15 If that recommendation is adopted, how could the CQBAT
model be improved to account for the costs of providing both broadband and
voice service?
o The State Members propose that recipients of support meet specific broadband
build-out milestones at years 1, 3 and 5 of deployment.16 A company that
exceeded a specified minimum standard, but failed to meet the higher standard at
a given milestone would receive a pro rata share of support. We seek comment
on what specific interim milestones would be effective in ensuring that carriers
receiving CAF support are building out broadband at a reasonable rate during the
specified build-out period.
o The ABC Plan proposes that CAF recipients provide broadband service that
meets specified bandwidth requirements to all locations within a supported area,
but does not address the pricing of such services or usage allowances.17 Should
the Commission adopt reporting requirements for supported providers regarding
13 See ABC Plan, Attach. 1 at 6.
14 See Letter from Steven F. Morris and Jennifer K. McKee, National Cable and Telecommunications Association,
to Marlene H. Dortch, FCC, WC Docket No. et al., Attach. at 3 (filed July 29, 2011) (NCTA Letter).
15 Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Recommended Decision, 25 FCC Rcd
15598, 15625, para. 75 (2010).
16 See State Member Comments at 62-63. Specifically, a company would lose all of its support if it failed to meet
the minimum standard of deploying gradually increasing speeds to increasing percentages of its area over the five-
year period. A company would receive full funding if it met or exceeded a higher standard. Id.
17 ABC Plan, Attach. 1 at 2-3, 7-8.
pricing and usage allowances to facilitate its ability to ensure that consumers in
rural areas are receiving reasonably comparable services at reasonably
comparable rates?
4. Eligible Telecommunications Carrier (ETC) Requirements
o The ABC Plan proposes a procurement model, in which recipients of CAF
support incur service obligations only to the extent they agree to perform them in
explicit agreements with the Commission, and CAF recipients are free to use any
technology, wireline or wireless, that meets specified bandwidth and service
requirements.18 What specific rule changes to the Commission's rules, including
Part 54, Subpart C of the Commission's rules, would be necessary to implement
such a proposal?
5. State Role
o The State Members and other commenters propose an ongoing role for states in
monitoring and oversight over recipients of universal service support.19 We seek
comment on specific illustrative areas where the states could work in partnership
with the Commission in advancing universal service, subject to a uniform
national framework, and invite comments on other suggestions. For example:
Were the Commission to adopt a ROFR mechanism, could the states
determine whether a provider has already made a substantial broadband
investment in a particular area, and therefore would be eligible to be
offered support amounts determined under a forward-looking model?20
Should ETCs be required to file copies of all information submitted to
the Commission regarding compliance with public interest obligations
with the states, as well as with USAC?
The ABC Plan contemplates that CAF recipients would serve all
business and residential locations within a supported area, but does not
specifically address the obligation to serve newly built locations within a
supported area over the ten-year term of the funding. Should states be
charged with determining whether any charges for extending service to
newly constructed buildings are reasonable, based on local conditions?
Should states collect information regarding customer complaints,
including complaints about unfulfilled service requests and inadequate
D. Reforms for Rate-of-Return Carriers.
18 ABC Plan, Attach. 1 at 2, 3, 7.
19 State Member Comments at 139-140; see also Cal. Pub. Util. Comm., April 19 Comments at 10-11; Pub. Serv.
Comm. of Mo. April 6 Comments at 9-11; Neb. Pub. Serv. Comm. April 19 Comments; of Wash. Util. and Transp.
Comm. April 18 Comments at 5-6.
20 ABC Plan, Attach. 1 at 2.
In light of the RLEC Plan and the Joint Letter, as well proposals by the State Members,
we seek comment below on specific issues relating to universal service support for rate-
of-return companies.
o Re-examining the Interstate Rate of Return. The Joint Letter proposes that CAF
calculations for areas served by rate-of-return companies would be calculated
using a 10 percent interstate rate of return.21 The State Members recommended
that the rate of return for universal service calculations be set at 8.5 percent.22
We seek comment on what data the Commission would need to have in the
record to enable it to waive the requirements in Part 65 of the Commission's
rules for a rate of return prescription proceeding, so that the Commission could
quickly adopt a particular rate of return.
o Corporate Operations Expense Limitation Formula. We seek comment on
applying the following formula to limit recovery of corporate operations
expenses for high-cost loop support (HCLS), interstate common line support
(ICLS), and local switching support (LSS).23
For study areas with 6,000 or fewer working loops, the monthly amount per loop
shall be limited to;
$42.337 (.00328 x the number of working loops) or $50,000/the number of
working loops, whichever is greater
For study areas with more than 6,000 working loops, but fewer than 17,888
working loops, the monthly amount per loop shall be limited to;
$3.007 + (117,990/number of working loops)
For study areas with 17,888 or more working loops, the monthly amount per loop
shall be limited to;
$9.52 per working loop
o Eliminating Support for Areas with an Unsubsidized Competitor. In responding
to the NPRM, the RLEC Plan suggested that the Commission could establish a
process to reduce an incumbent's support if another facilities-based provider
proves that it provides sufficient broadband and voice service to at least 95
percent of the households in the incumbent's study area without any support or
21 Joint Letter at 2.
22 State Member Comments at 36.
23 See NECA, Universal Service Fund Data: NECA Study Results, 2009 Report (filed Sept. 30, 2010),
https://www.fcc.gov/wcb/iatd/neca.html. 2011 support is based on 2009 cost data, filed on September 30, 2010. The
statistical regression techniques for developing the updated limitation formula are the same as used to develop the
initial formula. See First Reconsideration Order, 12 FCC Rcd at 10115-17, App. B. The statistical formula
produced by our updated analysis, as shown below, includes the allowance of 115% to permit more carriers to fall
within the range of reasonableness.
cross-subsidy.24 We seek comment on such a process, including how to allocate
costs to the remaining portions of the incumbent's study area for purposes of
determining universal service support. Would a cost model be a way to allocate
costs between the subsidized and unsubsidized portion of a rate-of-return study
area that overlaps substantially with an unsubsidized competitor?25 Could state
commissions administer proceedings to consider such challenges, similar to the
suggestion in the ABC Plan that state commissions could elect to determine
which census blocks served by price cap companies have unsubsidized
competitors, and therefore are not eligible for CAF support?
o Limits on Reimbursable Operating and Capital Costs. We seek comment on
limiting reimbursable levels of capital investment and operating expenses for
E. Ensuring Consumer Equity
Rate Benchmark. In the USF/ICC Transformation NPRM, the Commission sought
comment on the use of a rate benchmark to encourage states to rebalance their rates and
ensure that universal service does not subsidize carriers with artificially low rates.26 In
response to the NPRM, one commenter suggested that we should develop a benchmark
for voice service and reduce a carrier's high-cost support by the amount that its rate falls
below the benchmark.27 Under such an approach, the Commission would reduce
intrastate universal service support (specifically, HCLS for rural carriers and high-cost
model support (HCMS) for non-rural carriers) dollar for dollar during the transition to
CAF to the extent the company's local rates do not meet the specified benchmark. These
reductions would not flow to other recipients. We seek comment on this proposal and
proposed variations on it. Should we set the initial benchmark using the most recently
available data that the Commission has regarding local rates? For example, according to
the 2008 Reference Book of Rates, the average monthly charge for flat-rate service was
$15.62 per month. Using the same data, the average monthly charge for flat-rate service,
plus subscriber line charges of $5.74 per month, would total $21.36 per month.28 Should
the benchmark rise over a period of three years, for instance, with an end point of $25-
$30 (or some other amount) for the total of the local residential rate, federal subscriber
line charge (SLC), state subscriber line charge, mandatory extended area service charges,
and per-line contribution to a state's high cost fund, if one exists? Should this benchmark
be the same as the ICC benchmark?
Total company earnings review. The State Members recommended that a Provider of
Last Resort Fund include a total company earnings review to limit a supported carrier
24 RLEC Plan at 51-56.
25 See NTCA Letter, Attach. at 2.
26 USF/ICC Transformation NPRM, 26 FCC Rcd at 4733-34, para. 573. See also id. at 4603, para. 139 and note
27 Ad Hoc Telecommunications Users Committee April 18 Comments.
28 Industry Analysis and Technology Division, Wireline Competition Bureau, Reference Book of Rates, Price
Indices, and Household Expenditures for Telephone Service, at Table 1.1 (2008).
from earning more than a reasonable return.29 We seek to further develop the record on
the mechanics of conducting an earnings review to ensure that universal service is not
providing excessive support to the detriment of consumers across the United States.
o We seek comment on the State Members' recommendation that, at least initially,
the support mechanism should not factor in either the revenues or marginal costs
of video operations to avoid the risk of subsidizing video operating losses
attributable to unregulated programming costs.30
o We seek comment on what total company rate of return should be used, what the
mechanism should be for reducing support to the extent that total company rate
of return is exceeded, and how often a total company earnings review should be
o We seek comment on what carriers should be required to submit to USAC, in a
standard format, to facilitate a total company earnings review. For example,
should we require submission of the audited financial statements for the
incumbent LEC, a consolidated balance sheet and income statement for the
incumbent LEC and its affiliates, a list of affiliates, a schedule showing dividends
paid to shareholders or patronage refunds distributed to members of cooperatives
for the last five years, a Cost Allocation Manual, an explanation of how revenues
from bundled services are booked, a trial balance of accounts at a Class B
accounting level or greater, and the number of retail customers served by the
incumbent LEC and its affiliates for voice and broadband service?
F. Highest-Cost Areas.
The ABC Plan would rely on satellite broadband to serve extremely high-cost areas.31
We seek comment on a proposal by ViaSat to create a Competitive Technologies Fund to
distribute support through a combination of a reverse auction and consumer vouchers to
enable consumers in highest-cost areas to obtain service from wireless, satellite, or other
We also seek comment on what obligations are appropriate to impose on recipients of
funding, as a condition of receiving support, to facilitate provisioning by others in areas
the recipients are not obligated to serve. For example, Public Knowledge has proposed to
require recipients to make interconnection points and backhaul capacity available so that
29 State Member Comments at 56-58. The Commission sought comment on including all revenues (including
broadband revenues) when evaluating rate of return requirements. USF/ICC Transformation NPRM, 26 FCC Rcd at
4674, para. 392.
30 State Member Comments at 35.
31 See ABC Plan, Attach. 1 at 4.
32 See generally Letter from John P. Janka, Counsel to ViaSat, Inc. and WildBlue, Communications, Inc., to Marlene
H. Dortch, FCC, WC Docket No. 10-90 et al. (filed July 29, 2011) See also NCTA Letter, Attach. at 2
(recommending that the Commission identify areas that are prohibitively expensive to serve and provide subsidies to
consumers living in those areas to subscribe to satellite broadband service).
unserved high-cost communities could deploy their own broadband networks.33 Should
recipients' Acceptable Use Policies also be required to allow customers to share their
broadband connections with unserved customers nearby, for example, through the use of
WiFi combined with directional antenna technology?
G. CAF Support for Alaska, Hawaii, Tribal lands, U.S. Territories, and Other Areas
GCI has proposed an Alaska-specific set of universal service reforms that it asserts better
reflect the operating conditions in Alaska and the lower level of broadband and mobile
deployment in that state.34 We seek comment on this proposal for Alaska, and ask
whether this, or a similar approach, would also be warranted for Hawaii, Tribal lands, the
U.S. Territories, or other particular areas, and how we should consider such proposals in
light of the Tribal lands exclusion from the current cap on high-cost support for
competitive ETCs. We further seek comment on other proposals relating to Alaska and
Hawaii that have been proposed in the record. We further seek comment on how such
proposals could be improved, if the Commission were to adopt a plan to constrain the
size of the CAF and access restructuring within a $4.5 billion annual budget, and
whether, in the alternative, other modifications are warranted to the national policy to
better reflect operating conditions in these areas.
H. Implementing Reform within a Defined Budget.
The ABC Plan recommends a five-year transition for phasing down legacy funding,
concomitant with a phase-in of potential CAF support, including potential access
recovery associated with intercarrier compensation reform; the Joint Letter suggests
several potential measures that could be taken to keep support totals within a budget,
such as phasing in funding for mobility, deferring CAF funding for study areas served by
particular price cap companies, or deferring reductions in intercarrier compensation.35
We seek comment on the implications of these and alternative proposals, including
variations to the Commission's prior proposals regarding safety net additive (SNA) and
LSS, for ensuring that total funding remains within a defined budget.36
I. Interim Reforms for Price Cap Carriers.
33 C.f. Public Knowledge and Benton Foundation April 18 Comments, at 5-7; Letter from John Bergmayer, Public
Knowledge, to Marlene H. Dortch, FCC, WC Docket No. 10-90 et al. (filed July 28, 2001).
34 See Letter from Christopher Nierman, GCI, to Marlene H. Dortch, FCC, WC Docket No. 10-90 et al. (filed Aug.
1, 2011).
35 See ABC Plan, Attach. 1 at 8-9; Joint Letter at 2-3. The Joint Letter states that $2.2 billion in support would be
provided to areas served by price cap companies, and initially $2 billion in funding would go to areas served by rate-
of-return companies, with the opportunity for that funding to increase to $2.3 billion by 2017. Joint Letter at 2.
36 For instance, could the Commission allow companies that previously qualified for SNA with a year-over-year
increase of total plant in service of 14 percent or more to receive the remaining amounts of SNA for past
qualification, while eliminating it immediately for those companies that did not increase total plant in service
investment by 14 percent (i.e., that qualified for SNA due to line loss)? What would be the impact of adjusting the
formula for LSS so that it only would be available for companies with 15,000 or fewer access lines, as suggested by
one commenter. See Alexicon April 18 Comments at 13-14.
As an interim step, Windstream, Frontier and CenturyLink suggest that the Commission
could immediately target support that currently flows to price cap carriers to the highest-
cost wire centers within their service territories, using a regression analysis based on the
Commission's existing high-cost model to estimate wire center forward-looking costs for
both rural and non-rural price cap carriers.37 We seek comment on this proposal and how
it relates to other proposals in the record for comprehensive reform.
o In addition to combining and distributing HCLS and HCMS, should the
Commission also include funds currently provided through LSS and SNA to
price cap carriers? Should we also include funds currently provided to price cap
carriers through interstate access support (IAS) and frozen ICLS?
o Should the Commission increase annual HCMS support by an additional amount,
such as $100 to $200 million, to be repurposed from ongoing reductions in
support for companies that have chosen to relinquish universal service funding?
Should we impose a cap on the amount of support a carrier is eligible to receive
for a wire center? For instance, should that cap be set at $250 per line per month,
similar to the Commission's proposal for a cap in total support for all existing
o What public interest obligations for using funding for broadband-capable
networks should apply to carriers receiving support under this approach? Should
carriers receiving such support be prohibited from using the funds in areas that
are served by an unsubsidized facilities-based broadband provider?
o Do any special circumstances exist in the states of Alaska and Hawaii, or
Territories and Tribal lands generally, or other areas, that warrant a different
approach for price cap carriers serving such areas, if the Commission were to
adopt this interim measure?
Intercarrier Compensation
A. Federal-State Roles1. Federal Framework.
The ABC Plan proposes that the Commission set the framework to reduce intrastate
access rates, and recovery to the extent necessary for those reduced intrastate access
revenues would come from the federal jurisdiction through a combination of federal SLC
increases and federal universal service support.38
o How would this aspect of the ABC Plan affect states in different stages of
intrastate access reform those that have undertaken significant reform and
37 See Windstream Communications, Inc. April 18 Comments at 9; Letter from Jennie B. Chandra, Windstream
Communications, Inc., to Marlene H. Dortch, FCC, WC Docket No. 10-90 et al. (filed June 30, 2011); Letter from
Michael D. Saperstein, Jr., Frontier Communications, to Marlene H. Dortch, FCC, WC Docket No. 10-90et al. (filed
July 26, 2011).
38 ABC Plan, Attach. 1 at 10-13.
moved intrastate rates to parity with interstate rates, those in the process of
reform, and states that have not yet initiated reform?
o The ABC Plan provides a uniform, consistent framework for reform across all
states. We seek comment on whether the ABC Plan could be improved by
providing states incentives to increase artificially low consumer rates or create
state USFs for example through the use of a consumer monthly rate ceiling or
benchmark or by requiring states to contribute a certain amount per line of
recovery to offset intrastate rate reductions?
In calculating access recovery, the ABC Plan proposes a $30 "rate
benchmark" for price cap carriers, and the Rate-of-Return plan proposes
a $25 benchmark, both of which are structured as a ceiling on consumer
rate increases (via a federal SLC), to limit increases on consumer rates in
states where such rates have already been raised as part of intrastate
access reform.39 Is this ceiling sufficient to mitigate any potential impact
on consumers in states that have already begun reforms (and thus are
already paying increased local rates and/or state universal service
contributions associated with such reform) relative to consumers in states
that have not yet undertaken such reforms (for which all recovery would
come through the federal mechanism in the ABC Plan)? Should there be
different rate benchmarks for different carriers or should there be a single
In the ABC Plan, in calculating access recovery, the initial consumer
monthly rate is taken as a snapshot in time as of January 1, 2012. In lieu
of a snapshot, and in order to avoid deterring states from rebalancing
local rates and/or establishing state USFs, should the rate used to
determine access recovery be the "higher of" (1) the rate as of January
2012 and (2) the rate at future points before annual access recovery
amounts are calculated? In this scenario, any increased consumer rates
as a result of state reforms,40 would count toward the benchmark, more
accurately reflecting the actual consumer burden at that time.
A rate benchmark could also be used as an imputation for a certain level
of end-user recovery for intrastate rate reductions, rather than as a ceiling
on federal SLC increases. For instance, the Ad Hoc Telecommunications
Users Committee proposes a local rate benchmark that could be imputed,
rather than used as a ceiling,41 and commenters propose a range of
39 ABC Plan, Attach. 1 at 12; Joint Letter, Attach. at 3 n.1.
40 This could occur, for example, if the Commission were to reduce HCLS or HCMS if local rates are below a
specified threshold. See supra Section I.E. (Rate Benchmark).
41 See Ad Hoc April 18 Comments at 54. For example, a benchmark structured as a ceiling would simply limit the
rates assessed on end-users, whereas an imputed benchmark would reduce the eligible recovery by the imputed
dollar amount regardless of whether those charges are actually assessed.
possible benchmarks from $25-$30.42 Would an imputation approach
better encourage states that currently depend on long distance consumers
to help subsidize local phone service for their local consumers to bring
consumer rates to levels more comparable to the national average? What
would be the appropriate level for such a benchmark, and should it be
phased in over time?
Instead of or in addition to a rate benchmark, should states be responsible
for contributing a certain dollar amount per line to aid in access
recovery? The State Members, for example, suggest that states
contribute $2 per line for purposes of universal service.43 In this
scenario, a state would be responsible for recovery of $2 per line of
reduced intrastate access revenues, which could be imputed to carriers
before they become eligible for federal recovery. Does this approach
appropriately balance the interests of consumers in states that already
have implemented some reforms, with the associated burden of reform
being born by consumers in those states, rather than federal recovery
mechanisms? If so, should states that already have a state universal
service fund be exempted completely from this per-line contribution, or
only to the extent of, for example, the $2 per line state contribution to
2. State-Federal Framework.
In the alternative, the State Members propose that the states reform intrastate rates and
that the Commission facilitate this reform through state inducements rather than a federal
framework.44 We seek comment on this proposal.
o To address concerns that some states may not reform intrastate access charges,
we seek comment on a framework, similar to a proposal in the USF/ICC
Transformation NPRM,45 under which states have three years to develop an
intrastate reform plan. Under this alternative, after three years, the Commission
would set a transition for reducing intrastate access rates and deny any further
federal recovery to offset reduced intrastate revenue.
o If the Commission adopts the state-federal framework approach advocated by the
State Members, how can the Commission best incent states to reform intrastate
access rates? Should the Commission match some federal universal service
dollars to a state universal service fund for states that are using such a fund to
reform intrastate access charges? Such matching could be structured in several
42 See, e.g., Joint Letter, Attach. at 3 n.1 ($25 benchmark); ABC Plan, Attach. 1 at 12 ($30 benchmark); AT&T April
18 Comments at 33 ($27 initial benchmark that could increase over time, such at to $30).
43 Cf. State Member Comments at 60 (suggesting that federal universal service support be reduced by $2 per
location, which "States can restore . . . on a 100% matching basis, with funds raised under a high-cost universal
service program under Section 254").
44 See State Member Comments at 148.
45 USF/ICC Transformation NPRM, paras. 548-49.
different ways, including on a per-line basis (such as $1-2), as a percentage of the
state contribution, or on an aggregate state basis.46 We seek further comment on
how such a match should be structured to provide adequate inducements and
maintain our commitment to control the size of the federal high cost fund.
Under the framework of leaving reform of intrastate rates initially to the states, the
Commission would begin immediate reforms of interstate access charges. We seek
comment on a glide path for the Commission to reduce all interstate access rate elements.
Should the length of the rate transition vary, providing three years for price cap carriers
and five years for rate-of-return carriers, given that rate of return carriers' interstate
access rates are higher at the outset?47 What should the transition be for competitive
LECs?48 Would an approach that provides different transitions for different types of
carriers, whether competitive, price cap or rate-of-return LEC raise any policy concerns?
We also seek comment on whether the Commission should reduce originating interstate
access rates and, if so, whether we should require the reductions at the same time or only
after terminating rates have been reduced.
B. Scope of Reform
We seek comment on the approach outlined in the ABC Plan to reform substantially
terminating rates for end office switching while taking a more limited approach to
reforming certain transport elements and originating access.49 Would any problematic
incentives, such as arbitrage schemes, arise from or be left in place by such an approach,
and if so, what could be done to mitigate them?
C. Recovery Mechanism.
We seek comment on the appropriate recovery mechanism for ICC reform, including the
ABC Plan's and the Joint Letter's recovery proposals.50 We also seek comment on the
relative merits and incentives for carriers associated with an alternative approach that
provides more predictable recovery amounts, such as the alternative described below.
1. Federal-State Role in Recovery.
o As noted above, the ABC Plan proposes to shift recovery for reduced intrastate
access charge revenues to the federal jurisdiction. Could the Commission
achieve more comprehensive reform of intercarrier compensation rate elements if
recovery is achieved through a federal-state partnership? We seek comment
46 See, e.g., Nebraska Companies April 18 Comments at 35-36 & App. B.
47 See, e.g., Comcast April 18 Comments at 5 (advocating a three year transition).
48 See, e.g., Letter from Karen Reidy, COMPTEL, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 10-90 et
al. at 3 (filed July 27, 2011).
49ABC Plan, Attach. 1 at 10-11(proposing to reduce certain rate elements to $0.0007 per minute with more limited
reforms for other intercarrier compensation rates).
50 ABC Plan, Attach. 1 at 11-13; Joint Letter, Attach. at 2-4.
above on different means by which states could share responsibility for recovery
of reduced intrastate access revenues.
2. Price Cap Carriers.
o For price cap carriers electing to receive support from the transitional access
replacement mechanism, the ABC Plan's recovery proposal includes annual true-
ups to adjust for possible increases or decreases in minutes of use. Although
minutes of use for incumbent LECs have been declining,51 the ABC Plan's
proposal establishing how VoIP minutes are included in the intercarrier
compensation system prospectively and addressing phantom traffic could cause
minutes of use to flatten or possibly even increase. In addition, the ABC Plan
would treat all VoIP traffic as interstate, which potentially could reduce the
minutes billed at intrastate access rates (depending upon existing payment
practices). Thus the true-up approach could result in the need for additional
recovery, including additional federal universal service funding. We seek
comment on alternatives to the true-up process.
o For example, as an alternative to true ups, we seek comment on a baseline for
recovery that would be 2011 access revenues subject to reform, reduced by 10%
annually to account for decline in demand (i.e., 90% of 2011 revenues in year
one (2012), 81.0% in year two (2013), 72.9% in year three (2014), 65.6% in year
four (2015), etc.).52 This (or a similar framework that may be suggested by
commenters) would be a brightline, predictable approach that would not include
true-ups, regardless of whether demand declines more quickly or more slowly. If
carriers reduce costs or are more efficient, this approach would enable carriers to
realize the benefits of these savings.
3. Rate of Return Carriers.
o We seek comment below on an alternative approach for recovery (or other
approaches that commenters might suggest) that would maintain the predictable
revenue stream associated with rate of return principles while also providing
carriers with better incentives for efficient investment and operations. This
option would provide a fixed percentage of recovery (which could be 100%) of
all reduced terminating access charges (both intrastate and interstate) based on
year 2011 revenues, but without true-ups to reflect changes in the revenue
requirement historically used for interstate access charges. This recovery
mechanism would lock in revenue streams, including intrastate access revenues,
which have been declining annually for many interstate rate-of-return carriers. It
thus provides more predictable revenue recovery while also providing incentives
51 USF/ICC Transformation NPRM, para. 503, Figure 13 (switched access minutes for incumbent LECs).
52 See, e.g.,. NCTA Letter, Attach. at 4 (advocating that recovery need not be revenue neutral, and should phase out
over a period of time). This framework could be used as a recovery mechanism even if we adopted a proposal for
reform that includes better state incentives outlined above.
for carriers to reduce costs and realize the benefits of these cost savings.53 The
eligible recovery amount would be recovered through end-user charges and
universal service support as described in the Joint Letter's proposal. We also
seek comment on the duration of recovery funding under this alternative. Should
it be phased out over time following the completion of rate reforms, such as with
the loss of demand?54
4. Reciprocal Compensation.
The ABC Plan's proposal provides recovery for reductions in reciprocal
compensation rates to the extent they are above $0.0007, but the ABC Plan
estimates on the impact of the federal universal service fund do not include
estimated recovery from reciprocal compensation. We ask whether providing
federal universal service support for reductions in reciprocal compensation rates
strikes the appropriate policy balance as we seek to control the size of the
universal service fund, and whether there are alternatives to such an approach.
5. Originating Access
If the Commission were to address originating access as part of comprehensive
reform, should the Commission treat originating access revenues differently from
terminating access revenues for recovery purposes since, in many cases, the
originating incumbent LEC's affiliate is offering the long distance service? For
example, is it necessary to provide any recovery for the originating access that an
incumbent LEC historically charged for originating calls from the retail long
distance customers of its affiliate?55
Alternatively, should recovery for such originating access take the form of a flat
per-customer charge imposed on the incumbent LEC's long distance affiliate for
each of its presubscribed customers? Should such a flat originating access
replacement charge be used for recovery of all originating access revenues more
generally? How would any of these approaches be implemented? Should any
53 Even carriers that are subject to interstate rate-of-return regulation can be subject to incentive regulation at the
state level or some other form of intrastate rate regulation that does not ensure rate increases every time costs
increase or demand decreases.
54 See ABC Plan, Attach. 1 at 12-13. Another possible alternative would be to use a recovery approach similar to
that for price cap carriers, discussed above.
55 Incumbent LECs typically provide retail long distance service through an affiliate in competition with other long
distance providers. If incumbent LEC end-user customers purchase long distance service from the incumbent LEC's
affiliate, it is the incumbent LEC's own affiliate that would pay those originating access charges, either directly or
indirectly. In particular, where the incumbent LEC's affiliate provided facilities-based long distance service, the
affiliate would pay the originating access directly. If the incumbent LEC's affiliate resells long distance service, the
wholesale IXC would directly pay the originating access. But it could pass through the originating access it pays to
the incumbent LEC in the rates it charges the long distance affiliate for wholesale long distance service (depending
upon the extent of any rate averaging), meaning the long distance affiliate would be indirectly paying the originating
access. This raises questions about whether the originating access revenues associated with end-user customers of
the incumbent LEC's own long distance affiliate should be viewed as additional revenue to the incumbent LEC.
flat originating access replacement charge differ by end-user customer class
(such as residential vs. business), by level of demand, or otherwise?
We seek the following data to help us evaluate originating access reform:
Separately for price cap and rate-of-return incumbent LECs, the number
of (1) long distance minutes that the average customer originates; (2)
8YY minutes that the average customer originates; and (3) long distance
and 8YY minutes that the average customer receives (terminating
minutes); and
Whether the ratio of originated long distance minutes to originated 8YY
minutes varies materially with the level of the customers' expenditure on
telecommunications services.
D. Impact on Consumers.
We seek comment on how to ensure that consumers realize benefits of reduced long
distance and wireless rates as part of intercarrier compensation reform. The ABC Plan
attaches a paper by Professor Jerry Hausman analyzing the consumer benefits of
intercarrier compensation reform. Should the potential realization of consumer pass
through benefits from intercarrier compensation reform be left to the market, as Professor
Hausman asserts, or should any steps be taken to ensure that such benefits are realized by
consumers? If so, what steps should be taken?
The ABC Plan permits incumbent carriers to increase the consumer SLC up to $9.20
before increasing the multiline business SLC, although multiline business SLCs
potentially could increase once consumer SLCs reach that level. To decrease the
potential burden on consumers and the federal universal service fund, should multiline
business customers also see a modest SLC increase and, if so, how much?
The ABC Plan permits incumbent carriers to increase consumer SLC rates $0.50-0.75 per
year for five years or until the consumer's rate reaches the rate benchmark of $30.
Similarly, the Joint Letter permits incumbent carriers to increase consumer SLC rates
$0.75 per year for six years or until the consumer's rate reaches the rate benchmark of
$25. Professor Hausman's paper indicates that companies are constrained by
competition, which could mean that companies may not be able to increase SLC rates on
consumers. We seek comment on the actual likely consumer impact of SLC increases, in
the aggregate and with as much granularity (e.g., by company, by type of state, by
specific state) as can be provided. We also seek comment on proposals that the need for
any recovery should be based on the carrier's showing of need based on its operations
more broadly.56
We seek the following data to help us quantify consumer benefits from intercarrier
compensation reform:
56 See, e.g., NCTA Letter, Attach. at 5.
o If ICC termination rates that currently exceed $0.0007 are reduced to $0.0007,
the services where pass through is likely to occur (perhaps, for example, long
distance, wireless service, 8YY services and monthly line rentals) and the likely
extent of that pass through; and
o Estimates of demand elasticities for those services where pass through is likely to
E. VoIP ICC
Implementation. We seek comment on the implementation of the ABC Plan's proposal
for VoIP intercarrier compensation.57 Under that proposal, VoIP access traffic would be
subject to intercarrier compensation rates different from rates applied to other access
traffic during the first part of the transition.58
o How would VoIP traffic subject to the ICC framework be identified for purposes
of the proposed tariffing regime?
o Would it be feasible to use call record information59 or factors or ratios to
identify the portion of overall traffic that is (or reasonably is considered to be)
relevant VoIP traffic, perhaps subject to certification or audits?60
o Should the Commission identify a "safe harbor" percentage of VoIP traffic for
use in this context? If so, what should be the factual basis for such a safe harbor?
For example, Global Crossing estimates "that on average roughly fifty to sixty
percent of the traffic [on its network] is VoIP."61 Would that, or other data,
provide a basis for a safe harbor?
o Are there alternative mechanisms besides tariffs that could be used to determine
the amount of VoIP traffic exchanged between two carriers for purposes of the
VoIP ICC framework, and if so, what would be the relative merits of such an
Call Signaling. In the USF/ICC Transformation NPRM the Commission proposed to
apply new call signaling rules designed to address phantom traffic to telecommunications
carriers and interconnected VoIP providers. Some commenters have expressed concerns
about whether and how the proposed rules would apply to one-way interconnected VoIP
providers.62 In particular, we seek to further develop the record regarding possible
57 The ABC Plan's proposal for VoIP ICC would apply not only to traffic to or from customers of interconnected
VoIP services, but also to customers of "one-way" interconnected VoIP services--in particular, to those that allow
users to terminate calls to the PSTN, but not receive calls from the PSTN, or vice versa.
58 ABC Plan, Attach. 1 at 10.
59 See, e.g., XO Section XV Comments at 33; Vonage Section XV Comments at 13-14.
60 See, e.g., XO Section XV Comments at 33; Verizon Section XV Reply at 24; Comcast Section XV Reply at 11.
61 Letter from Paul Kouroupas, Vice President, Regulatory Affairs, Global Crossing, to Marlene H. Dortch,
Secretary, FCC, CC Docket No. 01-92 at 2 (filed Dec. 17, 2010).
62 See Level 3 Section XV Comments at 10-11; AT&T Section XV Reply at 16; Level 3 Section XV Reply at 9.
implementation of any new call signaling rules that apply to one-way interconnected
VoIP providers.
o If call signaling rules apply to one-way interconnected VoIP providers, how
could these requirements be implemented?63 Would one-way interconnected
VoIP providers be required to obtain and use numbering resources? If not, how
could the new signaling rules operate for originating callers that do not have a
telephone number?64
o If one-way interconnected VoIP providers were permitted to use a number other
than an actual North American Numbering Plan (NANP) telephone number
associated with an originating caller in required signaling, would such use lead to
unintended or undesirable consequences? If so, should other types of carriers or
entities also be entitled to use alternate numbering?
o Would there need to be numbering resources specifically assigned in the context
of one-way VoIP services? Are there other signaling issues that we should
consider with regard to one-way VoIP calls?
o If call signaling rules were to apply signaling obligations to one-way
interconnected VoIP providers, at what point in a call path should the required
signaling originate, i.e. at the gateway or elsewhere?
o To what extent are such requirements necessary to implement the ABC Plan's
and Joint Letter's proposals that billing for VoIP traffic be based on call detail
information? More broadly, what particular call detail information would be
used for this purpose? What are the relative advantages or disadvantages of
treating such call detail information as dispositive for determining whether access
charges or reciprocal compensation rates apply?
Pursuant to sections 1.415 and 1.419 of the Commission's rules, 47 CFR 1.415, 1.419,
interested parties may file comments and reply comments on or before the dates indicated on the first
page of this document. All comments are to reference
WC Docket Nos. 10-90, 07-135, 05-337, 03-109,
CC Docket No. 01-92, 96-45, and GN Docket 09-51
Electronic Comment Filing System (ECFS) or (2) by filing paper copies. See Electronic Filing of
Documents in Rulemaking Proceedings, 63 FR 24121 (1998).
Electronic Filers: Comments may be filed electronically using the Internet by accessing the
ECFS: http://fjallfoss.fcc.gov/ecfs2/.
Paper Filers: Parties who choose to file by paper must file an original and one copy of each
filing. If more than one docket or rulemaking number appears in the caption of this proceeding,
filers must submit two additional copies for each additional docket or rulemaking number.
63 See, e.g., Level 3 Section XV Comments at 10-11 (seeking clarification that compliance would not require one-
way interconnected VoIP providers to obtain numbering resources).
64 See id.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission's Secretary,
Office of the Secretary, Federal Communications Commission.
All hand-delivered or messenger-delivered paper filings for the Commission's Secretary must be
delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325, Washington, DC 20554.
The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held together with rubber
bands or fasteners. Any envelopes must be disposed of before entering the building.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must
be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street,
SW, Washington DC 20554.
People with Disabilities: To request materials in accessible formats for people with disabilities (Braille,
large print, electronic files, audio format), send an e-mail to firstname.lastname@example.com or call the Consumer &
Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
In addition, one copy of each pleading must be sent to each of the following:(1) The Commission's duplicating contractor, Best Copy and Printing, Inc., 445 12th Street, S.W., Room
CY-B402, Washington, D.C. 20554, www.bcpiweb.com; phone: (202) 488-5300 fax: (202) 488-
(2) Charles Tyler, Telecommunications Access Policy Division, Wireline Competition Bureau, 445 12th
Street, S.W., Room 5-A452, Washington, D.C. 20554; e-mail: firstname.lastname@example.com.
Filings and comments are also available for public inspection and copying during regular
business hours at the FCC Reference Information Center, Portals II, 445 12th Street, S.W., Room CY-
A257, Washington, D.C. 20554. They may also be purchased from the Commission's duplicating
contractor, Best Copy and Printing, Inc., Portals II, 445 12th Street, S.W., Room CY-B402, Washington,
D.C. 20554, telephone: (202) 488-5300, fax: (202) 488-5563, or via e-mail www.bcpiweb.com.
This matter shall be treated as a "permit-but-disclose" proceeding in accordance with the
Commission's ex parte rules.65 Persons making oral ex parte presentations are reminded that memoranda
summarizing the presentations must contain summaries of the substance of the presentation and not
merely a listing of the subjects discussed. More than a one or two sentence description of the views and
arguments presented generally is required.66 Other rules pertaining to oral and written ex parte
presentations in permit-but-disclose proceedings are set forth in section 1.1206(b) of the Commission's
For further information, please contact Katie King, Telecommunications Access Policy Division,
Wireline Competition Bureau, at (202) 418-7400 or TTY (202) 418-0484, Daniel Ball, Pricing Policy
Division, Wireline Competition Bureau, at (202) 418-1520, and Sue McNeil, Auctions and Spectrum
Access Division, Wireless Telecommunications Bureau at (202) 418-0660.
65 47 C.F.R. 1.1200 et seq.
66 See 47 C.F.R. 1.1206(b)(2).
67 47 C.F.R. 1.1206(b).
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text:
Judge Marcus Clark smiles as he discusses election results Saturday in Monroe. He was elected to the Louisiana Supreme Court.
- Filed Under
Fourth Judicial District Court Judge Marcus Clark was elected Saturday to a seat on the Louisiana Supreme Court. Clark defeated Pineville attorney Jimmy Faircloth, who was endorsed by his former boss, Gov. Bobby Jindal.
With all 693 precincts reporting from 20 parishes making up the 4th Supreme Court District, Clark led by 28,521 votes to Faircloth's 25,495. Results are complete but unofficial.
Clark replaces Justice Chet Traylor of Winnsboro, who retired in May. ...


text:
Bryce Canyon National Park.
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This architectural wonder draws an international crowd and lets you stand above the Colorado River in less than an hour via transportation that befits a guest of ARIA. Daily tours range from 4 to 8 hours in length.


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text:
William Marlow (English, 17401813)
Designed by Sir William Chambers (English, 17261796)
Watercolor; 11 13/16 x 17 13/16 in. (28.4 x 45.2 cm)
This exquisite watercolor drawing depicts a view in the Royal Botanic Garden of Kew (near London), designed by the celebrated eighteenth-century English architect William Chambers. This sheet is bound in an album containing all the original watercolor drawings later published in print form as Plans, Elevations, Sections and Perspective Views of the Gardens and Buildings of Kew in Surrey, the Seat of Her Royal Highness, the Princess Dowager of Wales (London, 1763). This work beautifully illustrates the various garden sections and numerous structures at Kew, including a mosque, a classical rotunda, and a Chinese pagoda, demonstrating the fascination for eclecticism in garden art. The soft undulating shape of the lake and its surrounding lawns is combined with the crisp silhouette of the Chinese pagoda as focal point in the distance. This drawing provides a view of the quintessential English landscape garden, much admired and imitated on the continent.


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The 12-Step Buddhist
The face of addiction and alcoholism is a face that many have seen before—a celebrity, a colleague, or even a family member—and the damages from addictive behaviors ruin lives and rend families apart. Yet there is hope, even for those who haven't found longterm success in traditional twelve-step programs. By approaching addiction at its source, author and recovering addict Darren Littlejohn brings about a deep healing in The 12-Step Buddhist, with a potent introduction by Robert Thurman. Working within the 12-step philosophy, The 12-Step Buddhist incorporates exercises, meditations, and inner dialogues that validate all aspects of the recovery process. Littlejohn's approach makes Buddhism accessible for addicts, and the 12 steps understandable to anyone.
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Tuesday, October 19, 2010
The Take-Away
I am so happy I went because I got to re-hear advice I've been hearing from people and online forums. I heard some new information about the experiences of some kids in school. I heard of one private school who did not guide the student to take SAT II tests and it ruined the student's chances of even applying to some colleges.
I heard four stories of kids who were in public school and were able to get good grades and good teacher reports despite having not mastering content and being pulled out to homeschool and seeing the amazing progress that can be made with 1:1 tutoring at home with mom when the gaps were addressed once school was quit and homeschooling commenced.
More importantly I got a better sense for the rigor of basic high school courses (as outlined on paper not based on some hollow public high school experiences). I got a sense for how difficult honors or AP classes can be when taken through online schools (recommended). I got a sense for how hard it can be to get a good score on the AP test (a 4 or a 5) if self-study is done that is not rigorous.
The urgency of homeschoolers taking SAT II's was made clear and to pass with a good score requires serious study. It was advised that the test be taken shortly after the topic was studied.
The point has been made that writing composition is crucial as to communicate clearly and to also blend this with analytical thinking that is high school level writing important. Taking a high school class then writing like a middle school student or elementary student is just not good enough for high test scores, will lock kids out of college not to mention that they will not be prepared for college itself.
One more thing: the importance of not pushing standardized tests down to students in grade 7 or 8 or maybe even 9 was made clear because if their writing composition abilities are on that grade level not on a grade 11 or 12 level they will not score well (nor should they). One mother shared that her child knew the content thoroughly but didn't fare well on the writing component as the essay was typical for a student in grade 8 (she was able to obtain a copy of what her child wrote and judged this for herself). One friend of mine would argue that developmentally their brains are not ready at ages 12-14 to think analytically enough or they have not yet learned enough wide content to have context and to be able to write about it well to boot.
I have finally gotten it through my head that the level of rigor for a student such as my son with an engineering school college goal will not be met by mostly attending homeschool co-op's or at least not the ones he is currently in. At best we could spend one day a week at one co-op for social time and some extra-curriculars, but the rest of the time my son will have to work independently for core subjects, with me, take online classes or community college courses, or have 1:1 tutoring with a private tutor.
This fall semester is a mess of running around. Endings are in sight, chapters will be closing. The saddest is the ending of five years of experiential nature classes (because the school is closing). I need to really think about what we will when all of our committments end in December in order to decide which things we will re-enroll in. I fear that my son will have to either reduce his participation with the homeschool Science Olympiad team (one of his passions) or he won't participate in his high school years at all. Things have to be dropped in order to make time for the basic high school studies that are rigorous enough to meet his goals.
I didn't leave the meeting feeling overwhelmed or incapable. I left feeling reassured that changes need to be made and that things have to be kicked up some notches (hat tip to Emeril Lagasse for that phrase).
I am encouraged by the fact that my son is already stepping up to the plate this fall and accepting more work and doing his homework assignments on time. He is getting more organized with his school books and papers and is getting better at time management. My nagging is reducing and he is being more proactive and working independently without any nudging from me at all. He has a good attitude. The thing that bothers him the most is that we have too many appointments and not enough time at home for a slower pace and a more peaceful home study environment.
This eighth grade year is a learning curve for both of us, apparently.
(I am trying not to let my fifth grader get lost in this shuffle too! It seems that these issues of homeschooling high school and college admittance are using too much of my time and energy lately.)
I love the HSLDA brochure DEVELOPING A HIGH SCHOOL PLAN about homeschooling high school. It has three basic high school plans to pick from.
Be sure to read the college's websites about requirements for homeschoolers. The colleges may require more AP classes or SAT II tests that are more rigorous than the HSLDA brochure may indicate. The colleges may require more or less studies depending on the major (HSLDA says four years of history while two competitive schools for engineering require only two or more advanced math and science may be required than the brochure indicates).
4 comments:
- K said...
***The urgency of homeschoolers taking SAT II's was made clear and to pass with a score of 4 or 5 will require serious study.***
Don't get SAT II's confused with AP exams. SAT II's are scored just like the regular SAT with scores out of 800. AP exams are scored on the 2-5 scale. Generally the AP exams are more difficult and are taken more seriously by universities. Some universities require homeschoolers, without a transcript from an accredited cover school, to take SAT II exams, often in two subjects that are not math or reading.
- Tuesday, October 19, 2010 at 10:29:00 AM CDT
- christinemm said...
K thank you. I updated the blog post to be more clear and accurate. :)
- Tuesday, October 19, 2010 at 10:34:00 AM CDT
- TulipGirl said...
Thanks for this summary!
- Saturday, October 23, 2010 at 5:10:00 PM CDT
- Carlie said...
This is very interesting information to hear. I found you through HomeschoolersInclusive group and even though the high school period is years away for us, its good to be thinking a little in advance about what the options are. My husband was homeschooled all the way through and my parents stopped at high school so I am not sure what to expect for the higher grades. Thanks for sharing in so much detail.
- Friday, November 5, 2010 at 1:59:00 PM CDT


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Affiliate Professor in New Testament Greek
Ph.D. (Theology) University of Durham (U.K.)
M.T.S. (Biblical Studies) Eastern Baptist Theological Seminary
M.Div. Eastern Baptist Theological Seminary
Diplôme (Langue et Civilisation) Université de Paris, La Sorbonne
B.S. (Elementary Education) Gordon College
Deborah Watson serves on the pastoral staff of Narberth Presbyterian Church in Narberth Pennsylvania, where she began as a seminary intern in 1993. Prior to her seminary study, she taught French and English as a Second Language to high school students in New Hampshire. She also spent time studying and working in Paris, France and on a kibbutz in Israel.
The call of Scripture to care for those members of the community who cannot care for themselves became the focus of Deborah's dissertation, "Paul's Collection in Light of Motivations and Mechanisms for Aid to the Poor in the First Century World." Since its completion in 2006, she has taught classes on "Wealth & Want in Scripture" and "The Least of These: Aid to the Poor in the First Century." The theme of care for people in need continues to captivate Deborah and to inform her teaching and ministry.
She has taught at the Seminary since 1995, first as an adjunct and now as an affiliate professor in the areas of New Testament, New Testament Greek, Greek Exegesis, and Theological Research & Writing. She is a member of the Society for Biblical Literature and the American Association of Teachers of French.


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Official Name - The Republic of Vanuatu
Land Area - 12,190 sq km - four main islands, eighty smaller islands
Population - 234,023 (2009 census), 262,045 (2013 estimate). Citizens are known collectively as ni-Vanuatu
Capital City - Port Vila, Efate
Religion - Predominantly Christian
Languages -Official languages: Bislama (Pidgin), English and French. There are also approximately 115 local languages.
Currency - Vanuatu Vatu (Vt)
Exchange Rate - NZ$1 = 72 Vt (July 2013)
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Last election - September 2012 (legislature)
Next election due - September 2016 (legislature); August 2014 (President)
Main political parties - Union of Moderate Parties (UMP); Vanua'aku Pati (VP); National United Party (NUP); Melanesian Progressive Party (MPP); the Greens Confederation (GC); People's Progressive Party (PPP); Ground and Justice Party; Namange aute; Nagriamel Movement; Natatok Indigenous People's Democratic Party (NIPDP); Vanuatu National Party (VNP); People's Services Party (PSP); Iauko Group; People's Democratic Progressive Party (PPDP); Vanuatu Republican Party (VRP), Hope Party
GDP - US$743 million (to June 2012)
GDP breakdown - Goods 30% Services 70%
GDP per capita - VT286,844 (NZ$3984) 2011
Real GDP Growth - 2.6% (June 2012)
Exports of Goods (FOB) - VT 5,073 million (2012)
Main exports - (Vanuatu Statistics Office November 2012 Highlights)
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New Zealand's links with Vanuatu are long-standing, and strengthening through programmes such as the successful Recognised Seasonal Employer (RSE) scheme and tourism.
Artefacts and human remains of the Lapita people, the first inhabitants of the Vanuatu archipelago, have been unearthed near Port Vila on Efate Island and date back at least 4,000 years. The first European sailed through the area in 1606 and in 1774, Captain James Cook charted the islands which he named New Hebrides (after the Scottish islands). There gradually followed a range of missionaries, black-birders, whalers, sandalwood traders and colonists.
Britain and France established a Joint Naval Commission in the New Hebrides in 1887, and in 1906 the territory became the Anglo-French Condominium of the New Hebrides.
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...even after I was on the route it had calculated (i.e. at the very next on ramp). It would be great if you could detect a way point being reached even if a previous one was missed.Quote:
Originally Posted by Arathranar
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...even after I was on the route it had calculated (i.e. at the very next on ramp). It would be great if you could detect a way point being reached even if a previous one was missed.Quote:
Originally Posted by Arathranar
yeah.. that's a good idea.. but one of the codes I made had that in it.. I think I had to take that out because it was working right when for instance you had to go around something to come back closer to where you had to turn -- I may be able to do something about it though..
How can I use the Base App?? I cannot find it anywhere??:(:(
That would be cool to have and "Auto-recalculate" feature, without the button! You think you can add to your evergrowing list? If it is a major task than I am willing to "donate" more development funds, just let me know! (I like the fact I can bribe you for added features, this is awesome! :) )
It's in the source packages under the base plugin folder.. I have done a few improvements already, so you may just want to wait for the final version.. but it doesn't prevent you from looking at the code and try to get the hang of it..Quote:
Originally Posted by DjBac
I really have to do some testing to see if it is possible (that is reliably enough)..Quote:
Originally Posted by dougmorgan99
Originally Posted by guino
I must be really dumb because I can't understand how this FAV function works. I was able to figure out the show location, I find it tedious to use but it works :)
The FAV on the other hand is a different story. I followed your instructions and entered a location using the Route Planning Button > clicked add > searched for location > clicked ADD (middle at the bottom) > typed a name for the address (ie Mom and Dad). When I click the FAV button I see Mom and Dad in there.
Here is the confusion....I go back to Route Planning click on the FAV and select Mom and Dad. I then click Route and Calculate and it takes me out West someplace to a street closely resembly the name Mom and Dad!!! For some reason when I type the name for the FAV it seems to use this as the address.
What am I doing wrong?
Interesting.. this is not supposed to happen.. you might be missing something in the way:
-Go into the route planner
-Click FAV
-Delete all of your favorites to be sure
-Click Cancel
-Click ADD on the route planner screen
-Click on the street and enter the street name you wish to add to favorites
-Hit SEARCH (NOT ADD -- yet)
-From the results list, select the address you'd like to add to your favorites
-Now hit ADD, and enter whatever name you want for the location
-Hit ENTER on the OSK
-Return to the route planner
-Click FAV
-Select the location you've added,
-Click SELECT -- the name of the location should show on the list
-Exit the planner and click - Route->Calculate
If it doesn't show the route for the location you've added to the favorites, please send me your favorites.ini file so I can have a look at it.. I've been using it quite often lately with no problems..
Let me know,


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A new-look Kohl's joins a recent trend of remodeled chain stores in the Chillicothe area.
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|FP7 AdvanceETV (226824): Coordination action on Environmental Technology Verification ETV
Aanbiedingen, Europa, Technologie, Website, Milieu - algemeen
AdvanceETV aims to demonstrate that the proposed schemes and protocols for Environmental Technologies Verification systems have the potential to be recognised internationally. Thus the main objective is to develop an international framework for cooperation and mutual recognition by supporting the cooperation of international ETV activities, e.g the International Working Group (IWG). This requires support by joint coordination activities: (i) Providing a European basis for mutual recognition (ii) Coordinating requirements for co-verification and joint verification (iii) Developing a framework for international harmonization. The European basis will be elaborated through integrating previous and on-going European RTD. This is done by bringing together protocols/verification reports out of the FP6 projects, consolidating stakeholder feedback of RTD and EC activities and by integrating experiences out of the CEN workshop agreement (CWA) elaboration and use. To raise awareness on gaps and overlaps of international cooperation a case study workshop on co- and joint verification will be initiated together with U.S. and Canadian partners. To foster recognition by harmonisation a standardisation framework will be identified to prepare the initiation of a standardisation procedure. Cross cutting issue workshops ensure feedback and exchange between these different areas. To bring forward mutual recognition, to support cooperation by co-/joint verification and harmonisation requires a strong link to international ETV activities and the IWG on ETV. A confirmed expert board with ETV system representatives from Canada, U.S., South Korea, Japan and others provides the direct link here. This concept supports the working structure of the CA: focused on a series of conferences, coordinated with international ETV activities, serving as a platform for incremental consolidation of the international framework. Partner institutions: DECHEMA Gesellschaft fuer Chemische Technik und Biotechnologie (DE); IVL Swedish Environmental Research Institute Ltd (SE); DHI (DK); European Commission - DG Joint Research Centre (BE); Sachverstaendigen-Buero Dr. Thomas Ertel (DE); Fundación Labein (ES); Environment Agency (UK); STICHTING DELTARES (NL); Instytut Ekologii Terenów Uprzemyslowionych (PL); Ontario Centre For Environmental Technology Advancement (CA); Battelle Memorial Institute (US); Comite Europeen de Normalisation (BE). For further information please contact the Contact Persons through the http://www.epa.gov/etv/pubs/AdvanceETV.pdf homepage


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