HomeMy WebLinkAbout20160616Filer Mutual Form 481.pdfREDACTED – FOR PUBLIC INSPECTION
VIA ECFS
June 16, 2016
Ms. Marlene H. Dortch, Secretary
Federal Communications Commission
Office of the Secretary
445 12th Street, S.W.
Washington, D.C. 20554
RE: REQUEST FOR CONFIDENTIAL TREATMENT
WC Docket No. 14-58 - ETC Annual Reports and Certifications
Request that Information Submitted to the Commission be Withheld from Public
Inspection Pursuant to 47 C.F.R. §0.459 and 5 U.S.C. §552(b)(4): Five-Year Service
Quality Improvement Plan Progress Report included in FCC Form 481
Confidential Information – Subject to Protective Order Before the Federal
Communications Commission
Dear Ms. Dortch:
In accordance with the annual reporting requirements of 47 C.F.R. §§54.313 and 54.422,
Filer Mutual Telephone Company (the Cooperative), Study Area Code 472220is
submitting a completed FCC Form 481 to the Commission via its Electronic Comment
Filing System (ECFS) in WC Docket No. 14-58. The version of the Cooperative’s FCC Form
481 submitted via ECFS is a redacted version of the filing that contains no confidential
information.
The Cooperative, by its authorized representative, hereby requests confidential
treatment of two attachments to its FCC Form 481: (1) the five-year service quality
improvement plan progress report and (2) the financial annual report, both of which
were redacted in the ECFS submission. The request for confidential treatment of the five-
year plan progress report is being made pursuant to Section 0.459 of the Commission’s
rules and Exemption 4 of the Freedom of Information Act (FOIA). The request for
confidential treatment of the financial annual report is being made pursuant to the FCC’s
Ms. Marlene Dortch
Page 2
March 22, 2016 Protective Order in WC Docket Nos. 10-90 and 14-58. These attachments
contain competitively sensitive data that Filer Mutual Telephone Company maintains as
confidential and does not normally make available to the public. Release of this
information would have a substantial negative impact on the Cooperative.
Five-Year Service Quality Improvement Plan Progress Report
Pursuant to Section 0.459 of the Commission’s rules and Exemption 4 of FOIA, Filer
Mutual Telephone Company requests that the text and data extracted from its five-year
service quality improvement plan progress report be withheld from public inspection
because it contains competitively sensitive commercial and financial information that the
Cooperative maintains as confidential. Public availability of this information would have
a substantial negative impact on the Cooperative.
In accordance with Section 0.459 of the Commission’s rules, the following information is
provided in support of this request:
(1) Identification of the specific information for which confidential treatment is sought:
Attachment to Line 112 of FCC Form 481 – Five-Year Service Quality Improvement
Plan Progress Report. Specifically, confidential treatment is sought for all
information in the five-year plan progress report related to the Cooperative’s access
line counts, existing broadband capabilities, and current and planned financial
investments in its network that will improve service quality, service coverage, and/or
service capacity for its customers.
(2) Identification of the Commission proceeding in which the information was submitted
or a description of the circumstances giving rise to the submission:
The information was submitted in WC Docket No. 14-58 as an attachment to FCC
Form 481- the Carrier Annual Reporting Data Collection Form. Section 100 of FCC
Form 481 requires incumbent local exchange carriers receiving high cost support to
attach a progress report on its five-year service quality improvement plan, pursuant
to 47 C.F.R. §54.313(a)(1).
(3) Explanation of the degree to which the information is commercial or financial, or
contains a trade secret or is privileged:
The five-year service quality improvement plan progress report contains granular
information on the Cooperative’s access line counts and/or existing broadband
capabilities as well as recent and planned capital investments in its network to
improve service quality, service coverage, and/or service capacity. It also contains a
Ms. Marlene Dortch
Page 3
map of the Cooperative’s service area detailing progress toward meeting broadband
deployment targets at the wire center level. This is closely guarded, privileged
information that the Cooperative does not make publicly available.
(4) Explanation of the degree to which the information concerns a service that is subject
to competition:
Broadband is subject to increasing competition in the areas served by rural, rate-of-
return incumbent local exchange carriers (RLECs). Virtually all RLECs face
competition from one or more wireless Internet service providers. Most RLECs also
face competition from at least one other wireline broadband provider, such as a
larger cable company, who will typically seek to “cherry pick” the lower cost portions
of the study area. In addition, all RLECs face competition throughout their territories
from satellite broadband providers.
(5) Explanation of how disclosure of the information could result in substantial
competitive harm:
Disclosure of the information contained in the five-year plan progress report would
provide competitors with detailed, granular information regarding the Cooperative’s
access line count, its existing broadband capabilities, and its recent and planned
network investments that improve service quality, coverage, and/or capacity for
subscribers. This would give competitors valuable confidential information with
which to develop their own strategies for investing in the service area, thereby
bringing substantial competitive harm to the Cooperative.
(6) Identification of any measures taken by the submitting party to prevent unauthorized
disclosure:
The Cooperative has continually treated the extracted information in its five-year
plan progress report as confidential and carefully controls the information to protect
it from competitors. Access to the information is limited to employees that require it
and to non-employees with confidentiality obligations such as lenders, consultants,
auditors, and attorneys. In addition, when such information is required to be
submitted to a state regulatory authority it has been filed as confidential information,
not available to the public.
Ms. Marlene Dortch
Page 4
(7) Identification of whether the information is available to the public and the extent of
any previous disclosure of the information to third parties:
The redacted information in the five-year plan progress report is not available to the
public, and third-party access is limited as described in (6) above.
(8) Justification of the period during which the submitting party asserts that material
should not be available for public disclosure:
The Cooperative requests that the extracted information be withheld from public
inspection indefinitely. The information in the five-year plan progress report details
the Cooperative’s most recent network upgrades in relation to its previously
submitted service quality improvement plan. It may also contain upcoming planned
network improvements during the five-year period ending 2019. This information
would provide a very useful baseline for competitors for several years beyond that
period.
(9) Any other information that the party seeking confidential information treatment
believes may be useful in assessing whether its request for confidentiality should be
granted:
Exemption 4 of FOIA shields from public disclosure commercial or financial
information obtained from a person that is privileged or confidential. Based on the
responses provided above, the information in question satisfies this test.
Financial Annual Report
Section 3005 of FCC Form 481 requires a privately-held rate-of-return carrier receiving
high cost support to attach a full and complete annual report of the company’s financial
condition and operations pursuant to 47 C.F.R. §54.313(f)(2). Filer Mutual Telephone
Company seeks confidential treatment of its financial annual report pursuant to the
March 22, 2016 Protective Order in WC Docket Nos. 10-90 and 14-58.1 The Protective
Order specifically covers information filed pursuant to 47 C.F.R. §54.313(f)(2).
Filer Mutual Telephone Company is providing to the Office of the Secretary, under seal,
this cover letter and the Form 481 filing which includes the confidential information that
is being requested to be withheld from public inspection.
1 Connect America Fund, ETC Annual Reports and Certifications, WC Docket Nos. 10-90 and 14-58, Protective
Order, DA 16-296 (rel. Mar. 22, 2016).
Ms. Marlene Dortch
Page 5
Each page of the five-year service quality improvement plan progress report confidential
submission bears the legend, “CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE.”
Each page of the financial annual report confidential submission bears the legend,
“CONFIDENTIAL INFORMATION – SUBJECT TO PROTECTIVE ORDER BEFORE THE
FEDERAL COMMUNICATIONS COMMISSION.”
The confidential information has also been submitted to the Universal Service
Administrative Company through its E-File system as attachments to the FCC Form 481.
In the filing submitted via ECFS, all pages containing confidential information bear the
legend “REDACTED – FOR PUBLIC INSPECTION.”
This cover letter includes no confidential information and the text is the same in both the
non-redacted and redacted versions except for the confidentiality markings.
Please contact me if you have any questions.
Sincerely,
Eric N. Votaw, Senior Manager
For Moss Adams, LLP
EV
Enclosures
cc: Bob Kraut, Filer Mutual Telephone Company
Page 1
Page 1
& &Žƌŵ ϰϴϭ
FCC Form 481 - Carrier Annual Reporting OMB Control Eo͘ 3060-0986ͬOMB Control Eo͘ 3060-0819
:ulLJ Ϯ013
<010> Study Area Code <015> Study Area Name
<020> Program Year
<030> Contact Name: Person USAC should contact
w t questons a out t s ata
<035> Contact Telephone Number:
um er o t e person ent e n ata ne <> <039> Contact Email Address:
ma o t e person ent e n ata ne <>
Data Collection Form
FŽƌŵ Type
54.313 and 54.422
Robert Kraut
2017
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
472220
Page 2
Page 2
<110> Has your company received its ETC certification from the FCC? (yes / no )
<111>
If your answer to Line <110> is yes, do you have an existing §54.202(a) "5
year plan" filed with the FCC?(yes / no )
If your answer to Line <111> is yes, ƉůĞĂƐĞ file a progress report, on line
<112> delineating the status of your company's existing § 54.202(a) "5 year
plan" on file with the FCC, as it relates to your provision of voice telephony
service.
<112>Attach FiveͲYear Service Yuality Improvement Plan or, in subsequent years,
your annual progress report filed pursuant to 4ϳ C.F.Z. § 54.313(a)(1). If your company is a
CETC which only receives frozen support, your progress report is only
required to address voice telephony service.
<113> Maps detailing progress towards meeting plan targets
<114> Report how much universal service (USF) support was received
<115>
<116>
<117>
<118>Provide an explanation of network improvement targets not met
in t e prior ca en ar year.
(100) Service Quality Improvement Reporting FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
Robert Kraut
Yes
2017
bkraut@filertel.net
Yes
Yes
FILER MUTUAL TEL -ID
2083264331 ext.
Yes
Yes
472220
472220ID100.pdf
Yes
Please select the appropriate responses below (Yes, No, Not Applicable) to confirm
that the attached document(s), on line 112, contains a progress report on its five-year
service quality improvement plan pursuant to §54.202(a). The information shall be
submitted at the wire center level or census block as appropriate.
Name of Attached Document
How much (USF) was used to improve service quality and how support was used to improve service quality
How much USF was used to im rove service covera e and how su ort was used to im rove service covera e
How much (USF) was used to improve service capacity and how support was used to improve service capacity
Page 3
Page 3
(200) Service Outage Reporting (Voice)FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
<220><a> <b1> <b2> <b3> <b4> <c1> <c2> <d> <e> <f> <g> <h>
NORS
Reference
Number
Outage Start
Date
Outage Start
Time
Outage End
Date
Outage End
Time
Number of
Customers Affected Total Number of
Customers
911 Facilities
Affected
(Yes / No)
Service Outage
Description (Check
all that apply)
Did This Outage
Affect Multiple
Study Areas
(Yes / No)
Service Outage
Resolution
Preventative
Procedures
<210> For the prior calendar year, were there any reportable voice service outages?
Robert Kraut
2017
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
472220
No
(ϯϬ0) hŶĨƵůĨŝůůĞĚ^ĞƌǀŝĐĞ ReƋƵĞƐƚ FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
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<ϯϯϬ>ĞƚĂŝůŽŶĂƚƚĞŵƉƚƐ;ďƌŽĂĚďĂŶĚͿ
Name of Attached DocuŵĞŶƚ
Name of Attached Document
Page ϰ
Page ϰ
Robert Kraut
2017
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
0
0
472220
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line
<030>
<039> Contact Email Address - Email Address of person identified in data line
<030>
<400>
Select from the drop-down list to indicate how you would like to report
voice complaints (zero or greater) for voice telephony service in the prior
calendar year for each service area in which you are designated an ETC for
any facilities you own, operate, lease, or otherwise utilize.
<410> Complaints per 1000 customers for fixed voice
<420> Complaints per 1000 customers for mobile voice
<430>
Select from the drop-down list to indicate how you would like to report
end-user customer complaints (zero or greater) for broadband service in
the prior calendar year for each service area in which you are designated
an ETC for any facilities you own, operate, lease, or otherwise utilize.
<440>
<450>
Complaints per 1000 customers for fixed broadband
Complaints per 1000 customers for mobile broadband
Page ϱ
Page ϱ
(ϰ00) EƵŵďĞƌ ŽĨŽŵƉůĂŝŶƚƐƉĞƌϭ͕ϬϬϬĐƵƐƚŽŵĞƌƐ&C Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
Robert Kraut
2017
bkraut@filertel.net
0.0
Offered only fixed broadband
FILER MUTUAL TEL -ID
2083264331 ext.
0.0
Offered only fixed voice
472220
(ϱϬϬͿŽŵƉůŝĂŶĐĞtŝƚŚ^ĞƌǀŝĐĞYƵĂůŝƚLJ^ƚĂŶĚĂƌĚƐĂŶĚŽŶƐƵŵĞƌWƌŽƚĞĐƚŝŽŶZƵůĞƐ&C Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
Page ϲ
Page ϲ
фϱϬϬхĞƌƚŝĨLJĐŽŵƉůŝĂŶĐĞǁŝƚŚĂƉƉůŝĐĂďůĞƐĞƌǀŝĐĞƋƵĂůŝƚLJƐƚĂŶĚĂƌĚƐĂŶĚĐŽŶƐƵŵĞƌƉƌŽƚĞĐƚŝŽŶƌƵůĞƐ
фϱϭϬхĞƐĐƌŝƉƚŝǀĞĚŽĐƵŵĞŶƚĨŽƌ^ĞƌǀŝĐĞYƵĂůŝƚLJ^ƚĂŶĚĂƌĚƐΘŽŶƐƵŵĞƌWƌŽƚĞĐƚŝŽŶZƵůĞƐŽŵƉůŝĂŶĐĞ
Robert Kraut
472220ID510.pdf
Yes
2017
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
472220
<010>
<015>
<020>
<030>
<035>
<039>
Study Area Code
Study Area Name
Program Year
Contact Name - Person USAC should contact regarding this data
Contact Telephone Number - Number of person identified in data line <030>
Contact Email Address - Email Address of person identified in data line <030>
(ϲϬϬͿ&ƵŶĐƚŝŽŶĂůŝƚLJŝŶŵĞƌŐĞŶĐLJ^ŝƚƵĂƚŝŽŶƐ FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
фϲϬϬхĞƌƚŝĨLJĐŽŵƉůŝĂŶĐĞƌĞŐĂƌĚŝŶŐĂďŝůŝƚLJƚŽĨƵŶĐƚŝŽŶŝŶĞŵĞƌŐĞŶĐLJƐŝƚƵĂƚŝŽŶƐ
Page ϳ
фϲϭϬхDescriptive document for Functionality in Emergency Situations
Page ϳ
Robert Kraut
2017
Yes
bkraut@filertel.net
472220ID610.pdf
FILER MUTUAL TEL -ID
2083264331 ext.
472220
Page ϴ
Page ϴ
<701> Residential Local Service Charge Effective Date
<702> Single State-wide Residential Local Service Charge
<703><a1> <a2> <a3> <b1> <b2>
State Exchange (ILEC) SAC (CETC) Rate Type
Residential Local
Service Rate
<c>
Total per line Rates and Fees
<b5>
Mandatory Extended Area
Service Charge
<b4>
State Universal Service Fee
<b3>
State Subscriber Line Charge
(ϳ00) WƌŝĐĞKĨĨĞƌŝŶŐƐŝŶĐůƵĚŝŶŐsŽŝĐĞZĂƚĞĂƚĂ FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010>
<015>
<020>
<030>
<035>
<039>
Study Area Code
Study Area Name
Program Year
Contact Name - Person USAC should contact regarding this data
Contact Telephone Number - Number of person identified in data line <030>
Contact Email Address - Email Address of person identified in data line <030>
Robert Kraut
1/1/2016
2017
-- See attached worksheet
--
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
472220
21.0
Page ϵ
Page ϵ
<711><a2> <b1> <b2> <c> <d1> <d2> <d3> <d4>
Exchange (ILEC) Residential Rate
State Regulated
Fees Total Rate and Fees
Broadband Service -
Download Speed
(Mbps)
Broadband Service -
Upload Speed (Mbps)
Usage Allowance
Action Taken When
Limit Reached {select}
<a1>
Usage Allowance
(GB)
State
(7ϭ0) ƌŽĂĚďƌĂŶĚPrice Offerings&C Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
Robert Kraut
2017
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
-- See attached
worksheet --
472220
Page ϭϬ
PageϭϬ
(800) Operating Companies FCC Form 481
Data Collection Form OMB Control No. 3060-0986
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
<810> Reporting Carrier
<811> Holding Company
<812> Operating Company
<813><a3>
Doing Business As Company or Brand Designation
<a1>
Affiliates
<a2>
SAC
<813><a3>
Doing Business As Company or Brand Designation
<a1>
Affiliates
<a2>
SAC
<813><a3>
Doing Business As Company or Brand Designation
<a1>
Affiliates
<a2>
SAC
<813><a3>
Doing Business As Company or Brand Designation
<a1>
Affiliates
<a2>
SAC
/OMB Control No. 3060-0819
Not Applicable
Robert Kraut
Filer Mutual Telephone Company
2017
bkraut@filertel.net
Filer Mutual Telephone Company
FILER MUTUAL TEL -ID
2083264331 ext.
472220
Page ϭϭ
<910>Tribal Land(s) on which ETC Serves
<920> Tribal Government Engagement Obligation
<921>
<922>Feasibility and sustainability planning;
<923> Marketing services in a culturally sensitive manner;
<924> Compliance with Rights of way processes
<925> Compliance with Land Use permitting requirements
<926> Compliance with Facilities Siting rules
<927> Compliance with Environmental Review processes
<928> Compliance with Cultural Preservation review processes
<929> Compliance with Tribal Business and Licensing requirements.
(ϵϬ0) dƌŝďĂů>ĂŶĚƐZĞƉŽƌƚŝŶŐ FCC Form 481
Data Collection Form OMB Control No. 3060-0986
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
/OMB Control No. 3060-0819
Pageϭϭ
<9Ϭ0>ŽĞƐƚŚĞĨŝůŝŶŐĞŶƚŝƚLJŽĨĨĞƌƚƌŝďĂůůĂŶĚƐĞƌǀŝĐĞƐ͍;zͬEͿ
Robert Kraut
2017
bkraut@filertel.net
No
FILER MUTUAL TEL -ID
2083264331 ext.
472220
Name of Attached Document
If your company serves Tribal lands, please select (Yes,No, NA) for each these boxes
to confirm the status described on the attached document(s), on line 920,
demonstrates coordination with the Tribal government pursuant to
§ 54.313(a)(9) includes:
Needs assessment and deployment planning with a focus on Tribal
community anchor institutions.
Select
Yes or No or
Not Applicable
Page ϭϮ
(ϭϬϬϬͿsŽŝĐĞĂŶĚƌŽĂĚďĂŶĚ^ĞƌǀŝĐĞZĂƚĞŽŵƉĂƌĂďŝůŝƚLJFCC Form 481
Data Collection Form OMB Control No. 3060-0986
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
/OMB Control No. 3060-0819
<1000> Voice services rate comparability certification
<1010> Attach detailed description for voice services rate
comparability compliance
Name of Attached Document
<1020> Broadband comparability certification
<1030> Attach detailed description for broadband
comparability compliance
Name of Attached Document
Page ϭϮ
Robert Kraut
472220ID1010.pdf
472220ID1030.pdf
2017
bkraut@filertel.net
Yes - Pricing is no more than the most recent applicable benchmark announced by
the Wireline Competition Bureau
FILER MUTUAL TEL -ID
2083264331 ext.
Yes
472220
Page ϭϯ
Page ϭϯ
(1100) No Terrestrial Backhaul Reporting FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
<1130>
Certify whether terrestrial backhaul options exist (Y/N)
<1100>
Robert Kraut
2017
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
Yes
472220
Please select the appropriate response (Yes, No, Not Applicable) to confirm the
reporting carrier offers broadband service of at least 1 Mbps downstream and 256 kbps
upstream within the supported area pursuant to § 54.313(g).
Page ϭϰ
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(1200) Terms and Condition for Lifeline Customers FCC Form 481
Lifeline OMB Control No. 3060-0986/OMB Control No. 3060-0819
Data Collection Form :uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
<1210> Terms & Conditions of Voice Telephony Lifeline Plans
<1221>
<1222>
<1223>Additional charges for toll calls, and rates for each such plan.
<1220>Link to Public Website HTTP
Information describing the terms and conditions of any voice
telephony service plans offered to Lifeline subscribers,
Details on the number of minutes provided as part of the plan,
www.filertel.com
Robert Kraut
2017
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
✔
✔
✔
472220
Name of Attached Document
“Please check these boxes below to confirm that the attached document(s), on line 1210,
or the website listed, on line 1220, contains the required information pursuant to
§ 54.422(a)(2) annual reporting for ETCs receiving low-income support, carriers must
annually report:
Page 1ϱ
Page 1ϱ
(2000) Price Cap Carrier Additional Documentation FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
Including Rate-of-Return Carriers affiliated with Price Cap Local Exchange Carriers :uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
Incremental Connect America Phase I reporting
<2010> 2nd Year Certification 47 CFR § 54.313(b)(1);iͿ - Note that for the July 1
2016 certification, this applies to Round 2 recipients of Incremental
Support
<2011> 3rd Year Certification 47 CFR § 54.313(b)(1);iiͿ - Note that for the July 1
2016 certification, this applies to Round 1 recipients of Incremental
Support
<2022> Recipient certifies, representing year two after filing a notice of
acceptance of funding pursuant to 54.312(c), that the locations in
question are not receiving support under the Broadband Initiatives
Program or the Broadband Technology Opportunities Program for
projects that will provide broadband with speeds of at least 4
Mbps/1Mbps - 54.313(b)(2)(i). Round 2 recipients only.
<2023> The attachment on line 2024 includes a statement of the total amount of
capital funding expended in the previous year in meeting Connect
America Phase I deployment obligations, accompanied by a list of census
blocks indicating where funding was spent. This covers year two -
54.313(b)(2)(ii). Round 2 recipients only.
<2024A> Round 2 Recipient of Incremental Support?
<2024B> Attach list of census blocks indicating where funding was spent in year
two - 54.313(b)(2)(ii). Round 2 recipients only.
Name of Attached Document Listing
Required Information
<2025A> Round 1 or Round 2 Recipient of Incremental Support?
<2025B> Attach geocoded Information for Phase I milestone reports (Round 1 for
year three and Round 2 for year two) - Connect America Fund , WC
Docket 10-90, Report and Order, FCC 13-
Name of Attached Document Listing
Required Information
<2015> 2016 and future Frozen Support Certification 47 CFR § 54.313(c)(4)
Select the appropriate responses below (Yes, No, Not Applicable) to note compliance as a recipient of IncrementalHigh Cost support, High Cost support to offset access charge reductions,
and Connect America Phase II support as set forth in 47 CFR § 54.313(b),(c),(d),(e). The information reported on this form and in the documents attached below is accurate.
Robert Kraut
2017
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
472220
Page 1ϲ
(2000) Price Cap Carrier Additional Documentation;ŽŶƚŝŶƵĞĚͿ FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
Including Rate-of-Return Carriers affiliated with Price Cap Local Exchange Carriers :uly 2013
Price Cap Carrier Connect America ICC Support {47 CFR § 54.313(d)}
<2016> Certification support used to build broadband
Page 1ϲ
Connect America Phase II Reporting {47 CFR § 54.313(e)}
<2017A> Connect America Fund Phase II recipient?
<2017B> Attach information for Phase II - 54.313(e)(1) - list of geocoded locations
already meeting the 54.309 public interest obligations at the end of
calendar year 2015 and total amount of Phase II support, if any, the price
cap carrier used for capital expenditures in 2015.
Name of Attached Document Listing
Required Information
<2018> Attach the number, names, and addresses of community anchor
institutions to which the carrier newly began providing access to
broadband service in the preceding calendar year - 54.313(e)(2)(ii)
Name of Attached Document Listing
Required Information
<2019> Recipient certifies that it bid on category one telecommunications and
Internet access services in response to all FCC Form 470 postings seeking
broadband service that meets the connectivity targets for the schools and
libraries universal service support program for eligible schools and
libraries located within any area in a census block where the carrier is
receiving Phase II model-based support, and that such bids were at rates
reasonably comparable to rates charged to eligible schools and libraries in
urban areas for comparable offerings - 54.313(e)(2)(v)
<2020> Recipient certifies that it offered broadband meeting the requisite public
interest obligations specified in §54.309 to 40% of its supported locations
in the state on December 31, 2017 - 54.313(e)(3)
<2021> Recipient certifies that it offered broadband meeting the requisite public
interest obligations specified in §54.309 to 60% of its supported locations
in the state on December 31, 2018 - 54.313(e)(4)
<2026>Recipient certifies that it offered broadband meeting the requisite public
interest obligations specified in §54.309 to 80% of its supported locations
in the state on December 31, 2019 - 54.313(e)(5)
<202ϳ>Recipient certifies that it offered broadband meeting the requisite public
interest obligations specified in §54.309 to ϭϬ0% of its supported locations
in the state on December 31, 20ϮϬ - 54.313(e)(ϲ)
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
Complete the items below to note compliance with five year service quality plan (pursuant to 47 CFR § 54.202(a)) and, for privately held carriers, ensuring
compliance with the financial reporting requirements set forth in 47 CFR § 54.313(f)(2). I further certify that the information reported on this form and in
the documents attached below is accurate.
Progress Report on 5 Year Plan
(3009) Carrier certifies to 54.313(f)(1)(iii)
(3010A) Milestone Certification {47 CFR § 54.313(f)(1)(i)}
(3010B) Please Provide Attachment Name of Attached Document Listing Required
Information
(3012A) Community Anchor Institutions {47 CFR §
54.313(f)(1)(ii)}
(3012B) Please Provide Attachment Name of Attached Document Listing Required
Information
(3013) Is your company a Privately Held ROR Carrier {47 CFR
§ 54.313(f)(2)}
(Yes/No)
(3014) If yes, does your company file the RUS annual report
Please check these boxes to confirm that the
attached PDF, on line 3017, contains the required
information pursuant to § 54.313(f)(2) compliance
requires:
(Yes/No)
(3015) Electronic copy of their annual RUS reports
(Operating Report for Telecommunications
Borrowers)
(3016) Document(s) with Balance Sheet, Income Statement
and Statement of Cash Flows
(3017) If the response is yes on line 3014, attach your
company's RUS annual report and all required
documentation
Name of Attached Document Listing Required
Information
(3018) If the response is no on line 3014, ŝs your company
audited?
If the response is yes on line 3018, please check the
boxes below to confirm your submission on line
3026 pursuant to § 54.313(f)(2), contains:
(Yes/No)
(3019) Either a copy of their audited financial statement; or
(2) a financial report in a format comparable to RUS
Operating Report for Telecommunications Borrowers
(3020) Document(s) for Balance Sheet, Income Statement
and Statement of Cash Flows
(3021) Management letter and/or audit opinion issued by
the independent certified public accountant that
performed the company’s financial audit.
If the response is no on line 3018, please check the
boxes below to confirm your submission on line
3026 pursuant to § 54.313(f)(2), contains:
(3022) Copy of their financial statement which has been
subject to review by an independent certified public
accountant; or 2) a financial report in a format
comparable to RUS Operating Report for
Telecommunications Borrowers
(3023) Underlying information subjected to a review by an
independent certified public accountant
(3024) Underlying information subjected to an officer
certification.
(3025) Document(s) for Balance Sheet, Income Statement
and Statement of Cash Flows
(3026) Attach the worksheet listing required information Name of Attached Document Listing Required
Information
page 17
(ϯϬϬϱͿZĂƚĞKĨZĞƚƵƌŶĂƌƌŝĞƌĚĚŝƚŝŽŶĂůŽĐƵŵĞŶƚĂƚŝŽŶ FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
Page 1ϳ
472220ID3012.pdf
✔
✔
✔
Robert Kraut
2017
bkraut@filertel.net
Yes - Attach Certification
472220ID3010.pdf
FILER MUTUAL TEL -ID
472220ID3026.pdf
2083264331 ext.
472220
Yes - Attach New Community Anchors
Page 1ϴ
Page 1ϴ
(300ϱ) Rate Of Return Carrier Additional Documentation;ŽŶƚŝŶƵĞĚͿ FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
Name of Attached Document Listing Required Information
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Robert Kraut
2017
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
472220
REDACTED- FOR PUBLIC INSPECTION
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
4005 Rural Broadband Experiment
Authorized Rural Broadband Experiment (RBE) recipients must address the certification for public interest obligations, provide a list of newly served
community anchor institutions, and provide a list of locations where broadband has been deployed.
Public Interest Obligations – FCC 14-98 (paragraphs 26-29, 78)
Please address Line 4001 regarding compliance with the Commission’s public interest obligations. All RBE participants must provide a response to Line 4001.
4001. Recipient certifies that it is offering broadband to the identified locations meeting the requisite public
interest obligations consistent with the category for which they were selected, including broadband speed,
latency, usage capacity, and rates that are reasonably comparable to rates for comparable offerings in urban
areas?
Community Anchor Institutions – FCC 14-98 (paragraph 79)
4003a. RBE participants must provide the number, names, and addresses of community anchor institutions to
which they newly deployed broadband service in the preceding calendar year. On this line, please respond
(yes – attach new community anchors, no – no new anchors) to indicate whether this list will be provided.
If yes to 4003A, please provide a response for 4003B.
4003b. Provide the number, names and addresses
of community anchor institutions to which the
recipient newly began providing access to
broadband service in the preceding calendar year.
Name of Attached Document Listing Required Information
Broadband Deployment Locations – FCC 14-98 (paragraph 80)
4004a. Attach a list of geocoded locations to
which broadband has been deployed as of the
June 1st immediately preceding the July 1st filing
deadline for the FCC Form 481.
Name of Attached Document Listing Required Information
4004b. Attach evidence demonstrating that the
recipient is meeting the relevant public service
obligations for the identified locations. Materials
must at least detail the pricing, offered broadband
speed and data usage allowances available in the
relevant geographic area.
Name of Attached Document Listing Required Information
FCC Form 481 (4005) Rural Broadband Experiment Additional Documentation
OMB Control No. 3060-0986/OMB Control No. 3060-0819
Data Collection Form
July 2013
page 19
Page 1ϵ
Robert Kraut
2017
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
472220
Page ϮϬ
Page ϮϬ
Certification - Reporting Carrier FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
TO BE COMPLETED BY THE REPORTING CARRIER, IF THE REPORTING CARRIER IS FILING ANNUAL REPORTING ON ITS OWN BEHALF:
Printed name of Authorized Officer:
Certification of Officer as to the Accuracy of the Data Reported for the Annual Reporting for CAF or LI Recipients
Name of Reporting Carrier:
Signature of Authorized Officer:Date
I certify that I am an officer of the reporting carrier͖ my responsibilities include ensuring the accuracy of the annual reporting reƋuirements for universal service support
recipients͖ and, to the best of my knowledge, the information reported on this form and in any attachments is accurate͘
Title or position of Authorized Officer:
Telephone number of Authorized Officer:
Study Area Code of Reporting Carrier: Filing Due Date for this form:
Persons willfully making false statements on this form can be punished by fine or forfeiture under the Communications Act of 1934, 47 U.S.C. §§ 502, 503(b), or fine or imprisonment
under Title 18 of the United States Code, 18 U.S.C. § 1001.
CERTIFIED ONLINE
07/01/2016
2083264331 ext.
Robert Kraut
Steve Cowger
2017
06/09/2016
bkraut@filertel.net
FILER MUTUAL TEL -ID
General Manager/COO
FILER MUTUAL TEL -ID
2083264331 ext.
472220
472220
Page Ϯϭ
Page Ϯϭ
Certification - Agent / Carrier FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
Certification of Agent Authorinjed to File Annual Reports for CAF or LI Recipients on Behalf of Reporting Carrier
TO BE COMPLETED BY THE AUTHORIZED AGENT:
Telephone number of Authorized Agent or Employee of Agent:
Signature of Authorized Agent or Employee of Agent:
Name of Authorized Agent &ŝƌŵ:
I, as agent for the reporting carrier, certify that I am authorized to submit the annual reports for universal service support recipients on behalf of the reporting carrier; I have provided
the data reported herein based on data provided by the reporting carrier; and, to the best of my knowledge, the information reported herein is accurate.
Date:
Eame of Authorized Agent Employee:
Title or position of Authorized Agent or Employee of Agent
Name of Reporting Carrier:
Study Area Code of Reporting Carrier: Filing Due Date for this form:
Printed name of Authorized Officer:
Name of Reporting Carrier:
Study Area Code of Reporting Carrier:
Title or position of Authorized Officer:
Telephone number of Authorized Officer:
Filing Due Date for this form:
TO BE COMPLETED BY THE REPORTING CARRIER, IF AN AGENT IS FILING ANNUAL REPORTS ON THE CARRIER'S BEHALF:
Certification of Officer to Authorize an Agent to File Annual Reports for CAF or LI Recipients on Behalf of Reporting Carrier
I certify that (Name of Agent)_______________________________________________________ is authorized to submit the information reported on behalf of the reporting carrier. I
also certify that I am an officer of the reporting carrier; my responsibilities include ensuring the accuracy of the annual data reporting requirements provided to the authorized
agent; and, to the best of my knowledge, the reports and data provided to the authorized agent is accurate.
Date:
Name of Authorized Agent:
Signature of Authorized Officer:
Persons willfully making false statements on this form can be punished by fine or forfeiture under the Communications Act of 1934, 47 U.S.C. §§ 502, 503(b), or fine or imprisonment
under Title 18 of the United States Code, 18 U.S.C. § 1001.
Persons willfully making false statements on this form can be punished by fine or forfeiture under the Communications Act of 1934, 47 U.S.C. §§ 502, 503(b), or fine or imprisonment under Title
18 of the United States Code, 18 U.S.C. § 1001.
Robert Kraut
2017
bkraut@filertel.net
FILER MUTUAL TEL -ID
2083264331 ext.
472220
Attachments
LINE100INITIALFIVEͲYEARSERVICEQUALITYIMPROVEMENTPLAN
REDACTEDFORPUBLICINSPECTION
Response Line 510
Filer Mutual Telephone Company
Study Area 472220
Voice Network
Pursuant to 47 C.F.R. § 54.313(a)(5) and or 47 C.F.R. § 54.422(b)(3) Filer Mutual Telephone
Company(“Filer”) is in compliance with appropriate FCC Service Quality Standards and Consumer
Protection Rules. Filer provides CPNI training to all of its new employees and in addition trains all of its
existing employees on an annual basis. Filer also conducts subscriber outreach regarding CPNI by
placing CPNI explanation onto its website at www.filertel.com which informs subscribers about CPNI
rules and other applicable customer rights and obligations. In addition Filer trains staff on Red Flag
issues on an annual basis. All company employees are required to sign and acknowledge that they have
completed CPNI and Red Flag training and understand obligations to adherence of applicable rules.
Filer also outlines its rates, terms, and conditions under which Filer offers service in its Local Exchange
Price List. The price list explains customer rights and obligations, customer service, dispute resolution,
deposits, billing and payment options, disconnection of service as well as cancellation of service options.
Filer keeps its Price lists available for public inspection at its business offices.
Broadband Network
Pursuant to 47 C.F.R. § 54.313(a)(5) and or 47 C.F.R. § 54.422(b)(3) Filer is in compliance with applicable
FCC Service Quality Standards and Consumer Protection Rules. Filer trains staff on applicable rules for
broadband services issues on an annual basis. In addition Filer has placed on its website at
www.filertel.com its network practices and policies regarding FCC’s Net Neutrality Rules.
Filer also outlines its rates, terms, and conditions under which Filer offers Broadband service in NECA
Tariff #5 to Internet Service Providers (“ISP”). The Tariff explains customer rights and obligations,
customer service, dispute resolution, deposits, billing and payment options, disconnection of service as
well as cancellation of service options. Public inspection of NECA Tariff #5 can be found on NECA’s
website. Retail DSL rates, terms, and conditions for retail services are provided by the ISP.
Response Line 610
Filer Mutual Telephone Company
Study Area 472220
Functionality in Emergency Situations:
Voice Network
Pursuant to 47 C.F.R. § 54.313(a)(6) and 47 C.F.R § 54.22(b)(4) as set forth in 47 C.F.R. § 54.202(a)(2)Filer
Mutual Telephone Company (“Filer”) meets the requirements to remain functional in emergency
situations and has the following capabilities: Back-up power is provided to FILER central offices by use of
a generator and batteries that provide it with 8 to 12 hours of emergency power. In addition, FILER field
electronics have 8 to 12 hours of back-up power by use of generators and batteries. FILER also has
SONET technology deployed in its core fiber optic network that is a self-healing and will automatically
reroute traffic should a fiber cut occur. FILER has also sufficient spare cards for its fiber optic network to
provide almost instantaneous replacement should there ever be a card failure in the core network. FILER
also has proper staff in place to repair any fiber cuts in a timely manner. FILER has connectivity with
neighboring telephone exchanges as well as the LATA tandem to provide diverse options to reroute
traffic should an emergency arise. FILER has developed and trained its staff on network preparedness
plans in case of emergency situations. FILER is prepared and capable of managing traffic spikes resulting
from emergency situations and has sufficient switching capabilities to handle such situations.
Broadband Network
Pursuant to 47 C.F.R. § 54.313(a)(6) and 47 C.F.R § 54.22(b)(4) as set forth in 47 C.F.R. § 54.202(a)(2)
FILER MUTUAL TELEPHONE COMPANY (“FILER”) meets the requirements to remain functional in
emergency situations and has the following capabilities: Back-up power is provided to FILER central
offices by use of a generator and batteries that provide it with 8 to 12 hours of emergency power that is
also used to provide service to the broadband network. In addition, FILER field electronics have 8 to 12
hours of back-up power by use of generators and batteries. FILER also has SONET technology deployed
in its core fiber optic network that is a self-healing and will automatically reroute broadband traffic
should a fiber cut occur. FILER has also sufficient spare cards for its fiber optic network to provide almost
instantaneous replacement should there ever be a card failure in the core network. FILER also has
proper staff in place to repair any fiber cuts in a timely manner. FILER has connectivity with neighboring
telephone exchanges as well as the LATA tandem to provide diverse options to reroute traffic should an
emergency arise. FILER has developed and trained its staff on network preparedness plans in case of
emergency situations.
(700) Price Offerings including Voice Rate Data FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
<701> Residential Local Service Charge Effective Date
<702> Single State-wide Residential Local Service Charge
<703>
<a1> <a2> <a3> <b1> <b2>
State Exchange (ILEC) SAC (CETC) Rate Type
Residential Local
Service Rate
<c>
Total per line Rates and Fees
<b5>
Mandatory Extended Area
Service Charge
<b4>
State Universal Service Fee
<b3>
State Subscriber Line Charge
Robert Kraut
1/1/2016
21.12
21.12
2017
bkraut@filertel.net
0.0Filer
Hollister 0.0
FILER MUTUAL TEL -ID
ID
ID FR
2083264331 ext.
FR
0.0
0.021.0
21.0
472220
0.12
0.12
21.0
(710) Broadband Price Offerings FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
:uly 2013
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>
<711><a1><a2><b1> <b2> <c> <d1> <d2><d3> <d4>
State Exchange (ILEC)Residential
Rate
State Regulated
Fees
Broadband Service -
Download Speed
(Mbps)
Other, Unl m ted-no act on
Other, Unl m ted-no act on
Other, Unl m ted-no act on
Other, Unl m ted-no act on
Other, Unl m ted-no act on
Robert Kraut
ID
ID
ID
ID
2017
ID
bkraut@filertel.net
999999
999999
999999
999999
999999
All
All
All
All
All
FILER MUTUAL TEL -ID
2083264331 ext.
49.95
39.95
59.95
69.95
89.95
12.0
6.0
50.0
25.0
100.0
49.95
39.95
69.95
59.95
89.95
472220
1.0
2.0
5.0
10.0
20.0
0.0
0.0
0.0
0.0
0.0
Total Rates
and Fees
Broadband Service
-Upload Speed (Mbps)
Usage Allowance
Action Taken
When Limit Reached {select}
Usage Allowance
(GB)
Response to Line 1030
Filer Mutual Telephone Company-ID
Study Area 472220
Broadband Services Comparability Report
Pursuant to 47 C.F.R. § 54.313 (a) (1) Filer Mutual Telephone Company-ID (“Filer”) charges a
residential rate of $49.95 for broadband providing 12 Mbps download, 2 Mbps upload, and an
unlimited usage allowance. This rate is lower than $77.80, which is the 2015 reasonable
comparability benchmark for the same offering established by the Wireline Competition
Bureau.1
1 Wireline Competition Bureau Announces Results of 2015 Urban Rate Survey for Fixed Voice and Broadband
Services and Posting of Survey Data and Explanatory Notes, Public Notice, WC Docket No. 10-90, DA 15-470 (rel.
April 16, 2015).
Response to Line3010
Filer Mutual Telephone Company-ID
Study Area 472220
Milestone Certification
Pursuant to 47 C.F.R. § 54.202(a) Filer Mutual Telephone Company (“FILER”) provides this certification
that it is taking reasonable steps to provide upon reasonable request broadband speeds of at least 10
Mbps downstream/1 Mbps upstream, with latency suitable for real-time applications, including Voice
over Internet Protocol, and usage capacity that is reasonably comparable to offerings in urban areas as
determined in an annual survey as specified in Public Notice DA 16-362, and that requests for such
service are met within a reasonable amount of time. Details for how CTTC is meeting its obligations for
meeting its goals and required obligations are specified within the FCC Form 481 annual filing.
Response to Line3012
Filer Mutual Telephone Company
Study Area 472220
Anchor Institutions
Pursuant to 47 C.F.R. § 54.313(f)(1)(ii) Filer Mutual Telephone Company (“Filer”) provides this document
that contains the number, names, and addresses of community anchor institutions to which the ETC
newly began providing access to broadband service in the preceding calendar year :
Filer did not begin providing access to broadband service to any community anchor institutions in the
preceding calendar year.
LINE3005RATEOFRETURNDATA
REDACTEDFORPUBLICINSPECTION